ML051960299

NUREG-1437, Supp 22, (2:2) Appx A-221 - End, Generic Environmental Impact Statement for License Renawal of Nuclear Plants Re Millstone Power Station Units 2 & 3, Final Report

ML051960299
Person / Time
Site:	Millstone
Issue date:	07/31/2005
From:	Emch R Division of Regulatory Improvement Programs
To:
References
NUREG-1437, S22
Download: ML051960299 (452)

Text

Appendix A

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.- // 1/0-II II Chief,-Rules and Directive Branch Office of Administrative Scrvices MailstopT-6D59 US Nuclear Regulatory Commission Washington, DC 20555 IJanuary 11, 2005 -.

Re: Millstone Nuclear Plante should be closed. :- *-- - - --

Dear Regulatory Commission Officer,

MPS-26-1 I write to you today on behalf of my family and close friends who all live near the Millstone Nuclear Plant. It has come to our attention that although the plant has already outlived its Intended life span, it is slated for re-licensing for another 20 years. We strongly oppose this decision and regard it as shortsighted and foolhardy.

Nuclear power plants, risky even under the best conditions,I should by no means be patched together to overextend their designed use. We simply roll the dice of fate every day we let this continue.

MPS-26-2 This is doubly alarming now tchat wec fate likely threats of terrorism on our oMn soil. Millstone is essentially a Weapon of Mass Destruction waiting to be detonated!

We wvish, as our founding fathers did, to be free from remote tyranny. We wvill not let a remote tyrant (Bin Laden or the US NRC) risk our lives, health, environment and livelihoods.

We look fornvard to your reply and assurance that Millstone vill notbe re-licensed. Until then, I am SincerelyYours, Lindsay Suter, AIA Rogers Mill -':'*-,

16 Mill Road Noith Branford, ET..0641 :;. *.

(203)4.84-5059  :.  ;.

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. Spee2 July 2005- A-221 NUREG-1437, Supplement 22

Appendix A I NRCREP - Response from Comment on NRC Documents' . . .. _ _ . _ . .P.e. I

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From: Michael Hess .crnchaeLd_hessOdom.com>

To: <nrcrep~nrc.gov>

Date: Tue. Jan 25.2005 7:37 AM J%9/081al Sublect: Response from *Comment on NRC Documents 6fz /0:,7 8elow is the result of your feedback form. It was submitted by Michael Hess (michael_d_hessOdom.com) on Tuesday. January 25.2005 at 07:37:42 DocumentTltbe: Generic Environmental Impact Statement for Ucense Renewal of Nuclear Plants.

Supplement 22. Regardcng Millstone Power Station. Units 2 and 3 MPS-27-1 Comments: QUESTION: Can the report be modirfed to make clear that entrainment d 20% of the lrvae production does not result hi 20% reduction of adult fish because the larvae entrained Is outside of the river and this larvae may have lIttle or no Impact on the total population of adult Niantic River Winter Flounder?

BACKGROUND: Section 4.1.1 seems to assume that the percentage of NMantic River Winter Flounder larvae that result hi adult fish Is tho same. regardless ol whether the larvae Is allowed to reach try stage hi the river or whether the larmae bsreleased to Niantic Bay and Long Island Sound. It would seem that larvae released to the bay and sound would experience a more hostile environment, even without Millstone. Therefore, larvae that have left the river would have significantly less Impact on the adult population than larvae that remains I the river. Skie Milkstone can only entrain larvae that has left the river, the effect of entrahment would seem to be greatly exaggerated by simple comparsons as a percentage of larvae production, as discussed on page 4-15 of the report organIzation: Representing Self addressl: 828 Old Black Point Road address2:

clty. Niantic state: CT zir: 06357 county: USA phone: (860) 444-4202

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Appendix A Chief, Rules and Directives Branch  ;/

Division of Administrative Services .

Office of Administration .. Iew 1-Af oJ Mailstop T-6D 59 US Nuclear Regulatory Commission Washington., DC 20555-0001 , >-

February 10, 2005 Commissioners: . - -^

MPS-28-1 TheGreenParty of New Haven opposes extension of operating licenses for Millstone's 2 and 3 nuclear power reactors in Waterford, Connecticut, owned by Dominion Nuclear Connecticut, Inc. for the following reasons:.-

MPS-28-2 1. After a hearing in Waterford on Jan.ll, a fire broke out Jan.14 highlighting the vulnerabilitycof these aging plants.

MPS-28-3 2. The draft Environmental Impact Statement (EIS) being prepared by the Nuclear Regulatory Commission (NRC) with respect to the license renewal does not address some highly-related issues such as the Evacuation Plan.

The current evacuation zone does not include the effect of a major release and its effect on Connecticut and its cities such as New Haven, only about 40 miles from the plant, nor does it consider the proximity of Long Island only a few miles away across the Sound where evacuation has been shown to be impossible.

MPS-28-4 3. Terrorism and sabotage are not included in the draft EIS even though these plants can be prime targets with their highly-radioactive spent fuel stored in unprotected pools or, as approved, in dry cask storage on the reactor site.

MPS-28-5 4. Environmental Justice issues were incorrectly discarded by not considering that the low-level radioactive wastes are shipped routinely to places such as Barnwell, S.

Carolina, an area that has a predominately poor and African-American population.

MPS-28-6 5. There is a need for an independent epidemiological 9 -Z)/3 July 2005 A-223 NUREG-1437, Supplement 22

Appendix A MPS-28-6 study of areas around the plant beyond Waterford and including New Lonaon County and parts of Long Island where cancer clusters have been identified. Radioactive and chemical contaminants are routinely released from the plants into air and water.

MPS-28-7 Dominion has a poor envirormental record having been fined for having hidden violations of the Clean Air Act at another of its facilities.

MPS-28-8 Speaking for the New Haven Chapter of the Green Party, we feel the draft EIS, as proposed, is flawed, and thus a new process should be initiated with hearings that include all stakeholders and their concerns.

Sincerely, Charlie Pillsbury Allan Brison 247 St. Ronan Street 115 Everit Street New Haven CT 06511 New Haven CT 06511 I

NUREG-1 437, Supplement 22. A-224 July 2005;-

Appendix A

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From: 'Dave Sirrpson <cdavid.sirnpsonlpostate.ct.us>

To: acmillstoneElSOnrc.gov>

Dato: Wed. Jan 5, 2005 3:11 PMh SubJect: Millstone GEIS comments  : -

Richard.

MPS-29-1 1reviewed the sections ol the GElS pertaining to entrainment and thought you folks did a very nice job.

especially summarizing the available informaUon and the debates/points of disagreement on models and analysis.

MPS-29-2 I have only a few minor comments on pages 2-25 and 2-26 reference li made to the Gull of Maine stock -

sure you meant southern New England.

MPS-29-3 pg 2-26 One 8 'The stock Is at low biomass level and Is considered to be OVER exploited (NOM 1998).

MPS-29-4 pg 2-25 Commercial havrest Is generally accomplished with trawl and salness. rd scratch selnes for our area. Virtually all landings are by trawt.

Thanks for sending us a copy of the report.

Dave David Simpson Supervising Fisheries Biologist State of Connecticut Department of Environmental Protection Marine Fisheries DMvis1on PO Box 719 Old Lyme, Cr06371 phone: (860)434-6043 fax: (860)434-6150 email: david.simpson"po.state.ct.us

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'2:0 July 2005' A-225 NUREG-1437,Supplem6nt 22

Appendix A rawI From: <Urfcomm @aol.comr To:

Date:

Subject:

<M1llstoneElS~nrc.gov>

Thu. Jan 6. 2005 3:07 PM EIS for Milstone Power Stations UnIts 2 & 3 ,q, 0,I To Whom It May Concern:

MPS-30-t I want to go on record as Opposing the renewal for licensing for Units 2 and 3.

MPS-30-2 I have grave concerns about the safety of this power plant. In the event of a terrorist attack. the Impact to the trI state area would be devastating. I would hate to have something occur as it relates to terrorism and this Power MPS-30-3 Plants. to find that my concerns are correct. In addition to my concerns.

It appears the NRC down plays the impact of EMF on the people and the environment MPS-30-4 There are alternative ways to generate electricity and Connecticut should be looking for those ways. In these uncertain times decisions can't always be about profits & shareholders. It must be more about safety and alternative ways to generate clean and efficient energy.

There are 69 Issues for which the GEIS reached generic conclusions. but if we can be objective about these 69 Issues. they would be frightening.

I oppose the renewal of this licensing for Units 2 & 3.

Sincerely.

Marie Domenici 330 Oldfletd Court Mattiluck. NY 11952 631 2987103 cz--d =- R- &ze-"F -)

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-. From: *Baran. Marie 'Marie.9aranOfb.gov>

To: . . ~IIstoneElS~nrc.gov>*- .. -

Date: Fri. Jan 7.2005 2:38 PM .

MPS-31-1 Until Long Island has and evaluation plan we should not have nuclear:-.-

power plants operating within 100 miles of us. As I have learned. Ws not it there wit be an accident I's lust when will it be. 911 should have taught us all that we are so vulnerable. Z'.43 7/9/-o Marie Baran

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.1. -1 From: Assemblywoman Pal Acampora <acampopQ assembly.slatemny.us>

To: <MillstoneEIShnrc.gov>

Date: Mon. Jan 10.2005 11:24 AMA

Subject:

Millstone License Renewal January 10. 2005 Mr. Richard Emch, Jr.

Division of Regubatroy Improvement Programs Office of Nuclear Reactor Regulation United States Nuclear Regutatory Commission Washington DC 20555 I write concerning the United States Nuclear Regulatory Commissionrs consideration for the Millstone Power Stations, Units 2 and 3 License Renewal forthe next twentyyears. Unfortunately. I will be unable to attend the during the Tuesday. January 11th public discussion forunm held in Waterford, Connecticut. The New Yortk State Legislature Is In session on that date and therefore, I will be in Albany.

MPS-32-1 I wish to share with you my serious concerns that Millstone's operation poses a serious risk to the residents of the North Fork of Long Island.

Without an emergency plan In place that expands the current 10 mile radius to a 50 mile radius including the North and South Forks, there should be no consideration of renewing Millstone's contract. In the event of an accident or terrorist attack, Long island Is currently extremely vulnerable. We must ensure that safety of the residents of Eastern Long Island. Therefore, I strongly oppose renewing the contract ol The Millstone Power Station.

Thank you for your consideration of this extremely Important matter. I would also like to be informed In the future regarding public meetings and discussions concerning the Millstone Power Station.

Sincerely.

Patricia L Acarnpora MEMBER OF ASSEMBLY CC: <dirrcomm OaoLcom>

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From: Wayne Burgess <wayneburgessasnet.nebt To: NRC <MistoneEtSonrc.gov> _

Date: TueJan1l,200510:4S9AM  :- r &k/j '

Subject:

Renewal of the Millstone Power Station '-

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January 11, 2005 To: MillstoneEISOnrc.gov From: Wayne J. Burgess-President Southeastern Connecticut Central Labor Council. AFL-CIO Re: Renewal of the Millstone Power Station operating license MPS-33-1 The Southeastern Connecticut Central Labor Council. AFL-CIO has voted to support the renewal of the operating license for Millstone Power Station.

Many of our members anc delegates have lived and worked In Southeastern Connecticut since Millstone Power Station started unit one.The Power Station has had some problems over the years. However. we believe the current management. DomInIon Nuclear. Inc has demonstrated responsible behavior, has been a good member of the community and has worked to provide good jobs for citizens In Southeastern Connecticut.

Therelore we support the license renewal of units two and three at Millstono power station.

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From: '8arbara Doyle'badoyleocorncastnot>

To: <MillstoneElS Onrc.gov>

Date: Tue, Jan 11, 2005 11:14 AM SubJect. renewal MPS-34-1 Hello NRC stafl. I would like to not see a renewal of Units 2 & 3 at the Millstone Power Plant site in CT.

MPS-34-2 Although I think that dry cask storage of radioactive waste at the plant I/,* -

is preferable to keeping the waste In a 'wetr pooL, the fact Is that this Is not a long term solution to the problem of disposing of the waste. We do not have a long term plan for dealing with the radioactive byproducts of nuclear power plants, so I would prefer that we not renew any nuclear power plant facility license.

Please keep In mind that any solution so lar proposed to dealing with radioactive waste Is expensive and should be considered part of the operating expense of any nuclear power plant. It is not a separate and unrelated cost to the running of such a facility and should not be presented to the public as so. I do not wish for my taxpaying dollars In any way to continue to support the license of new or renewal of any nuclear power facility.

Thank you. Barbara Doyle.

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Appendix A um5stuulma - Millestone ructear rower mant Page 1

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From: 'Arlene <typewel1OsbcglobaIlnet>

To: <MillstoneEIStnrc.gov> -

Date: Fri. Jan 14.2005 11:40 AM

Subject:

Millestone Nucleir Power Plant MPS-35-1 lam a former Long Island resident and I strongly oppose the relicensig ol the Miltestone Nuclear Power MPS-35-2 Plant. Units 2 and 3 to the year 2045. However, should the license be renewed. I believe It Is Imperative that the NCR expand the scope of its evacuation plant to a 50-mile radius to include an of Long Island. I Implore you to consider this for the benefit and safety of the Long Island residents. '

Arlene FarInacct 4812 W. 140th Street Hawthorne. CA 90250 /*

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J.. - A>4p -ir-From: cCaseathome@aoi.com>

To: .cMllstoneElS~nrc.gov>

Date: Fri. Jan 14.2005 3:43 PM Subject. (no subject)

MPS-36-1 tam wnting to voice my strong objection to the Millstone rcense renewat without making a plan for the evacuation of Long Istands north shore-within the 10 mile radius of Millstone This is unacceptable. My e-mail. In case you wish to respond Is caseathome Oaol. corn.

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Frorn: RANDAZZO crafel @optonline.net>

To: <cMillstoneEIStnrc.gov> -

Date: Fri Jan 14,2005 4:28 PM

Subject:

Millstone Power Plant 1 t0 MOies Oi1U Sound - License Renewal MPS-37-1 I arn a Long Island resident and I strongly oppose the reficensing of the Millestone Nuclear Power Plant, MPS-37-2 Units 2 and 3 to the year 2045. However. should the license be renewed. I believe It Is Imperative that the NCFi expand the scope or Hs evacuation plant to a 50-mile radius to Include alt of Long Island. I implore you lo consider this for the benern and safety of the Long Island residents.

Janice Circo-Randazzo 213 Pine Road Coram, NY 11727

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-lY~~SA ,-raeu ,I From: VicBarb cvicbarb9@optonline net>

To: Marie Domenicl drrcomm e aol.com>. <MfillstoneEtS @nrc.gov>

Date: Mon. Jan 17. 2005 4:27 PM Sir:

MPS-38-1 I would like to protest your scheduling a vital public meeting on operations at the Millstone nuclear plant without adequately notifying the residents who would be effected If an accident should happen. I read the New York Times every day. No notice was published. It looks MPS-38-2 like you didn't want anyone to know there was a meeting. ItIs my E~xitv; /

understanding that the Nuclear Commission In the State of Connecticut have no plants for notification of residents who reside Ina ten to filty mile radius In the event o0a nuclear matluncUon. A planfor evacuation of this area Is vital. Without a plan for viable evacuation, the plant should be shut down.

Barbara & Victor DiPaola vicbarb9Ooplonline.net

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,,e From: <BeaconHA~aol.com>

To: <malstoneElS@nrc.gov>

Date: Mon. Jan 17,2005 5:05 PM

Subject:

Millstone Nuclear Projects MPS-39-1 I urge you to not allow the Millstone nuclear faclilties to operate for 8l the safety, toxic waste. public health and national security reasons cited by so rnany for so long end documented over the years by members ol the scientific community who have no economic or other pecunlary Interests I the MIstoneo proJects. E111 Garrett, 520 Savoy Street. Bridgeport, CT P&17hJ!,

<NancyBurtonEsqO aol.com>. .cupthesunocshore com>

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• . . /)4 ts86' From: <BeaconHA O aoLcom>

To: mrnklstoneEIS~nrcmgov>

Date: Mon. Jan 17.2005 5:05 PM

Subject:

Millstone Nuclear Projects MPS-39-1 1urge yu to not anow the MlWlstono nuclear faclfities to operate for all the satety. toxic waste, public health and national security reasons cited by so many for so long and documented over the years by members of the sclentific community who have no economic or other pecuntary Interests In the Millstone projects. Bil Garrett, 520 Savoy Street. Bridgeport. CT CC: <NancyBIurtonEsq~aoI.cOm>. .upthesun~cshore.com>

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• IICf~*D- ,OWn.,. fl Iw*I "-l*I rayt e I 4DO /e/,e From: Maureen and Valerie <rmaureenandvalerieOyahoo.com>

To: cMillstoneElSOnrc.gov> - --

Mon. Jan 31.2005 10:58AM - - - -

Date:

Subject:

renewing of Millstone ric. -

MPS-40 We want to voice our concern about the renewal of the Millstone Power Plant license. We are strongly opposed to this, and hope that you will consider closing the plant.

MPS-40-2 We are veryconcerned that there Is no apparant notification system In place.-we site thethis recent fire, and site evacuation In Jan. 2005. There are no policies In places to notify neighboring states, Isa huge concern of ours. As residents of New Jersey. we would want to be fully advised, and alerted to when public meetings are being held to dliscuss/debate the renewal of the license.-

Again, I urge you to refuse the renewal of the Millstone opereating Units 2&3 Sincerely.

\'ValeieOB~riody'*'1 . a/j- .

0 Maureen Swearingen 9 Delsey Road 67/v Z Y&/

Kendall Park, NJ 08824 732.398.9454 Please rie up to your mission statement:

"NRC's primary mission Isto protect pubrlic health and safety and the environment Irom the effects of radiation from nuclear reactors, materials, and waste facllities.7 Do you Yahoo!?

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From: cTMJM19680aot.com>

To: .cMillstoneEISlnrc.gov>

Date: Tue. Feb 1. 2005 11:00 AM

Subject:

(no subject)

MPS-41-1 I have read the available Information sent to me about Millstone. I am deeply distressed that you would even consider extending the opening of this facility. It seems that it would be common sense with all the other data in the world about this type of situation, that you would have no reason to keep this open or to extend the opening of IL Please think about the future of our children and grand children and do the right thing.

In God We Trust Josephine

I . I . -1.

Date: Wed, Feb 9,2005 7.30 AM . I

Subject:

License Renewal at Millstone ' :

Dear Sir.

MPS-42-1 I wish to register my opinion that license renewal for Millstone nuclear power plant be delayed. Al the parties who have concerns about this renewal have not been fully heard. These parties Include Long Island communtlies, citizen groups and anti-nuclear activists. The health effects of this power plant may not have been fully considered. As a consequence. I urge you to delay renewal of the license.

- Sincerely.

John Magnesl '-:

7 Partridge Run Cy~/"/? e%?'

-Wallingford, CT 06492 Do You Yahool?

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^x!;,i.A From: .c-lrrcommn~aol.ccm>

To: 4MiiUlflsbnElS~nrc.gov>

Date: Wed, Feb 23.2005 4:41 AM FT/9/S

Subject:

Address Correction regarding Mifltione and-Hello Mr. Emrch.

I have submitted my written comments regarding the re licensing of the Millstone several many weeks ago and yesterday. I received communication from your office regarding sutlject:

'Response to Joshua Y. Horton, Southold Supervisor. Regarding Millstone Power Station. UnIts 2 and 3 License Renewal Review' and found the NRC has an Incomrct address for me. The purpose of this email to ask that you correct my address to read as follows:,

Mario Domenici 330 Okftfeid Court Mattituckc, NY II1952 MPS-43-1 In the future, when posting 'public meefirgs I recommend the NBC place your notlflcatlon* in no less than 3 newspapers:

1. NY Times

2. Newsday

3. Suffolk Thies The Eastharripton Independent Isa free newspaper that Is distributed in local supermarkets andIs not necessay a wellread newspaper. So.in fairness to the residents of Long Island Itwould be prudent on your boWa to place your public notifications In the 3 newspapers stated above. It you require contact Info on these newspapers. I wilt be happy-to provide that information.

Additionally, on January 12.I sent art email to Mr. Zalcman providing himt with all the elected officials contact Information, from the Town Supervisor all theway up toGovernor Palakito ensure thatfuture ,ourcalom were -

made as appropriate. If you would lke acopy of that emailplease contatme.

Lastly. I ask that I be added as a contact name for future meetings that will be conducted as It relates to Millstone.

Thanking you In advarnce for your attention to this matter.

Marie Domencll 631 298 0211

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Appendix A NRc FORM 655 . Rt 7.

NRC PUBLIC MEETING FEEDBACKI

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[11 U.S. NUCLEAR REGULATORY COULOSSION Moeting Meeting Public Meeting to discuss the Draft Supplemental Environmental Impact Date: 01/11/2005 -- Tlt: Statement for License Renewal at Millstone Power StaUitKT1its 2 and 3 In order to better serve the public, we need to hear from the meeting participants. Please take a few minutes to fll out this feedback form and return It to NRC.

1. How did you hear about this meeting? Z o NRC Web Page o NRC Martng List .8Newspaper Q RadZoTV 9 Other___

No Somewhat IPlease explain t2w

2. . Were you able to fnd supporting information prior to - . -c 0 -

the me6etng?

3. . Did the meeting achieve Its stated purpose? * ::0' Z/.

4. - Has this meeting helped you with your understanding - -0 -07 of the topic?

5. Were the meeting starting time, duration, and location reasonably convenient?

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6. - Were you given sufficient opportunIty to ask questions - . -'

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or express your views?

7. -Are ou satisned Overa wtth Me NRC staff who *.---- ' 3 - 0O MpatETSDatUd I the E meeting? t y I COMUIENTS OFI SUGGESTIONS: "Thank you for an5vwwing these questionr.

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Appendix A NRC FORU 955 ,,3 hoft, 4ib A.::g '0 U.S. NUCLEAR REGULATORY COUUISSION NRC PUBLIC MEETING FEEDBACK I1 Meeting Meeting Public Meeling to dscuss the Draft Supplemental Environmental Impact Date: 01/11/2005

Title:

Statement for-Ucense Renewal at Millstone Power Station. Units 2 and 3 In order to better serve the public. we need to hear from the meeting particpants. Please take a few minutes to fill out this feedback form and return It to NRC.

1. How did you hear about this meetinh?

O NRC Web Page o NRC Mailing Ust o RadbtV E Other No Somewha : i yeas tPleaso exotstn below) I

2. Were you able to find supporting Information prior to the meeting?

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3. Did the meeting achieve its stated purpose? l Ml""

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4. Has his meeting helped you with your understanding of the topic?

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5. Were the meeting starting time, duration and location reasonably convenient?

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6. Were you given sufficient opportunity to ask questions or express your views?

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7. Are you satisfied overall with the NRC staff who 0 C-- 0 pautlcated in the meeting?

COMMENTS OR SUGGESTIONS: Thank you for answering these questions.

MPS-45-1 M ;/ViAlve JL4-3 ecl-b ' i 1o- MPS-45-3 Le A1CLC1C~i-zly PCt~I/

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a-4 -I-c I

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Continue Comments on the reverse. >

i OPT7ONAL Name L /t! - j. Poro h4s Organlzation R etr X,4 "'Jsm" TelephoneNo.. 5 -,19/- EMaE Mvkh hereayofavAoMnlayo I Ad "memba'1of as NRCsk a, cooa da'oa Please fold on the dotted fines with Business Reply side out. tape the bottom, and mall back to the NRC.

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NUREG-1 437, Supplement 22 A-242 July 2005.

Appendix A CONNEJCTICIUT COALITION AGAINST MITlSTONE P.O. Box Niantic CT 06357 -.

- -www.srothballmillstone.or -

ANTI-MILLSTONE COALITION REPORTS MOUNTING EVIDENCE OF MILLSTONE LINK TO HIGH CANCER RATE IN NEW LONDON COUNTY

.,FOR IMMEDIATE RELEASE - - -

JANUARY 11, 2005

Contact:

Joseph J. Mangano Tel. 610-666-2985:-

Nancy Burton Tel. 203-938-3952 Michael Steinberg Tel. 860-739-7002 WATERFORD - Evidence is mounting of a scientific correlation between routine radiation emissions from the Millstone Nuclear Power Station and high cancer incidence in the surrounding area, the Connecticut Coalition Against Millstone reported today.

MPS-46-1 Laboratory analysis of baby teeth donated by children with cancer in the areas near the Millstone and Indian Point Nuclear Power Plants found levels of radioactive strontium-90 more than twice as high as found in teeth collected from other parts of the state, according to Joseph J. Mangano, National Coordinator of the Radiation and Public Health Project. -

OThe average level of strontium-90 concentration close to the nuclear power plants was 6.16 picocuries per grai of calcium, compared with 2.70 picocuries in other parts of the state,' Mangano said.- -

5vz ef o o ICat -s =,Ip,-I. 4- )

July 2005 A-243 NUREG-1437, Supplement 22

Appendix A MPS-46-1 'For children suffering from cancer, the average level of strontium-90 concentration was 7.03 picocuries per gram calcium,- Mangano said.

Strontium-90 is a radionuclide routinely emitted by the Millstone Nuclear Power Plant into the air and water,* said Mangano, who as national coordinator of the Radiation and Public Health Project (RPHP) has participated in analysis of baby teeth collected from around the country. RPHP has published 21 articles in peer-reviewed medical journals (including 4 on the tooth study), and five books, since 1994.

'Strontium-90 mimics calcium and when it is taken into the body of an exposed person it collects in the teeth and bones,' Mangano said.

MPS-46-1 OThe presence of strontium-90 elevated levels near the nuclear power plants cannot be accounted for other than from their routine releases of strontium-90,* Mangano said.

MPS-46-2 Mangano stated that cancer rates in the New London area, which used to be below the state average, have risen steadily during the period the Millstone nuclear reactors have been In operation, beginning in 1970.

'in the 1950s and 1960s, cancer incidence in New London County, where Millstone Is located, was 8 per cent below the state rate," Mangano said. -After Millstone began operations in 1970. the state rate rose steadily until it reached a level of 6 per cent above the state rate in the late 1990s.'

• New London County's current cancer rate is the highest of all counties in the state," Mangano said.

Mangano acknowledged that the Information about strontium-90 levels in baby teeth in Connecticut is based on a sampling of 37 teeth, and therefore the information is still of a preliminary nature. The tooth-testing program is continuing to analyse baby teeth.

2 NUREG-1437, Supplement 22 A-244 July 2005

Appendix A MPS46-3 In its most recent report of radiological emissions to the environment, based on samplings taken in the year 2002, Dominion reported the presence of strontium-9D in the milk of goats living two miles downwind of Millstone.

'Despite Information to the contrary in its own reports, the owners and operators of Millstone have denied that strontium-90 found in goat milk near and downwind from Millstone has been coming from their nuclear, reactors," said Michael Steinberg,.author of wMillstone and Me," a book analyzing Millstone's radiological releases.

Stronbium-90 is only one of hundreds of radioactive waste products Millstone releases into the air and water during routine operations.

MPS46-4 Millstone has the third-highest'record of airborne radiation releases to the environment of all nuclear power plants operating in the United States according to Its own reports," said Mangano.

The official Tumor Registry maintained by the state of Connecticut shows the region around Millstone has the highest incidence of cancers known to be triggered by certain of the radionuclides routinely released by Millstone, according to Mangaho.

MPS-46-5 According to the Coalition, Millstone radiological releases of tritium

- radioactive hydrogen - to the environment are increasing to all-time highs. -

The Connecticut Coalition Against Millstone comments were prepared for delivery to the U.S. Nuclear Regulatory Commission at a proceeding today to consider the draft Environmental Impact Statement (EIS) NRC staff prepared to assessenvironmental consequences of extending the Millstone operating license an additional twenty years.

MPS46-6 In its draft EIS, the NRC concluded that the agency need not consider issues of human health as it relates to radiological emissions from nuclear power plants undergoing relicensing because 3

July2OO5' A-245 NUREG-1437, Supplement 22

Appendix A MPS46-6 an NRC guidance document released in 1996 discounted health effects from nuclear power plant radiological releases.

"Millstone is poisoning our air and water and killing our children in the year 2005,' said Nancy Burton, a founder of the Coalition, OWe do not need its deadly megawatts. The community can no longer tolerate the Millstone menace.-

The Coalition cited high cancer levels, environmental degradation and the threat of terrorism as causes for Millstone shutdown.

'Dominion sold itself to the people of Connecticut as a conscientious environmental steward when it bought Millstone for

$1.3 billion In 2001, Burton said.

MPS46-7 Yet, according to research by Public Citizen, a public-interest organization based in Washington, D.C., Dominion's record has proved otherwise.

According to Public Citizen, in April 2003, a Dominion subsidiary agreed to pay $1.2 billion in a settlement with the U.S. Department of Justice when it violated the Clean Air Act by increasing power-generating capacity of a huge coal-fired power plant in West Virginia without obtaining mandatory permits.

A year later, according to Public Citizen, Dominion paid a

$500,000 civil penalty and had to offer a $4.5 million refund to its customers after the U.S. Federal Energy Regulatory Commission (FERC) caught the company violating federal regulations.

'When an outlaw company operates a killing machine that targets innocent families In our community, it Is time to demand that its operations be terminated,' Burton said.

The Connecticut Coalition Against Millstone is an organization of statewide safe-energy groups, Millstone whistleblowers and families.

4 NUREG-1437, Supplement 22 A-246 July 2005

Appendix A it

• MWIaO N. wly Coolest. 1*

4- illuene ragv 9alick

- AAIII0uuuAuI RoweFerwyRoA MaCldowJ. cm OC63SS '

. ,.1 I - . .  : _..

February 25, 2005 GAgrA 71'- 7 Chief. Rules Review and Directives Branch United States Nuclear Regulatory Commis! ;ion Serial No.: 04-745 4~;p%

1\1 Mail Stop T6-D59 - LPJG - R0 Washington, DC 20555-0001 Docket Nos.: 50-336

. . S , .  ! 50-423

- LUcense Nos.:* DPR-85 NPF-49 DOMINION NUCLEAR CONNECTICUT. INC. (DNC1 MILLSTONE POWER STATION UNITS 2 AND 3  :

LICENSE RENEWAL APPLICATIONS --

COMMENTS ON DRAFT SUPPLEMENT 22 TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT On Decemberi 2004, the Nuclear Regulatory Commission (NRC) issued Draft Supplement 22 to the Generic Environmental Impact Statement (GEIS) regarding the license renewal applications (LRAs) for Millstone Power Station Units 2 and 3.

Comments on the draft were solicited.

DNC has reviewed the draft and presents the following observations. Draft Supplement 22 fairly represents the environmental conditions associated with plant operation.

Furthermore, we concur with the overall conclusions concerning the Impacts associated with the station's operation, and offer the attached comments and clarifications concerning the content of the draft.

Should you have any questions regarding this letter, please contact Mr. William D.

Corbin. Director. Nuclear Engineering Department. Dominion Resources Services, Inc.,

at (804) 273-2365. ---

Very truly yours,- ; . - - . I J"'I r: : :--: _1, .

I . ., -- - --- ,

I I- " I -  ; _. .

E. - Vas-.... '-. ' :z Vice President - Nuclear Support Services ','i!'. - .

Attachment:

Comments on Draft Supplement 22 to th GElS for License Renewal Commitments made in this letter None.

5- 5 / Oqe //-c 1 0 -,-

GusZ.<_ = .6 ctD e1, dec)

July 2005 - A-247 NUREG-1 437, Supplement 22

Appendix A Serial No. 04745 Docket Nos.: 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Page 2 of 4 cc: U.S. Nuclear Regulatory Honorable Christopher Dodd Commission US Senate Region I 100 Great Meadow Road 475 Allendale Road Wethersfield, CT 06109 King of Prussia. PA 19406-1415 Ms. Catherine Marx Mr. V. Nerses Governor's Eastern Office Senior Project Manager P.O. Box 1007 U.S. Nuclear Regulatory 171 Salem Turnpike Commission Norwich, CT 06360-1007 One White Flint North 11555 Rockville Pike Mr. William Melnert Mail Stop 8C2 MMWEC -

Rockville, MD 20852-2738 P.O. Box 426 Ludlow. MA 01058-0426 Mr. S. M. Schneider NRC Senior Resident Inspector Honorable Andrea Stillman Millstone Power Station CT State Senate 5 Coolidge Court Honorable Wayne L Fraser Waterford, CT 06385 First Selectman P.O. Box 519 Honorable Ed Jutila Niantic. CT 06357-0519 CT House of Representatdves 23 Brainard Road Mr. Stephen Page Niantlc. CT 08357 Central VT PSC 77 Grove Street Honorable Robert Simmons Rutland, VT 06701 US Congress 2 Courthouse Square Honorable Elizabeth Ritter Norwich, CT 06360 CT House of Representatives 24 Old Mil Road Mr. Thomas Wagner Quaker Hill, CT 06375 Town of Waterford Town Planner Mr. Denny Galloway 15 Rope Ferry Road Supervising Radiation Control Waterford, CT 06385 Physicist State of Connecticut - DEP Dr. Edward L Wilds Division of Radiation Director, Division of Radiation 79 Elm Street State of Connecticut - DEP Hartford. CT 06106-5127 79 Elm Street Hartford. CT 06106-5127 NUREG-1437, Supplement 22 A-248 July 2005

Appendix A Serial No.04-745 Docket Nos.: 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Page 3 of 4 Chairman Donald Downes Mr. Jim Butler DPUC Executive Director - Council of 10 Franklin Square Governments New Britain, CT 06051 8 Connecticut Avenue

'Norwich. CT 06360 Honorable Dennis L Popp Chairman - Council of Mr. Bill Palomba Governments Executive Director, DPUC Municipal Building 10 Franklin Square 295 Meridian Street New Britain, CT 06051 Groton, CT 06340 Honorable Ernest Hewett Chief Murray J. Pendleton State House of Representatives Director of Emergency 29 Colman Street Management New London. CT 06320 41 Avery Lane Waterford, CT 06385-2806 Honorable Terry Backer CT House of Representatives Honorable Richard Blumenthal Legislative Office Building Attorney General Room 2102 55 Elm Street Hartford, CT 06106 Hartford, CT 06106-1774 Honorable Kevin DelGobbo Mr. John Markowlcz CT House of Representatives Co-Chairman - NEAC 83 Meadow Street 9 Susan Terrace Naugautuck, CT 06770 Waterford, CT 06385 Honorable Thomas Hertihy Mr. Evan Woolacott CT Senate Co-Chairman - NEAC 12 Riverwalk 128 Terry's Plain Road Slmsbury, CT 06089 Simsbury, CT 06070 Honorable Cathy Cook Honorable M. Jodi Rell CT Senate, 18 District Governor 43 Pequot Avenue State Capitol Mystic, CT 06355 Hartford, CT 06106 Mr. Edweard Mann Mr. Mark Powers Office of Senator Dodd 4 Round Rock Road Putnam Park Niantic, CT 06357 100 Great Meadow Road Wethersfield, CT 06109 Mr. Jay Levin 23 Worthington Road New London. CT 06320 July 2005 A-249' NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos.: 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Page 4or4 Chairperson Pam Katz CT Siting Council 10 Franklin Square New Britain, CT 06051 Mr. Ken Decko CBIA 350 Churcn Street Hartford, CT 06103 Hono-able Paul Eccard Fiist Selectrman Town of Waterford 15 Rope Feny Road VWaterford, CT 06385 Mir. Richard Brown City Manager New Lcndon City Hall 181 State Street New London, CT 06320 Honorable Jane G. Glover Mayor, New London New London City Hall 181 State Street New London, CT 06320 NUREG-1437, Supplement 22 A-250 July 2005

Appendix A SN: 04-745 Docket Nos.: 50-336/423

Subject:

Comments on Draft Supplement 22 to the Generic Environmental Impact Statement COMMONWEALTH OF VIRGINIA )

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck. who is Vice President -

Nuclear Support Services, of Doninion Nuclear Connecticut. Inc. He has affirmed before me that he Is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements In the document are true to the best of his knowledge and belief.

Acknowledged before me this j day o . 2005.

My Commission Expires: gool-

//2ts' / *zio,,

Notary Public (SEAL)

July 2005 A-251 NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment/ Page 1 of 27 Attachment Millstone Power Station Units 2 and 3 License Renewal Applications Comments on Draft Supplement 22 to the Generic Environmental Impact Statement for Ucense Renewal Dominion Nuclear Connecticut NUREG-1437, Supplement 22 A-252 July 2005

Appendix A Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 2 of 27 MPS-47-1 Section 2.1.1 External Appearance and Setting Page 2-2. Line 18 Draft GEIS Supplement 22 Statement All development at Millstone Is situated south of this mostly below-grade rail ine.

Dominion Comment - - - -

After the word Millstone.' Insert 'except the training facility." such that the sentence reads:

'All development at iAUstone, except the training facility, Is situated south of this mostly below-grade ran ine.'

MPS-47-2 Section 2.1.3 Coollna and Auxiliary Water Systems -

Page 2-7. Line 9 Draft GEIS Supplement 22 Statement

...cuts excavated from the bedrock at the eastem end of the quariy into Long Island Sound.

Dominion Comment

'eastem should be changed to 6southemn. such that the line reads:

...cuts excavated from the bedrock at the southern end -of the quany Into Long Island Sound.

MPS-47-3 Section 2-1.3 Cooling and Auxiliary Water Systems .

Page 2-7. Unes 29-32 Draft GEIS Supplement 22 Statement Service water Is withdrawn and diverted from the 'system bbfore the water enters the condensers. This water Is used In a variety of applications, Including component cooling 3 (e.g., pump bearings and spent fuel pool water) and fire protection. A maximum of 2.3 m /s (36f000 gpm) of senrlce water Is withdrawn.

July 2005 A-253 NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 3 of 27 MPS-47-3 Dominion Comment The configuration of the service water system Is somewhat different than that stated, and the stated pump capacity Isthat only for the three pumps at Unit 2. During normal operation, two pumps at each unit are operating, for a total of 3.4 m3ls (54.000 gpm). Also, service water Is used as backup for several other systems, but not for fire protection. This paragraph should be changed to read:

• Service water Is also withdrawn Inside the Intake structures. This water Is used In a variety of applications, Including component cooling (e.g.. pump bearings and spent fuel pool water) and as an emergency backup supply for some systems. During normal operation.

approxImately 3.4 m3/s (54.000 gpm) of service water Is withdrawn for both units.'

MPS-47-4 Section 2.1.4 Radioactive Waste Management Systems and Effluent Control Systems Page 2-8. Ines 27-29 Draft GEIS Supplement 22 Statement Millstono is in the process of obtaining a permit to construt a dry fuel storage area for additional spent fuel assemblies.

Dominion Comment Millstone has obtained the permit described above. It Is suggested that 'is In the process of obtaining a permit to construct be changed to 'has constructed' so the sentence reads:

Millstone has constructed a dry fuel storage area for additional spent fuel assemblies.'

MPS-47-5 Section 2.1.4.3 Solid Waste Processinq Page 2-12. line 3 Draft GELS Supplement 22 Statement

...volume was 24.3 m3 (858 ft)...

NUREG-1437, Supplement 22 A-254 July 2005 I

Appendix A Serial No.04-745 Docket Nos. 50-336/423

-. - - . I.:, .;

Comments on Draft Supplement 22 to the I . . . . I ,~. Generic Environmental Impact Statement

. . . . w . ' Attachment I Page 4 of 27 MPS-47-5 Dominion Comment Change to:

,...volume was 243 m3 (8580 ft?)...

MPS-47-6 Section 2.1.5 Nonradloactive Waste Systoms

g. I . . ..

2-12. U s 1 ' 1 Page 2-12, Uines 11-12 Draft GEiS Supplement 22 Statement DomInIon has petitioned the CTDEP to be classified as a small-quantity generator because of a reduction In the amount of waste generated at Millstone.

Dominion Comment Although Millstone generates hazardous waste at the rate of a smatquantity generator, the decision was made not to pursue dassificatlon as a small-quantity generator, In order to maintain flexibility In storage and shipping. It is suggested that this sentence be deleted.

MPS-47-7 Section 2.1.5 Nonradloactive Waste Systems Page 2-12. Unes 17-19 a Draft GEIS Supplement 22 Statement Common types of hazardous waste generated at Millstone are lead acid sludges and batteries, solvent rags, and sawdust contandnated with chemicals regulated under RCRA.

Dominion Comment Lead acid batteries and sawdust contaminated with chemicals are classified as Connecticut-regulated wastes. ihis sentence should be changed to the following:

• Common types o0hazardous waste generated at Millstone are aerosol cans, paint-related waste mateiials.iand solvent rags.

Jul2.

Jul y2005 A-255 NUREG-1437. SuDpleme.. ant 22'

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 5 of 27 MPS-47-8 Section 2.1.6 Plant Operation and Maintenance Page 2-12. line 37 Draft GEIS Supplement 22 Statement Dominion assumes that an additional 60 employees will be needed...

Dominion Comment Sentence should be changed to:

'Dominion assumes that no more than 5 additional employees will be needed...'

MPS-47-9 Section 2.1.7 Power Transmission System Page 2-15, Line 2 Draft GElS Supplement 22 Statement All personnel applying herbicides are required to process a valid applicator's license.

Dominion Comment It is suggested that the word 'process be changed to 'possess: so that the sentence reads:

'All personnel applying herbicides are required to possess a valid applicators license.'

MPS-47-10 Section 2.2.2 Water Use Page 2-17. Line 2 Draft GEIS Supplement 22 Statement Additional minor amounts ofocean water are used for fire protection and other systems.

NUREG-1437, Supplement 22 A-256 July2005 I

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 6 of 27 MPS-47-10 Dominion Comment Although ocean water can be used as backup for some systems. it Is not used In the fire -

protection system: The sentence should be modified as follows:

• Additlonal minor amounts of ocean water may be used as emergency backup for other systems.

MPS-47-11 Section 2.2.2 Waler Use Page 2-17, Unes 6-7 Draft GEIS Supplement 22 Statement Dye tracer and modeling studies estinate that 20 percent of the Niantic River discharge goes through the plant.

Dominion Comment These studies determined flow characteristics during three-unit operation. It is estimated that current two-unit operation results in approximately 15 percent of the Niantic River discharge going through the plant The sentence should be changed to:

Dye tracer studies estimated that 20 percent of the Niantic River discharge went through the plants during three-unit operation. It Is estimated that current two-unit operation results In approximately 15 percent of Niantic River discharge going through the plants.'

MPS-47-12 Section 2.2.3 Water Quality Page 2-17. Line 36 Draft GEIS Supplement 22 Statement The NPDES pem2r, which Is renewed every five years, expired In 1997.

Dominion Comment Change 'expired in 1997- to 'was set to expire In 1997 but remains In effect because a timely renewal application was filed with the CTDEP so sentence reads:

July 2005 A-257 NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 7 of 27 MPS-47-12 'The NPDES permit, which Is renewed every five years. was set to expire In 1997 but remains In effect because a timely renewal application was filed with the CTDEP.'

MPS47-13 Section 2.2.3 Water Quality Page 2-18, Lines 7-8 Draft GEIS Supplement 22 Statement Recent monitoring results show that the discharge quality occasionally exceeds pennit limits Dominion Comment It is suggested that the sentence be changed by adding 'There have been occasional Instances when' before 'monitoring results,' substituting 'have been above' for 'show that the discharge quarity occasionally exceeds' and adding 'These Instances have been property reported In Millstone's monthly discharge monitoring reports to the CTDEP so the sentence reads:

'There have been occasional Instances when monitoring results have been above permit limts (e.g.. total suspended solids). These Instances have been property reported In Millstone's monthly discharge monitoring reports to the CTDEP.

MPS47-14 Section 2.2.3 Water Quality Page 2-18. Line 24 Draft GEIS Supplement 22 Statement

... nay be present for no more than two hours In any one day.

Dominion Comment After 'two hours.' Insert 'per unit,' so the sentence reads:

.. may be present for no more than two hours per unit in any one day.'

NUREG-1437, Supplement 22 A-258 July 2005

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 8 of 27 MPS.47-15 Section 2.2A Air Quality Page 2-20, Unes 20-22 Draft GEiS Supplernont 22 Statement Air emissions from these sources are subject to Connecticut General Statutes section 22a-174-33 of the Regulations of Connecticut State Agencies (Connecticut Legislature 2003).

Dominion Comment In addition to section 22a-174-33 (which regulates TIle V air permits), air emissions from site sources are subject to other regulations. it Is suggested that this sentence read:

'Air emissions from these sources are subject to Connecticut General Statutes, various sections of the Regulations of Connecticut State Agencies, Title 22a-174. 'Abatement of Air Pollution, and various federal regulations. - - -

MPS-47-16 Section 2.2.5 Aquatic Resources Page 2-20. Unes 28-29

- -Draft GEIS Supplement 22 Statement . _ '

Millstone Is located at Millstone Point, a small peninsula of land situated on the west shore of Long Island Sound near Waterford, Connecticut.

Dominion Comment -; -

Change 'wesr to north, and change 'near to in,' so the sentence reads:

Mllstone is located at Millstone Point. a small peninsula of land situated on the north shore of Long Island Sound In Waterford, Connecticut'*

MPS-47-17 Section 2.2.5 Aquatic Resources Page 2-20, Unes 38-39, and Page 2-21, Une 4.

July 2005 A-259 NUREG-1 437, Supplement 22

Appendix A Serial No. 04.745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 9 of 27 MPS-47-17 Draft GEIS Supplement 22 Statement

...about 20 percent of the water discharged from the station from the Niantic River could be passed through the Millstone cooling water system under three-unit operation...

Dominion Comment Delete 'from the station, and add 'and about 15 percent under two-unit operation' to the end of the sentence, so the sentence reads:

...about 20 percent of the water discharged from the Niantle River could be passed through the Millstone cooling water system under three-unit operation, and about 15 percent under two-unit operation...'

MPS-47-18 Section 22.5.1 General Water Body Characteristics Page 2-22. Unes 12-15 Draft GEIS Supplement 22 Statement Millstone Point lies on the western shore of Long Island Sound, near the mouth of the sound.

This area of Long Island Sound experiences a safinity of approximately 23 paels per thousand. Salinity Is Influenced by the presence of three major divers. the Thames, the Housatonic. and the Connecticut. T7ese ries flow Into the Sound in the vicinity of the site.

Dominion Comment It Is suggested that wyestem shore' be changed to 'eastem end,' that '23' be changed to

'26-30. and that 'These' be changed to -The Thames and Connecticut,* so the sentence reads:

MiAfstone Point lies on the eastern end of Long Island Sound, near the mouth of the sound.

This area of Long Island Sound experiences a salinity of approximately 26-30 parts per thousand. Salinity Is influenced by the presence of three major rivers: the Thames. the Housatonic, and the Connecticut The Thames and Connecticut rivers flow Into the Sound In the vkity of the site.'

NUREG-1437, Supplement 22 A-260 July 2005 I

Appendix A Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the

.Generic Environmental Impact Statement

-  ; Attachment I Page 10 of 27 MPS-47-19 Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish Species Page 2-24. Une41 -

Draft GEIS Supplement 22 Statement

...and the northem Atlantic cost of the U.S.

Dominion Comment -

Change cost to coast-MPS-47-20 Section 2.2.5.5 Ponulation Trends Associated with -Impirtant Fish and Shellfish Species Page 2-25. Une 28 Draft GEiS Supplement 22 Statement - . -

IndMdual females can produce up to 500,000 eggs.

Dominion Comment ' - - -

It Is suggested that the sentence be changed to read:

'Individual females can produce up to 2,500.000 eggs, but 500,000 eggs Is an approximate

-- -awraged MPS-47-21 Section 2.2.5.5 Population Trends Assoclated with Important Fish and Shellfish Species Page 2-25. Une 36 and Page 2-26, Flgure 2-6. * -

*. Draft GEIS Supplement 22 Statement --

.. reporting years (Fgture 2-6) (NOAA 1998; MacLeod 2003; National Marine -Fisheries Service...

July 2005 A-261 NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 11 of 27 MPS47-21 Dominion Comment It Is suggested that Gottschall et al. 2003 be added to the reference list for Figure 2-6 on line 36, and In the figure Itself. Gotschall et al. Is the citation for the CTDEP Long Island Sound Trawl Survey.

MPS47-22 Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish Soecies Page 2-26. Unes 4-8 Draft GEIS Supplement 22 Statement According to NOA, 'The continuing low levels of landings, catch per unit effort Indices and survey Indices suggest that winter flounder abundance in the Gulf of Maine has been reduced substantially. Future Improvemnents In the condition of the stock wiff depend on decreases In exploitation in both the recreational and commercial fisheries, and on improved recruitment.

The stock Is at a low biomass level and Is considered to be exploited) (NOAA 1998).

Dominion Comment It Is suggested that the following Information regarding the Southern New England stock be added to this paragraph, or as an additional paragraph:

YWith regard to current winter flounder stock abundance, NEFSC (2003) stated that the Southern New England/Mid-Atlantic winter flounder stock complex has been overfished and overfishing Is continuing to occur. The current assessment provided a much more pessimistic evaluation of stock status than the previous assessment made In 1998.

Recruitment to the winter flounder stock has been below average since 1989. and indications are that the 2001 year-class Is the smallest In 22 years.'

The reference for this statement Is:

NEFSC (Northeast Fisheries Science Center). 2003. B1. Southern New England/Mid-Atlantic (SNE/MA) winter flounder. Pages 139-220 in Report of the 36ah northeast regional stock assessment workshop (SAW): stock assessment review committee (SARC) consensus summary of assessments. NOANNational Marine Fisheries Service, Woods Hole, MA.

Accessed via:

httrn/Avww.nefsc-noaa.aovlnefscloublicationslcrdlcrdO3O6 NUREG-1 437, Supplement 22 A-262 July 2005

Appendix A Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the

- - Generic Environmental Impact Statement

- - ;Attachment I Page 12 of 27 MPS47-23 Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish Species Page 2-28, Unes 15-16 Draft GEIS Supplement 22 Statement fm ang~ng

...wth comrnrdat harvests over the past seven years for tho Atlantis seaboard approximatlay 259 to over 300 MT (286 to 331 tons)...

Dominion Comment Change Atlantis to Ailantfc Also. all of the numbers In this sentence should be followed by 'x 10'.:

MPS47-24 Section 2.2.5.5 Ponulation Trends Associated with Important Fish and Shellfish Page 2-28, Line 25 Draft GEIS Supplement 22 Statoment The stverslde (Menidia menid;a. family Athernidae) Is a small...

Dominion Comment Two different species of silverside are found In the area. It Is suggested that the sentence be changed to:

'The silversides (Menidia menldiaiMenidiaberyllina, family Atherinidae) are small.."

MPS47-25 Section 2.2.5.5 Ponulation Trends Associated with Important Fish and -Shellfish Species Page 2-28. Une 32 July 2005 A-263 .- NUREG-1 437, Supplement 22*

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 13 of 27 MPS-47-25 Draft GEIS Supplement 22 Statement Regional abundance data are not available.

Dominion Comment Dominion notes that Gotschall et al (2003) observed sImilar fluctuations. without trend throughout Long Island Sound.

MPS-47-26 Section 2.2.5.6 Other Important Aquatic Resources Page 2-31. Une 8 Draft GEIS Supplement 22 Statement

... bamaclos~tMe algaeFucus spp., the red alga Chondrus spp., and...

Dominion Comment It Is suggested that this sentence include Ascophyllunt nodosurm, and that It read:

'...bamnades, the brown algae Fucus spp. and Aso~phyllum nodosum. the red alga Chondrus cdfspus. and...

MPS-47-27 Section 2.2.5.6 Other Imp~ortant Aquatic Resources Page 2-31. Una 22 Draft GMlS Supplement 22 Statement

... and the bivalve mollusc Nuculana annulate...

Dominion Comment Change'Nuculana to'Nucula.'

NUREG-1 437, Supplement 22 A-264 July 2005 I

t tI I

f Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment Page 14 of 27 MPS-47-28 Section 2.2.5.7 Threatened or Endangered Aguatic Species Page 2-33. Une 9 Draft GEIS Supplement 22 Statement Adult-sized (10 cm (6 or niore n.D sturgeon are occasIonally seen...

Dominion Comment Dominion believes that the Intent was to characterize adult-sized sturgeon as 6 feet long, rather than 6 Inches.

Section 2.2.6.1 Site Terrestrial Resources >- -

MPS-47-29

- Page 2-36. line 10  ; I Draft GEIS Supplement 22 Statement

...173 fledglings have been produced overthis period. -

Dominion Comment - -.

As of the present time, the number of fledglings produced at Millstone stands at 186.

MPS-47-30 Section 2.26.1 Site Terrestrial Resources Page 2-36. line 14 Draft GEIS Supplement 22 Statement There are 18 specIes listed by FWS or the state of Connecticut as being known to occur on the site. -'

July 2005 . A-265 - NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 15 of 27 MPS-47-30 Dominion Comment Dominion belleves this sentence refers to the 18 species listed in Table 2-3. Some of those species have been observed on the site or along the transmission lines, and some have not been observed. but may occur. It is suggested that the sentence be changed to:

There are 18 species listed by FWS or the State of Connecticut that have either been observed on the site or have the potential to occur In the area or along transmission lines.*

MPS-47-31 Section 2.2.6.1 Site Terrestrial Resources Table 2-3 Draft GEIS Supplement 22 Statement This table lists terrestrial species known to occur or that potentially occur at Millstone or along the transmission lines.

Dominion Comment Dominion notes the following:

• As of June 2004. the Cooper's hawk Is no longer listed by the State of Connecticut.

• The piping plover Is listed as 'threatened' by the State of Connecticut.

• Dominion Is unable to find any citation by the State of Connecticut that lists the New England cottontail as either threatened or endangered.

• The seabeach sandwort Is listed by the State of Connecticut as a special concern' species.

MPS-47-32 SectIon 2.2.8.1 Housing Page 2-44, One 1 Draft GEIS Supplement 22 Statement

...while another 200 live in Niantic and East Ume.

NUREG-1437, Supplement 22 A-266 July2005 I

Appendix A Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the

... . . - . . - .- Generic Environmental Impact Statement

..  ;- - Attachment I Page 16 of 27 MPSX7-32 Dominion Comment Change 'Llme to OLyrne.'

MPS-47-33 Section 2.2.8.2 Public Services Page 2-47, ines 10-12 ,,~

'L Draft GEIS Supplement 22 Statement . - -  ;

A new water supply line was constructed In 2000 to supply Mlstone, and this line replaced the use of two shallow low-)4eld wells that had been used to Inigate ball fields and supply concession stands on the Millstone site licensed to Waterford.

Dominion Comment , . _ . ,

It Is suggested that this paragraph be replaced with the following clarification:

'A new water supply line was constructed In 2000 to supply a concession stand at the ball fields licensed by Millstone to Waterford. The stand had been suppiled by a shallow low-yield well, which continues to be used to Irrigate the ball Selds on a seasonal basis.'

MPS-47-34 Section 2.2.8.5 Demography Page 2-55, LIne 30 Draft GEIS Supplement 22 Statement Source: Dominion 20004a Dominion Comment ,

Delete a zero in the date of the citation. '.

MPS-47-35 Section 2-2.8.5 tDemoqraphv Page 2-56. Line 35 July 2005 A-267' NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 17 of 27 MPS-47-35 Draft GEIS Supplement 22 Statement

...after September 11. 2000...

Dominion Comment Change '2000 to '2001.-

MPS-47-36 Section 2.2.9.1 Cultural Backqround Page 2-60, Une 25 Draft GEIS Supplement 22 Statement

...Park overlooking the Thames River about 8kan (5 mt) northwest of Millstone.

Dominion Comment Change 'northwes' to'northeast.'

MPS-47-37 Section 2.2.9.1 Cultural Backaround Page 2-63, Une 16 Draft GEIS Supplement 22 Statement Actual power generation began In 1975.

Dominion Comment Unit 1. which Is not the subject of this report, began generating power In 1970. It Is suggested that 'at Unit 2' be Inserted so sentence reads as follows:

'Actual power generation at Unit 2 began In 1975.'

NUREG-1437, Supplement 22 A-268 July 2005

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 18 of 27 MPS-47-38 Section 2.3 References Dominion Comment It Is suggested that the following new references be added to this list. as discussed In comments above:

iGottschali, K.F., D.J. Pacileo, and D.R. Molnar. 2003. Job 2: Marine finfish survey. Part l:

Long Island Sound trawl survey and Part II: estuarine seine survey.' Pages41-149 In: of A study of marine recreational fisheries In Connecticutt CT Dept of Envir. Prot., Bureau Natural Resources. Fisheries Divislon.'

and

'NEFSC (Northeast Fisheries Science Center). 2003. B1. Southern New England/Mid-Atlantic (SNE/MA) winter flounder. Pages 139-220 in Report of the 36k northeast regional

• *stock assessment workshop (SAW): stock assessment review committee (SARC) consensus

-summary of assessments. NOAA/National Marine Fisheries Service, Woods Hole, MA.

• Accessed via:' .

httDpl/www.nefsc.noaa.oov/nefsclDublications/crd/crdO3O6

• MPS-47-39 Section 4.1 Coollna System Page 4-7. lines 38-39 Draft GEIS Supplement 22 Statement The barierprevents fish from entering the quany. Since Instaftedon of the fish barriers, the

- licensee has not observed any fish ktis related to the station discharge. -

Dominion Comment As discussed In section 4.1.3, page 4-28. lines 26-27, temperatures within the quarry occasionally exceed lethal temperature thresholds for some species. Some periodic, smaller-scale fish kills have occurred due to themnal stiess for fish that entered the quariy as eggs/larvae, as juveniles, or during barrier maintenance activities. None of these occurrences have been of a magnitude that resulted In an Impact to source populations, and they have been confined to the quany. The sentences should be modified as follows:

July 2005 A-269 ; NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 19 of 27 MPS-47-39 The barrier Is designed to prevent fish from swimming into the quarry. Since installation of the fish barriers, the licensee has not observed any gas bubble disease-related fish kills related to the station discharge.'

MPS-47-40 Section 4.1.1 Entrainment of Fish and Shellfish In Early Life Stages Page 4-10. lines 17-19 Draft GEIS Supplement 22 Statement Licensees are required to demonstrate compliance with the Phase it performance standards at he time ofrenewal of their NPDES permit Dominion Comment

.are' should be changed to 'will be, and 'at the time of renewal of their NPDES permit should be changed to 'in accordance with the provisions of the new rule' so the sentence reads as follows:

'Licensees will be required to demonstrate compliance with the Phase II performance standards In accordance with the provisions of the new rule.'

MPS-47-41 Section 41.1 Entralnment of Fish and Shellfish In Early Life Staces Page 4-10. UnLes 19-21 Draft GEIS Supplement 22 Statement Licensees may be required as part of the NPDES renewal to alter the Intake structure, redesign the coofing system. modify station operation, or take other mitigative measures as a result of this regulation.

Dominion Commont Delete Me words 'as part of the NPDES renewar so the sentence reads as follows:

'Ucensees may be required to alter the intake structure, redesign the cooling system. modify station operation or take other mitigative measures as a result of this regulation.'

NUREG-1437, Supplement 22 A-270 July2005 I

-Appendix-A Serial No.04-745 Docket Nos. 50L-336/423 Comments on Draft Supplement 2-2 to the Generic Environmental Impact Statement Attachment I Page 20 of 27 MPS-47-42 Section 4.1.1 Entrainment of Fish and Shellfish In Early Life Stages Page 4-13,.Table 4-4 Dominion Comment

-The 2003 Annual Report (Dominion 2004b) contained minor changes to the data In this table.

--- Also. the data columns are eac x0.Iisuggested that the table be replaced with the following:

i I.

.1 ,. .

- I . 7 . . .

r.

.. i, 7.

July 2005 A-271 NUREG-1 437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-336/423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 21 of 27 MPS-47-42 Table 4-4 Estimated Numbe of Anchovtes. Wnter Flounder. American Sand Lance, Grubby, and Atanic Menhaden Larvae Entrained Each Year from 1976 Through 2003 at Millston. and the Volume of Codino Water on Which the Entralnment Estimates Were Based (From Dominion r2004bfl)

Anchovies Winter Flounder American Sand Grubby Atfantic Menhaden Lance Year No. Volume No. Volume No. Volume NO. Volume No. Vohune entrained (i- entrained {m') eftatne (mi)b entrained (min)' entrained (mn)'

(XIOI (10h (XtO' E10 (X10) r1061- (XI 100 (X (XI ) 10I 1976 381 738 121 629 - - - - 3 798 1977 418 821 29 444 01 954 30 489 2 773 1978 1t5 912 80 390 178 709 ItI S4 3 621 1979 805 788 44 343 110 919 20 546 <t 716 1980 67? 633 168 562 I1I 960 32 699 2 643 1981 1.452 860 45 373 74 620 42 408 2 711 1982 451 635 184 838 27 932 48 648 14 743 1983 623 691 211 541 30 902 54 828 19 564 1984 169 801 84 508 18 835 38 524 4 557 1965 693 697 8o 469 a 712 35 527 u 521 19t8 1.096 1.208 123 1.064 4 1.5T7 53 44 5 1.217 1987 119 1.332 165 t.193 30 1.712 51 1.144 2 893 1988 388 1.790 184 1.173 74 1291 112 1.132 6 791 1989 51S 1.445 167 889 42 1.511 67 857 208 1.420 1990 981 1.483 133 1.174 39 1,607 47 098 33 t.367 1991 4S5 899 116 750 7 1.278 31 760 56 802 1992 157 1.091 492 1.076 19 1.302 76 1.293 51 1220 1993 214 1.221 42 t87 46 1.801 51 1.15? 21 1.126 1994 507 1.033 173 920 58 899 58 43 68 8s8 1995 171 696 214 1.006 90 1.532 5r 996 88 997 1998 24 138 51 472 18 7 41 46? 23 92 1997 17 145 6s 173 3 212 28 154 5 135 1998 64 40 84 358 11 440 22 300 33 615 1999 157 1.119 148 748 14 880 49 820 124 .377 2000 75 875 333 1,003 8s 1.459 47 754 468 1.571 2001 26 1.031 377 963 13 1.008 178 721 143 908 2002 28 881 119 8810 6 760 33 875 1A54 1.088 2003 - 434 1.096 19 725 153 890 -

(a) Includes data from December of the previous calendar year.

(b) Volume was determined from the condenser and service cooling water flow at Millstone during the season of occurrence for each taxon.

NUREG-1 437, Supplement 22 A-272 July2005 I

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 22 of 27 MPS47-43 Section 4.1,1 Entrainment of Fish and Shellfish In Early Life Staaies Page 4-14, Table 4-5 Dominion Comment The 2003 Annual Report (Dominion 2004b) contained minor changes to the data In this table.

It Is suggested that the table be replaced wth the followingK' Table 4-5. Estimated Number of Cunner, Tautog, and Anchovy Eggs Entrained Each Year from 1979 through 2002 at Millstone and the Volume of Cooling Water on Which the Entrainment Estimates Were Based (Frorn Dominion r2004bl).

Cunner Tautog Anchovies Year No. Volume No. Volume No. Volume Enrained (m) entrained (m Entrained {m)a (XIo) (X1o) (X10') (XIO) (X1O) (x10) 1979 1.055 . 423 445 - 680 323 - 383 1980 1,640 677 962 773 87 359 1981 1.535 620 1.353 620 285 583 1982 2074 755 1.248 719 210 801 1983 .1888 - .462 1.019 -627 -411 377.

1984 2,089 532 1,S02 SS9~ .883 453 1985 2,809 737 1.717 774 26 * - 441 1986 2.855 1,795 3.747 1.795 523 772 1987 4,082 1,713 3.575 1.713 31 740 1988 4.294 1.800 2.693 1S -905 1989 4.306 1.436 3.001 1,510 5 632 1990 3.634 r 1.689, 2,100- 1,641 - - 27 .724 1991 4.116 1.223 1.513 1.214 105 538 1992 2.648 1.509 1.341 18 648 1993 5.379 1.492 2.048 1.492 228 626 1994 6.099 1.381 1.989 1.381 1TS 867 1995 5.524 1.198 2.481 -1.198 - , 29 - -737 1996 871 256 312 256 4 114 1997 569 185 105 134 'Cl 92 1998 577 718 494 709 - 47 376 1999 1i963 1.222 1.173 1t222 I 339 2000 4,800 1254 2.149 1.369 '1  :- 849 2001 4.339 1.416 3.015 1.416 635 2002 3.340 1,188 2.040 1.188 *ct 750 (a) Volume was determined from the condenser cooling-water flow at Millstone duning the season of occunence for each taxon.

r -,,..-.

July 2005 ! A-273 - NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 23 of 27 MPS-47-44 Section 4.1.1 Entrainment of Fish and Shellfish In Early Life Stages Page 4-16, Line 1 Draft GEIS Supplement 22 Statement

.. nonentralned, late stage larvae from reaching reproductive maturity.

Dominion Comment It Is suggested that 'and subsequent juveniles' be Inserted after larvae, so the sentence reads:

-... nonentrained, late stage larvae and subsequent Juveniles from reaching reproductive maturity.'

MPS-47-45 SectIon 4.1.1 EntraInment of Fish and Shellfish In Early Life Stages Page 4-18, line 17 Draft GEIS Supplement 22 Statement

...coolng water entrained through the cooling system, the number of eggs entrained...

Dominion Comment It Is suggested that 'eggs' be changed to larvae.'

MPS-47-46 Section 4.1.2 Implngement of Fish and Shellfish Page 4-22, lines 8-10 Draft GEIS Supplement 22 Statement Liensees are required to demonstrate compliance with the Phase II perfomance standards at the time of renewal of theirNPDES permit NUREG-1437, Supplement 22 A-274 July 2005

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment I Page 24 of 27 MPS-47-46 Dominion Comment

'are should be changed to will be,. and 'at the time of renewal of their NPDES permit' should be changed to 'in accordance with the provisions of the new rule so the sentence reads as follows:

• ULcensees will be required to demonstrate compflance with the Phase It performance standards In accordance with the provisions of the new rule.'

MPS-47-47 Section 4.1.2 Impingement of Fish and Shellfish '

Page 4-22. lines 10-12 Draft GEIS Supplement 22 Statement Lkensees may be required as part of the NPDES renewal to after the Intake stfrcture.

redesign the coohing system, modify station operation, or take other mitigative measures as a result of this regulation.

Dominion Comment Delete the words 'as part of the NPDES renewar so the sentence reads as follows:

• Lcensees may be required to alter the Intake structure, redesign the cooling system, modify station operation or make other mitigative measures as a result of this regulation.

MPS-474B Sectlon 4.12.1 Implngament Monitoring Page 4-24, Table4-6 4: -'

Dominion Comment Dominion believes that the correct reference for this table is Jacobson et al (1998). See the comment below for SectIon 4.10 for the complete reference. - -

Also, on line 18, the species name for the rock crab Is irwratus.

I.

July 2005 - A-275 NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment J Page 25 of 27 MPS-47-49 Section 4.1.3 Heat Shock Page 4-29, Lines 9-15 Dominion Comment Dominion offers the following minor edits:

Une 9, change 'concorta'to 'contoda.'

Line 10. change 'gragi7e' to 'ragile,' and change 'Saragassum gilipendula to 'Sargassum filipendula.-

Une 13, change abundance' to 'nodal growth.'

LUne 15. change 'abundance to 'growth.

MPS-47-50 Section 4.4.2 Public Services: Public Utility Impacts During Operations Page 4-40. Lines 17-18 Draft GEIS Supplement 22 Statement Millstone's 2000 to 2001 potable water usage avenged 1.257 X 10e L per day (3.320 X 10' gpd).

Dominion Comment Change 3.320 X 108 gpd to '3320 X 105 gpd.'

MPS-47-51 Section 4.6.2 Terrestrial Species Page 4-52. Unes 33-34 Draft GEIS Supplement 22 Statement Both the bald eagle (Haliaeetus leucocephalus) and the piping plover (Charadnus melodus) are known to occasionally use the Millstone site.

NUREG-1437, Supplement 22 A-276 July 2005

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement

- . - . t Attachment I Page 26 of 27 MPS-47-51 Dominion Comment To Dominion's knowledge, the piping plover has not been observed on the Millstone site.

Dominion believes the Intent may have been to name the roseate term. which has been observed on the site. It is suggested that the sentence be changed to:

-Both the bald eagle (Hailaeetus leucocephalus) and the roseate tern (Stema dougallil) are known to occasionally use the Millstone site.'

MPS-47-52 Section 4.10 References Page 4-62 Dominion Comment -

Add the following reference, as discussed above:

'Jacobson, P.M., E. Lorda, D.J. Danhia, J.D. Miller. CA Tomichek, and RA Sher. 1998.

Studies of cooling water Intake effects at two large coastal nudear power stations In New England. In Proceedings of a workshop on Clean Water Act Section 316(b) Technical Issues held at the Coolfont Conference Center, Berkeley Springs. WV, September 22-23, 1998.

Electric Power Research Institute, Palo Alto, CA EPRI Technical Report.'

MPS-47-53 Section 8.1 No-Action Alternative IPage 84, Unes 26-27 I .. - .. .. $ ..

Draft GEIS Supplement 22 Statement When the plant stops operating, there will be a reduction I use of groundwater.

Dominion Comment The station Itself does not use groundwater. The only use of groundwater Is that used by the town of Waterford for seasonal Irrigation of the ball fields. Therefore, closure of the plants would not necessarily result In a reduction In the use of groundwater.

July 2005 A-277' NUREG-1437, Supplement 22

Appendix A Serial No.04-745 Docket Nos. 50-3361423 Comments on Draft Supplement 22 to the Generic Environmental Impact Statement Attachment / Page 27 of 27 MPS-47-54 Section 8.2.5.10 Utillty-Sponsored Conservation Page 8-50. LUne 18 Draft GEIS Supplement 22 Statement Dominion participates in State-wide residential, commerilal, and industrfal pregrams to reduce...

Dominion Comment Dominion Is not the local distributor of electricity. It Is suggested that 'Dominion participates In be replaced with 'Connecdcut has so the sentence reads:

'Connecticut has State-wide residential, commercial, and industrial programs to reduce...'

MPS-47-55 Atnondix H Page H-1. Unes 17-18 Draft GElS Supplement 22 Statement

...or were related to a reactor coolant pump (RCP) seat loss of coolant accident (LOCA).

Dominion Comment loss of coolant accident (LOCAr should be replaced with 'dependency on charging pumps' so the sentence reads:

...or were related to a reactor coolant pump (RCP) seal dependency on charging pumps.'

NUREG-1437, Supplement 22 A-278 July 2005 I

Appendix A

.. - , lep -

. ~ ~ ~

.o 5/ o - -

69 744~7 Jean M. Thorsen -

4 Bay View Avenue -

Old Saybrook, CT06475.

February 20, 2005 Chief, Rules and Directives Branch Division of Administrative Services Office of Administration Mailstop T-6D 59 U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Re: License Renewal Millstone 2 & 3 Dear Sir.

I attended the hearing on January 11, 2005 in Waterford, CT concerning the license renewal for Millstone. It appeared to me that your experts did an excellent job for their client, the Department ofEnergy.

MPS-48-1 In their comparisons of alternative methods of electricity production, I could not find a chart showing total dollar costs for production by the various alternative means.

When considering environmental costs, I feel that nuclear waste and the production of depleted uranium are the most undesirable. The cost of electricity keeps rising for Connecticut residents. As a citizen of this state I would prefer to pay more if the MPS-48-2 power came from more environmentally friendly method of generation. Iberefor, I hope you will not renew this license.

Sincerely, M. Thorsen 5 ,,°/cvy L

.5- ,Ire-.v e-,, m R- -I 3 Go= ta..Ac CAte.45 July 2005 A-279 -. NUREG-1437, Supplement 22

Appendix A Doris Menr~da-1l Doi doa-ReotN b NUREG-1437. Supplement Report Number .. 22 Page II

/aI ). AAw-ff-Frorm: saintrobert csaintrobertncomcastnetb To: <opaOnragovv Date: 2/28/05 9:01 PM '311A/4AO SubjecL Report Number NUREG-1437. Supplement 22 Please see the attached comrments.

,I, >-- 7,1137 Robert Fromer 6" ... CS G 7 Suppeme /2t2 NUREG-1437, Supplement 22 A-280 July 2005 I

Appendix A P.O. Box 71 Windsor, Cr 06095 February 28,2005 Chief -

Rule Review and Directives Branch US. Nuclear Regulatory Commission MailstopT-66D59 Washington, DC 20555 1

-Re: Draft Report For Comment on Generic Environmental Impact Statement for

-License Renewal of Nuclear Plants, Regarding Millstone Power Station, Units 2 and 3, NUREG-1437, Volumes land 2, Supplement 22

Dear Chief Rule Review and Directives Branch:

K

-Itihe problem at hand, which is that centrally generated eectricity is a vulnerable genie.

In order to be used it must travel on an ugly, complex and inefficient labyrinth of wires and substations Even from a security view (national or otherwise) such a fragile system is suicide."

Gordes, Hartford Courant Letter to the Editor, February 1978.

Dominion his not provided a comparative analysis and assessment o life cycle energy.

consumption to determine that re-licensing of Millstone is the preferred option. Nor, has Dominion considered cumulative alternatives (ife., energy sources) to meet the current and future energy demands.

A. INTRODUCFION The United States Nuclear Regulatory Commission ('NRC') considered the environmental impacts of renewing nuclear power plant operating licenses ("OsW) for a 20-year period in its Generic Environmental Impact Statementfor License Renedal of Nuclear Plants (GELS),

NUREG-1437, Volumes I and 2, and codified the results In 10 Code of Federal Regulations (CFR) Part 51. In the GEIS (and Its Addendum 1), the staff identifies 92 environmental issues and reaches generic conclusions related to environmental impacts for 69 of these issues that

• - apply to all plants or to plants with specific design or site characteristics. Additional plant-specific review is required for the remaining 23 issues. These plant-specific reviews are to be included in a supplement to the GEIS.' [GEIS, p. iii.)

Tlhis draft supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted to the NRC by the Domninion Nuclear Connecticut (Dominion) to renew the OLs for Millstone Power Station, Units 2 and 3 (Millstone) for an additional 20 years under 10 CFR Part 54. This draft SEIS includes the NRC staff's analysis that considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives to the proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also includes the staff's preliminary recommendation regarding the proposed action.' Id. -

July 2005 - A-281 NUREG-1 437, Supplement 22

Appendix A Robert Fromer Feb. 28,2005 B. BACKGROUND

'By letter dated January 20,2004, the Dominion Nuclear Connecticut, Inc. (Dominion) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating licenses (OLs) for Millstone Power Station, Units 2 and 3 for an additional 20-year period. If the OLs are renewed, State regulatory agencies and Dominion will ultimately decide whether the plant will continue to operate based on factors such as the need for power or other matters within the State's jurisdiction or the purview of the owners. If the OLs are not renewed, then the plants must be shut down at or before the expiration dates of the current OLs, which are July 10 2015 for Unit 2 and November 2025 for Unit 3. The NRC has implemented Section 102 of the National Environmental Policy Act (NEPA) (42 United States Code [USCI 4321) In 10 CFR Part SL In 10 CFR 5120(b)(2), the Commission requires preparation of art environmental impact statement (EIS) or a supplement to an EIS for renewal of a reactor OL In addition, 10 CFR 51.95(c) states that the EIS prepared at the OL renewal stage will be a supplement to the Generic Environmental Impad Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes I and 2." (Emphasis added.) [Executive Summary, p. xv.)

"Upon acceptance of the Dominion application, the NRC began the envirounental review process described in 10 CFR Part 51 by publishing a notice of intent to prepare an EIS and conduct scoping. The NRC staff visited the Millstone site in May 2004 and held public scoping meetings on May 18, 2004, in Waterford, Connecticut. In the preparation of this draft supplemental environmental impact statement (SEIS) for Millstone, the staff reviewed the Dominion Environmental Report (ER) and compared it to the GEIS, consulted with other agencies, conducted an independent review of the issues following the guidance set forth in NUREG-1555, Supplement 1, the Standard Review Plans for Environmental Reviews for Nuckear Power Plants, Supplement 1: Operating License Renewal, and considered the public comments received during the scoping process. .... Id.

-"his draft SEIS includes the NRC staff's preliminary analysis, which considers and weighs the environmental effects of the proposed action, the environmental impacts of alternatives to the proposed action, and mitigation measures for reducing or avoiding adverse effects. It also includes the staff's preliminary recommendation regarding the proposed action.

Id, xv-xvi

-NRC regulations [10 CFR 51.95(c)(2)] contain the following statement regarding the content of SEISs prepared at the license renewal stage.

The supplemental environmental impact statement for license renewal is not required to include discussion of need for power or the economic costs and economic benefits of the proposed action or of alternatives to the proposed action except insofar as such benefits and costs are either essential for a determination regarding the inclusion of an alternative in the range of alternatives considered or relevant to mitigation. In addition, the supplemental environmental impact statement prepared at the license renewal stage need not discuss other issues not related to the environmental effects of the proposed action and the alternatives, or any aspect of the storage of spent fuel for the facility within the scope of the generic determination in § 51.23(a) ["Temporary storage of spent 2

NUREG-1 437, Supplement 22 A-282 July 2005

Appendix A Robert Fromer Feb.28, 2005 fuel after cessation of reactor operation-generic determination of no significant environmental inpacti and in accordance with § 5123(b).'

Id., xvi.

-If the Millstone operating licenses are not renewed and the units cease operation on or before the expiration of their current operating licenses, the adverse impacts of likely alternatives will not be smaller than those associated with continued operation of Millstone.

The impacts may, in fact, be greater in some areas.' (Emphasis added.) Id., xix.

• . . - ~. ...,.,.....

- he 'preliminary recommendation 'of -the NRC staff Is that the Commission determine that the adverse environmental impacts of license renewal for Millstone are not so great that preserving the option of license renewal for energy planning decislonmakers would be unreasonable. This recommendation is based on (1) the analysis and findings in the GElS; (2) the ER submitted by Dominion; (3) consultation with other Federal, State, and local agencIes; (4) the staff's own independent review; and (5) the staff's consideration of public commetS receivedi during the scoping process." (Emphasis idded.) Id.

123 The Proposed Federal Action' The proposed Federal action is renewal of the OLs for Millstone. The Millstone site is located in Waterford, Connecticut on' the coast between the Niantc and Thames Rivers, appwoximately64 km (40 nil) east of New Haven, 64 km (40 ml) southeast of Hartford and 32 km (20 mi) west of Rhode Wland. Unit 2 is a Corn oningineenng-designed pressurized-water reactorwith a design power level 2700 megawatts tonal (MW~tD and a net-power output of 870 megawatts electric (MWIe]). Unit 3 is a Westinghouse-designed pressurized-water reactor with a design power level of 3411 MW(t) and a net power output of 1154 MW(e).

Plant cooling is provided by'a once-through cooling-water system that is withdrawn from Niantic Bay and dissipates heat by discharge into Long Island Sound. Units 2 and 3 produce electricity to rteet about 50 percent of the electrical use of Connecticut. The current OL for Unit 2 expires on July.31, 2015, and for Unit 3 on November 25,2025. .By letter dated January 20, 2004, Dominion submitted an application to the NRC (Dominion 2004b) to renew these OLs for an additional 20 years of operation (i.e., until July 31, 2035, for Unit 2 and November 25, 2045, for Unit 3)." [GEIS, p. 1-8.1

_nA The Purpose and Need for the Proposed Action:

Although a licensee must have a renewed license to operate a reactor beyond the term of the existing Ok the possession of that license is just one of a number of conditions that must be met for the licensee to continue plant operation during the term of the renewed license. Once an OL is renewed, State regulatory agencies and the owners of the plant will ultimately decide whether the plant will continue to operate based on factors such as the need for power or other matters within the State's jurisdiction or the purview of the owners. Thus, for license renewal reviews, the NRC has adopted the following definition of purpose and need (GEIS Section 1.3):

- ;. 1 ', Cl£l- * .- . , -, ;

.3 July 2005' A-.283 -" NUREG-1437, Supplement 22

Appendix A Robert Fromer Feb. 28,2005 The purpose and need for the proposed action (renewal of an operating license) is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, as such needs may be determined by State, utility, and where authorized, Federal (other than NRC) decisionmakers.-

[GEIS, p. 1I-&

This definition of purpose and need reflects the Commission's recognition that, unless there are findings in the safety review required by the Atomic Energy Act of 1954 or findings in the NEPA environmental analysis that would lead the NRC to reject a license renewal application, the NRC does not have a role in the energy-planning decisions of State regulators and utility officials as to whether a particular nuclear power plant should continue to operate.

From the perspective of the licensee and the State regulatory authority, the purpose of renewing an OL is to maintain the availability of the nuclear plant to meet system energy requirements beyond the current term of the plant's license. (Emphasis added.) [GELS, pp. 1-8 to 1-9.]

-LS Compliance and Consultations Dominion is required to hold certain Federal, State, and local environmental permits, as veU as meet relevant Federal and State statutory requirements. In its Environmental Review, DdTmilon provided a list of the authorizations from Federal, State, and local authorities for current operations, as weU as environmental approvals and consultations associated with Millstone license renewal. Authorizations and consultations relevant to the proposed OL renewal action are included in Appendix E- [GEIS, p. 1-9.1 The staff has reviewed the list and consulted with the appropriate Federal, State, and local agencies to identify any compliance or permit issues or significant environmental issues of concern to the reviewing agencies. These agencies did not identify any new and significant environmental issues The ER states that Dominion is in compliance' with applicable environmental standards and requirements for Millstone. The staff has not identified any environmental issues that are both new and significant." Id.

S.2.5 Other Alternatives Other generation technologies considered by NRC are discussed in the following paragraphs.' [GEIS, p. .

8.21Wind Power Wind power, by itself. is not suitable for large base-load electrical generation. As discussed in Section 83.1 of the GEIS, wind has a high degree of interinittency, and average annual capacity factors for wind plants are relatively low (less than 30 percent). Wind power, in 4

NUREG-1437, Supplement 22 A-284 July 20051.

Appendix A Robert Fromer Feb.28, 2005 conjunction with energy storage mechanisms, might serve as a means of providing base-load power. However, current energy storage technologies are too expensive for wind power to serve as a large base-load generator' [GEIS, p. .1 SThe State of Connecticut is in a wind power Cass 2 region (average wind speeds at 10-m 130-ftD elevation of 5.6 to 6A m/s [18 to 21 ft/sJ): On the coast, Connecticut Is in a wind power Class 3 region (average wind speeds at 10-m (30-ft) elevation of 6.4 to 7.0 rn/s [21 to 23 ft/sD)(DOE 2004a). -In wind power Class 2 areas wind turbines are economically marginal for development, but in lass 3 areas may be suitable with future technology (DOE 2004a)." Id.

'There are active wind power facilities in the region, and others are proposed. As of January 16 2003, there were approximately 48 MW of grid-connected wind power facilities in New York State, with an additional 410 MW of additional capacity in various stages of planning (American Wind Energy Association 2003). In addition, the US. Army Corps of Engineers (USACE) is preparing an environmental impact statement for a proposed wind farm to generate 420 MW(e) using 170 turbines off the coast of Massachusetts (USACE 2004)!' Id.

"Access to many of the best land-based wind power sites near the coast likely would require extensive road building, as well as clearing (for towers and blades) and leveling (for the tower bases and associated facilities) in steep terrain. Also, many of the best quality wind sites are on ridges and hilltops that could have greater archaeological sensitivity than surrounding areas. For these reasons, development of large-scale, land-based wind-power facilities are not

-only likely to be costly, but could also have MODERATE to LARGE impacts on aesthetics, archaeological resources, land use, and terstrial ecology." Ed..

The offshore wind speeds are higher than those onshore and could thus support greater energy production than onshore facilities. Ten offshore wind power projects are currently operating in Europe, but none have been developed in the United States The European plants together provide approximately 250 MW(e),whdch is significantly less than the

-- : electrical output of Millstone (British Wind Energy Association 2003). For the preceding reasons, the staff concludes that locating a wind-energy facility an or near the Millstone site, or offshore as a replacement for Millstone generating capacity, is not only lIkely to be costly, but

- could also have MODERATE to LARGE impacts on aesthetics, aquatic ecology, and shipping lanes." Id.

-825.2SolarlPower Solar technologies use the sun's energy and light to provide heat and cooling light, hot water, and electricity for homes, businesses, and industry. In the GEIS, the staff noted that by its nature, solar power is intermittent. Therefore, solar power by itself Is not suitable for base-load capacity and is not a feasible alternative to license renewal of Millstone. The average capacity factor of photovoltaic cells is about 25 percent, and the capacity factor for solar thermal systems is about 25 percent to 40 percent (NRC 1996). Solar power, in conjunction with energy storage mechanisms, might serve as a means of providing base-load power. However, current energy storage technologies are too expensive to permit solar power to serve as a large base-load generator. Therefore, solar power technologies (photovoltaic and thermal) cannot "5

July 2005 A-285 - NUREG-1437, Supplement 22

Appendix A Robert Fromer Feb. 28.2005 currently compete with conventional fossil-fueled technologies in grid-connected applications, due to high costs per kilowatt of capacity. (NRC 1996)." [GEIS, p..1 WThere are substantial impacts to natural resources (wildlife habitat, land-use, and aesthetic impacts) from construction of solar-generating facilities. As stated in the GEIS, land requirements are high - 14,000 ha (35,000 ac) per 1000 MW(e) for photovoltaic and approximately 5700 ha (14,000 ac) per 1000 MW(e) for solar thermal systems. Neither type of solar electric system would fit at the Millstone site, and both would have large environmental impacts at an alternate site. Yd.

'The Millstone site receives approximately 3 to 35 kWh of solar radiation per square meter per day (Dominion 2004), compared to 6 to 8 kWh of solar radiation per square meter per day in areas of the western United States, such as Califoinia, which are most promising for solar technologies (DOE/EIA 2000). Because of the natural resource impacts (land arid ecological),

the area's relatively low rate of solar radlation, and high cost, solar power is not deemed a feasible base-load alternative to renewal of the Millstone 01s. Some solar power may substitute for electric power in rooftop and building applications. Implementation of nonrooftop solar generation on a scale large enough to replace Millstone would likely result in LARGE environmental impacts." Id.

8.253Hydropower Connecticut has an,estimated 43.5 MW(e) of undeveloped hydroelectric resources (Idaho National Environmental and Engineering Laboratory 1995). This amount is far less than would be needed to replace the 2024 MW(e) capacity of Millstone. In Section 83A of the GEIS, the staff points out that hydropower's percentage of U-11 generating capacity is expected to decline because hydroelectric facilities have become difficult to site as a result of public concern about flooding, destruction of natural habitat, and alteration of natural river couhes' [GEIS, p. .1

-In the GEMS, the staff estimated that land requirements for hydroelectric power are approximately 4.0 x 105 ha (1.0 x 106 ac) per 100 MW(e). Replacement of Millstone generating capacity would require flooding more than, this amount of land. Due to the relatively low amount of undeveloped hydropower resource in Connecticut, and the large land-use and related environmental and ecological resource impacts associated with siting hydroelectric facilities large enough to replace Millstone, the staff concludes that, on its own, local hydropower is not a feasible alternative to Millstone O> ?M/ GOFF=DOFSTHEex Ft-37 March 2, 2005 -

Chief, Rules Review and Directives Branch U.S. NuclearRegulatory Commission -

(li-): - -

Mail Stop T6-D59 Washington, DC 20555-0001 Re: Draft Supplemental Environmental Impact Statement (DSEIS) for Lcense Renewal of Nuclear Plants at the Millstone Power Station, Units 2 and 3, NUREG-1437, Supplement 22 (EPA ERP #NRC-B06005-CI) * -

Dear Sir/Madam:

In accordance with our responsibilities under thcNational Environmental Policy Act (NEPA) and Section 309 of the Clean AirAct we have reviewed the Nuclear Regulatory Commission's (NRC's) Draft Supplemental Environmental Irnpact Statement (DSEIS) for relicensing of Units 2 and 3 of the Millstone Nuclear Power Station in Waterford, Connecticut.

As described in the DSEIS, Dominion Nuclear Connecticut, Inc. (Dominion) as submitted an application to NRC forrenewal ofthe operating licenses for an additional 20 years. The current operating licenses expire in 2015 for Unit 2 and 2025 for Unit 3. The DSEIS was prepared to provide site specific information to supplement NRC's 1996 Generic EIS forLicense Renewal of Nuclear Plants. It contains the NRC staff's preliminaryrecommendation that adverse environmental effects of license renewal at Millstone arc not so great that preserving the option of license renewal would be unreasonable.

Our comments on the DSEIS, which are contained in the attachment to this letter, highlight areas ovhere we believe additional information is needed to more fully describe the impacts of the Millstone facility. Specifically, these comments address the environmental impacts of operation.

including entrainment and impingement of fish and shellfish, impacts from heat shock, and cumulative impacts. We encourage the NRC to address these issues prior to the close orthe NEPA process. We also recognize that the intake and discharge of water at Units 2 and 3 are regulated under the Clean Water Act's National Pollutant Discharge Elimination System (NPDES) permit, administered in Connecticut by the Connecticut Department of Environmental Protection (CTDEP). As discussed in the DSEIS, Dominion has submitted an application to the CTDEP for rnewval of the NPDES permit. The comments in this letter are based solcly on our review of the information in theNRC's DSEIS from the standpoint ofwhat is required byNEPA and are not intended to address the requirements of the Clean Water ActNPDES permit.

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July 2005: A-299. NUREG-1 437, Supplement 22

Appendix A i

i i

I iI For the reasons discussed above (and in the attachment which follows), EPA has rated this DSEIS "EC-2 Environmental Concems-Insufficient Infomnation" in accordance with EPA's national I rating system, a description of which is attached to this letter. We look forward to reviewing responses to the issues highlighted in this letter and technical attachment in the Final Supplemental Environental Impact Statement (FSEIS). My staffis available to provide additional input, as necessary, to help the NRC respond to the issues discussed in this letter.

Please feel free to contact me or Timothy Timnmermann of the Office of Environmental Review at I 6171918-102S if you wish to discuss these comments further.

Sincerely, c Robert WV. Varney Regional Administrator Attachment cc: I i

I I Gina McCarthy, Commissioner, Connecticut Department of Environmental Protection I I

I I

I i

i i

i i

I I

I i i I I

t I

NUREG-1437, Supplement 22 A-300 July 2005

Appendix A Summary of Rating Definitions and Follow-up Action Frirronrigntrl lmnact ofthe Aetion - - - -

LO-Lack or Objections' ' - -

The EPA review has not identified any potential enviroiirnental irmpacts requiring substantive changes to the proposaL The teview nayhave disclosed opportunities for application of mitigation measures that could be accomplished with no more than minor changes to the proposal.

EC-Environmental Concerns The EPA review has identified environmental impacts tbat should be avoided In order to fully protect the environmentL Corrective measures msy require changes to the preferred alternative or application of iitigation measures that cani reduce the environmental impact. EPA would like to workc with the lead agency to reduce these impacts.

EO-Environmental Objections The EPA review has identified significant environmental In-pacts that must be avoided in order to provide adequate protection for the environrient. Corrective tuasures miy require substantial changes to the preferred alternative or consideration ofsome other project alternative (including the no action alternative or a new alternative). EPA intends to work with the lead agency to reduce these impaets.

EU-Environm 'ntallyUnsatisfactory t e of s mh The EPA reviewhas identified adverseenvironnental irpactsthatarofsuffcintrmtruthattheyare nusatisfaetory from thestandpoint of publiechealth or welfare orenvironrental quality. EPA intends toworkwith the led agency to reduce these impacts. Ifthe potentiallyuntisfactory inpacts are not corrected at the final EiS stage, this proposal will be recommended for referral to the CEQ.

Adeouaev of the Imnact Statement --  ;

Category I-Adequiate EPA believes the draft EIS adequately sets forth the environmental impact(s) ofthe preferred alternative and those of the alternatives reasonably available to the project or action. No further analysis or data collection Is necessary. but the reviewer rmay suggest the addition oeclarifying language or information. -- -

Category2-lnsulleient Infortation ' , ,' . .

The draft EIS does not contain sufficient infornmtion for EPA to fully assess envronental impacts that should be avoided in order to fully protect the environment, or the EPA ver has Identified wresonably available alternatives that are vithin the spectrumofalternatives analyzed in the dft EtS which could reduce the environmental impacts of the action. The identified additional information, data, analyses, ordiscussion should be included in the final EIS.

Category3-1nadequate EPA does not believe that the draft EIS adequately issesses potentially significant enviroomenal impacts orthe action, or the EPA reviewer has ientified new. reasonably available alteinatives that are outside of the spectrum of alternatives analyzed in the draft EIS whichshould be analyzed in order to reduce the potentially significant environmental Impacts. EPA believesthat the identified additional Information, data, analyses, or discussions are of such a magnitude that they should have full public review at a draft stage. EPA does not believe that the draft EIS is adequate for the purposes of the NEPA and/or Section 309 reviewv and thus should be formally revised and made available for public comment In a supplemental or revised draft EIS. On the basis of the potential significant impacts Involved, this proposal could be a candidate for refeiral to the CEQ.

ADC-1 July 2005' A-301 OF NUREG-1 437, Supplement 22

Appendix A Additional Detailed Comments Draft Supplemental Environmental Impact Statement (DSEIS) for License Renewal of Nuclear Plants at the Millstone Power Station, Units 2 and 3, NUREG4I437, Supplement 22.

Comments on Chapter 2 - Description of Nuclear Power Plant and Site, and Plant Interaction with the Environment MPS-50-t Pg. 2-1. The DSEIS identifies the years when construction began for each of Millstone's three units, but does not mention when the units came on line for commercial production of electricity.

These dates, as well as dates when each unit was offline for extended periods, would be helpful in reviewing fish impingement and entrainment data, and should be included in the FSEIS.

MPS-50-2 Pg. 2-7. Intake velocity is estimated to be about 0.2 meters per second in front of the Unit 2 structure. The DSEIS does not state at what distance from the intake screen the velocity was measured. Intake velocity should be presented in feet per second and should be estimated as through-scrccn velocity, not in front of the screen, which estimates approach velocity.

Additionally, no intake velocity data are provided for Unit 3. This information is important for assessing the potential of the intake structure to impinge organisms, and should be provided in the FSEIS.

MPS:50-3 Pg. 2-7. The DSEIS identifies some features of the intake structure (eg., traveling screens, fish return trough), but additional information is needed to assess the adequacy of the system for returning fish and other organisms in good condition, as well as the potential to re-impinge organisms that have been discharged from the fish return troughs. We recommend that the FSEIS include information on the water pressure(s) of the spray wash system used to remove fish and debris from the traveling screens, the frequency at which the traveling screens are rotated, a

- spatial-view diagram that includes the location of the intake structures and fish return troughs of each unit, and any other information pertaining to system design or operation that may affect the impingement oforganisms and the likely condition of those that are impinged.

Comments on Chapter 4 - EnvIronmental Impacts of Operation Among the various potential impacts to the environment associated with the operation of a power plant that utilizes once-through cooling water technology, the NRC identifies three issues that wanant a site-specific rcvieev at Millstone, identified in the DSEIS as Category 2 issues. These are 1) entrainment of fish and shellfish, 2) impingement of fish and shellfish, and 3) "heat shock".

The following comments identify information that we believe should be provided in the FSEIS.

ADC-2 NUREG-1437, Supplement 22 A-302 July 2005

Appendix A

-Entrainment MPS-50-4 - In Section 4.1.1 entitled "Entrainment of fish and shellfish inEarlyLifestages 'we could not find data or discussion about shellfish resources. While shcllfish larvae miy represent a small fraction:

- ': of the total composition'iof all larvae entrained, *e recommend that the FSEIS include a discussion about species such as lobster, which has suffered significant declines throughout Long Island Sound. Larval lobster are entrained at other coastal plants, and it is likcly that there is some loss occurring atMillstone associated with the daily withdrawal of up to 2.1 billion gallons of water. We recomniend that the FSEIS address the entrainment of larval lobster, blue crab, and othershellfish ofcommercialandrecreationalinterest.

MPS-50-5 Pg.4-12. Table 4-3 (Percent Composition ofFlish Larvae and Eggs) is unclear on what the significance of the dates is for each columniand why dates for larvae differ from those for eggs.

in addition, it is unclear why a 26-year average ofpercent composition data for larvae is compared to data from one year (2002.3). We believe it would be more useful to provide a graph that depicts how percent composition has changed annually over the past 27 years. We recommend that the graph include, at minimum, bay anchovy, winter flounder, Atlantic menhaden, American sandlance, grubby, tautog,'and cunner. -

MPS-50-6 Pg. 4-13. Table 44 presents larvae entrainmeni data for select'species of fish. As presented, this table is not clear as to how many larvae are entrained on an annual basis. While knowing larval concentration (i.e, the number of larvae per volume of water sampled) is important in understanding the seasonal variations in larval abundance for each species, it does not in itself provide a clear sense ofthe annual loss of larvae from the plant's operation. We recommend that this table be replaced or accompanied by a table in the FSEIS that lists the estimated total larvae for each species entrained annually froml 976- 2003. While the entrainment numbers may reflect differences in operating schedules from year to year and such considerations should be noted where they exist, ofgreatest interest is the number of larvae for'each species being removed from th6 system. We recommend that that number beprovided in the FSEIS.

Pg. 4-14.- Table 4-5 presents similar data to Table 4-4, but for eggs of three fish species.

However, Table 4-5 presents what appears to be the total numbers of eggs entrained annually and a volume that corresponds with the volume withdrawn during the period when these eggs were to be entrained. This maybe what the DSEIS was intended to illustrate in Table 4-4 (the likely number listed multiplied by I million), but it was not noted on the headers of each column.

MPS-50-7 While an understanding of how many eggs and larvae are entrained annually is important, the significance of those numbers varies from species to species based on a number of variables including species fecundity, age to maturity, estimated annual mortality, recruitment, and status of

- the local population. -Another consideration that we recommend be addressed is whether a species is an important forage'source to local predatory species, and what the loss of their eggs and larvae

- represent in terms of foregone productivity to the local ecosystem. -These analyses were likely-performed byMillstone, and we recommend that the FSEIS provide additional information on what the loss of eggs and larvae represent in terms of adult equivalenits, and the amount of ADC-3 Jul 2005 -:. A-303- NUREG-1437, Supplement 22 -

Appendix A MPS-50-7 production foregone for forage species. Additionally, for species that are exhibiting depressed MPS-50-8 local stocks, such as winter flounder and cunner, we recommend that information on spawning stock biomass forgone also be provided. The loss of one adult wintei flounder could represcnt the cumulative loss of future egg production for 14 years, or more.

MPS-50-9 Pg. 4-21. The DSEIS concludes that impacts to the Niantic Rivcrwinter flounderpopulation from entrainment is "moderate," though it suggests fishing mortality playsi much more significant role. Other stressors, including rising water temperatures, arm also cited as possible contributing factors. According to the DSEIS (pg.l-4), "moderate" is defined as "Environmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of the resource" From our review of the DSEIS, there seems to be general agreement that the Niantic River winter flounder stock has been destabilized, that multiple stressors are contributing to this condition, and that the entrainment of larvae at Millstone (eg., 492 milli6n in 1992) is one of the contributing stressors.

The DSEIS concludes that the NRC has no role in mitigating for entrainment impacts since such impacts are regulated under the Clean Water Act. We agree that these impacts are regulated under CTDEP's NPDES permit. However, we believe that under NEPA, the FSEIS needs to fully evaluate and disclose the potential enviromnmental impacts from this operation, and identify possible operational and technology alternatives that could effectively mitigate for the loss of aquatic resources. The DSEIS correctly identifies the unique vulnerabilities associated with the winter flounder's habitat of returning to natal systems to spawn, suggesting that localized impacts could dramatically influence local population dynam ics. However,, the DSEIS includes only a very limited discussion on mitigation alternatives, and suggests that any reduction in entrainment losses would lessen the impact of the plant on the Niantic Rivcr vinterflounderpopulation. This assessment does not fully document the plant's impact on the decline of local winter flounder stocks.

MPS-50-10 Pg 4-20. The DSEIS concludes that there is no clear evidence ofentrainment impact on species other than winter flounder. While other species may not exhibit the same site fidelity for spawning that winter flounder exhibit, data presented in the DSEIS indicate there is a potential cause for concern that additional losses associated with entrainment to already depressed fish stocks, such as bay anchovy and cunner, could impede stock recovery, at least locally. We believe that entrainment impacts to fish populations ihat arc regionally depressed should receive closer scrutiny in the FSEIS.

MPS-50-1 1 The DSEIS notes that populations of sandlancc, bay anchovy, and cunner have been depressed for decades. Anchovy populations reached a 27-year low in 2002. On pg. 4-27, the DSEIS states that anchovy declines appear to be reflecting a regional decline in the stock, but on pg. 2-28 it states that population data for anchovy are not available for Long Island Sound or the Mid-Atlantic region,.and thcrcfiore "...it is not possible to assess whether decreasing abundance of this species near Millstone is a reflection of regional populations". For the FSEIS, we recommend that Millstone's potential impacts to anchovy populations be reassessed and clarified.

ADC-4 NUREG-1437, Supplement 22 A-304 July 2005

Appendix A Lmpingenent - .. - .

MPS-50-12. Pg. 4-24. Table 4-6 provides impingement data for Units I and 2. Apparently, no data was collected forUnit 3 based on survival studies that indicated high survival rates for demersal species during cool and cold water periods. Pelagic species, Including long-finned squid, bay anchovy, and Atlantic silversides, had poorrates ofsurvival year-round. While these studies may provide some sense of the fish return system's effectiveness for demersal species in cool or cold water conditions, it also clearly demonstrates that some'species such as bay anchovy and menhaden are not likely to survive impingemen. In addition, it does not indicate what the survival rate is during the warm water months of summer and early fall when the nevest year class of some species such as vinter flounder are likely to be present in the vicinity of the intakes, and vulnerable to impingement. Wc recommend that Information on survival rates ofdemcrsal species during warmer periods be included in the FSEIS. -

MPS-50-13 The DSEIS states (pg. 4-23) that the highest annual irnpingement of winter flounder for Unit 2 and 3 combined was 2,446 fish, in 1986. However, Table 4-6 indicates that the largest annual impingement ofwinter flounder was estimated to be 23,5S4. The table does not mentionwhether the numberreflects impingement rates forUnit 3. The FSEIS should clarify the estimate oftotal annual impingement for winter flounder and other species listed in Table 4-6 that reflects impingement numbers forall units together. '

MPS-50-14 The DSEIS states (pg.'4-27) that the measures in place at Millstone Units 2 and 3 provide mitigation for impacts related td impingement, and no new measures are warranted.- This conclusion is a departure from NRC's approach taken'for entrainment which is io defer the issue of mitigation to the CTDEP. It is unclear why the DSEIS advises that no further mitigation is warranted for impingement, but for entrainment impacts which the NRC believe are moderate, the question of need for, and altemative ways to accomplish, mitigation is largely deferred. As noted abovc, we believe that underNEPA, a discussion ofappropriate mitigation alternatives should be in the FSEIS. In addition, we recommend that the FSEIS not view entrainment and impingement as mutually exclusive impacts, but instead assess the combined effects ofrentrainment,.

impingement, and the thermal plume on species such as winter flounder and anchovy that are vulnerable to two or all of these stressors.

it Shock MPS-50-15 Pg 4-27. This section ofrthe DSEIS provides a limited discussion of some potential environmental impacts associated with the discharge ofrheated effluent. The use of the term 'heat shock" implies a fairly limited scope of review for a pollutant (i.e. heat) that can affect aquatic organisms and their habitats in many ways. We recommend that the FSEIS's discussion be expanded to address heat's less conspicuous ability to: 1) preclude the use of affected areas by temperature-sensitive species; 2) attract and expose organisms to areas ofclcvated temperature during spawning periods; and 3) expose eggs and larvae to water temperatures well above levels that are typical under ambient conditions. . - i AD t.

ADC5 -

July 2005 A-305' NUREG-1 437, Supplement 22

Appendix A MPS-50-15 Whilo thermal plumes tend to remain near the surface during most of the year, they have been known to become negativelybuoyant during the colderwvinterperiods. Ifthis is the case at Millstone, or if the thermal plume affccts the entire water column in shallow areas of Niantic Bay, we recommend that the FSEIS address how the pluine might affect adult winter flounder entering Niantic Bay in the winter months en route to spawning grounds in the Niantic River. The 8,000 foot thermal mixing zone, in which temperatures are permitted to exceed ambient levels by4°F, appears to covermost ofNiantic Bay. We recommend that theFSEIS provide a spatial-view graphic depicting maximum temperatures of the thermal plume under various tidal conditions and seasons, and a more comprehensive analysis of the potential sub-lethal effects caused by the thermal plume.

The DSEIS contains a preliminary conclusion that potential impacts to fish and shellfish due to heat shock are small, and that no new mitigation measures are wwaranted (pg. 4.29). As stated above, EPA believes that the FSEIS should provide a broader review to ensure that all of the possible thermal effects associated with Millstone's daily discharge of up to 2.1 billion gallons of heated waler are adequately assessed. We recommend that the FSEIS re-evaluate Millstone's thermal impacts, at least for winter flounder, before reaching a final conclusion on this issue.

Cumulative Tmracts MPS-50-1 6 The DSEIS (pg. 4-57) identifies fishing mortality, entrainment from Millstone water withdrawvals, environmental changes associated with regional increases in water temperature, and predator-prey interactions as the primary stressors contributing to continuing lowv winter flounder population levels 7in the Niantid River area. EPA agrees that there are multiple stressors affecting winter flounder, but eve believe that other impacts from Millstone besides entrainment may be helping to

impede stock recovery, if not contributing to the population decline.'

Impacts from impingement on winter flounder and other depressed stocks have an additive effect to entrainment losses, and we recommend that they be discussed in the assessment of cumulative impacts. In addition, while the thermal plume from Millstone may not be causing acute mortality to winter flounder and other species, non-lethal effects may have a significant effect to the Niantic Bay area. According to the DSEIS, water temperatures in Long Island Soiind (US) have increased over a 25-year period by 2.80 F11.8°F (dailylannual mean). Temperatures in Millstone's mixing zone are permitted to be up to 4.0OF higher than ambient. The DSEIS states that elevated water temperatures in LIS may be a major contributing factor to the Sounder's decline, but the report does not address possible effects elevated temperature from Millstone's thermal plume has on Niaritic Bay, most ofwhich is contained within the designated thermal mixing zone. Ifthere is infornation supporting a conclusion that thermal effects are not having any adverse impacts on winter flounder behavior, spawning success, habitat use, young-or-year survival, changei in trophic dynamics or forage opportunities, we recommend that it be included in the FSEIS.

We recommend that the FSEIS provide maps with depictions orthe thermal plume on multiple stages of the tide. These maps should include known aquatic resources, such as shellfish beds, fish spawning and nursayhabitats and fish migration routes.

ADC-6 NUREG-1437, Supplement 22 A-306 July 2005

Appendix A F__ , 6 -

CONNECTICUT COALITION AGAINST MILLSTONE

• . i . , . www.mothballmillstone.orag ; - v

- March 2,2005 -;, -,

I, ' ./oY Chief Rules and Directives Branch Division of Administrative Services , ,-

Office of Administration .

Mailstop T-6D59 , ,

U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Re: Millstone Nuclear Power StationlDraft Environmental Impact Statement - -: -

Dear Sirs:

The Connecticut Coalition Against Millstone submits herewith preliminary comments concerning the draft Environmental Impact Statement (EIS) which the NRC staff has prepared in support of relicensing of Millstone nuclear reactors Units 2 and 3 to extend their terms to the years 2035 and 2045 respectively.-These comments will be supplemented with a separate filing with attachments. -

MPS-51-1 The Coalition strongly opposes Millstone relicensing.

The data-available to the U.S. Nuclear Regulatory Commission in its'environmental review establishes a clear link between Millstone's radiological and chemical discharges to the environment and major health effects in the surrounding community.

The data reviewed by the NRC is alarming.' '

MPS-51-2 The data strongly suggests - and indeed does so almost to a certainty- 'that Dominion Nuclear Connecticut, inc. is operating and,-

will continue to operate the Millstone Nuclear Power Station in violation of NRC regulations requiring limiting doses to the public of 15 millirems per year to any organ. "4 Z-.

I Jl - 0 N - 437, S-,upplmen 2 July 2005 A-307 NUREG-1437, Supplem'ent 22 '

Appendix A Put another way, the data strongly suggests that Dominion's Millstone daily operations exceed the permissible dose of radiation to the public and will continue to do so during the proposed relicensing period.

Based on Dominion's own reporting of radiation sampling in the environment, the Coalition believes the available data reviewed by the NRC for the years 2001, 2002 and 2003 prove that routine operations of Millstone are in violation of federal health standards and are illegal.

MRC-51-3 By its own admission, the NRC confined Its review of Millstone radiological releases, for Environmental Impact Statement purposes, to the years 2001,2002 and 2003. ('Radioactive Waste Management Systems and Effluent Control Systems 2.1.4,* DEIS at 2-9) (No explanation is provided in the DEIS as to why the years 1970-2000 and the year 2004 - with the most current data - were excluded from review.)

MRC-51-4 The Annual Radiological Environmental Operating Report submitted by Dominion Nuclear Connecticut, Inc. to the NRC for the year 2001 - one of the few reports the NRC specifically identified that it had reviewed in its EIS procedure - contains the following information:

On September 19, 2001, a concentration of strontium-90 of 55.5 picoCuries per liter (pCiAl) was measured in a sample of goat milk taken from a location 5.5 miles north-northeast of the Millstone Nuclear Power Station. The uncertainty factor reported was plus or minus 5.3 pCi/L A concentration of 55.5 picoCuries per liter is an extremely large concentration, close to twice the highest concentration measured in Connecticut pooled milk at the height of nuclear weapons testing in 1963 of 23 pCi/L," according to a report dated March 1, 2005 by Dr.

Ernest J. Stemglass, Professor Emeritus of Radiological Physics at the University of Pittsburgh School of Medicine and an acknowledged pioneer in the field of the effects of low-level ionizing radiation on living cells. The report appears annexed hereto as Exhibit A.

NUREG-1437, Supplement 22 A-308 July 2005

Appendix A MPS-51-4 Moreover, according to Dr. Stemglass, since the measured value is ten times as large as the measurement uncertainty, this isan -

extremely significant result, with an astronomically small chance'that it is a statistical fluctuation.

Put into perspective, an individual drinking two eight-ounce glasses of the strontium-90-contaminated goat milk on a daily basis would receive a maximum permissible dose of radiation -'under NRC guidelines - within 30 days.

This assumes no other radiological contamination of the milk.

However, strontium-90 never appears alone in the environment.

When the radiological effects-of identified concentrations of radionuclides also reported in the same goat milk samrple - cesium-134, cesium-137, iodine-131, badrium-140andothers - are considered, the effect is even more damaging and far less milk would need to be consumned over fewer days before the 'maximum permissible racdiati6n'does established by federal law would be exceeded, according to Dr. Sternglass.

'The dose to bone or the bone marrow when other fission products are present is some 5 to'6 times greater than from strontium-90 alone, and the Dominion reports for goat milk show significant concentrations of other fission products,'such as cesium-137, in significant concentrations," Dr. Sternglass states in his report, Exhibit A. -' . -

'Using the NRC NUREG 1.109 dose factor'of 0.0172 mrem/pCiAl

[millirem] from Table A-5, a mere 2.4 pCiA daily intake results in the maximum permissible dose to any organ of 15 mrem per year set by NRC guidelines; 23 times the amount mIeasu'red in a single liter,'

according to the Sterrgglass report.

Attached to Dr. Stemglass' report ar'easurements, reported to the' NRC 'byDominion, of strontium-90 in goat milk sampledat locations within-5 miles of Millstone during the years 2001, 2002 and 2003. . - . . u t y , 20 and S - - < 3.

rt- - a ,:i.! < - -

July 2005 A-309 NUREG-1437, Supplement 22

Appendix A MPS-51-4 The reported samples of measurements show concentrations of 13 to 14 pCi/A on other days during the three-year period. According to Dr. Stemglass, these are also significantly high readings since strontium-90, concentrating in milk due to atmospheric nuclear weapons testing which ended in 1980, has declined to less than 1 pCi/I in areas far removed from any nuclear reactors.-

Since the samples are collected by Dominion only twice a month, it is unknown whether actual concentrations on other days exceeded the levels reported.

In 1997, Millstone's previous owner, Northeast Utilities, persuaded the NRC to permit it to discontinue sampling for strontium-90 in its air filter monitoring program. As the 1997 Annual Radiological Environmental Operating report states:

Section 4.5 Air Particulate Strontium (Table 5)

Table 5 in past years was used to report the measurement of Sr-89 and Sr-90 in quarterly composited air particulate filters.

These measurements are not required by the Radiological Effluent Monitoring Manual (REMM) and have been discontinued. Previous data has shown the lack of detectable station activity in this media. This fact, and the fact that milk samples are a much more sensitive indicator of fission product existence in the environment, prompted the decision for discontinuation. In the event of widespread plant related contamination or special events such as the Chemobyl incident, these measurements may be made.

MPS-51-5 Strontium-90 is among the most deadly byproducts of nuclear fission. Once ingested, its highly-energetic electrons damage and cause mutations in nearby cells. Exposure to low levels of strontium-90 and other bone-seeking radioactive chemicals routinely released by nuclear power plants does not merely increase the risk of bone cancer or leukemia, but it weakens the immune defenses provided by the white cells of the blood that originate in the bone marrow. See Declaration of Ernest J. Stemglass (August 8, 2004) submitted to the NRC in In the Matter of Dominion Nuclear Connecticut. Inc., Docket No. 50-336-LR, 50-423-LR, ASLBP No. 04-824-01-LR, annexed hereto as Exhibit B.

NUREG-1 437, Supplement 22 A-31 0 July 2005

Appendix A MPS-5;1-5 'As recently shown in the 2003 report by the European Committee on radiation Risk, numerous epidemiological a'nd laboratory studies' have shown that the risk of cancer and other diseases produced by local internal doses to critical organs from fission products that are inhaled or ingested have been underestimated by extrapolation from high external doses by factors of hundreds to thousand of times,'

according to the Stemglass report, Exhibit Ai "This explains why it now appears that releases from nuclear plants, often acting synergistically with other environmental pollutants, are'a major neglected reason for the recent rise of illness -

and deaths both among newboms'and the elderly observed in the U.S. in the last two decades, as also discussed in the ECRR report,".-

according to Dr. Sternglass. Id.

For these reasons, it ismy professional opinion that the Millstone' Nuclear Plant should not be relicensed,' Dr. Stemglass stated. In his report, Exhibit A.-

The Coalition has previously submitted, in these and the related Atomic Safety and Ucensing Board proceedings, documentation from Joseph Mangano and Michael Steinberg which links the Millstone radiological effluent releases - including strontium to significant negative health consequences in the community. These documents are incorporated by reference herein.

CONNECTICUT COALITION

'AGAINST MILLSTONE Nan urton-PIl ease address correspondence to: v NeincyBurton..

147 Cross Highway Redding Ridge CT 06876 Tel. 203-938-3952 5

I July 2005 A-311 NUREG-1437, Supplement 22

Appendix A ietmovu dunt to: Nancy Burton Date: 031 IJOS From: En est J. Stemglass. Ph. D.

Subject:

) fillstone Relicersing I have rec ntly had the opportunity to examine the levels of radioactivity-in goat milk samples r poned by Dominium Nuclear Connecticut, hc In thei Anrida Radiological Eniron=r ntal Operating Reparts and found that highly significant concentations of cardinogei ic fission products were measured, Indicating that the Millstone nucleir plant continues o represent a major health hazard to the people of the area.

Thus, in enclosed copy of Table 8 of the Report for the year 200 1,3a concentration of 55.5 picoC nes per liter (PCltL) of milk of Strontium-90 was reported for Location 22 for the saz4 le measured on September 19,2001. with an uncertainty of plus or minus 5.3 PCIIL. Thi is an extremely large concentration close to twice the highest concentration measured connecticut pooled milk at the height of nuclear weapons testing in 1963 of 23 PCIL, can be seen from the enclosed Figure 6-1 prepared by the Dominion Company rthe period 1961 to 1993. Moreover, since the measuredzvaluc is ten times as large as the measurement uncertainty, this is an extremely significant result, With an astronomic Miy small chance that it is a statistical fluctuation.

To put this nto perspective, wing the NRC NUREG 1.109 dosc factor of 0.01 72 mrem/PCI oin Table A.5. a mere 2.4 PC1 daily Intake rcsults in the nIaxint:

permissibl dose to any organ of I Snrrcm per year set by NRC guidelines. 23 times the amount mc sured in a single liter.

Moreover, ince strontium-9 0 has a physical half-life of 2S years, it must have been present for number of days that month. In fact, only 16 days at the measured concentrat ri of 55 PCV/L are sufficient to reach the permissible dose.

As the enellscd saples of mcasurcents show, concentrations of 13 to 14 PCI/L -ere found on o cr days, again significantly higher than the measurement uncertainty of 1-2 PCI/L. .I' Moreover, s discussed Irxthe United Nations UNSCEAR reporutbcedose tobonc or tle  !!

bone MLario when other fission products at thon fnrm Sr-90 done. and the Dominion Report for rilk show significant cODeentratiOns other fissios products. such as Cesiurn-13 7 , again significant concentrations.

chsicentrations of Sr-90 and other isotopes measured clearly exclude the possibility 1they are due to past nuclear bomb-tests. No other sources of Sr`90.exdst other than tefission of Uranum, so the measured values repreent releases from Millstone.

NUREG-1437, Supplement 22 A-312 July2005 I

'Appendix A PAGE 02 21:e9 4126e16251

.~  :.

Asmea y shown iithe 2003 report by the Eurupani Committee on Radiation Risk, nrninerou~ epidemiological and lhboratory studies hav shown that the riskl of cancer and other d ises preduced by local internal dosts to critical organS From fBssion products tbat are r iWled or ingested, have been underesUtmated by exspoaton from high

-.. extrald ,ses by factd orhundreds to thousands of times. Ths explains i*hv it now I_ .,l .

-1.- . appears it releases from nuclear plants, often acting ynergitically w;ith odher

.- environnu nrta pollutants, are a major neglected reason for the recent rise of illness aid

- dchs bot amnong newborns and the elderly obserud in the U.S in the last two decades,

,i.- as also dis :ussed In the ECRR repor.-

For thcse =as s, It is vy professional opinion that the Millstone 1clear Plant should

- not be relh cnse&* ,

Ernest J. S enmglass;Ph. D.

Professor tmeritus of Radiological Physics Universit f Pittsburgh School of Medicine

- Horne ad ss: .-  :  :.

UnivCrsity uare #2 4106 Fifth Y . .-

Pittsburgh, PAIS213 - -.

I

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July 2005 A-313, NUREG-1 437, Supplement 22 -

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Appendix A h4;1W- 6"6 UNrITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA D In the Matter of DOMINION NUCLEAR CONNECTICUT, INC.: Docket No SO- 3 36 -LR, 50-423-LR (Millstone Nuclear Power Station, Ualts 2 and 3)  : ASLBP No.( I4824-01-LR DECLARATION OF ERNEST I. STERNGLASE 1,Ernes J. Stemilass. dobereby decdre as followx 1.1 am above the age of ighten (18)years and I believe in the obigationao an oath.

2.1 reside a 4601 FiMh Avenue in Pitbburg Pnnisyrvaduk, 15213.

3. 1 submit this declarion in suppoat of CGnndcut Coalition Agaist nebtervenfion the above rcfrenced matter.

4. 1 2m PrOfesor Enaaitns of Rdiological hysics at the University of Pi school of Medcine and bave written and published extensively in the a of low- level rad don amd h ann helth. and about the advere effst of radioactive etmsi& from the Mlskm iear Power Station in particular.

S. I Am the 2unt of the book oSecr Fallout Low-Lerd Radtadoo fio Wim Mfileolandw published by McGrawnHill in 1981, of the review artidce "Enviro= toThree.

Human Health" published by the Univesity of Califoria P tIJ Radiation and mss1972. and the de ICac Morlity Changes Around NuclearFacilities in Connecticut" published in Rdj Human Health ftmeedings of I CogMsuicaj Seminar Febny 10.197M8, by Standards ad Pblicy Institilte in Wanb~ngton L)C. The fiacts and statements comtined in these En vironmental incorporated by refermco herein as efrnces 1. 2 and3 respectively. icatlons AM

6. 1 have published a ser. of papers co *8ects of low-kevcl enriroenta Iuman health and develop produced by nucew weapow kst and reactorel radiation on sses for thiqlads IE 9V~d TGZ9T.99ZTV 62:T' G20Zi1W0/E NUREG-1437, Supplement 22 A-31 8 July 2005

Appendix A I

'I forty years. and have testified on this subject at bearings held by the U.S. cboq ress. the Natioml Acadcmy Cf Sciens. State Legisgatuas and U.S. Government Rcgtduatory AV this subject. . , .

ncies as an expert on

7. It is my pr opinion that the rAdioactive relee fron the Milda Nudear Power Station since its startup in 1970 have caused and will continue to cause excess a {ant mortality. low bixihweight, le"kemia and cancer as well as increased rates dboh chronic and Infetious diseases in the towns armuid llstone as well as in New d bmty and. Comtecticut s a whole.

8. Accordingo theNRCppubliu Rndioaxive Matials Rdeaed Frm 4ude Power

.Ya- Ins (NUREG ICR -2907), by 197f Millstone bad relcased a total oi32 Curi of rdioactive

,Iodine and ParticuLates into the air which include the hihl carcinqec Strwt 0md dine 13 1. together with 6.7 million COuries of Total Fission and Activation gses sx as Xenco and K-yptoa. and tih higst liquid rdeasca orMxoedsFsiou ndActivation Podu ny nuclear aof

- plant in the Utnited States, namely 581 Curies or 581 trillion plcoCuries. the uni of concern in mrilk

nlddinking wwa.

• and

9. In a Iinge year. 1975. Mhllstom rdeased a record high of 9.99 COmics ofl Pamiculatas into he air, more thm wice as high as the 4 Curies released shortly *sartupin

- 1971. together with 29.7 n2illicm Cuxics oirTota Fission ad.Activation Gsses, I C99uCries r liquid Mfixed hssion and Activadon Products into Lng sland Sound also are rdfor al U.S.

V nudlearnt

10. Betweien tartu cfMillstone in 1970 and 197S, asz6wrn in the 197816 repot (3 X cancer mortality rose 89% in Waterford where the reacir is locai, 44% In Nle London S miles a, noist, ethe 27% in New Haven 30 zmiles to the west. 12% for he Stare of Cq ats a wbole. 8% in nearby Rhode Island, 7% in Massachtusetts and 1% in New Haim while it actually declined by 6% in the most distant New England tt fllo the pattetn d Strontiurnn90 in 66 mile shown in the samc rtpoii ' ' t mn wn

11. As shown iniTxlc 9 of reference (3). while theS cost enttatt in dt milk

.~~ ... . I ,,t, declined for tbe U.S. xs &a Whole between 1970 and 1975 from 8 picoCuties per terto only 3 pCiil.

it roae from 9.8Ln 1970 to a hi Or 15.8 in 1973 and 14.8 in 1974 Dear the NMill Nuclear Plant.

remainingat10.7by1975.ThisisfarincxcessoftheU.S.averageof3pCMlr ping out any signi-cant confrlltionoto the local milk bom bomb test fa tby France aiW Ch that continued ri uintil 1980.SO..i.' ... .

I

.,.- - - _ .,-- P:Iz. 5OO:/131E0

- 39d July 2005 A-319 NUREG-1 437, Supplement 22

Appendix A I

. .i I

12. As shown it Table 10 ozfrfnce (3) the calculated yealy radiation dw tto bone of a child i

due to the excess Strontium-90 within 10-15 miles of the plant In excess of e ,early dosn for the I

U.S. rose from 33 Mireme per year in de first full year of operation to 204 mr r/yr by 1974, I naiy thee timcs the nrmal bakground levelof 70 mrmyr inConeclicut-I I 13. These doses due to Stroniumw90 alone may be compared with the 1.5 mr = to myoara permitted under currentNRC reuladonsto the 2 mem produced to bone m~mi in a typical chest II X-ray ofm chil and the 80 turezumyr to a devdoping fetus fotaid to produce a ububs of the rate i of childhood leukemis in the studies of Dr. Alice Stewait cted ir Reerence7 d rfertee (3) for I exposure in the mothcr's womb to X-rays in the fust three n of pregnanc I 14. These considertions, later suppotted by the mo c studies of Sum um 90 measured in I baby fteeh togetw with effecu an cancer m addcc and infanl molality as by Maganw I submitted in the prsent case and referred to here as reference (4) plide ovem gevidence for I the existence o01a relationship betwcen the aboonmily high levels of Str aum-90 in the milk

.I and the pattern of cancer changes at various distances from the Millsoone planL I

I I

15. The extence ol' directcs rcatioshipbeween Sir n-90 e from riucder I

reactos and an increased risk of cancer is very strongly supportedby the fdin described by II Mwngwo (4) thwt baby teeth of children dignosed with cancer have doe blc the concentration of Strntium-90 than childkk bom the same year and in the area.

This fInding II has led to a lawsuit havig been fMid in odida against the :rida Power and Eght compmny by the family of a child with a very high Strontium-90 ooh concentration selCing peasation. a suit which a fed Ijudge ruled to be of suflicictt merit to go to tial in 2005, despi Pefrts of the I defendant to hate it dimissed (5).

ii i

i

16. As panted ota in reference (3), this cncelusion is slp types of cacer that se most straogly in the Connecticut a YThe fact tat the i r Mi Nuclear Plant are I exactly those that have been found to be most sensitive ito adiat in ir i tes by national and I intcniational standrd setting organizations nazsely those that inceased the mt Iby 1975, such as I respirutory ancers (37%). breast ca (12%), and pancreatic cancer (32%).

I I 17. Likewise. furdhrr support for a causal relationship of nuclear plint rees a and adverse health I Lpriddd by the rct cited by Mwcuso et a.(S) cited in reference (1) effects is it canc deaths I showed a much greater rise in women than in me, nmmely 17% for white " aand only I1% for i

i I

I CE I TS9tst9elp 60:Tz I OOVO/ Ea NUREG-1437, Supplement 22 A-320 July 2005

Appendix A I ..- ...

. .I

'. I white m This r diffTce between males and females was foumd by M oandhis co investigators for atmic workers at the Hanford Nuclear Plant exposed to low doseiof both int-.nt exposes to aidical ors due to inhaled and ingested radioactive den mu n minblr to those

. -leasedby Millstone over a period of years, together with protced extenmil :$poss from gamma rays produced by fission products accumulated on the gund. nther th tovery shortX-ray exposures used in diagnostic p.-ocedures. . --

F I1A renwed rin in infant morality in the six towns neaest Millsloe took afteraslap

.decline by 18% when thaem units had been shut down for ost of 1996-97 as dscaibed inTablc 9 of the 2004 repoctby M gano (4), with smlr decline oc 3.1% in 1998-99 relative to 1994-95.

Ifolowed by a rise of 8.8% in 2000-01. This is very strong evidence Induating even the much s-mallerreca Orm the two remaining PWR type of reactos confinue t adr yaffect the health of the newborno tat ther canbe no safe opeaion of anyexiing typ of n plant for the jd ndi on whomtbefuture ofournationdepends.-*-

• 19. Temuch gretersik to buman heah from rdodve ases ad particl s t6nt are inhled or ingcst md contrte in certain critical orans such as the bone marrw or' hormcn prodiing glands such as the pituitary gland targeted by the highly radioactive daughter Pr duct of Strontium.

- 90, the element Yttziun-90 t& has differest cdamical proeies and leaves the te to concentSate j in soaf tisueL his sts in vesj high locil doss to boththe bone rw an the critical hormone producing glands ovrlong periods of time that greatly exceed the w -body 4Iose and result in cancer and other advc deects an health hundreds to thousands oltimes reat than had been expected by a linear extrapolation to low doss of the risk (run shat exte.al Postres such as received by the survivors ofl iroshima and Nagisaki orindivlduals exposed to aedictil Xnrays that j - do not co _ in SpOTic lorgadnp . as dscaibed in the ECRR Seport (6).

20. ftisimpornt bnde thatexposue tolowlevels ofrSt tum-90ando c bone seeking

^.- ctivechtnlsrideays eaedby atdesptnts Ihesnble Caliu ddo not merely

'increae the HAsof bone cance or leukemia. but they weakein the irntman defe es provided by the

- white cells of he blood that orginatc in the bone maiW. As a result the ntc of cancer de, elonpent au over the body normally held in check by white cells is inad, and the derf ts against infectious diseases such as influen pneumonia and AIDS sie lowered. in.. X zg both total and infant matility due to all causes combined as discusse in refercses (IX2X3) mid(6).

*.I' r*.*.

-^;--wT_,, .

21. Unfomnatdiyforthe protection otbuman bea the opeao of nucla ] plants such as NMillstone are no lon required to measure Strantium-90 in to milk, the sail, t water and other

._.__.,,,5 ;b:Tz -o90VI/ED July 2005 A-321 NUREG-1437, Supplement 22

i Appendix A I

i i

enronmental sampes, nr does the government caure boao hiselerment after i 1982. and milk concentrtons of this critical dement each mouth in a series of tes across the nation since 1990. Thus. preschdy dhe operators of nuclear y dt measne gamma ray emitting elements such as CesiuI- 137 tat can be more easily and cheply meas 5rred than Strontium.

90 that emits only short range electrons that cannot penetrateth gecmer used for gamma i i

rays. and which rquir more costly laboratory procedures for eac le.

i I

22. As rec'evty bhoughl out in the ECCR report (6), the reao the i C low protracted i exposures due to inhaled or ingesttd radioactive chemica is is 100 to 1000 Iimegrener %an the i sa dose due to shart expoas is that for dhe low d given over a long pes rodthe damage by I free-radicals of oxygen dominate over direct damage to the DNA and cel memb uica. Thisleadsto a doeresponse curve thatse extemely rapidly for very mai dses and nlatten out at high doses, thsn causing the ero made by a linear extrapolation to zero doe used to Caabliush the cxisting safety standardsfor pemitted releases from nuclearpants I

i I

23. Thus, the ECRR report states in paragraph 10 of its execadre summatyi that the present cancer epidemic is a conseqence ofexpour to global amospeic weap; sf*'[lout il the period i I

1959-63 and that more recent releases or radiolsotopes to the enviro imentt from the I

operation of the uaudear fuel.cyde will result In signifkant Increas: z In cancer and I I

II other types or III health Emphasis added).

I

24. Thus, in the conduding paragraph of the executive sunruy. it sMs thatl tis 'he I

committees belief that nuclear power is a cosdy way of pdudcing emtcr when i-man health defiitb ar: included in the overall asessment' and tat dte envirl a ceru peinerms of radioactive discharges must be asscssd in rehuion to the total envroii n, int ding both direct and i indirecteifects on an living sysinza.(6).

I 2.5. Although the mot serious airborne rAdioactive releAses so far have ocoir from the II operation of Unit I which was a Boiling WaterReactor (BWR) peranenyda in 1996, Eca I

described in referenes (1) and (2) have found similar incrase in infant l. low birthwtiht and cancer awmd Presstuied Wae Reactors (PWR) such as Sb 2pingport n2f ittsburgh and II Indian Ptint neatr New York City. Therefore. it is to be expected that a twenty yer renewal of the I

operting liUc for leLtn Units 1 ald 2 would further ICae the adverse effects an human i

health and their associated cost in health cam, as well as the damage to wil :ife, irds and fish taut have been rising ala gly in recnt years.

I f

I I

GE MI, Sd TSt89Mtt 63:TZ SOOZ/T3/Eo NUREG-1 437, Supplement 22 A-322 July 2005

Appendix A

. I ." I I

26. This fuiher increase of damagc to hmn health and the envirvmnet isu Iet only due to the I I

shortilived ndiosive elements such as Iodine-131. but also due to the longhai I -life of marty of the i radioactive chemicals routinely deasedby nuclearplants such as the 28 years il takes forthe actirity .

i i

II of StrUumt90 to decreae by half. Ibus. itis vey likely that coctinued oPCvu Ion of the Millstone I Nuclear Hant will uiheRnas the rates of cancer,. low tirtbweigh. Infant ia 0 xEtality and chronic 1 and bormonal diseases such as yptrdism. diabetes, and other diseses rlaed to I I system damage a these eements accumulatc in the underground wid table fic n which wells draw I their waler, maing it impoasible to safely protect the public. .

II

.i.1. 27. The unexpectedly gra Hi to the life and future heAlh of the newboan c e to very $en doses of radiation to cniical organ has just been further supported by a study c the inciAdence of 1.,I I prematurc births leading to underweight infants as repwtd in the Apil 28. 2 4 isse of the

.I Journal of the American Medical Association (7). 1his study revealed that thev oI y mall doe due to i scaured rME1ion to the thyroid in the neck ofthe modher puced by just am Dr two detal X-rays I

. I . during the riust te moxths of pregnancy, approximately 40 tillirym each, Sir ificanty increased I the risk of prmatuebirth and low birth weigL Tbis in turn is knon t Incres I meinfant ortaliy as I well as prodcing a ge danger of mental and pbyscal problems for infants' rho survive as a I

resdt of rccnadvats in neonatal cart, but at huge emotionil cost to the fam an rimi health, cam costs to society * -

I-1'"

28. In the lightofcn kwledge of the unnidpatedseus adersx effI cts onhumz health

- ereeyam doses of prolonged enviromental radiation exposures to Strdlntium-90 and other fissiot puts professional opin as descibed above, it is may fitt the M sapoe 2 md 3 reators I would need to end anl radiation releases in order to meet public heslith raqierel ~ts forsafety. and thad tirmforel should not be granted ficense renewals to continue operadons " the proposed I twenty year rnewal periodwithout demonstrating that this objective can be achie edr I bereby declre the foegoing to be true and accuate to the best of ry knowl j ,informatonx and belief underpenlty of pajury..

Dated Aupst 8, 2004 I~~ ISZ918szl 60:1z ScOOZ/io0c July2OO5 A-323 NUREG-1437, Supplement 22

Appendix A "I

LIST OF REFERENCES

1) Ernest J. S t& Secret FAllout Low-Level Raiton from EHlrshim ktolue~lwe Island (McGraw - HEi.New Yost, 1981) Available on the wdsisc wwwm&, lion-org I

2) Ernest J. Ster;ass, Enviromntal Radiation and Human HeaiW, pp.1 15-216. Procedings I

of the Sixth Berkdley Sympomizm on3 . aical Suaitics and Probability: EJ rects of Polh on I

Health', Edited by 1t L Lecamn, J. leynan El. Scott Univensity of Califomia Pres Berkeley and Lw Angeles 1972.

I I

3) Ernest J. S tern2&%

"Caner Motality Canges Amtd Nucdear Fkihit m in Coinmcticui.

I pp. 174-212, nRadato Sbandads ndHn HeAt Proceedings of a Coagr smnal S .minwr" i Fenuzy 10.197ppliashd byt EnionmmeniPolicyWitA, Wmntoa DC.

I 4). Joep . MNzgmno.,Riks of cancer And Other Diseame Froui The Oi tion Of 'Me II XMIstone Nudewr Plant,' August 5, 2004, Radiation and Public HeaIIII Pro,-ct,.New Yodr, NY.

-Ii 5). Einesns vs. ,PP Casn Number 03-140040-CIV-COHNILYNCHC I 6) Philip P. Hud eta]. wAnteptma Dental Radlogrupdy and Low I jithWtight'.

Journal of tit Ameican Medical Assoiation. Volume 291, .o.16. April 28. 2 )04. pp. l987-1993.

II 7) .'Heallh Effcts o 1onizing Radisdon Exposur at Low Dose forRadiai a Protction I

i

Purpose:

Recomndadons of the European Committee on %distion Rik, E Sitedby Cvis Busby with Rosalie Bated. Inge Schmitz - Yerhake,.Molly Scou Cato and Alexci Y; blokdv, Published for the ECRR by Green Audit Press, Castle Cottage. Aberystwyth. SY 23iDZ,1 Jaited FKingdom.

(2003) Webeitb wrw. curdcoutorg 2003.

ZE 3Sd TSZT83 ZTL' 60:1Z sOO iioico NUREG-1437, Supplement 22 A-324 July 2005

Appendix A COUNTY OF SUFFOLK 3/ /

-OFFICE OF THE COUNTY.EXECUTIVE - (^'4 0'A St.-- Levy, f'i CO. .YExEcunvE-

ccvin S.tLaw . - tkd;r^

Cc.hizcp CmtyExccccuw '*rc; or nmcaut Arain February23,2005 -

Chie, 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

~~~~~~~~~~* - * ,-*

..- , ,*,,*..* - . ..e. -,t

Dear Chief:

A-draft-.upplemental impact stateme'nt (SElS)'ias been's6bniitted to the' Nuelear Regulatory Commission (NRC) by Dominion-Nuciear ConnecliEUt lIncorporated concerning the application

..- to renew the operating IicenselforMillsl6oi'-Pover Statioii, Units 2 and 3 for an additronal 20 MPS-52-1 years- -,heCounty of Suffolk finds the do nidntvrliry'irrow in scope, aid lacking de'ail with regard to.the issues of concern to the 1.4 milli6&i residerits of our county. *it appears thhi public

- notifications to areas in'Suffolk-County-within the!'f'a'dT50 mtileerersencylanning zones

- - were neglected; that there is no need to rush 1d6* tirigc'liecnse Jreienwal for he plants decadcs prior to their license expiration; and, that radiological emergency evacuation plans for Suffolk Cdunityvere not addresseda.. 61 ,. ^-- . - ( *:  ! -:i

! ' .' was dismaycdi'tfat a public hearing was noi held in Suffolk County concerning the renewal

' application and that the Commission failed to contact local municipalities and environmental groups on easter Long Island (Supplement 22, Appendix D,- Organizations Contacted). An

- analysis'of major points -of vev 'conerning signlficinti'probeies' ind obfeeiions rsised by

. 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, ve request that a public hearing be held in Suffolk County where the NRC and Dominion can respond to ss e. ..

• h.se . . .. . .

MPS-52-2 Suffolk County views the-applicattons to rcnew Millstone's.opcrting licenscs as preinatueICat this time. 'The current operating licenses do n6t e6pize' forpeniodi Of 10rand 20 yeirs, 'until Jiiiy 201 5.for Unit 2 and November 2025 for Unit 3: 'Wilh the advance'of scicnce in 'ihe -next two.

decades, itis iikely that alternative cleaner e'nerg s'ources anidlor conservaiion wvil inegait the' need for license renewvil foroutmoded andliazrdoiis hbclear jeherating plants:' it is clearl self-serving for the Commission-to conclude'1that 'FiVron'me- al impacts for futfre'gencrating and -

• -: ' conservation altematives-uould be greater than tlioc opfeating Millstone'(Supplementf22, pages xix and 8-51). :te NRC Fact Sheet on Reactor Lfcense'Reneial states that the license renewal onoDtsoti I 1ANSLRt6OAllWAY *fAbOIw10

• IIMWUAUGA V.Ifl-8 * (I)I

/'/{ "' @- ' ";- *-::; "'-l' -,' '- -. g5t '~-0

<g-<)AP- @i zFs,<

July 2005 A-325 NUREG-1437, Supplement 22

Appendix A 2

MPS-52-2 procedure is expected to tate 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 MPS-52-3 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. *That is the fate of researchers and operations at Plum Island in the event ofa severe accident at Millstone?

A 50-mile Ingestion Planning Zone is identified in the State or 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

- -T ownship. -Alftugh-ngestion sugcM.an-asssmentnofdv ndfdrinklrM7Nvacr,-a-rccasc=--

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-wAest transportation facilities have been constructed, hand 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.

MPS-524 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. Ihe NRC recognizes that some structures and components or 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, VoLI, section 53.1.

"In assessingthe impact on the environmentfrom postulatedaccidents during the license renewral period, the assumption has been made that the license renewial process it-l1 ensure. that aging effects on the plant are controlled and that the probability of any radioactive releaserfrom accidents vill not increascover the license reneiralperiod."

__~ . This does not appear to be a credible position in light ofDominion'sstatement.(Supplement-22,,.__

page xvifi) that it dn'otideniJ5;`anymajorplant refurbishment activities or mod~tycations as necessary to support the continued operationof Milstonefor the license renewalperiods The county has difficulty reconciling the two positions that, l) 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:

MPS-52-5

• 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.

MPS-52-6

• In the event of a severe accident at Millstone the probability of wcighted 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 I4DLNISLVM Dflt:

• 100VErMANS1nIORAt1J1GHWAY2

• P.AOOX4100

• tAVpAUOLPMY.118S4)00 *. jI3S12.6=

NUREG-1437, Supplement 22 A-326 July 2005

Appendix A 3

MPS-52-6 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 forvard to hearing your response at a forum held in Suffolk County. -

Sin cy teve vy Sti* ' folkCounity iXeCUlVCc - .-

Cc: Diane Screnci, Public Affairs Officei, United Statcs Nuclear Regulatory Commission, 475 Allendale Road, King of Prussia. Penutsylvanial9406-1415 Kevin Law, ChiefDeputy County Executive and General Counsel Paul Sabatinol1, ChiefDeputy CountyExecutive - -

Christine Malafi, County Attorney Lynne Bizzarro, Deputy County Attomrey -

Michael Deering, Director of Environmental Affairs Brian Harper, M.D. Commissioner, Department of Health Vito Minci, Director, Division of Environmental Quality SL.EDE O5NBJL~Dc.' * .SOOVETtRARS~t£J1OUJLNfICIIA3. s O.OOWX4IOO *UIAUIPAUGLU.Y.I?1*~9 * (s2I)it-~

July 2005 A-327 NUREG-1437, Supplement 22

Appendix A

• Richard Emich - Deny Millstones Relicensing Page 1-

. s1 31/043Azd,-

From: Helga Waller chgloptonane net>

To: <reOnrc.gov>

Date: 2/25/05 8:19PM SubjecLe Deny Millstone's Reticensing 1 0 2,4'/A1 MPS-53-1 I urge you to deny Millstone's Relicensing MPS-53-2 1. There are no emergency plans in place for Long Island In the event or 67 z/~~,

an incident or accident at the facility.

The DEIS Ignores the safety threats to Long Island residents and the environmental Impacts of the aging reactors.

MPS-53-3 2. Minstone has been operating with an expired Clean Water Act discharge permit since 1997. The Clean Water Act mandates permit holders to obtain five-year permits so that every live years they will have to demonstrate that they have Implemented best available technology to reduce or eliminate polution I they want their permits ronewed. Milstone has been able to got away with operating with non-updaled technology an extra ive years.

MPS-53-4 3. Millstone is responsible for the depletion of native lish species through the operations of Its Intake structures. All these assaults on the environment would end If (a) Millstone were shut down or (b) If Millstone converted to closed cooling system. This important Issue certainly affects Long Island because of the dispersion of toxic and radioactive waste byproducts by tidal and wave action.

I urge you to deny Millstone's Relicensing I H. Gelsier Walter Long Island Resident hgeoptonrlne.net Se- 1 l B z Olee =- Af4t_-xv C C~ et) 7 y 2 , 6 5 a, 6/P3 NUREG-1437, Supplement 22 A-328 July 2005

Appendix A Page I Richard Emch - Deny license extension to Millstone.  :

Se. -

From: Margie Brock <margieb: 3@optonline.neb To: <rleOnrc.gov>

Date: 2125/05 8:58PM

Subject:

Deny license extension Ito Millstone.

MPS-54-1 Please deny the icense extension to MfilsI tone. -

V .5

_ -- .,. /C-C_ *S -A9Ž A1-4-0 *Z5 2005 July - -

-; &Z =: e bLe -On 13 July 2005- A-329, NUREG-1437, Supplement 22

Appendix A

. I

I i i I  !

0!_l-4 r rnh _ I .- ,IKhotl _,-

. V. . I i,

From: <SMEP2OaoLcom> i.

To: <r1e0 nrc.gov>

Date: 2Q26/05 9:38AM Subject (no sublect)

To Whom It May Concern.

MPS-55-1 Nuclearenergyhas its attnbutes but plants should be located In sensible areas where evacuation In case ol emergency Is possible. / ;'/"/D MPS-55-2 Please use your common sense and protect both the public and the fragile LI MPS-55-3 Sound environment before you bcense Millstone to continue for another twenty 6G/.i( /737 years.

Sylvia Palenyk Southold. LI CC: <nlec 0 oplonlinenetv t-,- = 4 "/- - e- 11 c, A-- 4 -,=)

NUREG-1437, Supplement 22 A-330 July 2005

Appendix A Richard Emch - rolicensing of Millstone Pige11 From: .cCaseathome~aol.com>

To: <flrtinrc.qOV.

Date: V27t/5 33-8PM SubJect: relicensing of Minstone MPS-56-1 Gentlemen: It is very upsetting to leam that you are considering relicensing the Millstone plant with all the negative considerations that has: 6~7Fe,59Y$57 MPS-56-2 1. Millstone has been operating an expired clean water act permit 1or a full 5 years beyond the alloted lime. - . - - i - -

MPS-56-3 2. The Millstone operation depletes the natve lish population due to Ineffective Intake methods MPS-56-4 3. There is no plan In existance for a sale evacuation from Long Island In spite of the fact that It is 11 miles away. Shoreham was shut down for just .

that reason. -F, . .-

MPS-56-1 How can you be thinking of this? Millstone must be shut down. Dent tool with our Rvest - - .

Yours truly Constance K Case -

,6r-,,O.qaS =,09 PC-3 f -.. c- . . e) -,- . -;

VR- . S m July 2005A A-331 , NUREG-1437, Supplement 22

Appendix A Richard Emch- Minstone Relicensing Pane s _A* o From: <JudgekkOaol.com>

To: <WeQnrcgov>

Date: 2/26105 11:34AM

Subject:

Millstone Reticensing / -s /cx Mr. Emch. 6 IrVeV,56 MPS-57-1 As a property owner on Long Island Sound at Northville Beach. lam opposed to the relicensing of the Millstone Nuclear Plant. My reasons are as totlow MPS-57-2 1.The Millstone Dralt Environmental Impact Statement Is completely silent on Impacts to Long Island. There are absolutely no evacuation plans In place for Long Island.

MPS-57-3 2. Millstone has been operating with an expired Clean Water Act discharge permit since 1997. The Clean Water Act mandates permIt holders to obtain five-year permits so that every live years they will have to demonstrate that they have Implemented best available technology to reduce or eliminate pollution If theywant their pernits renewed. Millstone has been able to get awaywith operating with non-updaled technology an extra five years.

MPS-57-4 3. Millstone Is responsible for the depletion of native fish species through the operations of Ks Intake structures. All these assaults on the environment would end if (a) Millstone were shut down or (b) It Millstone converted to closed cooling system. This important Issue certainlyaffects Long Island because of the dispersion of toxic and radioactive waste byproducts by tidal and wave action.

Kathleen McGraw

,5 G -r- O>Af -D --:3 - - ,

,5.r-, ,. ye j/ I- z- , ,

e5zc 1, -r-R-1,- t3-" C4, M L .

--/I- 109bA4 -0/3 NUREG-1437, Supplement 22 A-332 July 2005-

Appendix A Richard Emeh - I Oppose the Nuke Plant Relicensing at Millstone CT Page 1i From: Justin Porter <Justembase~yahoo.com>

To: rle0nrc gov> .  : -

Date: 2128/05 10.09AM Sublect: I Oppose the Nuke Plant Rolicensing at Millstone CT -

Hi Dick.

MPS-58-1 I oppose renewing the license on the Milibrook Nuke. I feel It - *- - - -'S/7 threatens the safety and security of Eastern Long Islanders. I am a US Citizen that votes.

Justin Porter 848 Roanoke Ave Riverhead NY 11901

- NFEC <nfec0optonrinoneta wrote:

> Tell the NRC to Deny Millstone's Relfcensing! Deadrmo March 2.

a 2005!

> The operators of the Millstone Nuclear Reactors are seeking to renew a>their MPS-58-2 > license. If renewed, these reactors will be up and runnirig fori i>another2D i>years. yet there are no emergency plans In place for eastern Long

> Island In

> the event of an incdent or accident at thefacility. - -.

a>The Nuclear Regulatory Commission Is accepting comments on the Draft a>Environmental Impact Statement (DEIS) for relicensing. The DEIS a>Ignores a>the safety threats to Long Island residents and the environmental

.>Impacts a>of the aging reactors.

> Reasons to oppose:

MPS-58-2a 1.The Millstone DEIS I completely silent on Impacts to Long

>.Island. Shoreham did not come on inhe becuse we couldn't put an a>evacuation plan hI place.

MPS-58-3 > 2. Millstone has been operating with an expired Clean Water Act

> discharge permit since 1997. The Clean Water Act mandates permit

> holders to a obtain five-year permits so that every live years they will have to - '_

a>demonstrate that they have Implemented best available technology to a>reduce a>or efiminale pollution If they want their permits renewed. Millstone a>has a>been able lo get away with operating with non-updated technology an a>extra a,.five years.

MPS-58-4 > 3. Milstone is responsible for the depletion of natve fish a>species

!> through the operations of Its Intake structures. All these assaults

> on the a>environment would end If (a) Millstone were shut down or (b) If a Millstone

£/ 3_J,1 (ew.A14,-4 s /b/RL. e -- S July 2005 A -333 - NUREG-1437, Supplement 22

Appendix A Richard Eminh - I Oppose the Nuke Plant Relicensing at Millstone CT Page 2.l MPS-58-4 > converted to closed cooling system. This Important issue certainly

> affects

> Long Island because of the dispersion of toxic and radioactive waste

> byproducts by tidal and wave action.

> Tell the NRC to deny license extension to Millstone.

>Emal your comments to rlefnrc.gov or send your comments to:

>Richard L

> Emch, Environmental Project Manager. U.S. Nuclear Regulatory

> Commission.

> Washington DC 20555-0001.

> The deadline is March 2.20051

> powered by ebasettm) v1.03. maito:inloOebase.org.

> http:/?ww.ebase.org

> North Fork Environmental Council

> P.O. Box 799

> Mattituck. New York 11952

, 631-298-8880

> Fax: 631-298-4649

> E-mail: niec~optonlinenet

> wwwnteci.org Do You Yahool?

Tired of spamn? Yahoof Mail has the best sparn protection around httpJ/mail.yahoo.com CC: NFEC <ntec~optonline.net>

NUREG-1437, Supplement 22 A-334 July 2005

Appendix A Richard Emch - Millstone Page i

.. 4-. _...... .m ,

.'r .. .. I

'??)

Z- - -

From: .cABenners 0 aoLcom>

To: Iao0 nrc.gov>

Date: 2t28/D5 10:45AM SubJect:. Millstone

.,.,,'1 , -.- , 6?g ,7/a MPS-59-1 Deny license extension lo Millstone

.~~ I ( S).

The operators of the Millstone Nuclear Reactors are seeking to renew their MPS-59-2 license. If renewed these reactors will boeup and running horanother2O years. yet there aro no emergency plans In place for eastern Long Island In the event of an incident or accident at the facility. - *

• The Nuclear Regulatory Commission Isaccepting comments on the Draft Environmental Impact Statement (DEIS) for relicensIng. The DEIS Ignores the safety threats to Long Island residents and the environmental Impacts of the aging reactors.

Reasons to oppose:

MPS-59-2 t. The M1lstone DEIS Is completely silent on impacts to LongIlsand.

Shorehamn did not come on line because we couldn't put an evacuation plan In place.

MPS-59-3 2. Millstone has been operating wfit an expired lean Water Act discharge permit since 1997. The Clean Water Act mandates permit holders to obtain live-year permits so that every five years they wll have to demonstrate that they have implemented best available technologyto reduce or eliminate pollution i they want their permits renewed. Millstone has booen able to get away with operathng with non4updated technology an extra five years.

MPS-59-4 3. Millstone Isresponsible for the depletion of native fish species through the operations of Its Intake structures. Anl these assaults on the ehvironment would end If (a) Millstone were shut down or (b) if Millstone converted to closed cooling system. This Important Issue certainly aflects Long Island because of the dispersion of toxic and radioactive waste byproducts by tidal and wave action.

Deny license extension to Millstone.

Andrew Banners South Jamesport NY

.. I , .  ; ...

,e-A b5, - I. -es 5oK' >/4.- - -:. .;- . ...

7d-e @Z3 July 2005 A-335 NUREG-1437, Supplement 22 -

Appendix A

Richard Emch - Please deny Milistone's License Page 14 From

Jenny Bloom <onnybloomOoptonline.net' To: <rlo~nrcrgov>

Date: 2128105 5:22PM

Subject:

Please deny Millstone's License 4aZ3 2VC_/

Richard L Emch. Environmental Prolect Managor. U.S. Nuclear Regulatory Commission, Washington DC 20555-0001.

Mr. Emch.

MPS-60-1 Please deny Millstone's operating license.

MPS-60-2 As a resident of the North Fork of Long Island It Is unacceptable to me that Millstone be allowed to operale without a workable evacualion plan In place for my township.

MPS-60-3 The threat posed my Millstone's operation to Long Island's environment and MPS-60-4 quarity of life are larger than the benefits to CT's energy costs.

Sincerely.

Jenny Bloom 11600 Main Rd East Marion. NY 11939 (631) 477-3617 5ez:;/ /6 el.A, 4 7;Ta Z i, -013 NUREG-1437, Supplement 22 A-336 July 2005

Appendix A Richard Emch - Millstone Paan 1 .1

.3/0/,45=7 From: cSweelSen aolcomr>

To: crte~nrc.gov>

Date: 2/28105 5.08PM

Subject:

Millstone - -

Dear Richard L Ech.

MPS_61-1 Does Millstone have an updated Clean Water Act discharge permit? I 9fA' 4 L3 7 understand their's expired In 1997. II this Is true, why has It been allowed to'.

operate without one???

MPS-61-2 And it a closed coding system existed, would that not have a postive irpact upon the environment? Why Isnt one being Installed?

How can we face the guilt of destiroying our envirment for our luture generations because we are too cheap to do the right thing?

MPS-61-3 CLOSE MILLSTONE PLEASE.

Thank you.

Judi

,,9c 5 -e 3 S

I ,I *. . .-

r eqA4 -zD /3 July 2005 A-337 NUREG-1437, Supplement 22 -

Appendix A Richard Enmch - Milstone Nuclear plant in CT Page 1 h 6 Aler From: MBS <corango050optonlIne.net>

To: <rle~nrcgov>

Date: 2/28/5 2:28PM

Subject:

Millstone Nuclear plant In CT Greetings.

MPS-62-1 I am a resident of Connecticut and I am writing to you to strongly urge you .6 I to deny the renewal of the ricense for this plant There are significant MPS-62-2 health concerns associated with this plant that merit Immediate MPS-62-3 Investigation. Also, the State of Connecticut has enacted legislation that mandates a move to Clean. Renewable energy (referred to as Class I renewable). ThI plant does not meet this criteria. The denial of this extension would go a long way to Improving the health and environment of Ct as well as exephing the move to Clean Energy.

I am sure that you have received many requests similar to this one: please look at the facts and make the right decision. What decision would you make if you Eyed next door to this plant? Reject this application for the sake of the residents, specifically the children of CT and of planet Earth.

Respectfully submitted.

Michael Schwartz Orange. CT

'It Is amazing what you can accomplish If you do not care who gets the credrit.

-Harry S. Truman.

CC: .dnfoOmothballmilstone.orrg>

,e-gUJP5- .19 X _3 Cab Igr- rcEC NUREG-1437, Supplement 22 A-338 July 2005 I

Appendix A

= s Richard Emch - Millstone Nuclear Plant Paoe 1 l i

I -,  :

lb 13 0//10-1,7 A- Mar From:.

To: crle.nrc.gov>

Date: 2/28105 11:27AM

Subject:

Millstone Nuclear Plant MPS-63-1 My husband and I rave in Greenport NY and are seriously opposed to the . /,qL/q 1041 relicensing of Millstone. It Is and has been what lisname portends, a milstone around the neck of alt who ive on the eastern end of Long Istand. .1 dv,,r--4

.MPS-63-2 There is no way we can be safelyevacuated. should there be a problem, the communications of warnings between the states seem to be nearly non-existent MPS-63-3 and this plant Is functioning with an expired clean Water discharge permit MPS-63-4 for over 4 years time. Long Island Sound Is dying and the NRC and EPA seem (F).

to care very little for the welifare of the people who consume the fish and shellfish that have managed to survive this long. Our rates of cancer have drastically increased in recent years and someone needs to address the fact that Millstone can be a serious contributor to the food chain poison we

• consume and breath. .

Please do riot retceinse this plant until it is able to pass all CURRENT

permit requirements such as the Clean water discharge permit and the health issues and evacuation route of Eastem Long Island are satisfiably addressed.

We rive and work here.oour lives are no less Important than those of the citizens of ConnectictA who receive their power from this plant. Make it safe or close It down. -

Amy Martin 5th St -  ;

Greenponr, New York

.. p..., -  : , b .. .- -:.

6 7 /

.~~ - - ,--. . - . .- .. -.9 . . , .\ .4 ~

.-  ! )

..;,3. 9 .U E - 1 437., ... ppl e me-n t 22-July 2005

Appendix A Robert Fromer sent his comments to NRC's Office of Public Affairs by email message on February 28,2005. His comments are located in comment document #24 (MPS-49) starting on page A-280. He also sent those same comments to NRCs Rules Review and Directives Branch (the address given in the draft SEIS). by letter dated 2/2812005. Mr. Fromer's letter was received on Mardh 10. 2005.

His letter was designated as comment document #39 before it was realized that the letter was a duplicate of his email message (#24).

Only the first page of his letter is reproduced here. All of his comments are reproduced. starting on pA -2 l, idXox P.O. Box 71 VIndsor, CT 06095 February28,2003 //7 Rule Review and Directives Branch US. Nuclear Regulatory Commission Mailstop T-6D59 (ii Washington, DC 20555-0001 Re: Draft Report For Comment on Generic Environmental Impact Statement for Lcense Renewal of Nuclear Plants, Regarding Millstone rower Station, Units 2 and 3, NUREG-1437, Volumes 1 and 2. Supplement 22 Dear Chief Rule Review and Directives Branch

• ttlhe problem at hand, which is that centrally generated electricity is a vulnerable genie. In order to be used It must travel on an ugly, complex and Inefficient labyrinth of wires and substations Even from a security view (national or otherwise) such a fragile system is sulcide. Gordes, Hartford Courant, Letter to the Editor, February 1978.

Dominion has not provided a comparative analysis and assessment of life cycle energy consumption to determine that re-licensing of Millstone is the preferred option. Nor, has Dominion considered cumulative alternatives (Ie, energy sources) to meet the current and future energy demands A. INTRODUCTION The United States Nuclear Regulatory Commission (-NRC-) considered the environmental Impacts of renewing nuclear power plant operating licenses (01s') for a 20-year period in its Generic Environmental Impact Statement for License Rnewm l of Nuclear Plants (GElS), NUREG-1437, Volumes 1 and 2, and codified the results In 10 Code of Federal Regulations (CFR) Part 51. In the GEIS (and its Addendum 1), the staff Identifies 92 environmental issues and reaches generic condusions related to environmental impacts for 69 of these issues that apply to all plants or to plants with specific design or site characteristics.

Additional plant-specific review Is required for the renmaining 23 Issues. These plant-specific reviews are to be included In a supplement to the GEIS." [GEIS, p. HiQ This draft supplemental environmental impact statement (SEiS") has been prepared in response to an application submitted to the NRC by the Dominion Nuclear Connecticut (Dominion) to renew the Ofs for Millstone Power Station, Units 2 and 3 (Millstone) for an additional 20 years under 10 CFR Part 54. This draft SEIS includes the NRC staff's analysis that considers and weighs the environmental Impacts of the proposed action, the environmental impacts of alternatives to the proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also includes the staff's preliminary recommendation regarding the proposed action.' Id.

B. BACKGROUND upe et 2 A-340 July 200 NUREG-1437, Supplement 22 A-340 July 2005 I

Appendix A Riichaid Ermch" Millstone License Page 1

.. . . .: - - -- 3 -

• / 10A; From: ' :Jpr=261761 Caolcorm>

To: .rle~nrc.gov>

Date: 312/05 9:47AM

Subject:

Millstone LUcense MPS-64-1 Do NOT reissue license to Milislone reactor in Connecticut. There Is no MPS-64-2 evacualion plan for eastern Long Island. and its clean water permit Is expired. 6 7 pe. f4 -

MPS-64-3 Millstone Is a serious danger.

John Rooney .177- >

PO Boi 1622 (425 Maple Lane)

SoutholdNY 11971:

S ' le o A.4 - C ~ Ct). -

July 2005 A-341 NUREG-1 437, Supplement 22

Appendix A MillstoneEIS -_oppose nuclear revival Page 1 r From: amanda meisel camandameiselyahoo.com>

To: <mifstoneeis nrc.gov>

Date: Fr. Feb 25, 2005 1:19 PM

Subject:

oppose nuclear revival To Whom it may concern.

MPS-65-1 I am writing to oppose the license renewal for the millstone nuclear reactors In Waterford. I am a MPS-65-2 physiclan and am truly concerned about the health Impact of the radioactive particles on the residents and MPS-65-3 workers int our area. I would appreciate your consideration of a new hearing to include all stakeholders.

MPS-654 including nearby Long Island Communities, as the effects are far-reaching. The nuclear site also makes MPS-65-5 us a target for terrorist activity, whIch Is certainly a concern In today's world. It has also come to my attention that nuclear waste is shipped to Bamswell. South Carolina and has a negative health impact on the poor community. This information about the destination and Impact of nuclear waste from Waterford should be included In the NRC's environmental Impact agenda. Please reconsider the decision to extend the operating licences for the Millstone 2&b reactors. Even a small percentage of cancer Increase Is too much, if it can be prevented.

Thank you. Amanda M. Levitt, ND Do you Yahool?

Yahool Mail Helps protect you from nasty viruses. 495'4 onxgR/-,<

b5 - - A~-1 -0 ST$,,'

b 4 -a-cz~, , A-/ e'Ae- Ofze ~Ž NUREG-1437, Supplement 22 A-342 July 2005

Appendix A MillstoneEIS - Millstone Paco I I

.53f/OD/.-

From: *Baran. Marie- cMarie.Iaran~ffb.gov>

To: .cMiltstoneElS~nrc.gov>

Date: Fri. Feb 25,2005 11:40 AM

Subject:

Millstone MPS-66-1 I wish to voice my opposition to the Millstone Nuclear power plant MPS-66-2 1. The Millstone draft Environmental Impact Statement Is completely silent on Impacts to Long Island. This gross omission by tho NRC Is reason to deny re licensing on this basis alone. Meaning If and when there Is a nuclear event (and there was one on January 14. 2005). they do not have to notify Long Island who is Just 10 miles south of the Millstone along the Long istand Sound. Shoroham did not come on lne because we couldn't put an evacuation plan in place. Millstone Is our e),

Shoreham!l MPS-66-3 2. Millstone has been operating with an expired Clean Water Act discharge permit since 1997. The Clean Water Act mandates permit holders to obtain five-year permits so that every five years they will have to demonstrate that they have Implemented best available technology to reduce or eliminate pollution Itthey want their permits renewed.

Millstone has been able to get away with operating with non-updated technology an extra five years.

The Connecticut Coalition Against Millstone believes this Is a flagrant violation of fedoral law. (In Connecticut. the Department of Environmental Protection Is delegated by the federal EPA to Implement the Clean Water Act and hence is the permitting agency. DEP has routinely Issued 'emergency authorizations' of indefinite duration which violate the permit conditions and which allow for increased pollution by toxic chemicals. This Is a scandall Meaning the NRC and Millstone are above the law and play by their own rules.

MPS-66-4 3. Millstone is responsible for driving the native fisheries stock to near-extinction through the operations of Its Intake structures. AU these assaults on the environment would end If (a) Millstone were shut down or (b)It Millstone converted to closed cooling system. This Important Issue certainly affects Long Island because of the dispersion of toxic and radioactive waste byproducts by tidal and wave action.

Marie Baran X ,-ee 5,

'-r At x)e zc CiZ.z3

-77S d. /Ci4 3- b At' <3 July 2005: A-343 NUREG-1 437, Supplement 22'

Appendix A

.MillstoneEIS - Millstone _ Page 2!

2567 7th Avenue East Meadow NY 11554 CC: <tim.bishoprmaIDhouse.gov>, <jennhifr.gunnOrmaP.house.gov>.

<JonschneiderQmaR.house.gov>. <hilliary.cflntone mafl.house.gov>

NUREG-1437, Supplement 22 A-344 July 2005-

Appendix A I MillstorleEIS -Minstone Pa22 IJ I ,, -,.:-13 Ae -,e I . -- -- -

From: -cCayLea300aobcom>

To: .cMillstoneEISOnrc.gov' . -

Date: Fri. Feb 25,2005 11:27 AM

Subject:

Miltstone MPS-67-1 Sirs: I want to go on record as beig agamst the re licensing of 6- #/-13/7 MPS-67-2 Millstone. They do not have an emergencey evacuation plan for where I Ave on Long Island. . ArthurTaiman, Mattituck. N.Y.

C_-AZ--F ' -.-

5Zy<=~& O/>ffis-L r < .- r- I; ^c, ( S) .

July 2005 A-345 NUREG-1 437, Supplement 22

Appendix A Richard Emch - Millstone Power Plant relicensing Page 1 c3/o/c7/OG From: Kathleen Faraone <kathylaraone~yahoo.com>

To: crleOnrc.govn>

Date: 312t05 10:59AM Subjcct: Millstone Power Plant reoicensing Kathleen Cunningham Faraone 7'/3 59 7 44 Cosdrew Lane East Hampton. New York 11937 t - 631-324-3581 1-631-324.7439 e-kathyfaraone~yahoo.com Mr. Richard L Emch Environmental Project Manager U.S. Nuclear Regulatory Commission Washington. DC 20555-0001 2 March 2005 Dear Mr. Emch.

I understand the operators or the Millstone Nuclear Reactors across Long Island Sound In Connecticut are MPS_68-1 seeking to renew their license. If renewed, these reactors will be up and running for another 20 years, yet there are no emergency plans In place for eastern Long Island In the event of an Incident or accident at the facility. I also understand that the DEIS tor this relicensing Ignores the safety threats to Long Island. New York residents and the environmental Impacts of the aging reactors.

I oppose the relicensing of these reactors for the olowing reasons:

1. The Millstone DEIS Is completely silent on Impacts to Long Island. A nuclear power plant in Shoreham. Long Island did not come on line because an evacuation plan could not be put in place.

particularly for Eastern Long Island.

MPS68-2 2. Millstone has been operating with an expired Clean Water Act discharge permit since 1997. The Clean Water Act mandates permit holders to obtain frie-year permits so that every five years they will have to demonstrate that they have impfemented best available technology to reduce or elrminate pollution if they want their permits renewed. Mllstone has been able to operate with non-updated technology for an additional live years with no consequence.

MPS-68-3 3. Millstone Is responsible for the depletion of native fish species through the operations of Rts Intake structures. All these assaults on the environment would end U (a) Millstone were shut down or (b)It Milstone converted to closed cooling system. This important Issue certainly affects Long Island because of the dispersion of toxic and radioactive waste byproducts by tidal and wave action.

,Vo Vo /3,-494 r " ~ ~ .? ) 5 ~

<4~~~k 69ke&

Z.r NUREG-1437, Supplement 22 A-346 July 2005

Appendix A

____Page 2i Richard Emch - Millstone Power Plant relicensing MPS-68-4 Ptease do not allow this power plant to reopen without --

mitigation of the above impacts.

Thank you.

Sincerely.

Kathleen Cunningham Faraone Celebrate Yahool's 10th Birthdayt Yahoo! Netrospective: 100 Moments of the Web http:/ibirlhday.yahoo.con/netrospectiveI S- - ,,

I . . . I , .

,. ~..

I:.

July 2005 . A-347 NUREG-1 437, Supplement 22

i

. i i

. I II Appendix A

Ricard Emch - I Oppose Millstone Ucenso Extension Page 1 r . . 51 15.m '

alldld!OS-From: Kersten Elenteny <Melenteny~mac corn>

To: .crlelnrcgov>

Date: 3/2/05 11:30AM Subject, I Oppose Millstone License Extension Dear Mr. Ernch -

MPS-69-1 t am writing to Inform you that as a resident of New London County, I am In opposition of the license MPS-69-2 extension of Millstone. The plant has a negative envlronrrental Impact on our waterways and wildlife. In MPS-69-3 addition to the harnful health hazards posed to humans.

Please deny the Millstone license extension. Feel free to contact me with any questions or for further discussion Kersten Etenteny 33 Essex Street 6tN / ,

"ytic. CT 06355 CC: cpmcquown mac.con>

_ ,2:z <-o 3 c ZZ-45

- YV9'-)

NUREG-1 437, Supplement 22 A-348 July 2005

Appendix A Richard Enich - relicensing of Millstone Page I i

,. , - - i

. :C' -: ' V;

. . I -I - .

A )6 Ad--

_4 - , , 1, , - -

op-0/05 From: , . Andy Greene <aJgreeneuaoptonzinn.net.

To:. <rleonrc.gov>

Date: 3S 5 12 42PM -- <r > 7

Subject:

relicensing of Millstone -

Dear Mr. Emch:

Kindly accept the following as my comments on the DEIS related to the relicensing of Millstone.

MPS-70-1.I lam appalled that the Millstone DEIS is completely silent on impacts to Long Island. I live less than 25 miles from Millstone, In an area that is downwind from the plant several months a year. There Isno question my family would be directly Impacted In the event of any accident or a terrorist attack. How is It possible that you can Ignore Long island when considering Millstone?

MPS-70-2 2. MiUstone has been operating with an expired Clean WaterAct discharge permit since 1997. have The Clean Water Act mandates permit holders to obtain five-year permits so that every five years they will to demonstrate that they have Implemented best available technology to reduce or eliminate pollution It they want their permits renewed. Millstone has been able to get away with operating with non-updated technology an extra five years. Why Is Millstone allowed to subvert the Intent of the law?

MPS-70-3 9. Milstone is responsible for the depletion of native fish species through the operations of its intake structures. All these assaults on the environment would end If (a) Millstone were shut down or (b) If Millstone converted to closed coo6ing system. This Important Issue certainly affects Long Island because of the dispersion of toxic and radioactive waste byproducts by tidal and wave action.

I hope that these crucial matters will be considered In the final DEIS.

Sincerely yours.

Andrew Greene 1220 Sigsbee Road Mattituck. NY 11952

.. -4 ,

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"- -0/:F.

July 2005- A-349 .-t NUREG-1437, Supplement 22

Appendix A MillstoneEISI- opposing the ro licensing of Mitistones Units 2 & 3 Page 1i

-L -

From: Rory MacNish <rm246@comentedu>

To: <MilstoneElS~nrcgov>

Date: Fr. Feb 25.2005 321 PM

Subject:

opposing the re Ncensing of Millstones Units 2 & 3 To Whom it may Concern.

MPS-71-1 My famil (which consists of my4 children and my wife) and myself are opposed to the re licensing of Millstones Units 2 & 3.

,-3 Thank you.

Rory MacNish 370 Pacific Street Mattituck NY 11952 rmacnish~optonline.net CC: <cjennifer.gunnCmail.house.gov>,. dimbIshopomafLhouse.gov>.

<jon.schn9ider~mail.house.gov>. cacampop0assombly.stateny.us>. <Umrrcofm OaoLcom>

,6- 4-.5 s- F --a a GC= fi ~ZC2) re = 0 3, NUREG-1437, Supplement 22 A-350 July 2005

Appendix A ra MilstoneIIS - Millstone iener.rn OFFICIAL COMMENTS OF THE TOWN OF SOUTHOLD P.O. Box 1179 Southold, NY 11971-0959 Tel.: (631)765-1889 .--

Fax: (631)765-1823. . .  :

March 2. 2005 Chief. Rules and Directives Branch Divsion of Administrative Sernices Office of Administration -

Ma-lstop T-6D 59 -

U.S. Nuclear Regulatory Co.mission Washington. D.C. .20555-01 RE: objections to DEIS, Millstone PowerrStation Unfts 2 and 3 To Whom It May Concern:

• I am Supervisor of the Town of Southolddthe eastem-most town on the North Fork of Long Island. located on a narrow peninsula directly opposite the Millstone plant MPS-72-1 across the Long Iand Sound. On January 11. 20051 appeared and made comments on the record on behalf of the residents of the Town of Southold at the public hearing on

• the Draft Environmental Impact Statement (DEIS) for the proposed renewal of the operating licienses for the Millstone Power Station. Units 2 and 3. Those comments stand; thoe" written comments serve as supplemental objections to the renewal of those licenses in the absence of the due consideration for the safety of the affected nearby Lon ars g Island residents. On J r 1 Furthermore, I hereby join In the request of other parties. Including, without imitation, the Connecticut Coalition Against Millstone, for an extension of time In which to submit written comments due to the failure of the NRC to make available for review relevant documents such as the transcript of the January 11n 2005 hearing.

In the first instance. I object that the Town of Southold was given no notice whatsoever of the -scoping process that was apparently held In this purportedly public environmental review procedure. It is precisely because we were not Includedin this process, and not af orded the opportunity to identify the significant Issues to be analyzed in depth, that critical Issue of the safety of Long Island residents has been completely omitted from the environmental review.

JJuly 2005 A-351 NUREG-1 437. Sunolement 22

, __ - r

Appendix A minstontiQs - Millstone ienter.m ,ags z

~ .

U.S NuclearRegulatoryCommission March 2,2005 MPS-72-2 This safety issue fallssquarelyunder the topical severe accident mitigation.

which the DEIS Is mandated to analyze in detail. However. completely omitted from all review was the topic d an evacuation plan for the residents di Southold Town or elsewhere on eastern Long Island. The reason for such omission is simple: no such plan exists, nor has one ever been studied or even considered. The geography o Long I

Island creates an extremely dangerous situation for those residents in the case of a severe accident at Millstone. At the very end of a narrow strip d land, there is only one direction for these residents to travel in the case of an emergency - West. There is. in some cases, only one road on which to travel - New York State Route 25 in the event of a Millstone-induced emergency. Southold residents will be unaccounted for by the NRC.

By the time Southold residents evacuate and reach the mainland of Long Island, we will be lined up on the Long Island Expressway behind the literally millions of other Long Island residents who have the same one and only direction to travel. This is a natural i

recipe for a manmade disaster that must be avoided. f To the extent that the drafters of DEIS seek to avoid creating an evacuatin plan for the Town of Southold and eastern Long Island on the purported grounds that federal regulations only require such plans to do so within a 10 mile radius. they should and must consider the extreme circumstances that are present The North Fork of Long Island is cirectly across the Long Island Sound. Strong prevairing winds blow across the water directly to our shores. We are the first affected residents to the south of this plant.

To say that we are beyond the affected area is just wrong and cannot be the basis for a - A proper EIS. With that knowledge. I believe it is imperative that the NRC expand the scope of its evacuation planning to include the residents of the Town of Southold and other affected areas of eastern Long Island.

MPS-72-3 Clearly, as far as safety odaffected residents is concemed, the environmental review process has not yet begun. Since this isa matter d federal corcem, and which is the subject of federal regulation, it is crucial that the NRC seek and heed the input di ii the federal elective otficials in the surrounding areas for their input regarding the concerns of their constituents. The NRC must, therefore, seek formal input from the r Senators and Representatives in New York as well as Connecticut Furthermore, the NRC must appropriate funding and conduct a proper study for the evacuation of eastern Long Island residents, which should then be included as part .

of the DEIS, and subject to public input, at a forum Long Island residents can attend - on Long Island. The DEIS must not, and cannot move forward until these crucial matters are property considered and integrated into the document. K Very truly yours, Joshua Y. Horton Supervisor NUREG-1437, Supplement 22 A-352 July 2005

Appendix A From: Gwynn Schroeder <gdsnfecOoptonHlne.net>

To: -cMiitstoneEIS~nrc.gov>

Date: Tue. Mar 1,2005 4:58 PM

Subject:

Millstone Ucensure Renewal March 1,2005  ;, , - S < 37 Mr. Richard Emch, Jr.

Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation United States Nuclear RegulatoryCommission Washington DC 20555

Dear Mr. Emch:

North Fork Environmental Council (NFEC) Is a grassroots advocacygroup established in 1972. We are located In Mattituck, New York and represent over 1500 members in the Townships of Riverhead, Southold and Shelter Island.

MPS-73-1 On behalf of NFEC, I am writing to strongly oppose the relicensure of the Millstone Nuclear Reactors and to express my grave concerns about their continued operation. The Millstone reactors are ocated hi Waterford, Connecticut and although the facilityis located only 11 mites from the i,

Town of Southold, the Nuclear Regulatory Commission continues to ignore the safety and environmental concerns held by the residents of the North Fork when considering the continued operations of these aging reactors.

MPS-73-2 If the NRC is not prepared to deny the request of Dominion to renew the-operating icense for the Millstone reactors, we request, at the very least, that the NRC hold an additionalpublic hearing on Long Island. The actions of the NRC in this licensing renewal process will affect residents .-

d the North Fork and it Is morally reprehensible to deny our voice In the process. The Januaryhearing held inCt was poortynoticed. Although the hearing may have met the legal requirements for notification, very few stakeholders on the North Fork were aware of the hearing. or for that matter, the entre scoping process. We certainlywore not given ample time'A to luilytadconsiderand prepare thoughtfulcommentson the Generic Environmental Impact Statement (GEIS) for Ucense Renewal of Nuclear Plants or the 449 page draft Supplemental Environmental Impact Statement (SEIS) which examines the renewal of the Millstone licenses specifically.

MPS-73-3 Residents, dvic and environmental groups haveJoined many elected officials from the East End and across Long Island and called for the extension of the emergency planning zone from the current I 0-miles radius to a 50 miles mile radius. By doing so, emergency planning for the North Fork would be required.

Because the North Fork Isessentially a peninsula. surroundedby water on three sides, we have only one direction to evacuate west Residents In Orient only have one Road heading west until Greenport. There are only two roads from Greenport to Matituck. three from Mattituck to Riverhead. In the event of an emergency, evacuation of the 20.000 year round North Fork residents, or 30,000 summer residents would be virtually impossible not to mentions the hundreds of thousands dl Long Island residents to the west Because evacuation of Long Island Isimpossible, the Shoreham Nuclear Plant wa shut down. Many d us live closer to Millstone than to Xe-e25), -A bt -z' 3 i; f~,a¢g, em1cL~ GizL~c- t- )?.b l (,tL

v July 2005

, A-353 NUREG-1437,-Supplement 22

Appendix A MPS-73-3 Shoreham.

MPS-734 It is common knowledge that nuclear power plants and Ihe adjacent spent fuel pools are vulnerable to terrorist attack. In addition to living in close proximity to Millstone. North Fork residents live very close to other potential terrorist targets Including the Plum Island Animal Disease Center (PIADC). If there were an incident at the Millstone Faciity. there are no emergency plans in place for PIADC. The NRC would be negligent it these facts were not considered in your deliberations.

Sincerely, Gwynn Schroeder I Executive Director I

I Gwynn Schroeder Executive Director North Fork Environmental Council P.O. Box 799 Mattituck. New York 11952 631-298-8880 -

Fax 631-2984649 E-mail: gdsntecOoptonline.net www.nfecl.org NUREG-1437, Supplement 22 A-354 July 2005

Appendix A MilIstoneEIS - Comments, Millstone Power Station. NUREG-1437 [Virus checked] Pace 1

.. . . . .

• A From:: - .Diane-iazirskyv bos.doi.gov>

To: <MiflstoneEIS~nic.gov>

-, Date: Mon. Feb28.2005 11:11 AM' Sublect: Comments, Millstone Power Station, NUREG-1437 [Virus checked)

Dear Mr. Emch:

Please see the attached file for the Department of the Interior's comments on the draft Supplemental Environmental Impact Statement (SEIS) Millstone Power Station. Units 2 and 3, Waterford. Connecticut. Thank you and please feet free to contact me lt you have any questions.

Sincerely. I . . . .. .

Diane Lazinsky Diane Lazlnsky U.S. Department of the Interior Of race of the Secretary Office of Environmental Policy and Compriance 408 Atlantic Avenue., Room 142 - -

Boston.MA 02210-3334. .

Phone: 617-223-8565 Fax: 617-223-8569

- "~ . jI1 ..- ,

3 =4 NURE1 Supp-ement 22 G! .=. eC'-4 (r. r-)

July 200/3 July 2005 A-355 NUREG-1 437, Supplement 22

Appendix A United States Department of the Interior OFFICE OF THE SECRETARY onice of Environment] Policy and Compliancc TAKE PRDtor 40S Attantic Avenue-Room 142 ItAIM ERICA Boston, Massachusens 02210-3334 February 28,2005 ER 041921 Richard L. Emch. Jr.

U.S. Nuclear Regulatory Commission Mail Stop 01 IFI Washington, DC 20555-0001 RE: COMMENTS Review ora Draft Supplemental Enslronmental Impact Statement (SEIS),

NUREG-1437, Supplement 22, License Renewnl, Dominion Nuclear Connecticut, Millstone Power Station, Units 2 and 3, Vaterford, Connecticut Dcar Mr. Emch:

Thc Department of the Interior (Department) has reviewed the Draft Supplemental Environmental Impact Statement (SEIS), NUREG-1437, Supplement 22, regarding Millstone Power Station, Units 2 and 3. Thc Dcpartment has no comment on, or conccrn with the Draft Supplcmental Environmental Impact StatemcnL Thank you for your attention to these comments.

Sincerely, Andrew L. RaddantIsl Regional Environmental Officer NUREG-1437, Supplement 22 A-356 July 2005

Appendix A

-r rz .-

. rIIItSy Caub *ntfl iuaj:IIm SII %Ataust~ U~bPUvJUUI tv 1U- LIt-es _ _ _ _ -- ratsI I

From: WALLMULLER <JWALLY063CAOLCOM> , - , - /

To: <operliclnrc.gov>

Dt: ,. 1117105 1:08PM

Subject:

. Response from 'Contact Us About Operator Llcensing',, -

- Below is the result of your feedback form. It was submitted by ' . -

WALLMULLER (JWALLYo63@AOL.COM) on Monday, January 17, 2005 at 13:07.10 recipient location: Washington. DC (Hdqtrs.) -

MPS-75-1 comments: I am against Millstone Nuclear Power Plant which Is located In Connecticut renewing Hs operating licenses. ,, ,'

organization:

addressl: PO BOX 1312 address2:

city. SMITHTOWN state: NY zip: 11787 country USA '

phone:

./ . .C . .

C7,-e- /' =f f$ t- 3 -:-

, . I 1 July 2065 A-357 NUREG-1437; Supplement 22

Appendix A Richard Emch - NO. TO MLLSTONEIII Page II IfP. /, g _

From: <Carjam10@aol.com>

To: <opa~nrc.gov>

Date: 1116/0511:36PM

Subject:

NO.TO MtLLSTONEIII The Millstone spokesman adds that the company is In the beginning of the license renewal process so North Fork residents still have time to voice their opinions.

MPS-76-1 I am saying NO to this proposed Millstone license renewal. One can hardly get off Long Island now without there being a catastrophet This renewal would put too many lives here on Long Island In danger should anything happen al the Millstone Nuclear ptanL.There Is no leasable escape route possible for so many Long Island Inhabitants.

A NUCLEAR LEAK OR ACCIDENT WOULD BE WORSE THAN A TSUNAMI HITTING LONG ISLANDIII NO. NO. NO TO THIS RENEWAU

,  ;,-- )5 i-y =4) ., 3f /A' )

NUREG-1437, Supplement 22 A-358 July 2005

Appendix A

!MinstoneElS- Comments of Connecticut DEP on Document NUREG. 437. Supptement22 Page 1 From: *Merrily Gore' cnerrily.gere~po state.ctLus=;

To: .cMillstoneEISlnrc gov>

Date: Tue. Mar 8. 2005 9:45 AM

Subject:

Comments of Connecbicut DEP on Document NUREG4i437. Supplement22 Attached please find the comments of the Connecticut Department of Environmental Protection Bureau oa Air Management on the Draft Generic Impact Statement for the LUcense Renewal of the Millstone Power Staton Units 2 and 3 (NUREG-1437, Supplement 22). These comments wrll also arrive by U.S. mail.

MerrilyA.Gero Environmental A n~alyst 2 Connecticut Dep artment of Environmental Protection Bureau oaAir Ma nagement 79 Elm Street Hartford. CT 061 06-5127 TeL (860)424-3 416 To conserve, Imnprove and protect the natural resourcres and environment oathe State,

I CC: Edward Wids' <edward.wlds~postateocLus> '

I i I i

- -- -----&ee A*&e4 (A)

July 2005: A-359 NUREG-1437, Supplement 22 -

Appendix A

?d[stoneElS - Comment on Millstone, reticensina final.doc M panae, VIA ELECTRONIC AND REGULAR MAI March 2,.2005 Chtief. Rules and Directives flraneh U.S. Nuclear Regulatory Commnission Mail Stop T6-D59 WVashington, DC 20555-000I MillstoncElSQnrcev_

Re:~ Comments of thre Connecticut Department of EnvironmentalProtection-Bureau of AirMAnoragement -

Draft Generic Impacd Statem ent for LIcense RenewalofoNuclarPlantsRegarding Afilhisone Power Station, Units 2 and`3 NUREG-1437Z Supplement 22 To the Chief of the Rules and Directive Branch:

The Connecticut Department of Environmental Protection Bureau ofrAir Management (the Bureau) submits these comments on the U.S. Nuclear Regulatory Commnission's; (NRCs) Draft Genseric Fn tironmentalImpact Statementfor Lkense Renewal of NuclearPlantsRegarding Milbt one PoverStation. Units 2 and3 (Draft E3S). The Draft EIS discusses the environmental impacts or the proposal to renew the operaiting licenses for Units 2 and 3 of the Millstone Power MPS-77-1 Station. including the alternatives to license renewal. The Bureau has considered the alternatives presented Id the Draft EIS and is concerned that any fossil-fueled alternative electricity supply will hawe negative air quality Impacts as compared to re-licensing the Millstone units.

If the license for the Millstone units is not renewed, additional fossil-fueled generation would likely be necessary to meet the state demand for electricity. as an alternative consisting only of demand reduction. energy elricrincy and altemnative energy sources is not feasible in the given time-firane. Moreover, teConnecticut EnergyAdvisory Board's 2004 energplan specirically identified the Inadequacy of the State's transmission Infrastructure. Falure to re-icens units 2 and 3 will further exacerbate this problem. The Bureau supports the use ofrclean alternative energy sources and measures thatt reduce electricity demand, However. the Bureau recognizes that such measures require Immediate and substantial changes In behavior with regard to energy use, a substantial Investment in low- and no-emitting resources and large-scale implementation of energy conservation and load reduction measures by residential and Industrial energy users.

Such changes can only occur over a longer timeframe than that allowed by denial or the license renewal.

The air quality impact or replacing the electricity generated by the Millstone units with electricity generation by large-scale fossil-fujeled electric generators is substantiaL As the Draft EIS identifies, emissions ornitrogen oxides (NOx), sulfur oxides, carbon monoxide, particulate NUREG-1 437, Supplement 22 A30Jl20 A-360 July 2005 I

Appendix A Pano 21 i MilistoneEIS - Comment on Millstone relicensino final.doc MPS-77-1 matter and hazardous air pollutants would increase. Increased NOx emissions are a particular July 2005 i- A-361 NUREG-1 437, Supplement 22

Appendix A ft.hlistoneEIS-Comment on Millstone relicensing finaI.doc Page 3i Chief. Rules and Directives Branch Page 2 MPS-77-1 concern to the Bureau since reductions in emissions of ozone precursors are of immediate importance to Connecticut's strategy to attain and maintain the national ambient air quality standards (NAAQS) for ozone. In order to attain the new 8-hour ozone NAAQS statewide by 2010. as required by the U.S. Environmental Protection Agency (EPA), Connecticut is now in the process of identifying additional reductions that may be obtained from a variety of sources in the state Furthermore, the same assessment is underway for fine particulate matter, in order to comply with EPA's designations under the NAAQS for particulate matter less than 2.5 microns in diameter.

The Bureau appreciates the opportunity to submit these comments and wvill be glad to provide any additional information that you may require.

Sincerely, Is/Anne R. Gobin. Chief Bureau of Air Management ARGIMAG/mag NUREG-1437, Supplement 22 A-362 July 2005

.Appendix A IRichard Emch - Millstone Uconse Renewal - Letter of Opposition and Contact Information Page 1I

.... It . . .- . .I--/I_ ,-

8  !

.-- ~.: - -R 1g -t, /OS From: dirrcomm~aol.com>

To: <bxzOnrc.gov>

Date: 1112105 11:54PM

Subject:

Millstone Lcense Renewal - Letter of Opposition and Contact Inform nation . , .

Sq/p@'

Dear Mr. Zakeman.

softX37 I would like to take this opportunity to thank you for iistening to our concems as it related to cutting short the NRCs presentation at the Millstone Meeting on Tuesday. I also appreciate the fact that myself Mike Domino and Supervisor Horon were given the opportunity to speak first as we had to catch a 5:00 Ferry back to Long Island. .

The attached email Isfrom Assemblywoman Pat Acampora of Mattituck. Please take a moment to review her comments that were forwarded to Mr. Emch. ....

MPS-78-1 Lastly. I would like to provide you with contact Information of our local representatives who should be put on your list of people to cbntacr . ,

representing Long Island & NYS. These Individuals should be advised of future meetings as it relates to the Millstone Power Plant license renewal or other matters relating to this plant. Please ensure your community affairs people have this information for future reference. Additionally, would like to recommend

. . . X.

conducting this ficensing meeting on Long Island for *pubtic feedback. If . .. . ..

you would like to plan a meeting on Long Island. I recommend you contact one of the Individuals listed below to determine a mutually agreeable location. . . .

The following information applies:

Southold Town Supervisor Joshua Horton 631 765 1889

_Joshua.Horton~town-southold.ny.us_

(maBlo:Joshua.Horton~town.southold.ny.us)

JoshhortonO3Oyahoo zom_ (maiito:JoshhortonO3Cyahoo.com)

Assemblywoman Patricia Acampora 631 727 1363 (Long Island Y) 5184555294 (Albany#)

-acameoooassemblvstate.nv.us (mailto acamooooassemblvstate nv.us)

Congressman TIm Bishop 3680 Route 112 Sulte C Coram. NY 11727 631 696 6500 (Coram) ask for Jennifer Gunn 631 259 8450 (Southampton Ofrice)

_Tim.BishopCmall.house gov_ (malto:rim.BlshopOmaD.house.gov)

_Jennlfer.Gunncman.house.gorv- (maillo:Jennlfer.GunnOmal.house.gov)

County Legislator Michael Caracciolo 423 Grifng Avenue Riverhead. NY11901 -

1=.-4 r- = ,.6P-b,-0-O *

,--' 6q-22 0 e -f&/

July 2005 A-363- NUREG-1437, Supplement 22

Appendix A Richard Emch - Millstone License Renewal - Letter of Opposition andl Contact Inlormation Page 2 631 852 3200

_Michael.Caracciotobco.sutfotk.ny.us_

(mailto:MkchaeLCaracclolo~co.sulrotk ny.us)

Senator Ken LaValle 631 696 6900

_LAVALLEOsenate.slale.ny.us_ (maifto:LAVALLEOsenate.stateny.us)

Governor George Pataki 212 681 4580 631 952 6583 I would also like to add:

North Fork Environmental Council Gwynn Schroeder Executive Director 631298 8880 5gdsnfecOoptonfine.neL (mailtogdsnfec optonlinenet)

Marie Domen'ci 631 2987103

_LircommOaol.com_ (mailto:Lirrcomm @aoLcom)

Thank you for taking the time to review this information and please feet free to contact me should you have any questions regarding this Inlormation.

Sincerely, Marie Domenic' CC: <gdsn1ecOopionIano.net>. rleOnrc.gov>, iJdSoutholdOaol.com>

NUREG-1437, Supplement 22 A-364 July 2005

Appendix A

.qA ~

STATE OF CONNECTICUT DEPAMRTNT OFPUBIC LJ77M' CONTROL VOKALW W.VOWNES -

MA R I ,: ..

Nils J. Diaz Chairman . ,- I

• U.S. Nuclear Reg 6uatory Commission i Washington, DC: 20555-0001 I I

RE: Millstone ,owprQlion Application. or.RenewedpOpeattngU ce nse I

Dear Chairman Diaz:

MPS-79.1 The Connecticut Department of Public Utility Control (Department) submits this letter in support of the Application for Renewed Operating U.cense for Millstone Power Station, located In Waterford,- Connecticut. Millstone Power Station consists of Unit 2 and Unit

3. Unit 2 Is solely owned and operated by Dominlon Nuclear Connecticut., Inc.

(Dorminion) and Unit 3 is 4olntly.owned by-Domin ortqetrdeIVyermont Public Service Corporatlin and Massauciiuetts MunicipblV C . is

.the .operator~o~f. Unit 3'anid buthoriiedio act as ag $ortheJont d nbrs~bDominloniss seeking renewal of the operatlng licenie for a Period bf 20 years beyond'ilie eipiration date 61 the current ojperating license for both units (Unit 2 current depiration date Is July 31.2015; Unit 3 current explrallioidate Is November25. 2025). This letter is in support of both applications forthe units, colfectwvety referred to herein as Millstone.

The Department belleves.that Dominion is boe bf.ihe best nucler plant operators In the countryand that It his demon'strated an cxcelleht history of nuclear plant operation and safety. The Department would like to offer two additional reasons for granting Millstone's request.

MPS-79-2 First, from a regional and Connecticut energy needs point of view, Millstone has been an essential resource for the existing bulk power system: This essential resource need Is expected to continue as such Into the future. . It Is for this reason that Millstone's license etednsloh is Impoitant to continue 6' serve New England and Connecticut energy needs. -.The Independent System Operator for the New England bulk power supply system (ISO-NE) publishes an annual regional system plan meant to Identify system,needs lhatlcan impact regional.useriiand Identify system solutions that will benetithe entfi ireiregion._. Its mcost.rhceht annual reporl;:dated Jhnuary,4,20D5, stales Pi~ n~ d - .. r~.i'* ...

• .4. . .!V. -

• 1.

aI6#riankuau Nquare, aNcw Minnm; C.oanctcuiw 14J)J An Equal opp~onuuoly Eaployer (:

.j5_,5 C., = '- -/_ -"e-;-.r-e C4 - cez-1 _-)

July 2005 A-365 NUREG-1437, Supplement 22

Appendix A The ISO-NE annual report states that New England could face a capacity shortage If there Is high demand for electricity beginning In 2006 and continuing Into the future. Id, page 6. Possible means of resolving this looming problem includes. inter alla, additional

-* generation. Accordingly, the Department is greatly concerned that existing, reliable, sare. high capacity factor units.such as Millstone be allowed to continue and extend operation. This Is especially true given the high demand for fossil fuels upon which MPS-79-3 most new generation Is based. Keeping Millstone operational greatly adds to the diversity of fuel supply In Connecticut and the region.

Second, on August 28.2001 Connecticut and the New England region committed to a Climate Charige Action Plan. The goal of.this plan Is to mitigate the release or greenhouse gases that are emitted by-the-combustion.bfossil fuels..Asislwellknown, the greenhouse gaseriisions fromn nuclear power plants are negligible. Continued operation or Millstone past Its present license expiration dates will displace fossil generation, helping the region to meet Its greenhouse gas reduction targets. Extension of the licenses forthe Millstone units Is very important to meeting this goal.

The Department urges the Commission to consider the above factors in reviewing the request for the Millstone license extension.

Sincerely, DonalW. es Chairman Public Utilities Control Commission NUREG-1437, Supplement 22 A-366 July 2005

Appendix A Pace I -

iMinstoneElS - testimony

' I . . I .

From: .cSLKaleeCaol.com>

io: emilisioneElwnrc.gov> ... - -

Date: Fri. Mar11.2005 8:15AM -

Subject:

testimony MPS-80-1 Do you believe that true costs are considered when assessments, such as the one you are about to read of, are done? Pollution from mining. -

transportation, processing, waste products and their disposal as well as the health and MPS-80-2 environmental costs. etc. make up those unaccounted for costs. If we really- IC91IF119-L want to cut C02 emissions we need to look at the big picture, wind, solar.

geothermal. bie-diesel, methane from dumps used as a fuel source. forest craft 2'1,V conservation, green building. etc. --

11we take a nuclear power plant otl line, clearly any wind generated power will not make a dent In the C02 until there Is more electricity produced from ..- (2 -

the wind source than by the nuclear power plant .. and don't forget those . -

hidden costs. How much C02 Isproduced in the processing, and other the other steps mentioned before? Have you ever heard of someone getting cancer from a wind generator or Its by-products? How about the danger oea terrorist attack on a wind generator (shades of Don Quixote)? Is there a Price Anderson Bil to cover the Insurance for wind generators and do we find an exclusion h our home insurance polices for damage caused by an accident or an attack upon a wind generator? And one last qustion. Is there a good evacuation-plan In case of a major problem with a wind generator?

Larry Kaley From:

httpifvw.wirod.comrrdAvrctaiivo/13.O2~uzcloar.htmi

. .- I , - '. r4 ,, - .. :-- - . . .

Nuclear NowlI How clean. green atomic energy can stop global warmig By Peter Schwartz and Spencer ReissPage Peter Schwartz (peterschwartz@ gbn~com) is chair of Global Business Network, a scenario-planning fiNm. Contributing editor Spencer Reiss (sponcerO upporroad net) wrote about pebble-bed nuclear reactors In issue 13.01. Additional research by Chris Coidewey.

On a cool spring moming a quarter century ago, a place In Pennsylvania caled Three Mile Island exploded Into the headlines and stopped the US nuclear power Industry In Its tracks. What had been billed as the clean, _ I .

cheap, limitless energy source for a shining future was suddenly too hot to handle.  : - - -. .

. . 0. . .

In the years since, we've searched for altematives, pouring billions of -

dollars hito windmills, solar panels, and bloluels. Weve designed fantastically efficient lightbulbs. air conditioners. and refrigerators. - .1 . . .' -

We'Ve built enough gas-fired generators to bankrupt Califomha. But mainly. -

each year wo hack 400 million more tons of coal out of Earth's crust than we did a quarter century belore, light It on tire. and shoot the proceeds Into -

the atmosphere.

The consequences aren't pretty. Burning coal and other fossil fuels is

• I t '- '

driving climate change, which Isblamed for everything from westernlorest- - - -

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19-)> Ia July 2005' A-367 NUREG-1437, Supplement 22

Appendix A MillsloneEIS - testimony Page 2 rtos and Florida hurricanes to melting polar Ice sheets and flooded Himalayan hamlets. On top of that, coal-buming electric power plants have fouled the air with enough heavy metals and other noxious pollutants to cause 15,000 premature deaths annually in the US alone. according to a Harvard School of Public Health study. Believe It or not, a coal-fired plant releases 100 times more radioactive material than an equivalent nuclear reactor - right Into the air, too, not Into some carefuily guarded storage site. (And, by the way, more than 5,200 Chinese coal miners perished In accidents last year.)

Burning hydrocarbons Is a luxury that a planet with 6 billion energy-hungry souls can't afford. There's only one sane, practical allemative: nuclear power.

We now know that the risks of splitting atoms pale beside the dreadful toll exacted by fossil fuels. Radiation containment, waste disposal, and nuclear weapons proliferation are manageable problems In a way that global warming Is not. Unlike the usual green ahemativos - water, wind, solar, and biomass - nuclear energy Ishere, now, In Industrial quantities. Sure, nuke plants are expensive to build - upward of S2 billion apiece - but they start to look cheap when you factor In the true cost to people and the planet of burning fossil fuels. And nuclear Is otr best hope for cleanly and elficlently generating hydrogen, which would end our other ugly hydrocarbon addiction - dependence on gasoline and diesel for transport.

Some of the world's most thoughtful greens have discovered the logic of nuclear power. including Gala theorist James Lovelock. Greenpeace cofounder Patrick Moore. and Britain's Bishop Hugh Montefiore, a longtime board member of Friends of the Earth (see 'Green vs. Green. page 82). Western Europe is quietly backing away from planned nuclear phaseouts. Finland has ordered a big reactor specifically to meet the terms of the Kyoto Protocol on climate change. China's new nuke plants - 26 by 2025 - are part of a desperate effort at smog controL.

Even the shel-shocked US nuclear industry Is coming out of Its stupor. The 2001 report of Vice President Cheney's energy task force was only the most high profile in a series of pro-nuke developments. Nuke boosters are especially buoyed by more efficient plant designs. streamlined licensing procedures, and the prospect of federal subsidies.

In fact, new plants are on the way, however tentatively. Three groups of generating companies have entered a bureaucratic maze expected to lead to formal applications for plants by 2008.11 everything breaks right, the first new reactors In decades will be online by 2014. 11 this seems ambitious, It's not: the industry hopes merely to hold on to nuclears current 20 percent of the rapidly growing US electric power market.

Thars not nearly enough. We should be shooting to match France. which gets 77 percent of its electricity from nukes. Irs past time for a decisive leap out of the hydrocarbon era, time to send King Coal and, soon after. Big Oil shambling off to their well-deserved final resting places - maybe on a nostalgic old steam locomotive.

Besides. wouldn't it be a blast to barrel down the freeway In a hydrogen Hummer with a clean conscience as your copilot? Or not to feel like a planet NUREG-1437, Supplement 22 A-368 July 2005

Appendix A I MiltstoneElS - testrmony Page 3 killer every time you frick on the A/C? Thars how the future could be, 11 only we would get over our fear of the nuclear bogeyman and forge ahead -

for real this time - Into the atomic age.

The granola crowd likes to talk about conservation and efficlency, and surety substantial gains can be made In those areas. But energy Is not a -

luxury people can do without, like a gym membership or hair gel. The developed world built Its wealth on cheap power - burning firewood, coal, petroleum, and natural gas, with carbon emissions the Inevitable byproduct.'

Indeed, material progress can be tracked In what gets pumped out of smokestacks. An hour of coal-generated 100-watt electric light creates 0.05 pounds of atmospheric carbon, a bucket of Ice makes 0.3 pounds, an houres car ride S. The average American sends nearly half a ton of carbon spewing -

Into the atmosphere every month. Europe and Japan are a little more - --

economical, but even the most remote forest-burning peasants happily do their part. - ,  :

And the worst - by far - Is yet to come. An Mrr study forecasts that worldwide energy demand could triple by2050. China could build a Three Gorges Dam every year forever and still not meet its growing demand for electricity. Even the carbon reductons required by the Kyolo Protocol-which pointedly exempts developing countries like China - will be a drop tri the atmospheric sewer. - -.

What is a rapidly carbonizing world to do? The high-minded answer, of.

course, Is renewables. But the notion that wind, water, solar, or biomass will save the day Is at least as fanciful as the once-popular Idea that nuclear energy would be too cheap to meter. Jesse Ausubel, director of the human environment program at New York's Rockefeller University. calls, renewable energy sources false gods - attractive but powerless. They're capital- and land-Intensive, and solar Is not yet remotely cost-competitive. -

Despite alt the hype, tax breaks, and Incentives, the proportion of US - .

electricity production from renewables has actually fallen hi the past 5S years, from 11.0 percent to 9.1 percent. . -

The decline would be even worse without hydropower, which accounts for 92 percent of Ihe worlds renewable electricity. While dams In the US are under attack from environmentalists trying to protect wild fish populations, the - . -

Chinese are building them on an ever grander scale. But even China's -

autocrats cant get past Nimby. Stung bycritcism of the monumental Three Gorges project - which required the forcible relocation of t million people - of rcials have suspended an even bigger project on the Nu Jiang River In the country's remote southwest. Or maybe someone In Beijing questioned the wisdom of reacting to climate change with a -

muftibillion-dobar bet on rainfall. - * - --

Solar power doesn't look much better. Its number-one problem Is cost: While the price of photovoltaic cells has been slowly dropping. solar-generated electricity Is still tour times more expensive than nuclear (and more than five times the cost of coal). Maybe someday we'll all live In houses with photovoltaic roof tiles, but hi the real world, a run-of-the-mill 1,000-megawatt photovoltalc plant will require about 60 square miles of panes alone. In other words, the largest Industrial structure ever built.

T ,  :

July 2005 - A-369 NUREG-1437, Su,pple ment. 22

Appendix A I MillstoneEIS - testimony Page 41 Wind is more promising. which Is one reason Itrs the lone renewable attracting serious Interest from big-timo equipment manufacturers like General Electric. But even though price and performance are expected to improve. wind, like solar, is inherenUy ficke, hard to capture, and widely dispersed And wind turbines take up a lot of space; Ausubel points out that the wind equivalent of a typical utility plant would require 300 square mrlesof turbines plus costly transmission tlines from the wind-scoured fields of. say. North Dakota. Alternatively, there's California's Altamont Pass. where 5.400 windmills slice and dice some 1,300 birds of prey annually.

What about biomass? Ethanol Isclean, but growing the amount of cellulose required to shift US electricity production to biomass would require farming - no wilting organics. please - an area the size of I 0 lowas.

Among fossil fuels. natural gas holds some allure; it emits a third as much carbon as coal. Thars an Improvement but not enough it you're serious about rolling back carbon levels. Washington's favorite solution is so-called clean coal. ballyhooed In stump speeches by both President Bush (who offered a $2 billion research program) and challenger John Kerry (who upped the ante to $10 billion). But most of the work so far has been aimed at reducing acid rain by cutting sulphur dioxide and nitrogen oxide emissions. and more recently gasifying coal to make it bum cleaner. Actual zero-emissions coal Is still a lab experiment that even fans say could double or triple generating costs. It would also leave the question of what to do with 1 million tons of extracted carbon each year.

By contrast. nuclear power Is thriving around the world despite decades of obituaries. Belgkim derives 58 percent of Its electricity from nukes, Sweden 45 percent. South Korea 40, Switzerland 37 percent. Japan 31 percent. Spain 27 percent. and the UK 23 percent. Turkey plans to build three plants over the next several years. South Korea has eight more reactors coming, Japan 13, China at least 20. France, where nukes generate more than three-quarters of the countrys electricity. Is privatzig a third of its state-owned nuclear energy group. Areva, to deal with the rush of new business.

The last US nuke plant to be built was ordered In 1973, yet nuclear power is growing here as well. With clever engineering and smart management, nukes have steadily increased their share of generating capacity In the US.The 103 reactors operating In the US pump out electricity at more than 90 percent of capacity up from 60 percent when Three Mile Island made headlines. That increase Is the equivalent of adding 40 new reactors.

without bothering anyone's backyard or spewing any more carbon Into the air.

So alornic power Isless expensive than it used to be - but could it possibly be cost-effective? Even before Three Mile Island sank, the US nuclear Industry was foundering on the shoals of economics. Regulatory delays and billion-dollar construction-cost overruns turned the business Into a financial nightmare. But Increasing experience end efficiency gains have changed all that. Current operating costs are the lowest ever - 1.82 cents per kilowatt-hour versus 2.13 cents for coal-fired plants and 3.69 cents for natural gas. The ultimate vindication of nuclear economics is playing out in the stock market- Over the past five years. the stocks of leading nuclear generating companies such as Exelon and Entergy have more than doubled.

Indeed. Exelon Isfeeling so flush that It bought New Jersey's Public NUREG-1437, Supplement 22 A-370 July 2005

Appendix A v

IMillstoneEIS -testimony __- s Pace 51 .

Service Enterprise Group In December, adding four reactors to Its former roster of 17. , - - -

This remarkable success suggests that nuclear energy realistically could replace coal in the US without a cost Increase and ultimately lead the way lo a clean, green future. The trick is to stan building nuke plants and - -

keep building them at a furious pace. Anything less leaves carbon In thoe climatic driver's seat.

A decade ago, anyone thinking about constructing nuclear plants in the US would have been dismissed as out of touch with reality. But today, for the -

first time since the building of Three Mile Island. now nukes in the US seem possble. Thanks to Improvements in reactor design and Increasing - '

encouragement from Washington. DC, the nuclear Industry ts posed for unlikely revival. AII the planets seem lo be coming Into alignment, says David Brown. VP for congressional altairs at Exelon.-

The original US nuclear plants, built during the 1950s and '60s, were descended frorn propulsIon units in t950s-vintage nuclear submarines, now known as generation I. During the '80s and SOs, when new construction

• hailted In the US, the major reactor makers - GE Power Systems, British-owned Westinghouse. France's Framatome (part of Areva), and Canada's AECL- went after customers in Europe. This new round of business led to system Improvements that could eventually, after some prototyping. be deployed back in the US.

By all accounts, the latest reactors, generation iII+, are a big Improvement. Theyre fuel-eficient. They employ passive safety -

technologies, such as gravity-fed emergency cooling rather than pumps.

Thanks to standardized construction, they may even be cost-competitivo to butld - S1,20 per kilowatt-hour of generating capacity versus more than

$1,300 for the latest low-emission (which Is not to say low-carbon) coal plants. But there's no way to know for sure until someone actually builds . . 7 . ,

one. And even then, the first few will almost certainly cost more.'

Prodded by the Cheney report, the US Department of Energy agreed In 2002 to pick up the tab of the first hurdle - getling from engineering design to working blueprints. Three groups of utility companIes and reactor makers have stepped up lor tho program, optimistically dubbed Nuclear Power 2010.

The govemment's bill to taxpayers for this stage of development could top S500 million, but at least wel get working reactors ralher than 'promising technologies.,

But newer, better designs don't free the Industry Irom the Intense public :

oversight that has been nuclear power's special burden Irom the starL - -- . .

Betieve It or not. Three Mile Island wasn't the ultimate nightmare; that --

would be Shoroham. the Long Island power plant shuttered In 1994 atter a

. I I I - iI nine-year legal battle, without ever having sold a single electron. -

Constuction was alreadycomplete when opponents challenged the plant's application for an operating license. Wall Street won't Invest billions In - : I - I -

new plants (S5.5 billion In Shoreham's case) without a clear path through e the maze of judges and regulators. I - - t-Shorehamn ridn't die completely in vain. The 1992 Energy PolicyAct aims to '

forestall such debacles byauthorzhng the Nuclear Regulatory Commission to July 2005' A-371 NUREG-1437, Supplement 22

Appendix A I MillstoneEIS - testimony Page 61 Issue combined construction and operating lkenses. It also allows the NRC to pro-certify specific reactor models and the energy companies to bank preapproved sites. Utility executives fret that no one has ever road-tested the new process. which still requirei public hearings and shelves of supporting documents. An kIo reactor site at Browns Ferry. Alabama. could be an early test case: the Tennessee Valley Authority Is exploring options to refurbish it rather than start from scratch.

Meanwhile. Congress looks ready to provide a boost to the nuclear energy Industry. Pete Domenicl (R-New Mexico). chair of the Senate's energy committee and the patron saint of nuclear power in Washington. has vowed to revive last years energy bil which died In the Senate. Earlier versions Included a 1.85 cent per-kilowatt-hour production tax credit for the first half-dozen nuke plants to come onrine. That could add up to as much as SB billion In federal outlays and should go a long way toward luring Wall Street back Into the fray. As pork goes the provision Is easy to defend.

Nuclear power's extraordinary startup costs and safety risks make It a special case for government intervention. And the amount Is precisely the same bounty Washington spends annually in tax credits for wind. biomass, and other zero-emission kilowattage.

Safer plants. more sensible regulation, and even a helping hand from Congress - al are on the way. Whats stll missNg Is a place to put radioactive waste. By law, US companies that generate nuclear power pay the Feds a tenth of a cent per kilowatt-hour to dispose of their spent fuel. The fund - currently $24 billon and counting - is supposed to rnance a permanent waste repository the ill-fated Yucca Mountain In Nevada. Two decades ago when the payments started, opening day was scheduled for January 31.1998 But the Nevada facility remains embroiled In hearings, debates and studies. and waste Is piling up at 30-odd sites around the country.

Nobody will build a nuke plant unti Washington offers a better answer than

'keep piling At Yucca Mountain, perfection has been the enemy of adequacy. It's fun to discuss what the design life of an underground nuclear waste facility ought to be. One hundred years? Two hundred years? How about 100.000? A quarter of a million? Science fiction meets the US govemrnment budgeting process. In courtl But throwing waste into a black hole at Yucca Mountain Isnt such a great Idea anyway. For one thing. In coming decades we might devise better disposal methods, such as corrosin-proof containers that can withstand millennia of heat and moisture. For another. used nuclear fuel can be recycled as a source for the production of more energy. Either way, It's clear that the whole waste disposal problem has been misconstrued. We don't need a million-year solution. A hundred years will do just fine - long enough to lot the stuff coot down and allow us to decide what to do with It.

The name for this approach Is Interim storage: Find a few patches of Isolated real estate - we're not talking about taking It over tareternity-and pour nice big concrete pads, add floodlights, motion detectors, and razor wire: truck in nuclear waste In bombproof 20-foot-high concrete casks.

Voilb: safe storage while you wait for either Yucca Mountain or plan B.

Two dozen reactor sites around the country already have their own interim facilities; a private company has applied with the NRC to open one on the NUREG-1437, Supplement 22 A-372 July 2005

Appendix A I MitisloneElS - testimony Page 7 Goshute Indian reservation In Skull Valley, Utah. Establishing a hall-dozon federally managed sites Is closer to the right Idea. Domenicl says he'll Introduce legIslation this year for a national Interim storage system.

A handful of new US plants wilt be a fine start. but the real goal has to be dethroning King Coal and - until something better comes along - pushing nuclear power out front as the worlds default energy source. Kicking carbon -

cold turkey won't be easy, but h can bo done. Four crucial steps can help:-

Increase the momentumn Regulate carbon emissions, revamp the fuel cycle.

rekindle Innovation In nuclear technology, and, finally, replace gasoine with hydrogen.

. Regulate carbon emissions. Nuclear plants have to account for every radioactive atom of waste. Meanwhile, coal-fired plants dump tons of deadly refuse into the atmosphere at zero cost. Its time for that tree ride to end, but only the government can make It happen.

The industry seems ready to pay up. Andy White. CEO of GE Energy's nuclear division, recently asked a roomful of US utility executives what they -- --. -: - - I thought about the possibility of regulating carbon emissions. The idea didn't faze them. 'The only question any of them had, he says, 'was when andhow much. - -

- . I - . . , . , 4

-.- . , . __ 4 . 7 I..I., .- .

i I I.

J4

. , -i I -

July 2005- A-373 NUREG-1437, Supplement 22

Appendix A MinsloneElS - Millstono license Page 1

'From: Connecticut chapter~slerraclub.org,.

• -To: miltstoneeIs~nrcrgov>.

Date: Fri. Mar18. 2005 955 AM

Subject:

' Millstone license Dear NRC MPS-81-1 The Connecticut. United States. and worldwide community demands are clearifts time to phase out nuclear power. It's an experiment that didn't work for a number of reasons.

MPS-8 1-2 It an accident happened we could not evacuate the population (we cant even got home during rush hour).

MPS-81-2 We have no way to deal with the contamination should an accident occur.

MPS-81-3 It appears we have not dealt with the environmental justice Issue of shipping nuclear waste to poor communities.

MPS-81 4 Milstone has had radiation releases Into the local environment many times.

MPS-81-5 And now we have to spend money on terrorist precautions. (It nuclear powerwas so safe. why do we have to worry about terrorists attacks? rIe never heard of a terrorist attack on a solar panel)

Gemnany (the old Europe) as already started to phase out all nuclear power. We have the technology and money to do the same in the US. Yes. this does mean in the next two decades you will have to look MPS-81-5 for anotherjob. Can I interest you In something related to hydrogen fuel cells? (hydrogen produce from clean sources not nuclear)

MPS-81 -6 The recent successes of hybrid cars and solar Incentive programs are pointing to the same thing.-do not renew the Millstone license . Nuclear power Itself Is over and Millstone's record are arguments enough to move on from nuclear. Besidos. we have enough cancer In the US. without having to worry about another source like nuclear power.

John D. Calandrelil State Coordinator for 12.500 members of the CT Sierra Club CC: <secyOnrcgova' e hr>.-D NUREG-1437, Supplement 22 A-374 July 2005

Appendix A:

CONNECTJCIJT COALITION AGAINST MILLSTONEI www.mothballmillstone or' March 16, 2005 Chief Rules and Directives Branch Division of Administrative Services' Office of Administration Mailstop T-6D59 '

U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Re: Millstone Nuclear Power Station/Draft Environmental Impact Statement/Supplemental Comments -

Dear Sirs:

The NRC Is committed to protecting the public health and safety.

- Statement of NRC's Organizational Values' The Connecticut Coalition Against Millstone submits herewith its supplemental comments concerning the draft Efivir6nmental Impact Statement (SEIS) which the NRC staff has prepared 'in support of relicensing of Millstone nuclear reactors Units2 arid 3 to extend their terms to the years 2035 and 2045 respectively. These comments were preceded by preliminary comments submitted on March 2, 2005.,

Unfortunately, our review of the SEIS and our interaction with NRC's SEIS staff concerning its evaluation of the operational history of the Millstone Nuclear Power Station lead us to conclude that in this instance the NRC has entirely departed from its self-defined organizational' values (see above).

Indeed, we are driven to conclude that, in,this instance, the NRC,,

staff is not even remotely concerned about the effects of Millstone -

releases of radiation to the public health and safety and to the environment.

• .- . . .: a-,~ . ~ .':.

July 2005,. A-375- NUREG-1437, Supplement 22:.

Appendix A Nor has the NRC staff adhered to the 'Principles of Good Regulation' heralded on the NRC's website.'

The standard defining evaluation criteria for the NRC staffs environmental review is defined in 10 CFR 51.95( c )(4) as follows:

... whether or not the adverse environmental impacts of license renewal are so great that preserving the option of license renewal for energy planning decisionmakers would be unreasonable.

MPS-82-1 The NRC staff has preliminarily concluded in its draft Environmental Impact Statement that the adverse environmental impacts of license renewal are not so great that preserving the option of license renewal for energy planning decisionmakers would be unreasonable.

This conclusion is clearly erroneous and based on incorrect and incomplete information, industry bias and flawed analysis. It also manifests a profound disregard for the health and welfare of the community.

This conclusion ignores substantial available evidence that Millstone operations have had and will continue to have devastating health Impacts on a wide scale and will continue to cause irreversible environmental damage on a wide scale.

Our detailed comments follow. Following the Introduction, our comments appear in sequence conforming to the appearance of topics in the draft Environmental Impact Statement (SEIS). Our comments today address the SEIS up to 5.0 ('Environmental Impacts of Postulated Accidents").

Additional comments addressed to Section 5.0 et seq. will be provided subsequently hereto.

Introduction The U.S. Nuclear Regulatory Commission ("NRC") is considering relicensing of the Millsone Nuclear Power Station, Units 2 and 3 for additional 20-year terms. Without relicensing, Unit 2's operating license See NRCs 'Principles of Good Regulation, attached.

1 NUREG-1437, Supplement 22 A-376 July 2005

- - -, 'Appendix A would expire in the year 2015 and Unit 3's operating license would expire in the year 2025. ' -

MPS-82-2 Together with Unit .1, these reactors have had an operational history since 1970 which Is among the ugliest in the annals of the nuclear industry.2 Millstone's radioactive releases have beenlamong the highest of all nuclear reactors in the United States.3 Millstone's routine radiation releases were linked early-on with cancers and other diseases.4 Millstone's treatment of its workforce by way of exposing It to unnecessary radiation levels5 and Its treatment of nuclear whistleblowers'b'y ostracism and6 retaliatory firings have made it notorious within the nuclear industry. While full-time inspectors from the NRC were onsite, Millstone lost two highly radioactive spent fuel rods. These irradiated rods contain plutonium and other fission'elemrents which may be diverted to create dirty bombs. While Millstone's environmental monitoring program was beinig monitored by the NRC and Connecticut's Department of Environmental Protection ('DEP"),

Millstone's personnel brazenly falsified environmental monitoring reports to the NRC and DEP and sabotaged the sample-taking activities.7 MPS-82-3 Connecticut's regulatory apparatus has failed to'safeguard the public.

Millstone's five-year National Pollution Discharge Elimination System'

("NPDES") permit expired on December 14, 1997- eight years ago - and it has not been renewed. Nevertheless, DEP has permitted Millstone to -

operate under the 1992 permit in brazen violation of the letter and spirit of the federal Clean Water Act. Former DEP Commissioner Arthur J. Rocque,'

MPS-82-4 2 For this reason, each of the environmental issues required foriconsideration In the Environmental Impact Statement process should be considered to be a Category 2 issue, subject to site-specific consideration. - .

3 See Millstone & Me: Sex. Lies and Radiation in Southeastern Connecticut by Michael Steinberg (Black Rain Press 1998).

4 See Testimony of Ernest J. Stemglass, Ph.D., presented to a Congressional Committee Investigating nuclear power issues.

5 See. e.g., www.mothballmillstone.ora. experience of Charles D. Douton. Jr.

8 See. James Plumb v. Northeast Nuclear Energy Companv (Superior Court, Judicial District of New London); Clarence 0. Reynolds v. Department of Public Utility Control (Superior Court, Judicial District of New Britain); John DelCore v. Northeast Nuclear Energy Co, U.S. District Court. District of Connecticut.

7 See 'Owner of Connecticut Nuclear Plant Accepts a Record Fine' (The New York Times September 28, 1999), attached.

July 2005 ' A-377 -.- NUREG-1437, Supplement 22

MPS-82-3 Jr., routinely authorized 'emergency authorizations" ("EAs') while recognizing his lack of legal authority to do so.8 These EAs - of indefinite duration permitting releases of toxic and carcinogenic substances without enforceable limits - permit Millstone's owners and operators to do, inter alla, what Northeast Utilities pleaded guilty to doing wilfully and illegally when it pleaded guilty in the U.S. District Court in September 1999 to committing environmental felonies at Millstone and paying a $10 million fine. Clearly, the Clean Water Act prohibits major waivers of NPDES permit conditions without notice to the public and a meaningful opportunity for public input. Commissioner Rocque issued sequential EAs without notice to the public and he did not provide an opportunity for public comment. To our knowledge, Rocque's successor, DEP Commissioner Gina McCarthy, has done nothing to bring the Millstone operations into compliance with the law.

She has permitted the status quo to reign. Connecticut Attorney General Richard S. Blumenthal is complicit in the illegal Millstone activities. Mr.

Blumenthal successfully suppressed the truth of Millstone's illegal operations in litigation brought to require Millstone operations to comply with existing laws.

Regardless of whether Millstone has been technically out of compliance with the law during much or all of its 35-year operational life, its operations have systematically endangered the public health and safety.

Millstone operations are a clear and present danger to the public health, safety and welfare.

MPS-82-5 Although Millst6ne's reactors have been operating since 1970, and thus have generated a 35-year history of operations and record of environmental impact, the NRC selected only a three-yearperiod (2001, 2002 and 2003) to review to assess Millstone radiological emissions for purposes of its SEIS evaluation. Necessarily, the NRC staffs superficial MPS-82-3 6 The Coalition attaches hereto the 'Emergency Authorization' issued on October 13, 2000 which legalizes' violations of the expired NPDES permit and which ex-Commissioner Rocque 'transferred' to Dominion when it was a paper company without assets. Prior to issuing EAs for Millstone operations, Commissioner Rocque admitted in writing he lacked authority to issue emergency authorizations on an emergency basis for unlimited durations. The EA attached hereto has been in effect on an emergency basis since 2000 premised on a "finding- that it was required to avert an imminent threat to health or safety.The SEIS makes no reference to this EA.

4 NUREG-1437, Supplement 22 A-378 July 2005

Appendix A MPS-82-5 and selective review deprived it of the opportunity to engage in a meaningful assessment of the environmental impacts of Millstone's complete operating history to inform the evaluation necessary to evaluate' the full scope of future effects during a potential period of license extension.

MPS-82-6 At the same time, the NRC staff virtually ignored the information available to it even in the limited area it selected for review: the years 2001-2003." -

The most glaring example we may provideyou 'of this appears as the preliminary comment we provided to you on,' together with theddeclaration of Ernest J. Sternglass, Ph.D.10 Dr. Sternglass evalu'ated Dominion Nuclear Connecticut, Inc.'s reports of strontium-90 levels sampled in goat milk five miles from Millstone'during 2001, 2002 and 2003.-Although one sample measurement reported by Northeast Utilities in 2001 'was at a level nearly twice the highest level of measured strntium-90 concentration in Connecticut milk-during the height of the atmospheric nuclear weapons testing in the 1960s, -this fact is not reported in the SEIS nor is'it analyzed, nor are the'other high'strontium-90 measurements in goat milk sampled, five miles downwind from Millstone analyzed. 1 - ' '

MPS-82-7 We perceive a determined lack of dedication by the NRC staff to genuinely'understand the full scope of environmental - Including human health - impacts of continued operations of Millstone. Documents which we provided to the NRC have apparently been destroyed.' 2 -Comments made in relicensing proceedings attended by the SEIS staff and documents submitted in such proceedings were ignored or disregarded by the SEIS staff.' - .

9 Webster's Dictionary defines misfeasance as 'the performance of a lawful action in an illegal or improper manner.: - -.

10 Refer to the Coalition's March 2. 2005 submission and attachments thereto.:

A Webster's Dictionary defines malfeasance as 'wrongful conduct, especially by a public official."

1 See Response of Richard L. Emch, Jr. to the Coalition's February 5. 2005 queries, Paragraph 7 (attached): Documents responsive to this request were presented to the NRC by the Coalition as attachments to the Affidavit of Cynthia M. Besade dated -

August 5,2005. - , - -

See Transcript of January 11, 2005 public informational meeting sponsored by the NRC's SEIS staff at the Waterford CT Town Hall.

S.

July 2005 A-379 .' NUREG-1 437, Supplement 22'

Appendix A MPS-82-7 We continue to be troubled by the fact that documents produced by the SEIS staff in response to our queries about the SEIS submitted to the SEIS staff on January 23, 2005 were withheld by the NRC's own Freedom of Information staff and have yet to be released. 1 4 MPS-82-8 Similarly, we are astonished that the NRC staff most involved with the SEIS declined our invitation to attend the press conference we gave on the Niantic Bay shoreline 1.5 miles from Millstone on March 10, 2005. At our press conference, we introduced Zachary M. Hartley, a 7-year-old boy born with a rare cancer in his jawbone.15 During critical months of her pregnancy, Zachary's mother swam regularly and.unknowingly in the nuclear 'mixing zone"16 which is known locally as the Hole-in-the-Wall Beach. We invited the entire NRC to attend the press conference and address questions to our expert, Dr. Helen Caldicott, world-renowned pediatrician, co-founder of Physicians for Social Responsibility and a leading authority on the health effects of low-level Ionizing radiation such as is routinely emitted by Millstone. Zachary's medical records were available for NRC review. Not a single representative of the NRC appeared, not even one of the resident inspectors assigned to Millstone. Dr. Caldicott linked young Zachary's rare jawbone cancer to Millstone's radiological and toxic chemical emissions as being the likely causative agent. Dr. Caldicott acknowledged that, while there cannot be a 100-per-cent certainty that Millstone caused Zachary's medical condition, cesium-137 which Northeast Utilities found in a fish in the same nuclear 'mixing zone" in 1997 - the year of Zachary's mother's pregnancy - and which contamination it admitted was discharged by Millstone, Is known to be associated with cancer, including cancer of the bone. We are transcribing Dr. Caldicott's comments and will provide the NRC with a copy as soon as the transcription is available.

In light of the facts which have come light regarding Zachary M. Hartley, the Coalition has requested that the Connecticut General Assembly's Public Health and Environment Committees convene a special public 14 The Coalition will address this issue In a subsequent filing.

'5 Press clippings from the Hartford Courant, Norwich Bulletin and The New London Day are attached.

16 See SEIS at 4.1.3.

6 NUREG-1437, Supplement 22 A-380 July 2005

Appendix A 7

hearing to consider our request to close the Niantic shoreline beaches.'

We understand that the legislature may find it necessary, in order to - -

adequately protect the public health and safety, to'enact legislation to close Millstone forthwith. Governor M. Jodi Rell has referred our request to the Commissioner of Public Health; we are asking him to exercise his authority to close the Niantic beaches as a health hazard. We further anticipate that the Connecticut DEP will orderthat Millstone convert from Its once-through cooling system to a closed cooling system, thereby virtually eliminating the discharge of radioactive and toxic chemical contaminants to the Niantic and MPS-82-9 Waterford shorelines. The SEIS does not address the prospect that '

Millstone will undergo a major refurbishment in the conversion from the once-through to a closed cooling system. This is a major omission in the SEIS. :

We recognize that the events in question in Zachary's life arose in 1997, prior to Dominion's takeover of Millstone in 2001. However, Zachary's sickness is a factor which must be considered in the operational history of Millstone. Under Dominion ownership, Millstone has continued to release the same radioactive and toxic chemical waste byproducts as NU before.

MPS-82-10 Indeed. Dominion is currently seeking permission from CTDEP to-add new chemicals to the "mixing zone' and continue the routine discharge of others. Nowhere in the SEIS is it stated that the NRC staff reviewed Dominion's application for renewal of the NPDES permit. Nowhere are these'facts assessed in 'the SEIS. - .

MPS-82-11 'The SEIS fails tomheaningfully consider the routine environmental impacts of Millstone's radiological releases, relying on'the 'conclusion" in the NRC's GenericErnvironmental Impact Staterment that all the nation's"'

nuclear power plants release radiation within levels-pernitted under the NRC's regulations and therefore may be expected to continue to do so in the future. These conclusions do not apply to Millstone. See discussion at infra. '- -

Even NRC's Generic Environmental Impact Statem'ent (AGEIST) states that cesium-137 -for one - may be expected to bloaccumulate such that its buildup in the environment will increase by 35 per cent during-17 See Coalition letter to Connecticut General Assembly Public Health and Environment Committees dated March 4. 2005, attached.

7 X ,.

July 2005 A-381 NUREG-1 437, Supplement 22

Appendix A the postulated renewal period at each of the nation's nuclear power plants undergoing relicensing.1 8 GEIS section 4.6.1.1 states in part as follows:

To determine whether the added period of operation following license renewal would, by virtue of buildup, result In significant (double) added dose, the ratios of buildup factors for midlives of 30 to midlives of 20 years were evaluated. These ratios amount to a 35 per cent increase for Cesium-137 and a 6 per cent increase for cobalt-60.

In certain cases, the bioaccumulation factors may require reexamination. These principally involve fish (in the human food chain) that are bottom feeders. Bottom feeders may ingest worms and other blota that may remobilize radioactive materials accumulated in the sediments.

Accumulation of radioactive materials in the environment is of concern not only to license renewal but also to operation under present licenses.

(Emphasis added.)

MPS-82-12 This reference is entirely omitted from consideration in the SEIS. The SEIS omits any analysis of the predicted buildup of cesium-1 37 or cobalt-60 or any other radionuclides in the environment surrounding Millstone. To the extent that cesium-137 released to the environment will have enhanced effects, the NRC's staff's failure to assess the impact to the health and safety of the community - including Niantic Bay beachgoers who may be pregnant - borders on reckless endangerment.

It is known that cobalt-60 released by Millstone bioaccumulates in the sediment of Jordan Cove and is therefore subject to being ingested by worms and thereby enter the food chain.'9 Yet, the SEIS fails to re-examine' this phenomenon - and the potential for bloaccumulation of other radionuclides in the environment surrounding Millstone - consistent with GEIS section 4.6.1.1.

's GElS 4.6.1.1.

19 See [citation to follow]

NUREG-1437, Supplement 22 A-382 July 2005

Appendix A MPS-82-13 ; Nor does the SEIS examine the quality of environmental stewardship exercised by Dominion in its other corporate activities.

We suggest you review the October 2003 report by Public Citizen, "Dominion Resources, Inc.; A Public Citizen Corporate Profile." 20 Public Citizen reports that "MIen April 2003,-Dominlon's VEPCO agreed to a $1.2 billion enforcement settlement with the US Department of Justice and the US Environmental Protection Agency for violations of the Clean Air Act." -- '

(Emphasis added.)

The report further states that Dominion's VEPCO failed to install pollution control equipment at its coal-fired Mount Storm Power Plant in West Virginia after it made significant modifications that increased power-generating capacity. This was a violation of the Clean Air Act and, "according to the EPA, resulted in the release of 'massive amounts' of sulfur dioxide, nitrogen oxide, and particulate matter."

Dominion's Dominion Energy, owner of the Brayton Point Power Station in Massachusetts, releases 240 pounds of toxic rriercu'ry annually from that:

facility- enough to poison 120 million pounds of fish part of the Dominion network of companies, according to the Providence (RI) Joumal of March 11, 2005.21 Eating mercury Infish and shellfish presents a danger to ' -

children and pregnant mothers by harming developing nervous systems.

Dominion Energy has been served with a notice of Intent to sue by the Conservation Law Foundation, according to the newspaper report.'

According to the SEIS, four states and all or parts of 15 counties fall within the 50-mile radius of Millstone (eight In Connecticut, four in Rhode Island, two in Massachusetts and one in New York). An estimated '

2,868,207 people live within this area. This equates to'a population density of 219 persons/square kilometer or 567 persons per siquare mile. In the GEIS matrix of rank of sparseness (Category 4) and proximity (Category 4) result in the conclusion that Millstone is located in a high-population area.

MPS-82-14 Moreover, the population within a 10-mile'radius of Millstone increases seasonally as a result of an influx of approximately '10,500 summer 2 A copy of the report is attached. - -. - -

22 See 'Conservation Group Sues Brayton Point' (Providence'Journal, March 11, 2005).

attached.

July0015_ ., A-383- NUREG-1437, Supplement 22

Appendix A MPS-82-14 residents. The SEIS contains no figures of the seasonal influx of visitors to the eastern end of Long Island although it is within the 50-mile radius of Millstone.

MPS-82-15 In conclusion, it is clear that the adverse environmental impacts of license renewal are so great that preserving the option of license renewal for energy planning decislonmakers would be beyond "unreasonable" - license renewal for Millstone is a license to kill.

This conclusion is unassailable when the full scope of available information about Millstone's environmental impacts is properly considered.

Detailed Comments GEIS Is Inapplicable to the Millstone EIS MPS-82-16 The Millstone Draft Environmental Impact Statement analysis largely avoids the primary issue presented by the prospect of relicensing Millstone Units 2 and 3 for additional 20-year terms: the effects of routine releases of radiological and toxic chemical releases to human health and the environment surrounding the nuclear facility.

The troubled nuclear industry knew that if the truth about the radiological impacts of nuclear power plant operations could be addressed in relicensing proceedings, no community in American would accept the prospect to hosting a nuclear power plant beyond its initial 40-year licensing term. The GEIS is a fiction contrived by the nuclear industry and adopted by the NRC to deny the public an opportunity to challenge relicensing of nuclear power plants based on radiological impacts to human health and the environment.

MPS-82-17 The NRC's Generic Environmental Impact Statement ('GEIS") was published in the year 1996, or nine (9) years prior to the NRC's invitation for public comment on the SEIS, at a time when Unit 2 had operated for 26 years, Unit I for 21 and Unit 3 for 10 years. Necessarily, when the GEIS refers to 'current levels of radiation, it is referring to radiation levels which were 'current' in 1996 or earlier. The GEIS is not itself current, but is I0 NUREG-1437, Supplement 22 A-384 July 2005

Appendix A MPS-82-17 outdated and fails to account for the past nine (9) years of operations within the U.S. nuclear industry. C. ! --

The GEIS itself is obsolete. Although the NRC staff states in the SEIS it was not required to consider site-specific aspects of Millstone's routine radiological emissions because Millstone site-specific routine radiological emissions were considered in the GEIS at Appendix E, GEIS Appendix E is limited to 'routine' radiological emissions during the years 1985-1987. No explanation Is given why a report published by the NRC in 1996 relies on 10-year-old data, when its purpose is to project radiation levels five decades into the future. At best, GEIS's radiological analysis of "routine" Millstone radiological emissions is incomplete an'd'superficial.

More significantly, the GEIS fails to account for any of the following facts and circumstances - routine and extraordinary which have occurred at Millstone since 1996, including the following: ' .

MPS-82-18 1. The NRC placed the entire Millstone Nuclear Power Station on its

'Watch Listr and ordered an unprecedented three-reactor two-year

.shutdown in 1996 because of national media exposure of wilful, systemic disregard for safety standards and licensing requirements; Unit I never restarted, Unit 3 restarted in 1996 and Unit 3 restarted in

.1999; :-:-Mt -; t.*.

MPS-82-19 2. In 1996, after-workers in the site maintenance department at Millstone were diagnosed with brain cancers and Northeast Utilities dismissed the entire department - after securing releases the

--;-workers would not sue Northeast Utilities if the company paid them double severence pay - and hired transient contract workers to perform hot and dirty tasks within the plant, two of the workers died untimely deaths due to their brain cancers. - , '

3.- On December.16,1997, Zachary M. Hartley was born with a rare jawbone cancer which required major life-threatening surgery. His mother swam regularly in the nuclear/chemical mixing zone" otherwise known as the Hole-in-the-Wall Beach on the Niantic Bay shoreline during critical months of her pregnancy with Zachary.

4. In 1997, Northeast Utilities caught a fish contaminated with cesium-137, a deadly carcinogen, it admitted releasing into Niantic Bay, in the nuclear/chemical _mixing zone" which stretches from the Millstone:

., . .1- * *

-: .. ii . ;  ; - , , -- s ,.t s 7 July 2005' A-385' NUREG-1437, Supplement 22

Appendix A MPS-82-19 discharge point to the Niantic Bay shoreline, a popular summer destination for families with young children.

5. On or before 1997, Millstone dispensed with its measurement of strontium-90 In quarterly composited air particulate filters, relying instead on infrequent sampling of goat milk in the community to determine whether its strontium-90 emissions reached harmful levels after-the-fact.

MPS-82-20 6. In September 1999, Northeast Utilities, predecessor to Dominion, pleaded guilty to committing environmental felonies including falsifying environmental monitoring records and releasing hydrazine, a carcinogen, illegally into the Long Island Sound. 2 i MPS-82-21 7. A Connecticut Superior Court judge enjoined the restart of Millstone Unit 2 in 1999 because he was persuaded that the health and stability of the indigenous Niantic winter flounder stocks were endangered by operations of the Millstone intake structures through entrainment and impingement. Fish Unlimited v.! Northeast Utilities.

8. In 2000, two commercial fishermen sued Northeast Utilities for tortiously causing the collapse of the formerly commercially viable Niantic winter flounder fishing stocks; their suit remains pending.

MPS-82-22 9. In 2000, Northeast Utilities acknowledged that - even under daily supervision by onsite inspectors of the NRC - it had lost two highly radioactive spent fuel rods from the Unit I spent fuel pool'.

10. In 2000, the Connecticut Department of Public Utility Control

('DPUC") oversaw a 'public auction" by' Northeast Utilities to sell the Millstone Nuclear Power Station; the public was excluded from the

'public auction"; virtually all key 'public auction" documents were redacted and ordered sealed by the DPUC; over public protest, and despite the Coalition's disclosure that Dominion had the worst safety record in the nuclear industry including the deaths of seven nuclear workers at its nuclear facilities in Virginia, the DPUC approved the sale of Millstone to Dominion Nuclear Connecticut, Inc., ('DNC") at the time a paper entity with no assets with only a post office box in Niantic, Connecticut: when the Connecticut Coalition Against Millstone obtained a Superior Court hearing date for a judge to consider its challenge to the rigged sale and the prospective transfer of expired environmental permits to DNC, lawyers for Northeast Utilities and DNC met ex parte with Superior Court Chief 22 See 'Owner of Connecticut Nuclear Plant Accepts a Record Fine' (New York Times September 28, 1999). attached.

1n NUREG-1437, Supplement 22 A-386 July 2005

Appendix A Administrative Judge John J. Langenbach and obtained an order suspending the hearing so the sale could proceed without court review, when the matter was brought to the Connecticut Supreme Court,-Justice Christine Vertefeuille, ben'eficiary of a Northeast Utilities 401K plan, recused herself; Connecticut Attorney General Richard S. Blumenthal, although entitled to automatic' party status in the DPUCproceedings, declined participation. So occurred the

'public auction' of Connecticut's worst polluter.' -

MPS-82 1.' In April 2001, Connecticut's Commissioner of Environmental Protection, Arthur J. Rocque, Jr.. "transferred"an expired NPDES (National Pollution' Discharge Elimination System) permit '(it had expired four years earlier) and "emergency authorizations" (which he admitted in writing he lacked legal authority to issue) to "Dominion Nuclear Connecticut,'Inc.," at that time a paper company with a post office box in Niantic but no assets. Dominion has'been operating

'under the authority of the expired permit for fouryears and DEP has not renewed the permit in the intervening time.'

MPS-82-24 12." 'In 2001, Dominion reported concentration levels of strontium-90 contamination In goat milk-sampled within five (5) miles downwind of the Millstone Nuclear Power Station nearly twice as high as the highest recording measurement of strontium-90 concentrations in Connecticut milk during the height of the .1960s atmospheric nuclear weapons testing.

MPS-82-25 13. in 2001, terrorists who had targeted nuclear power plants--

hijacked a passenger jet and flew over the Indian Point Nuclear Power Plant 29 miles of New York City before slamming into the World Trade Center. The U.S. Department of Homeland Security, subsequently created, designated the Millstone Nuclear Power Plant

- a terrorist's target of choice. -

14. In 2004, Connecticut State Senator Melodie Peters, Chairman of the powerful Energy and Technology Committee, took a paying job with Dominion In public relations to advocate for Millstone relicensing, l without giving up her legislative commitments.-. -

MPS-82-26 11. On August 16, 2003, Joseph H. Besade became the seventh known pipefitter to die prematurely from workplace exposures at Millstone.

MPS-82-27 15. , - On August 5, 2004, Cynthia M. Besade reported to the NRC in an affidavit her personal knowledge of some 67 cancers in persons known directly or indirectly to her, all living within or close to the five-mile radius'surrounding Millstone, including childhood cancers and 13 July 2005 - A-387 NUREG-1437, Supplement 22

Appendix A MPS-82-27 the case of a 17-year-old Waterford high school student diagnosed with ovarian cancer, from one street alone - Seabreeze Drive, north-northeast and less than two miles downwind of Millstone - seven (7) cases of cancer were reported.

MPS-82-28 16. On August 5, 2004, Richard Heaton drove seven (7) hours from the University of Pennsylvania Medical Center to New London to participate in a press conference and proceeding before the NRC to share the facts of his daughter's rare thyroid cancer which developed following her exposure to Millstone effluents at age 10.

MPS-82-29 17. In 2004, Dominion rejected the U.S. Department of Homeland Security's offer of a free security enhancement to protect the three Millstone Intake structures from terrorist attack.2 3 MPS-82-30 18. In February 2005, the Coalition discovered that Zachary M.

Hartley's rare jawbone cancer, believed caused by his mother's in utero exposure to Millstone radiological and chemical effluents in the nuclear/chemical 'mixing zone" in 1997, was knowingly excluded from listing in the State of Connecticut's Tumor Registry because part of the orange-size cancerous tumor removed from Zachary's mouth in life-saving surgery was determined to be benign.

MPS-82-31 19. On March 10, 2005, Dr. Helen Caldicott, world-renowned pediatrician, authority on the health effects of low-level ionizing radiation and co-founder of Physicians for Social Responsibility, declared the likelihood that 7-year-old Zachary M. Hartley's rare jawbone cancer was caused by his mother's exposure to Millstone's radiological and chemical effluents.

MPS-82-32 Moreover, Millstone is unique in the annals of the U.S. nuclear industry:

Millstone has released the highest levels of radionuclides of any nuclear power station in the country at various times over the past 35 years of its operational history.

From 1970 to 1987, Millstone had released a total reported release of 32 curies of radioactive iodine and particulates into the air, which included the highly carcinogenic strontium-90 and iodine-1 31, together with 6.7 million curies of total fission and activation gases such as xenon and krypton. During the same period, Millstone released 581 curies or 581 trillion picoCuries of radiation in the highest liquid volume of such releases 23 See Millstone Owner Turned Down Free Homeland Security Device' (The New London Day. March 9, 2005) 14 NUREG-1437, Supplement 22 A-388 July 2005

Appendix A MPS-82-32 of mixed fission and activation products of any nuclear~plant in the United States.2 1 .

In a single year, 1975, Millstone released a record reported high of 9.99 curies of iodine and particulates into the'air and 199 curies of liquid mixed fission and activation products into the Long Islahd Sound, also a record for all U.S. reactors.2 5 Id.

MPS-82-33 While the strontium-90 concentration In milk declined for the United States as a whole between 1970 and 1975, from 8 pCiA to 3 pCiA, it rose, from 9.8 in'1970 to a high of 15.8 in 1973 and 14.8 in ,1974 near Millstone, remaining at 10.7 by 1975. This is far in excess of the U.S. average of 3 pCiA, ruling out any significant contribution to the local milk from bomb test fallout by France and China that continued until 1980.26 The calculated yearly radiation dose to bone of a child due to excess strontium-90 within 10 to 15 miles of Millstone, in excess of the yearly dose for the United States, rose from 33 millirem per year in the first full year of operation to 204 millirem per year by 1974, nearly three times the normal background level of 70 millirems per year in Connecticut.2 -

These doses of strontium-90 alone may be compared with the 15 -

millirem per year to any organ permitted under current NRC regulations, the 2 millirem produced to bone marrow in a typical X-ray of a child, and the 80 millirem per year to a developing fetus found to produce a doubling of the rate of childhood leukemia In the studies'of the renowned Dr. Alice Stewart. 28 MPS-82=34 Given all these facts and circumstances, the application of a 'Generic Environmental Impact Statement' to Millstone, thereby precluding site-24 See Declaration of Emest J. Sternglass. Ph.D., In the Matter of Dominion Nuclear Connecticut. Inc.: Docket No. 50-336-LR. 50-423-LR, ASLBP No. 04-824-01 -LR (August8,2004)_':

25Id.  : -. -- ' -. ,--- - . .. I ;

226

TId . - ' t -

28 IId.

July 2005, A-389 NUREG-1437, Supplement 22

Appendix A MPS-82-34 specific analysis in the Environmental Impact Statement, is so deeply flawed as to be fraudulent.

The Coalition and others have provided "new and significant" information which compels the NRC to conduct a site-specific analysis of the environmental impacts of relicensing Millstone Units 2 and 3. See discussion at pages 32 et seq. infra.

MPS-82-35 At the very least, the NRC should be required to evaluate the environmental impact of Millstone's radiological and chemical effluents -

singly, in synergy and cumulatively - under site-specific analysis to qualify under the standards of the National Environmental Policy Act.

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls In this section, the SEIS describes the liquid, gaseous and solid waste management systems presently in place to collect and treat the radioactive materials which are produced as a by-product of the nuclear plant operations.

The SEIS states as follows:

Radioactive material produced from fission of uranium-235 and neutron activation of metals in the reactor coolant system is the primary source of liquid, gaseous and solid waste. The radioactive fission products build up within the fuel. Most of these fission products are contained in the fuel pellets and sealed fuel rods, but small quantities escape from the fuel rods into the reactor coolant.

Neutron activation of trace concentrations of metals entrained in reactor coolant such as zirconium, iron and cobalt creates radioactive isotopes of these metals. Both fission and activation products in liquid and gaseous forms are continuously removed from reactor coolant and captured on several different types of filter media. Units 2 and 3 operate separate liquid and gaseous processing systems. Gaseous discharges for each unit are monitored separately before they are discharged to the stack or to other designated release points for each unit. All liquid discharges are directed to a canal which terminates in the old quarry and the quarry discharges to Long Island Sound.

16 NUREG-1437, Supplement 22 A-390 July 2005

Appendix A MPS-82-36 Despite these comrnments, it is clear that station monitoring of radioactive effluents is presently inadequate and incomplete and that some radionuclides are released into the environment without measurement or documentation.

For example, In 1997, Northeast Utilities reported in its Annual Radiological Environmental Operating Report as follows:

Section 4.5 'Air Particulate' Strontium (Table '5)

Table 5 in past years was used to report the measurement of Sr-89 and Sr-90 in quarterly composited air particulate filters. These,,

'measurements are not required by the Radiological Efflueni Monitoring Manual (REMM) and have'been discontinued.

Previous data has' shown the lack of detectable station activity in this

. media. This fact, and the fact that milk samples are a much more sensitive indicator of fission product existence in the environment, prompted the decision for discontinuation.-In the event of widespread plant related contamination or special events such as the Chernobyl incident, these measurements may be made."> ,

MPS-82-37 As Dr. Stemglass has pointed out, 29 in 2001, Dominion recorded concentrations of strontium-90 In goat milk sampled five miles from Millstone at a level nearly twice that of the highest recorded concentration of strontium-90 in milk in Connecticut during the peak of atmospheric atomic bomb testing in the 1960s. ,

MPS-82-38 In 1997 alone, there were numerous reported incidences of station radiation monitors being inoperable: - - i'T

- -:; ...*., ,,- - -;a.

j Nr..

Unit 1 Liquid Radwaste Effluent Monitor (inoperable 67/96 - 3125/97

-83 days in 1997, 291 days total) i -- -

Unit 1 Service Water Effluent Monitor (inoperable 6/9/96- 7/18/97 -

• -98 days in 1997, 404 days total) ---

29 See Coalition's March 2, 2005 filing to the NRC.

17 J 0 47, S July 2005 A-391' NUREG-1 437, Supple m .

menit 2.

22'

Appendix A MPS-82-38 Unit 2 Steam Generator Blowdown Monitor (inoperable 2/22/96 -

8/26/97 - 237 days in 1997, 551 days total)(NU claims no discharges were made during this period)

Unit 2 Clean Waste Monitor Tank Radiation Monitor (inoperable 5/25/97 - 7/1/97-37 days)(NU claims no discharges were made during this period)

Even the GEIS acknowledges that some airborne radioactive effluent releases are not monitored, recorded or documented.

Within the entire body of radioactive airborne effluents released by Millstone over the course of its 35-year operational life, the SEIS only specifically considers those reported by Dominion in 2002 as follows:

Unit 2: Total fission and activation gas activity released 128 Curies lodine-131 4.90 X 10-3 Curies Particulates 1.22 X 10 -5 Curies Tritium 31.2 Curies Unit 3: Total; fission and activation gas activity released 2.45 Curies lodine-131 1.52 X 10-6 Curies Particulates 6.08 X 10 -5 Curies Tritium 47.3 Curies MPS-82-39 These figures do not break down the radioisotopes released, other than for todine-131 and Tritium, and do not identify nor quantify which radioactive gases are emitted, such as xenon-137 (with a half-life of 3.9 minutes decaying to cesium-137 with a half-life of 30 years); xenon-135 (with a half-life of 9.17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> decaying to cesium-1 35 with a half-life of 3,000,000 years); nor krypton-89 (with a half-life of 3.2 minutes decaying to strontium-89 with a half-life of 52 days). These radioactive materials are long-lived and have cumulative impacts. The SEIS does not analyze these environmental impacts.

IX NUREG-1437, Supplement 22 A-392 July 2005

Appendix A The SEIS states: 'These releases from both units are typical of annual releases from Millstone and are not expected to increase during the renewal period.":

MPS-82-40 Since the SEIS analysis was self-limited to the years'2001, 2002 and 2003, and annual releases for the 32 other years Millstone has been operating were not considered, the statement that 'These releases from both units are typical of annual releases from Millstone' is not, -

substantiated. - - -

Moreover, the SEIS statement, that [these releases] are not expected to increase during the renewal period' is incorrect.-First, releases of tritium, a known cancer-causing radioactive toxic with a half-life of 12.3 years. are trending upward. Second, as Units 2 and 3 operate for longer periods at full capacity, airborne radioactive emissions will increase. Similarly, if during the renewal period Millstone Units 2 or 3 receive'approval for'power upgrades, airborrie radioactive emissions will increase'. The consequences -

of these reasonably foreseeable' circumstances were not analyzed in the SEIS.

MPS-82-41 Moreover, the SEIS does not identify nor quantify strontium-90 releases, nor note thie absence of strontium-90 monitoring from the station stack, while strontium-90 concentrations are regularly found to be Inordinately' high in goat milk taken from samples five miles from Millstone.

2.2.7 Radiological Impacts ' ' '

In section'2.2.7, Radiological Impacts,'on page 2-43, the section, concludes, "The applicant does not anticipate any significant changes to the radioactive effluent releases or exposures from Millstone operations during the renewal period and, therefore, the' irripa'cts to the environment are not expected to change." -

MPS-8242 However, in Dominion Nuclear Connecticut Millstone Station Annual Radiological Operating Report 2003, in section 4.14, Seawater, on page 4-9, it is stated, "since the restart of Unit 3 in 1998 and Unit 2 in 1999, tritium

'0See discussion at page 20 infra.

19 July 2005 A-393: J NUREG-1437, Supplement 22 '

Appendix A MPS-82-42 releases in liquid effluents have risen to levels at or above [emphasis added] those observed during pre-shutdown period."

Dominion records indicate that Millstone released 1854 curies of liquid radiation in 2000, an all time high. Such reported releases totaled 1273 curies in 2001, 1537 in 2002 and 1278 in 2003. NRC records for Millstone's liquid tritium releases totaled from 1970-1994 totaled 11,550 curies. The total from 1995-2003 was 8551 curies.

This trend of increasing amounts of tritium releases is dangerous because tritium has carcinogenic, mutagenic. teratogenic and transmutational properties whose effect upon the environment which have not been considered in the SEIS.31 The coastline around Millstone is lined with beaches and shoreline communities, with many summer residents as well. Human activities in the area include swimming, boating, fishing, clamming, scalloping. Thus there are ample opportunities for liquid tritium contamination of people and shore and marine life.

MPS-82-43 It is undeniable that the more the pressurized water reactors of Units 2 and 3 operate, the more tritium by-products they will create and release into the environment.

The current stated policy of both Dominion and the nuclear power industry in general is to operate power reactors as close to maximum capacity as possible. In 2003 Millstone 3 operated at almost 100%

capacity. Millstone 2 operated at 80% capacity, but only because it shut down for refueling.

The increasing amounts of tritium discharged into Long Island Sound means that Dominion's claim that it "does not anticipate any significant changes to radioactive releases or exposures from Millstone operations during the renewal period" is false. Therefore the NRC's conclusion that

'impacts to the environment are not expected to change" is also false.

3' See The Carcinogen, Mutagenic, Teratogenic and Transmutational Effects of Tritium," Citizens Awareness Network, April 1994.

20 NUREG-1437, Supplement 22 A-394 July 2005

Appendix A MPS-82-44 Given this history, the NRC should mandate the immediate installation of filters to mitigate liquid tritium discharges from Millstone units 2 and 3.

In addition, the NRC should mandate-the testing of drinking water, well water and groundwater and in 'marine life in'areas'affected by Millstone for the presence of tritium. At present only sea water is tested for tritium.

Until these measures have been put into place and monitoring results have been made public until Millstone's current operating licenses expire, or units 2 and 3 permanently shut down','the NRC should not consider granting license extensions for Millstone units 2 and 3, in consideration of the health and safety-of the public.

4.1 Cooling System -

MPS-82-45 The GEIS identifies the issue of scouring caused by discharged cooling water as a Category 1 issue. As a 'Category 1" issue, the NRC staff will not review it on a Millstone site-specific basis in the absence of 'new and significant information."

The SEIS states the NRC staff "has not identified any significant new information during its independent review of the Dominion ER, the staff's site visit, the scoping process, its review of monitoring programs, or its evaluation of other available information."--

MPS-82-45 Yet, scouring caused by discharged cooling water was identified by a technician in the Millstone Environmental Laboratory as an irreversible environmental impact during a recent public presentation on Dominion's environmental Impacts presented at the Three Rivers Community College.

Accordingly, the NRC staff should request Dominion to release details to -

it of this 'new and significant information."' *-' --

4.1.1 Entrainment of Fish and Shellfish'in Early Life Stages, Entrainment of winter flounder larvae at the Millstone intakes is a major issue and it is one which has been 'the subject of much-litigation in the Connecticut courts. Lawsuits' have been brought by local fishermen 21-July 605 ": A-395' ' NUREG-1437, Supplement 22

Appendix A complaining that Millstone intake structures have driven the indigenous Niantic winter flounder population to near-extinction. The fishermen have successfully resisted dilatory and repetitive motions on the part of Dominion and Northeast Utilities to dismiss their claims.

The SEIS states:

"The staff independently reviewed the Millstone Units 2 and 3 ER

[Environmental Report], visited the site, and reviewed the applicant's NPDES permit. The staff also reviewed relevant scientific articles and agency documents (CTDEP) and NOAA (National Oceanic and Atmospheric Administration) Fisheries (also known as National Marine Fisheries Service [NMFS]. interviewed agency staff, and interviewed a faculty member at the University of Connecticut who has conducted research on entrainment at Millstone." [Crivello 20031 MPS-82-46 Astonishingly, the NRC staff does not report any attempt to consult with the fishermen who are targeted in the SEIS for the demise of the Niantic winter flounder population. Had the NRC staff attempted to locate commercial fishermen who fish for Niantic winter flounder near Millstone, it would have learned that the resource has vanished and, with it, the fishermen and a way of life.

Nor, apparently, did the NRC staff make any effort to consult with the experts who have testified in court proceedings to the overwhelming evidence that the suction action of the Millstone intake structures is the predominant cause of the collapse of the Niantic winter flounder population and has been since 1986, when Millstone Unit 3 went online.

Northeast Utilities obtained operating licenses for Millstone in the 1970s based on projections - possibly knowingly bogus - that the Millstone intake structures would have a far less devastating effect on the Niantic winter flounder larvae than has in fact occurred.

MPS-82.47 Although NRC staff spoke with Prof. Crivello of the University of Connecticut, who has studied Millstone entrainment, the staff does not explicitly identify Prof. Crivello as a paid consultant to Millstone's owners and operators each time his name appears in the SEIS.

NUREG-1437, Supplement 22 A-396 July 2005

Appendix A MPS-82-48 Why did the NRC staff not meet with DEP's Victor Crecco, author of reports debunking'Dominion's theorizing about the Millstone impacts on the Niantic winter flounder collapse?

MPS-82-49 The SEIS analysis of the collapse of the indigenous fishing stocks does not mention the discovery of a fish caught in Niantic.Bay in 1997 contaminated with cesiurn-137- nor Northeast Utilities' acknowledgment that the cesium-I 37 originated in its nuclear operations.32 The SEIS analysis does not mention the build-up of cobalt-60 in Jordan Cove near the Millstone discharge point33 nor does .the SEIS analyze the contribution of cobalt-60 buildup in sediment as a contributing factor in the collapse of the population of the bottom-feeding Niantic winter flounder.

MPS-82-50 Attributing the collapse of the fishing stocks to elevated water temperatures, the SEIS fails to consider the contribution-of Millstone's 24-hour-a-day,' seven-day-a-week thermal discharges t6 the Long Island Sound.

MPS-82-51 While the SEIS reports that Ache CTDEP [Division of Marine Fisheries which has been analyzing this issue for nearly a decade] believes that Millstone is having a significant impact due to entrainment of winter flounder larvae," the SEIS relies on NOAA and NMFS reports - which contain no data of the unique conditions at Niantic Bay but are devoted to a broad, regional analysis of fishing stocks - to discredit CTDEP Division of Marine Fisheries, as follows: -

Regulatory agencies concerned with the management of winter -

flounder have concluded that the resource Is overfished and overexploited (NOAA 1998; NMFS 2003) and have instituted measures to reduce fishing pressure throughout Long Island Sound and the southern New England-middle-Atlantic region. Thus, there is ample evidence to suggest that fishing pressure is directly

-contributing to the decline both local and regional levels'at and 32 See Northeast Utilities 1997 Annual Radiological Environmental Operating Report at Section 4.17.2 ("Cs-1 37 was detected In one sample from the Niantic Bay (location 35).

Positive indications are seldom seen in this media outside of the immediate discharge vicinity.')

3 See [citation to follow] - --

July 2005 A-397- NUREG-1437, Supple ment 22

Appendix A MPS-82-51 may represent the major impact to this resource. The extent to which Dominion contributes to or exacerbates the problem in the Niantic River system is not elucidated by fish population studies reviewed in this SEIS." [Emphasis added.]

As stated, the SEIS does not identify either a NOAA or NFSS study specific to the Niantic River winter flounder nor the recent fishing habits of commercial fishermen in the area; thus, its failure to accord credit to the CTDEP for its insights appears to be result-driven, to obscure and downplay the fact that the Millstone Nuclear Power State has been the primary factor in driving indigenous fishing stocks to collapse. Or, as Rhode Island expert on Niantic winter flounder. Mark Gibson - a witness whose testimony aided Connecticut Superior Court Judge Robert Hale in issuing a temporary restraining order keeping Millstone Unit 2 shut down during the 1999 spawning season to avoid harmful entrainment effects to the fish population - has stated, Millstone is the worst predator of fish in the Northeast.

The SEIS concludes:

The staffs evaluation of past impacts of entrainment on Niantic River winter flounder is inconclusive because unresolved questions remain about population dynamics, life history, and unknown factors that may be impacting the population. The available data do not allow us to unequivocally link or decouple population declines with Millstone operations ... Because the spawning adult population is very low, and in consideration of the 20-year license renewal period, the staffs conclusion is that the impacts would be moderate.

MPS-82-52 The Coalition has reference to Figure 2-6 ('Comparison of Winter Flounder Population Trends in Niantic River and Long Island Sound". 3 4 This figure illustrates clearly that while the winter flounder fishing stocks in the region are rebounding - perhaps due in part to fishing restrictions that apply throughout the region - the Niantic River winter flounder population continues its collapse.

34 Draft NUREG-1437. Supplement 22. 2-26 (December 2004) 24 NUREG-1437, Supplement 22 A-398 July 2005

Appendix A MPS-82-52 The facts available to the NRC staff demonstrate that the sole factor which has prevented the Niantic River winter flounder population from enjoying a rebound as has the species elsewhere'in the region due to tightened fishing restrictions is the most obvious one: the Millstone Nuclear Power Station.-'

It is submitted that if the SEIS staff had pondered the ramifications of Figure 2-6in'consultation with the Niantic fishermen 'who have gone out of business and the fishermen's expert witnesses and CTDEP's marine biologist Victor Crecco, in light of all the facts and circumstances, the NRC staff would have been compelled to categorize the impact to Niantic winter flounder from continued operations of Millstone in a license renewal period to be 'major" and devastating and probably irreversible. -

The weight of credible evidence is that the operations of the Millstone Nuclear Power Station have driven the winter flounder to virtual extinction, a phenomenon not contemplated in the original Millstone environmental impact statement. Future entrainment during the license renewal period will definitely assure that the once-abundant, commercially important resource will never return.

4.1.2.1 Impingement Monitoring 4.1.2.2. Impingement Mortality At the request of Northeast Utilities, CT DEP permitted routine impingement monitoring for Unit 2 to cease In December 1987. Unit 2 did not have a fish return and all impinged marine organisms were presumed lost. Routine impingement monitoring has never been conducted for Unit 3.

MPS-82-53 The most recent data for Unit 2 involves sampling collected biweekly from July 2000 to June 2001. It is questionable whether the Unit 2 fish return was In operation during such period.3 5 Data for Unit 3 involve samplings collected biweekly from January to December 1993.

These samplings do not suffice in frequency to form a data base to support conclusions about impingement during the 35-year operations of Millstone, nor to provide an adequate basis for extrapolation to the future.

35 Report of a commercial lobsterman to the Coalition.

25 July 2005 A-399 NUREG-1437, Supplement 22

Appendix A MPS-82-53 Thus, the SEIS statement:

Based on the assessment to date, the staff expects that the measures in place at Millstone Units 2 and 3 (i.e., aquatic organism return systems) provide mitigation for impacts related to impingement, and no new mitigation measures are warranted.

is not supported by genuine evidence.

4.1.3 Heat Shock MPS-82-54 The SEIS states:

Millstone has remained in compliance with the NPDES thermal and discharge volume limits at the quarry cut [SEIS at page 4-28]

Yet, the SEIS report is absent any indicia of an independent basis from which to render such a conclusion.

The SEIS states:

The [NRC] staff also independently reviewed monitoring reports for the cooling-water discharge mixing zone... .the boundary of the mixing zone cannot exceed a radius of 2438 m (8000 ft) from discharge outlet at the quarry cut.

The SEIS report does not identify a single monitoring report by date or otherwise; any conclusions regarding the cooling-water discharge mixing zone are utterly unsubstantiated.

4.3 Radiological Impacts of Normal Operations' The NRC SEIS staff review of Millstone data on the most critical issue of

.radiological impacts of normal operations' was self-limited to the years 2001, 2002 and 2003.

26 NUREG-1437, Supplement 22 A-400 July 2005

Appendix A MPS-82-55 The NRC GEIS staff review of Millstone data on the most critical issue of "radiological impacts of normal operations" was self-limited to the years 1985, 1986 and 1987.36 - '

Thus, in its consideration of whether the Millstone Nuclear Power Station should be permitted to operate in the years 2015-2025 (Unit 2) and 2025-2045 (Unit 3), the NRC deliberately failed to consider the 'radiological impacts of normal operations for the years 1970-1984,"1988-2000 and 2004 to the present.,

Put another way, the NRC considered Millstone's 'radiological impacts of normal operations" for only 6 of the 35 years the Millstone nuclear reactors have been routinely releasing harmful radiation into the environment - just 17 per cent of Millstone's operational history. Twenty-nine (29) years of Millstone's routine releases of harmful radiation releases to the environment are not evaluated in either the GEIS or the SEIS.

By limiting the pool of data considered in the GEIS and the SEIS to a period of time which encompasses only 17 per cent of Millstone's, operational history of harmful radiation releases to the environment, the NRC failed to consider all available information. The NRC's evaluation of future impacts based on past impacts rests of an inadequate data base and its conclusions are accordingly unreliable, if not invalid. Certainly, the NRC staffs consideration of 4cumulative" impacts (SEIS section 4.8.3) is scientifically unsound if not indeed scientifically fraudulent, since the NRC staff did not review, tabulate or assess the full scope of past Impacts to be able to !accumulate" cumulate impacts.. -

On its website, www.nrc.govlwho-we-are/values.html, the NRC states that it 'adheres" to 'Principles of Good Regulation' which include the following: .. -

Independence:.. . Final decisions must be based on objective, unbiased assessments of all information, and must be documented with reasons explicitly stated."

36 See GEISS Appendix E.19 27 July 2005' A-401 NUREG-1437, Supplement 22

Appendix A The SEIS and GEIS systematically exclude all available information concerning Millstone's radiological effluents for the years 1970-1985, 1988-2000 and 2004 to the present. No reason for such exclusion is explicitly stated.

The GEIS addresses radiological impacts of 'normal' operations of nuclear power plants during a projected renewal period as follows:

Radiation exposures to public (license renewal term):

GEIS: 'Radiation doses to the public will continue at current levels associated with normal operations." (GEIS 4.6.2)

Occupational radiation exposures (license renewal term):

GEIS: 'Projected maximum occupational doses during the license renewal term are within the range of doses experienced during normal operations and normal maintenance outages, and would be well below regulatory limits.

The GEIS categorizes the issue of 'radiological impacts of normal operations' as a Category I issue, meaning that the SEIS reviewing staff need not consider site-specific issues at all in the absence of "new and significant information."

MPS-82-56 The Coalition believes that 'radiological impacts of normal operations' must be considered on a site-specific basis with regard to Millstone Units 2 and 3 as a Category 2 issue. See discussion at page 32 et seq. infra.

Because the SEIS did not consider the issue as a Category 2 issue. the SEIS is deeply flawed and inadequate and falls far short of meeting the NRC's Principles of Good Regulation."

MPS-82-57 Finally, as stated, the SEIS states that the NRC staff is not required to evaluate Millstone radiation releases on a site-specific basis because Millstone releases were subjected to site-specific analysis in the GEIS which found them to be 'well within regulatory limits." This statement is most misleading in that it fails to acknowledge that the NRC GEIS staff limited itself to reviewing Millstone's reported radiological emissions for the 2K NUREG-1437, Supplement 22 A-402 July 2005

Appendix A MPS-82-57 years 1985, 1986 and 1987 only.37 Millstone's largest 9 reactor, the 1,220-megaWatt Unit 3- was still under construction in 1 85.-By the year 1987, it had not established an operational record; it has since substantially  :

increased output and, hence, 'routine' radiological emissions.

GEIS Section 4.6 ("Radiological Impacts of Normal Operation")'"

provides in pertinent part as follows: ,: .

-  ; _f. . .- af This section provides an'evaluation of the radiological impacts on

'occupational personnel and members of the public'during normal operation following license renewal. This evaluation extends to all 118 nuclear'powier reactors. Radiation exposures occurring after

-license renewal are projected based on present levels of exposures.

' Estimates of additional maintenance,' testing and Inspections as'a result of a variety of age-related changes in operational procedures were made based on the anticipated changes to current operation

- and are detailed in' Section 2.6 ard Appendix B Added maintenance, testing, and inspection will be'accompanied by increased exposure time to members of the work force but are not expected to significantly Influence dose to members of the public.

As noted,3 8 the GEIS was published in 1996. Hence the above statement, Radiation exposures occurring after license renewal are projected based on present levels of exposures," must be read with regard to 1996-or-earlier levels of exposure, rather than actual *current" exposures. However,'the NRC SEIS staff limited Its review to 2001-2003 data, rather than actual current" exposures. As also noted, the NRC GElS staff only reviewed Millstone's 1985-1 987 exposure data.

With regard to the above statement: -

Estimates of additional maintenance, testing and inspections as a result of a variety of age-related changes in operatiorial procedures were made based on the anticipated changes too current operation and are detailed in Section 2.6 and Appendix B.-

3 See GEIS, Table E19. - ; " - -

38 See discussion at page 10 supra. -  : - i i 2')

July 2005 . A-403 NUREG-1 437, Supplement 22:

Appendix A MPS-82-58 the SEIS fails to identify or evaluate any 'additional maintenance, testing and inspections as a result of a variety of age-related changes in operational procedures" at Millstone.

With regard to the above statement:

Added maintenance, testing, and inspection will be accompanied by increased exposure time to members of the work force but are not expected to significantly influence dose to members of the public the SEIS fails to identify or evaluate any "added maintenance, testing, and inspection 'at Millstone and hence fails to evaluate increased exposure time to members of the work force and members of the public during the proposed renewal period.

MPS-82-59 The SEIS also fails to consider the environmental Impact of Dominion's August 24, 2004 submittal to the NRC requesting approval of the 'Nuclear Facility Quality Assurance Program Description." According to an Request for Additional Information ('RAI'), dated February 24, 2005, this program deletes from the Millstone Quality Assurance program radiological protection responsibilities which include maintaining records and reports on radioactive contamination levels." If this application is approved, a safeguard to protect against excessive worker radiological contamination will be lost and there will be no basis for the NRC to conclude now that occupational radiation exposures during the license renewal term will be small and within regulatory limits.

MPS-82-60 The NRC SEIS staff accepted at face value Dominion's self-assessment that it would not conduct 'major refurbishment in the future. Thus, the NRC SEIS staff considered neither 'major' or minor" refurbishments. The NRC SEIS staff's conclusions about the radiological impacts during refurbishment are therefore necessarily flawed. Given the strong likelihood that major refurbishment In the form of a stationwide conversion from once-through cooling to closed cooling systems will be ordered by the Connecticut DEP - to avoid future exposure of pregnant women and others to harmful radioactive and toxic waste effluents in the 'mixing zone' and to avoid irreversible impacts to the indigenous Niantic winter flounder - the radiological impacts from such refurbishment should have been fully explored and analyzed in the SEIS.

p0 NUREG-1437, Supplement 22 A-404 July 2005 I

Appendix A The NRC's GEIS further states at section 4.6.1.1:

To determine whether the added period of operation following license renewal would, by virtue of buildup, result in significant (double) added dose, the ratios of buildup factors for midlives of 30 to midlives of 20 years were evaluated. These ratios amount to a 35 per cent

' increase for Cesium-137 and a 6 per cent increase for cobalt-60.

This added Increase due to buildup will not significantly change the total dose to members of the public.

In certain cases, the bioaccumulation factors rmay require reexarmination. These'prinicipally involve fish (in the human food chain) that are bottom feeders. Bottom feeders may ingest worms and other biota that may remobilize radioactive materials accumulated in the sediments. .,

Accumulation of radioactive materials in the environment is of concern not only to license renewal but also to operation under present licenses. ' - ,i-MPS-82-61 ' As stated, 39 the bioaccumulation of cobalt-60 in sediment in Jordan Cove near the Millstone discharge point has been established. The SEIS does not address this phenomenon, even though required by theGElS.

Millstone's monitoring of the aquatic environmentfIn the area of the discharge has also revealed the presence of the following plant-related radionuclides: cobalt-60, zinc-65, silver-I 10 and cesium-1 37.*,

In 1997 and at other times, "['Wndications of plant releases were

-observed in aquatic flora, including detectable levels of cobalt-60, zinc and silver-I 10. According to the 1997 Radiological Environmental report filed by Northeast Utilities, -,, i, . - -

The detection of these fradio]nuclides throughout the year, as witnessed by positives detected in other aquatic media, correspond to radioactive liquid discharges from the three Millstone units. Sampling 39 See discussion at page 8 supra. a ,- , - -

40 See 1997 Annual Radiological Environmental Monitoring Program Report.

31 July 2005 A-405 ' NUREG-1437, Supplement 22

Appendix A MPS-82-61 of this media provides useful information because it is very sensitive to plant discharges. However, since seaweed is not consumed, other media are utilized in the determination of dose consequences (e.g.,

see Shellfish and Fish results)

The presence of cesium-1 37 in a fish caught in the mixing zone" within the Niantic Bay - as identified as a plant-related contamination in the 1997 Millstone effluent report - suggests widespread bioaccumulation of that carcinogenic radioisotope within the environment, requiring a 're-examination pursuant to GEIS standards.

The radiological impacts of normal operations" should be analyzed as a site-specific Category 2 issue.

4.4 Socioeconomic Impacts of Plant Operations During the License Renewal Period MPS-82-62 The SEIS considers the economic contribution to the community through payment of Dominion's workforce; however, the SEIS does not separate out the economic investment made in maintaining a workforce to monitor Unit 1, a nuclear power plant undergoing decommissioning, and its repository of spent nuclear fuel. Nor does the SEIS consider the prospect of a continuing workforce required to maintain Units 2 and 3 in the event each or both units is/are decommissioned or prematurely shut down before or during the renewal period.

MPS-82-63 The SEIS does not consider the enormous health care costs associated with the community's long-term exposure to low-level ionizing radiation, nor worker illnesses related to their exposures. We are aware of a recent surgery, upon a patient whose cancer is fairly linked to Millstone radiological and toxic chemical emissions, which cost In excess of $2.5 million. This does not include follow-up or lifelong care.

The SEIS is incomplete and inaccurate in its assessment of socioeconomic impacts.

4.4.6 Environmental Justice NUREG-1437, Supplement 22 A-406 July 2005 I

Appendix A MPS-82-64 The SEIS does not address the environmental justice issues involved in the transportation and storage of nuclear waste generate-by the Millstone Nuclear Power Station, either during its 35 years of operations or in the future. Transportation through poor urban areas and storage -of Millstone's nuclear waste in poor rural communities both implicat6 enivironmental justice concerns; neither aspect was addressed In the SEIS.

4.7 Evaluation of Potential New and Significant Information on Impacts of Operations During the Renewal Term The Connecticut Coalition Against Millstone and others have provided the SEIS staff with *new and significant information" which, once considered, dictates'site-specific review as Category 2 issues or, in the alternative, rejection of the SEIS in toto.

The 'new and significant' information may be summarized as follows:

Millstone causes cancer and Millstone is responsible for an increased cancer incidence in the surrounding community.

The SEIS states that "commentators have provided 'no evidence to support a causal relationship between increased cancer incidence and Millstone operations."

The NRC's SEIS staff concluded that the information provided during the scoping process was not new and significant with respect to the findings of the GEIS on the health effects to the public from radiological effluent releases due to the Millstone operations."s; MPS-82-65 To the contrary: the Coalition and others have presented overwhelming and unrebutted evidence of a causal relationship between' increased cancer incidence and Millstone operations.

33 July 2005 -'- A-407 NUREG-1437, Supplement 22

Appendix A While these facts are "significant," they are not "new."

Since practically the onset of Millstone nuclear operations, Millstone's radiological emissions have been linked to heightened cancer incidences."

This is hardly surprising.

Since the onset of its operations, Millstone's owners and operators have submitted reports to the NRC and the DEP detailing their radiological 4 2 and chemical43 effluent emissions to the air and water.

Millstone routinely releases to the air and water the following radioactive materials:

Ag Be-7 Ce-144 Co-57 Co-58 Co-60 Cr-51 Cs-1 34 Cs-1 37 Fe-55 Fe-59 1-131 1-133 Kr-85 Kr-88 La-140 Mn-54 Mo-99 Na-24 Nb-95 Nb-97 "See footnote 4 supra.

'2 See the list of radionuclides listed at pages 34-35.

43 See the list of chemical effluent emissions listed at pages 36-40.

34 NUREG-1437, Supplement 22 A-408 July 2005 I

Appendix A Ru-1 05 Sb-122 Sb-124 -

Sb-125 Sn-113 Sr-89 I Sr-90  ;

Sr-92 TC-99M-'

TC-101

`TC-104 Tritium ' * -4.. - -

Xe-1 33 Xe-1 35 Zn-69M Zr-95 Zr-9744 This list is not exhaustive.  :  ;*"'- - -

MPS-82-66 All radionuclides released by Millstone cause cancer.

According to the U.S. Environmental Protection Agency, Radioactive materials that decay spontaneously produce ionizing radiation. Any living tissue in the human body can be damaged by Ionizing radiation. Cancer is considered by most people the primary health effect from radiation exposure.

Simply put, cancer is the uncontrolled growth'of cells.

Ordinarily, natural processes control the rate at which cells grow and replace themselves. They also control the body's processes for repairing and replacing damages tissue. Damage occurring at the cellular or molecular level can disrupt the control -

processes, permitting the uncontrolled growth of cells - cancer.

This is why ionizing radiation's ability to break chemical bonds

" Fission and Activation Products - Millstone Unit 2 Liquid Effluents - Batch Sampling -

1997 as reported in 1997 Radiological Environmental Monitoring Program. - -- -

4' See selected bibliography prepared by Nuclear Information Resource Service.

attached. .. -

35 July 2005 A-409 NUREG-1437, Supplement 22

Appendix A MPS-82-66 in atoms and molecules makes it such a potent carcinogen....

There is no firm basis for setting a "safe" level of exposure above background for stochastic effects [those resulting from long-term, low-level exposure to radiation].... Other than cancer, the most prominent long-term health effects [from radiation exposure] are teratogenic [those that result from the exposure of fetuses or unborn children to radiation] and genetic

[those that can be passed from parent to child] mutations.46 According to the U.S. Nuclear Regulatory Commission, genetic effects and the development of cancer are the primary health concerns attributed to radiation exposure.' 7 MPS-82-67 Many chemicals discharged by Millstone are known carcinogens, such as hydrazine, hexavalent chromium, cadmium, lead and benzene and many others.

Millstone routinely discharges into the nuclear/chemical "mixing zone" which extends 8,000 feet toward the Niantic and Waterford shorelines, the following chemicals and others:43 Chemicals & Metals "Known or Suspected Present" in Discharge

[156 compounds listedl Aluminum Antimony Ammonia Ammonium Hydroxide Arsenic Barium Beryllium Boric Acid Boron 46 U.S. Environmental Protection Agency website. 'Understanding Radiation: Health Effects' (3116(05) 4 U.S. Nuclear Regulatory Commission website, 'Fact Sheet: Biological Effects of Radiation. (3/26105)

'5 Millstone 1997 Radiological Environmental Monitoring Program Report and documents filed with Connecticut DEP.

36 NUREG-1437, Supplement 22 A-41 0 July 2005

Appendix A Bromide Bulab 6002 Cadmium Carbohydrazide Chlorine Chromium Cobalt Conquor 3585 (methoxypropylamine and diethylhydroxylamine)

Copper Cyanide Dietylhydroxylamine Epichlorohydrin Ethanolomine Fluoride Freon Hexavalent Chromium Hydrazine -i .

Hydrogen Peroxide Iron Methoxypropylamine Molybdate Molybdenum Nalcolyte Nickel Nitrogen Oil & Grease Phosphorus Selenium . . - -

Silver Styrene Sulfate Sulfide Sulfite Surfactants Thallium - ,. - -

Ti n Titanium .

Tolyltriazole Xylene 37.

July 2005 A-411 - NUREG-1437. Supplement 22

Appendix A Zinc Zirconium Volatiles Acrolein Acrylonitrile Benzene Bromoform Carbon Tetrachloride Chlorobenzene Chlorodibromomethane Chloroethane 2-Chloroethylvinyl Ether Chloroform Dichlorobromomethane 1, 1-Dichloroethane 1, 2-Dichloroethane 1, 1-Dichloroethylene 1, 2-Dichloropropane 1, 3-Dichloropropylene Ethylbenzene Methylbromide Methylchloride Methylene Chloride 1, 1, 2, 2, -Tetrachloroethane Tetrachloroethylene Toluene 1, 2-Trans-Dichloroethylene 1, 1, 1-Trichloroethane 1, 1, 2-Trichloroethane Trichloroethylene Vinyl Chloride GCUMS Fraction Acid ComDounds 2-Chlorophenol 2, 4-Dichlorophenol 2, 4-Dimethylphenol 4, 6-Dinitro-O-Cresol 2, 4-Dinitrophenol NUREG-1437, Supplement 22 A-412 July 2005

Appendix A 2-Nitrophenol 4-Nitrophenol P-Chloro-M-Cresol Pentachlorophenol Phenol 2, 4, 6-Trichlorophenol Base Neutral Compounds Acenaothylene Benzidine Benzo(a)anthracene Benzo(a)pyrene Benzo(ghi)perylene Benzo(k)fluoranthene Bis(2-Chloroethyl) Ether Bis(2-Ethylhexyl)phthalate Chrysene Dibenzo(ah)anthracene 1,2-Dichlorobenzene 1.3-Dichlorobenzene 1.4-Dichlorobenzene 3.3-Dichlorobenzidines Diethyl phthalate Dimethyl phthalate Di-n-butyl phthalate 2,4-Dinitrotoulene 1,2-Diphenylhydrazine Fluoranthene Fluorene Hexachlorobenzene Hexachlorocyclopentadiene Hexachloroethane Indenoll ,2,3-ed)pyrene Isophorone; Nurobenzene V N-Nitrosodimethylamine N-Nitrosodiphenylamine Phenanthrene . --. 4 . - - - I -

i . ... . . ,,

Pyrene - -:, , , 17: -; : ", , , z ,

39 July 2005 A-ii'3 - NUREG-1437, Supplement 22

Appendix A Pesticides Aldrin Chlordane DDT DOE Dieldrin Endosulfan(alpha)

Endosulfan (beta)

Endosulfan Sulfae Endrin Endrin Aldehyde Heptachlor Heotachlor epoxide Arochlor 1016(PCB)

Arochlor 1232(PCB)

Arochlor 1242(PCB)

Arochlor 1248 (PCB)

Arochlor 1254 (PCB)

Arochlor 1260 (PCB)

Toxaphene Other Substances Ammonia Benzo(b)fluoranthene Chlorine Hexachlorocyclohexane (Alpha)

Hexachlorocyclohexane (Beta)

Hexachlorocyclohexane (Gamma) 2,3,7,8-TCDD MPS_82-68 The interaction of radionuclides and chemicals has been established to create a synergy, multiplying the harmful effects of each.49 49 See Memorandum of Ernest J. Stemglass. Ph.D. dated March 8. 2005 ('Synergistic Interaction of radiation. Air Pollution and Chemicals') and references therein (copy 40 NUREG-1437, Supplement 22 A-41 4 July 2005

Appendix'A MPS-82-69 Millstone discharges these radionuclides and chemicals - and more - into the air and into the nuclear/chemical "mixing zone" known as Niantic Bay, Pleasure Beach and Jordan Cove, defined as an area within 8,000 feet of the Millstone discharge point.

Some of the radionuclides, such as ceslumr-137, have' been' found In fish swimminrg in Niantic Bay.5 0 Some of the radionuclides, such as cobalt-60, have been found in the sediment of Jordan Cove where they enter the food chain when they are ingested by worms.6 1 Some of the radionuclides and toxic chemicals very likely entered Zachary M. Hartley's mother while she was swimming in the,'.,:

nuclearlchemical"mixing zone" popularly. knwn as Hole-in-the-Wall Beach during critical months of her pregnancy with Zichary, according to an expert on the health effects of low-level ionizing radiation, Dr. Helen Caldicott. 52 Four pathways are possible:

breathing, swallowing, skin contact and eating a radioactive fish.

Zachary was b6rn with a rare cancer In his Jawbone requiring lifesaving surgery.

In SEIS section 4.7, beginning on page 4-53, the NRC states, "During scoping, some commentators suggested that operation of Millstone resulted in excess cancers in populations around the plant site," and "other support of these positions at the May 2004 public meeting or thereafter commentators suggested there is no relationship between cancer incidence and nuclear power plants."-.  ;,

MPS-82-70 Millstone's cumulative dose to the environment and humans, based on annual Millstone reports filed with the NRC since 1970, totals over 6.5 curies. As reported in the response to section 2.2.7, releases of tritium into attached). And see Health Effects of selected Industrial Chernicals and Radionuclides' (STAND Technical Report 2003-2) at page 5 (copy attached).

See 1997 Annual Radiological Environmental Operating Report at page 4-5.

sI See [citation to follow] *,

• 2 See footnote 14 supra.

41 July 2005 A-415 NUREG-1437, Supplement 22

Appendix A MPS-82-70 Long Island Sound since Millstone's restart in 1998 are at all time highs in its operating history.

Current annual plant reports indicate that Millstone Units 2 and 3, as in the years since 1970, have been releasing radionuclides such as strontium-90, cesium-137, iodine-131, -133 and -135, cobalt -58 and -60, krypton-85, xenon-131, -133 and -135. and other such radioactive chemicals, all known to be carcinogenic.

The NRC's denial of a causal relationship between Millstone's 35 years of radioactive releases and elevated cancer rates in nearby towns, and in.

New London County as a whole, does not hold up to scrutiny.

The most glaring example of the NRC's denial in the- Millstone SEIS is its complete omission of consideration of the August 17, 2004'declaration of Dr. Ernest J. Sternglass. The Millstone SEIS lists, on' page C-9, Dr.'

Stemglass' declaration as received on August 17, 2004. This is the only mention of it in the SEIS.

Consequently, the declaration was omitted from the NRC's evaluation of potential new and significant information in section 4.7.

In his declaration, Dr. Sternglass presents his credentials as an expert in the field of radiation and human health. He has written and published numerous studies in this field in peer reviewed scientificJojurnals and testified to Congress and other government agencies on this subject.

The NRC knows full well who Dr. Stemglass is. He first brought up the problem of radioactive releases in relation to increasing cancer rates around nuclear plants, and in towns near Millstone in particular, to the public eye in the 1970s. He has conducted and published studies informing the public of this continuing problem ever since.-

In his declaration, Dr. Sternglass methodically outlines the "causal relationship between abnormally high doses of strontium-90 in milk produced near Millstone and the pattern of cancer changes at various distances from the Millstone plant.

MPS-82-71 Dr. Sternglass also states in his declaration, "It is my professional opinion that the radioactive releases from the Millstone Nuclear Power 42 NUREG-1437, Supplement 22 A-416 July 2005,

Appendix A MPS-82-71 Station since its startup have caused and will continue to cause

[emphasis added] excess infant mortality, low birthweight, leukemia and cancer as well as increased rates of both chronic and infectious diseases in the towns around Millstone as well as in New London County and Connecticut as a whole."

For the NRC to exclude Dr. Stemglass' declaration from section 47 is'a glaring major error in that in and of itself invalidates the NRC's conclusion that "information provided during the scoping process was not new and significant with respect to the findings of the GEIS on the health effects to the public from radiological effluent releases due to the Millstone operations."

This statement rather is indicative of the NRC's determination to support the nuclear industry's-and in this case Dominion's-rush to relicense old unsafe nuclear plants, to the detriment of the public'sihealth and safety.

This bias is repeated in statements and omission throughout section 4.7, as the following will demonstrate.

MPS-82-72 For example, in dealing with the Connecticut Tumor Registry's report.,

Cancer Incidence in Connecticut Counties 1995-99," the NRC does report that New London County "had the highest incidence rate of all invasive tumors for females," but omits that this rate was second highest for males, as was reported at the May 2004 public meeting. .;

Furthermore, the NRC characterizes information in the report indicating that New London County had the highest rate for 12,specific kinds of cancers as "several forms," a choice of words that seeks to minimize a major health crisis.

The NRC also fails to mention information from the report, which was testified to at the May 2004 public meeting, that New London County had the second highest rate for six more kinds of cancer, third highest for five additional ones, and fourth highest for seven more, totally 30 out of 39 kinds of cancers in which New London County was counted separately.

All of the above reveals a deliberate and systematic attempt to exclude the most important "new and significant" information about Millstone -

radioactive releases and its effects on human health;.,

'-  :  : i.

43 July 2005 A-417- NUREG-1437, Supplement 22

Appendix A MPS-82-73 Similarly, in dealing with a 2003 study by Joseph Mangano et at, presented at the May 2004 public meeting, "Elevated Childhood Cancer Incidence Proximate to U.S. Nuclear Power Plants," the SEIS selectively focuses on information from the study that indicates there may not be a causal relationship between Millstone's radioactive releases and health problems. So the NRC states the study "reported no significant difference in childhood cancer mortality rates between counties surrounding the nuclear plants and the U.S. population.'

This would be fine and fair if the agency did not also exclude the major finding of the study, which is that "cancer incidence for children less than 10 years of age, who live within 30 miles of each of 14 plants [one of which is Millstonel in the eastern U.S. (49 counties with a population of more than 16 million) exceeds the national average. The excess 12.4% suggests that 1 in 9 cancers among children who reside near nuclear reactors is linked to radioactive emissions."

Once again, this omission is deliberate and systematic, serving the nuclear industry's interests to the detriment of the public's health and safety.

MPS-82-74 The NRC also failed to mention numerous other studies listed in the bibliography of study that have linked radioactive releases from nuclear facilities to elevated cancers.

MPS-82-75 Another example of this exclusion of new and significant information is the NRC's treatment of the 1990 National Cancer Institute study of cancer in counties near nuclear power plants.

That study found that the risk for leukemia in children under 10 in New London County was over 3 times higher than for same aged children in "control counties" used for comparison. The NRC focused'on NRC information that sought to downplay of that finding.

MPS-82-76 However, the NRC excluded other NCI information cited by Joseph Mangano in his report, also presented and testified to at the May 2004 public meeting, entitled "2500 Excess Cancer Cases in New London -

County Since 1970; Radioactive Emissions From Millstone May Be Cause."

In that report Mangano stated, "in Millstone's first 14 years, leukemia cases 44 NUREG-1437, Supplement 22 A-418 July 2005 I

Appendix A MPS-82-76 for New London County children under 10 were 55% higher than the state, and leukemia deaths 45% higher. All scientists agree that children are most sensitive to low-level radiation's effects." -

Once again, the NRC's failure to give equal weight to critical evidence invalidates its analysis and makes its conclusions false, as well as disqualifying Itself as a Just arbiter. - -

Another example Is its treatment of another Connecticut Tumor Registry report, which examines cancer incidence in Connecticut towns 1995-99, rather than by county. -

First of all, this report was not brought in by the public during the scoping process. The NRC decided to do so on its own as part of its response to information presented at the May 2004'public meeting and thereafter. Why? The NRC reported on the results of the study for only one town,'Waterford, site of Millstone. The NRC reported "The town of Waterford does not have the highest ratio of observed cancers to expected cancers for any form of cancer analyzed."

MPS 82-77 As the NRC well knows, there is no barrier to prevent Millstone radioactive emissions from traveling beyond the boundaries of the town of Waterford. A more comprehensive such analysis would have Included other towns near Millstone. But the NRC didn't do that, once again excluding critical information.

However, investigative journalist and author Michael Steinberg of Niantic, CT, did perform such'an analysis, including the town's of Waterford, East Lyme, Old Lyme, New London and Groton together. Steinberg's analysis, included herein, found higher than expected incidence of cancer in these towns together for: all female cancers, lung crancer for females, colorectal cancers for females, prostate cancer for males, breast cancer-for.

females, melanoma for both males and females, and cervical cancer for females.. 3 These findings are consistent with findings presented from the Connecticut Tumor Registry's study of Connecticut Counties 1995-99, as

, See Cancer Incidences in Connecticut Towns 1995-1999.".as compiled by Michael Steinberg, attached.. -,*

45 July 2005 A-419 NUREG-1437, Supplement 22 '

Appendix A MPS-82-77 well as Information presented in Mangano's 1998 study "2500 Excess Cancer Cases...", Stemglass' declaration, and a new study by Mangano presented at the January 11, 2005 meeting.

MPS-82-78 Finally, the NRC reports in section 4.7 that a 2000 study by the Connecticut Academy of Science and Engineering (CASE) found that 'The town of Waterford was not in the highest ratio category for any cancer except thyroid cancer, and at least three other town had higher ratios for thyroid cancer. At least 30 town had higher ratios for pediatric leukemia (ages 0 to 14) than Waterford."

First of all, this analysis, as reported above, is defective by limiting it to Waterford. Secondly, the CASE study focused on the Connecticut Yankee Nuclear Plant, and Millstone is never mentioned in it. Therefore radioactive emissions from Millstone are not considered in its analysis. Furthermore, information for cancer is not reported statistically by town, other than in maps where towns are not identified specifically but are marked by varying shades of white to black.

Nevertheless, the maps do indicate elevated cancers in towns around Millstone for all the specific kinds of cancers studied: thyroid cancer is elevated not only in Waterford, but also in Groton, Old Lyme and Stonington. Multiple myeloma is elevated for Waterford. And acute adult leukemia is elevated for Groton and Ledyard, both downwind of Millstone.

However, while the CASE study uses information from the Connecticut Tumor Registry for 1976-95, i does not look for trends over those years (e.g. by comparing cancer rate increases or decreases over 5 year periods, as was done in studies by Sternglass and Mangano).

The CASE study was initiated in 1997. At that time, all three Millstone reactors had been shut down for two years because of gross mismanagement and harassment of whistleblowers. At that time Northeast Utilities owned and operated Millstone, and still owned the permanently shut down Connecticut Yankee Nuclear Plant. CASE reports that Northeast Utilities was one of its top financial supporters at that time, and its website still shows NU at the top of its list of financial supporters.54 54 We attach a study critical of the CASE report, entitled 'Epidemiological Evaluation of the CASE Report Entitled 'Study of Radiation Exposure from the Connecticut Yankee Nuclear Power Plant'(Suzanne Gutter and Edwin van Wijngarden)(February 21, 2001) 46 NUREG-1437, Supplement 22 A-420 July 2005

Appendix A Thus NU in effect was a major funder of the CASEstudy, which means CASE had a major conflict of interest, 'one that put pressure on it to come up with results that would please the hand that feeds it.

MPS-82-79 All the above'points to the failure of the NRC to conduct alfair and unbiased analysis of the critical information given as-public testimony at the May 2004 pubic meeting in Waterford, Connecticut, and in documents presented there and thereafter to the NRC.

As a result the NRC's conclusion that there Is'not new and significant information is fatally flawed. The agency excluded and downplayed the critical Information that was presented, information that establishes a strong and clear relationship between Millstone's 35 years of radioactive emissions and the concurrent rise of cancers and other diseases in towns around Millstone and in New'London County; as well~as across Connecticut and into Rhode Island. C a wE s ao Conectcu MPS-82-80 While the Connecticut Tumor Registry is a source of much information about the heightened incidence of cancer and related diseases in'the area surrounding Millstone, it is not a completely reliable source of information.

Zachary M. Hartley is not the only victim of Millstone's radiological and toxic chemical releases. In any individual cancer case,'a'100 per cent positive correlation with a suspected causative agent cannot be made. That is why we rely on all available Information obtained formally such as the.

Connecticut Tumor Registry and epidemiological research - as well as informally,'through reports of victims themselves or their family members to' understand the scope of this public health emergency.

Although Zachary was bom in Connecticut with a life-threatening cancer in his jaw and although a tumor the size of an orange was removed from his face when he was 14 months of age, the Connecticut Tumor Registry-does not list Zachary's cancer. The Registry's explanation is that a portion of Zachary's tumor was benign and therefore it does not qualify for listing in the Connecticut Tumor Registry. - --

MPS-82-81 The NRC SEIS staff relies on a report of the National Cancer Institute (NCI 1990), which in turn relies on data of the Connecticut Tumor Registry.

47 July 2005 A-421 NUREG-1 437, Supplement 22 -

Appendix A MPS-82-81 According to the Connecticut Tumor Registry website, it obtains its funding from the National Cancer Institute.55 The NCI report is fifteen (15) years old. The NCI report was released four (4) years after Millstone Unit 3 commenced generating nuclear energy and long before many cancers associated with its dangerous emissions might be detected. It does not reflect the extremely high concentrations of strontium-90, a carcinogen, found in goat milk sampled within five miles of Millstone in 2001. It does not report the case of Zachary M. Hartley. It does not report the case of Rachel Heaton. who developed a rare form of thyroid cancer years after swimming in the Niantic shoreline 'mixing zone' because she moved from the area.

Nor does it report the brain tumor of Charles D. Douton, Jr., one of three former Millstone site maintenance workers who developed brain tumors and were dismissed from their jobs at Millstone by Northeast Utilities, as identified by Cynthia M. Besade in her August 5, 2004 affidaviL The NCI report does not include any of the seven (7) cancer cases recently identified to the NRC SEIS staff among residents or former residents of a single road - Seabreeze Drive - in Waterford two miles downwind from Millstone. The Connecticut Coalition Against Millstone is actively investigating to determine to what extent the Connecticut Tumor Registry fails to maintain records of other Millstone victims.

The Connecticut Coalition Against Millstone is also actively investigating information it has received of rare cancers Including a fatal skin cancer confined to the feet of a woman who frequently waded for long periods in the nucleartchemical mixing zone" to the east of the Millstone discharge point - In the community surrounding Millstone. The information under review includes dozens of cases of early childhood death and disease.

MPS-82-82 The Coalition attaches a selected Bibliography compiled by the Nuclear Information Resource Service ("NIRS") linking nuclear power plant radiological emissions with cancers in their communities. For example, NIRS reports a 400 per cent Increase in leukemia incidence in the population living downwind from the Pilgrim (MA) Nuclear Power Plant during the first five years after nuclear fuel was known to have leaked excess radioactivity. A necessary review of Millstone records will reveal the occurrence of leaking fuel at Unit 2 after Dominion assumed ownership.

55 See www.dph.state.ct.usIOPPE/hptumor.htm 4J NUREG-1437, Supplement 22 A-422 July 2005 I

Appendix A MPS-82-83 The Coalition notes that the European Committee on Radiation Risk

("ECRR') has'reported that radiation dose models employed by the NRC and other governmental agencies are probably 100 to 1,000 times too high to be accurate.56 The NRC SEIS staff had to be reminded at the NRC's January 11, 2005 public meeting on the SEIS that the Coalition and others had previously submitted documentation to the NRC establishing a causative link between Millstone' radiological and toxic effluent emissions and the heightened cancer rates In the area surrounding Millstone.', - .- -

The NRC SEIS staff did not adhere to the NRC's Principles of Good Regulation, which require in part:

Independence: Nothing but the highest possible standards of ethical performance and professionalism should influence regulation.

However, independence does not imply isolation. All available facts and opinions must be sought openly from licensees and other interested members of the public;.The many and possibly conflicting

- public interests involved must be considered.-

The SEIS states that the NRC staff and Its contractors discussed Millstone's history of radiological effluent and environmental monitoring with officials from CTDEP's

-Division of Radiation. The reports cited above by CTDPH, CASE and the national Cancer Institute were-also discussed. CTDEP conducts

- own radiological environmental monitoring program around

-its Millstone. STDEP had also reviewed the reports by CTDPH, CASE and the National Cancer Institute. CTDEP concluded that Millstone's radiological effluent and environmental monitoring data were accurate. 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."

- . S- * . a, ,. @. .. _ .  :

5 See 'ECRR Report Challenges Entrenches Radiation Assumptions' (MIRS, February 21,2003) 49 July2005 A-423 NUREG-1 437, Supplement 22

Appendix A The Connecticut Coalition Against Millstone has sent correspondence to Dr. Edward C. Wilds, Director of the DEP Radiation Bureau, to determine what conversations occurred with the SEIS staff, whether the DEP staff agrees with the characterizations of its conduct and input in the SEIS.

Finally, the Coalition asked Dr. Wilds if he agreed with the SEIS statement that CTDEP concluded that Millstone's radiological effluent and environmental monitoring data were accurate.' and if so, to specify what radiological effluent and environmental monitoring data were referenced and, further, if so, how such statement could be reconciled with Northeast Utilities' plea of guilty in 1999 in the U.S. District Court to committing environmental felonies, including falsifying environmental monitoring records.

To date, Dr. Wilds has failed to respond to the Coalition's request.

4.8.3.Cumulative Radiological Impacts The GEIS did not perform a meaningful analysis of cumulative radiological impacts because its data base was limited to Millstone effluent discharges from 1985-1987.

The GEIS further states:

In addition, the radiological environmental monitoring program conducted by Dominion in the vicinity of Millstone measures radiation and radioactive material from all sources, including Millstone; therefore, the monitoring program measures cumulative radiological impacts.

The Health Physics Society defines cumulative dose as follows:

The total dose resulting from repeated exposures of ionizing radiation to the same portion of the body, or to the whole body, over a period of time.

MPS-82-84 Correspondingly, the SEIS failed to conduct the analysis required by virtue of GEIS 4.6.1.1, which provides:

co NUREG-1437, Supplement 22 A-424 July 2005

Appendix A MPS-82-84 To determine whether the added period of operation following license renewal would, by virtue of buildup, result in significant (double) added dose, the ratios of buildup factors for midlives of 30 to midlives of 20 years were evaluated. These ratios amount to a 35 per cent increase for Cesium-137 and a 6 per cent increase for cobalt-60.-

This added increase due to buildup will not significantly change the total dose to members of the public. -

In certain cases', the bioaccumulation factors may require reexamination. These principally involve fish (in the human food chain) that are bottom feeders. Botorn feeders may ingest worms and other bioia that may remobilize radioactive'materials accumulated in the sediments.

Accumulation of radioactive materials in the environment is of concern not only to license renewal but also to operation under present licenses.

Accordingly, the SEIS is substantially flawed on the issue of cumulative radiological impacts. - ;  ;

51 July 2005 A-425 NUREG-1437, Supplement 22

Appendix A Conclusion It has been demonstrated herein that the adverse environmental impacts of Millstone license renewal are so great that preserving the option of license renewal for energy planning decisionmakers would be unreasonable. The NRC should reach such a conclusion in its final Environmental Impact Statement.

In the alternative, the NRC should recognize that its staff has failed to consider the full scope of the environmental impacts of present or future Millstone operations, and similarly, the licensee has failed to fully apprise the NRC of all pertinent facts and circumstances sufficient to enable the NRC to undertake meaningful review; in the absence of such complete evaluation the NRC must deny relicensing.

CONNECTICUT COALITION AGAINST MILLSTONE Nancy Burton 147 Cross Highway Redding Ridge CT 06876 Tel. 203-938-3952 52 NUREG-1437, Supplement 22 A-426 July 2005

Appendix A Memo to: Nancy Burton, Esq.

From: E. J. Stemglass C Date: March 8, 2005 -  ;.

Subject:

Synergistic interaction of radiation, air pollutants and chemicals The synergistic or "super-additivc" action of radioactivity and chemicals or air pollutants has been discussed extensively in the scientific literature. A very comprehensive revicw of the subject wvas published in a monograph by Wriedt in the Department of Labor and Health of the City of Hamburg, Germany in 1989 (1). Particularly strong-syncrgistic - -

effects have been found for radiation exposure combined with such chemicals as lead, mercury, magnesium, sulfate and carbon-tetrachloride known or suspected to be emitted by the Millstone Nuclear Plant together with fission products and neutron'-activated radioactive elements - --

Also, an unexpected super-additive effect was discovered for the action of tranquilizers taken by a woman during pregnancy with radiation exposure in the cancer mortality of her children (2).'

The synergistic action of smoke particles and radioactive gases and particulates, such as exist in uranium mines and in heavily polluted urban areas near nuclear plants, was discussed in an article by Radford and Hunt as long ago as 1963 (3)

The increase in cancer rates due to the combination of small airborne particles such as cigarette smoke and iadioactive gases was studied by a series of authors beginning as early as 1938 (4)(5)(6). This explains the extremely high incidence of lung cancer in uranium miners who smoked.In the particular case of radioactive gases such as Radon and other radioactive gases such as Xenon and Krypton isotopes that are routinely emitted in large quantities by nuclear. plants. Thus, Cassarett pointed out in his introductory article in "Radionuclide Carcinogenesise in 1972 (7) that the lung is highly vulnerable to the potential cancer promoting action of localized damage resulting from infections and inflammatory conditions caused by other air pollutants."

Increased risk of infections is known to be produced by the fission product Strontium-90 emitted from nuclear plants due to its action on the cells of the immune system produced in the bone marrow, and so are inflamnatory conditions produced by'abnormal wvhite cells mutated by the beta particles emitted by Strontium-90 and other bone-seecing fission products such as Barium-140 Moreover, Yttnrium-90; the highly radioactive daughter product of Strontium-90, is known to seek out soft tissues like the lung, causing inflammation and cancer. This is strongly supported by the fact reported by the U.S.-

Department of Health and Human Services in the report "Health in the United States 1994 and 1996" that the age-adjusted respiratory cancer mortality of white U.S. females over 16 years of age began to rise only after 1960, increasing more than five-fold from 5 to 28 per hundred thousand by 1995, while the percent smoking actually declined from 35 to 23% (See enclosed graph).

, , . =.,;

: 7-:

July'2005- A-427 NUREG-1437, Supplement 22 -

Appendix A Not only cancer but also infant mortality, first linked to Strontium-90 releases in nuclear weapons testing (8). can be increased by the synergistic interaction with fine particulates in the urban atmosphere (9). Thus, the 2002 rise in infant mortality (10) which was the first increase since 1958 following the largest atmospheric tests in Nevada in 1957, wvas probably due to the combination of urban Diesel exhaust and nuclear fission product releases that increased in direct relation to the record rise in nuclear energy generated per reactor as capacity factors were pushed from 58 to over 90% (11) with decreased time for inspection, maintenance and repair of aging nuclear power plants.

Still another way in which the airborne releases from nuclear power plants produce unforeseen biological damage to humnans as well as to animals and plants arises from the interaction of the radioactive rare gases Krypton-85 and Xenon-133 that cannot be readily filtered out of the effluent with the nitrogen and oxygen molecules in clean air. This has been described in detail by Graeub (12), who reviewed the evidence that the radiation emitted by these gases ionizes the air just as ultraviolet radiation from the Sun does, resulting in the formation of toxic ozone and nitric oxides. The ozone in turn interacts with the chemicals emitted in automobile exhaust, producing smog that damages the lung, and contributes to the dying of the trees seen downwind from nuclear plants.

Furthermore, when the nitric oxides are brought down by precipitation, they act like fertilizer run-off that is carried by the rivers into the estuaries where they lead to blooming plankton that produce dead-zones depleted in oxygen where marine animals live, leading to declines in shrimp and other fisheries as recently seen especially in the Gulf of Mexico.

Thus, not only human life but marine life and the life of birds, land animals and plants is adversely affected not only by the direct effect of fission and neutron-activated radioactive chemicals released from nuclear plants, but also by the indirect effects involving clean air as well as chemical and particulate pollutants..

REFERENCES (1) H. Wriedt, Department of Labor, Health and Social Services, Hamburger Strasse

47. 2000 Hamburg 76, Germany, December 1989.

(2) L. AN.Kinnier-Wilson, G. W. Kneal and A. M. Stewart, Lancet I 1 .314-315 (1981)

(3) E. P. Radford and V. R. Hunt. Science 143, January 12,. 247-249. (1964)

(4) J. C. Mottram, Am. J. Cancer 32, 76 (1938)

(5) P. Shubik et al, Nature,171, 934 (l953)

(6) F. G. Bock and G. E. Moore J. Nat'l. Cancer Institute 22, 401 (1959)

NUREG-1437, Supplement 22 A-428 July 2005

Appendix A (7) G. W. Cassarctt, Radionuclide Carcinogenesis C. L. Sanders et al Editors, U. S.

Atomic Energy Commission, Office of Inf. Services CONF-720505, 15-24, June 1973 (8) E, J. Sternglass, Radiation Biology of the Fetal ahd Juvenile Mammal, Edited by

-- M. R. Sikow and D. D. Mahlum, U. S. Atomic Energy Commission, 693-717, December 1969.

(9) T. J. Woodruff, J. Grillo and K. C. Schoendorf, Environmental Health Perspectives 105, 608-612 (1997)

(10) Health United States 2004, Table 19, Center for Disease Control, Dep't of Health and Human Services. .

(I 1)Nuclear Regulatory Commission (NRC) Information Digest 2000 Edition, NUREG 1350, Vol. 12.

(1 2) R. Gracub, The Petkau Effect: Nuclear Radiation, People and Trees. Four 'Walls Eight WUindows, New York (1992).

Ernest J. Sternglass, Ph.D.

Professor Eineritus of~adiology University of Pittsburgh School of Medicine Home address:

4601 Fifth Ave. #824 Pittsburgh, PA 15213 July 200 J 2A-429 1UREG-1437, Suplement- 22

z AGE-ADJUSY11 RUESPIRNA'ORY CANCER MORTALITrY m WHITEl U.S. FE-MALES OVER 18 YEARS AND PERCENT ' CD c)__SMOKING a

= >

c',

PMCE?(SMOKING -

CD 30.0 -

30 SOUgCIs US. Dtrrnop JIm:nl KII!A11llUHNT1 SrfXl5 1994AMD IJU^NA SWtVICsiv AND 1996 0

0 0

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Appendix A 21 February2003. WVISFPMRS NudearMAonla. ,5239 ECRR REPORT CHALLENGES ENTRENCHED RADIATION.-;

ASSUMPTIONS A recently-released report claims that the radiation dose model of the International Commission on Radiological Protection (ICRP) Is Inadequate for Internal irradiation, and proposes a new model. The report made headlines with its predictions of over 61 million deaths from cancer attributable to nuclear activities since 1945.

(583.5493) NIRS - The European Committee on Radiation Risk (ECRR) Is an Independent committee formed in 1997 after a meeting at the European Parilamnent to review the controversial issue of low-level radiation. -

Shortly after it was set up. a meeting of the European Parliament's Scientific and Technological Options Assessment unit (STOA) considered evidence that low-level exposure to man-made radiation caused ill health and that models used by ICRP failed to predict these effects.

The ECRR was asked to come up with an altemative analysis.

The resulting report. 2003 Recommendations ofithe EuropanCommiieeon RadiationRisk addresses not only the science behind the low-dose debate, but also the ethical basis for allowable radiation exposures.

The Intellectual breadth and depth. and scientific Inclusiveness of this report are a refreshing change from*

current radiation establishment tctics.

If society is ever to have a proper debate on the effects of low-doses and dose rates of ionizing radiation. it must challenge the very basis of radiation dose and risk assessment. This report does.

For Its models. the ICRP uses ethlcaljustifications which are based on overall societal benefit rather thar.

individual benefit This does not account for rights-based philosophies which are pan of the UN declarato.n of human rights. Since any dose of radiation has a small probability of fatal harm. the ECRR argues. the

.celective dose' should be employed for all practices and tirne scales dealing with axoidable radiation exposure.

Among Inadequacies In the ICRP risk model. the ICRP makes assumptions that are Lased on a series of value judgments. Often the risk model rnus counter to actual and epidemiological study results.

Additinally. population dose Is rot accurate for each Individual since It averages the effects of many people who are genetically variable.

Current ICPP risk models do not differentiate enough between radiation delivered externally and that delivered Internally: a difference the report likens to 'a man warming himself in front of a fire and a man eating a red hot coal.'

Further. the ICR? risk model takes a high dose to a single cell and averages It over a larger tissue mass.

July 2005 A-431 - NUREG-1437, Supplement 22

Appendix A The ECRR accepts the ICRP s linear no threshold model for external Irradiation. Ilowever. because of the complex mechanism of cells. the ECRR says that the current linear damage model is not suitable for internal irradiation. The linear model must. according to the corrmmittee. be superseded in favor of relationships that show much higher effects al low doses.

To help correct for these shortcomings. ECRR has developed mathematical terms that extend the risk model of the ICRP. Thev Include two new weighting factors in the calculation of effective dose (for intemal exposures) which address ionization density In time and space at the cellular level. Ionization densities vary by radiation type (alpha. beta or gamma).

The committee also makes weighting adjustments for certain types of radionucildes which undergo damaging transmutation: and they make enhancement weightings based on biological and biophysical aspects of certain exposures.

ECRR derives these weighting factors from studies showing harm from low-dose exposures.

The committee recommends:

- the total maximum permissible dose to members of the public from all human nuclear practices be not more than 0. ImSv and 5rnSv for workers

- all new nuclear practices mnust be justified by considering thie rights of all Individuals.

- total consequences of radioactive discharge rrust be assessed for both direct and Indirect effects on all living systems.

- radiation exposures must be kept as low as reasonably achievabieusing best available technology.

For more information, visit the committee website at www.euradcom.org.

Source and contact: Cindy Folkers at NIRS (cindyf@'nlrs org)

A-432 July 2005 NUREG-1437, Supplement 22

Appendix A J

Cancer Incidences in Connecticut Towns 1995-1999

.Source: Connecticut Tumor Registry

,c All Sites - Female Town Cancers Expected - - - SIR East Lyme ': 251 239.04  ;-- 1.05 Groton 475 469.02 1.05 New London 365 302.10 1.21 Old Lyme 134 114.58 1.17 Waterford ' 320 323.42 .: ': .99 1.0-TOTAL 1,545 1,448.16 ;1.07 1,1.

All Sites - Male Town Cancers - : Expected SIR East Lyme 222 .- 253.68 -. .88 Groton - . 448 - 468.98 +. .96 New London 314 -. 292.52 1.07 Old Lyme 143 134.05 F,1.07 Waterford 325 -. t 337.83 1. S96 TOTAL 1,452 1,487.06 I'll. .98 Lung (Males)

Town . _ Cancers - Expected . SIR East Lyme - 24 --38.59 .r62 Groton . 69 . .69.92 .99 New London - 54 - 43.70 .1.24 Old Lyme -- -10 . 20.88 . .48 Waterford 46 52.39 .88 TOTAL 203 225.48 .90 Lung (Females)

East Lyme 32 29.81 1.07 July 2005 A-433 NUREG-1437, Supplement 22

Appendix A Groton 67 58.87 1.14 New London 51 37.51 1.36 Old Lyme 16 14.86 1.08 Waterford 48 42.56 1.13 TOTAL 214 183.61 1.17 Colorectal (Males)

East Lyme 26 29.62 .88 Groton 55 55.58 .99 New London 32 34.99 .91 Old Lyme 46 41.08 1.12 TOTAL 170 177.2 .96 Colorectal (Female)

East Lyme 24 26.32 .91 Groton 77 57.58 1.34 New London 50 37.79 1.32 Old Lyme 13 13.21 .98 Waterford 40 41.37 .97 TOTAL 204 176.27 1.16 Prostate East Lyme I 80 71.88 1.11 i Groton 118 128.37 .92 II New London 83 79.67 1.04 i Old Lyme 57 39.00 1.46 Waterford 97 97.22 1.00 TOTAL 435 416.14 1.05 Breast, Females NUREG-1437, Supplement 22 A-434 July 2005

.Appendix A East Lyme 78 77.33 1.01 Groton 139 143.17 .97 New London 103 91.22 1.13 Old Lyme, 53 36.62 1.45 Waterford 78 98.17 .79 TOTAL 451 446.51 1.01 Melanoma. Males East Lyme 15 11.63 1.29 Groton 33 21.42 1.54:

New London 10 - 13.33 .75 Old Lyme 13 5.79 2.25 Waterford 12 14.53 - -.84 TOTAL 83 66.53. 1.25 Melanoma, Females East Lyme 18 8.92 2.02 Groton 17 16.48 1.03 New London 13 10.57 1.23 Old Lyme 6 3.95 1.52 Waterford 14 10.46 1.34 TOTAL 68 50.38 1.35 Uterine/Cervix ,_-. I-East Lyme 7 - 4.72 - -1.48 Groton 9 8.52 1.06 New London 9 5.44 ,',,r: 1.65 Old Lyme 3 1.98 1.52 Waterford 6 5.10 1.18 TOTAL 34 25.76 1.32 July 2005. A-435 r, NUREG-1437, Supplement 22

Appendix A Health Effects of Selected'Industrial Chemicals and Radionuclides:

an introduction STAND Technical Report 2003 - 2 July 2003 NUREG-1437, Supplement 22 A-436 July 2005

Appendix A STAND is a SOI (c)(3) nan-profit grassroots organization dedicated to government that is accountable toshe communft,

-to citizen responsibilityforthe welfare of our communities.

and to aforwn for public debate in which to find solutions.

STAND's goal is L the protection of humnan health and the long-term preservation of the natural resources entnisted to our care.

Supported by a grant from the Citizens'NMonitoring and Trchnical Assessment Fund.

July 2005 A-437:- NUREG-1 437, Supplement 22

Appendix A Health Effects of Selected Industrial Chemicals and Radionuclides:

an introduction by Valerie Navab, M.S., Rachael Hawkins, M.S.

and Marvin Resnikoff Ph.D.

Radioactive wa2ste Management Associates preparedfor ISTAND July 2003 NUREG-1437, Supplement 22 A-438 July 2005

Appendix A TABLE OF CONTENTS inrduto . .................................... . i Introduction .pagel1 Chlorinated Solvents ..... ...... .. page 6 High Explosives Compoundss.......... page II Fuel Components and other Organic Chemicals .... page 14 Metals .-. .. . page 24 Pesticides .........  ; .;:_ page 32 Radionuclides . .p. .page 39 Appendix I - Abbreviations and Acronyms ...... pagc 42 Appendix 2- Glossary ........... - page 43 Appendix 3-Bibliography.-.. .... - -. page

44 July2005 - A-439 NUREG-1 437, Supplement 22

Appendix A Introduction he purpose of this report is to provide information about the health hazards that exposures to industrial chernicals and radionuclides may pose to the community. Sources of additional information are pro-vidcd in Appendix 3. In this way, the community might better under-stand the heath issues and hazards related to these chemicals and contaminants.

Determining and classifying health hazards to humans exposed to varying amounts of contaminants is difficult and subtle. The risks of serious illness as a function of exposure is not the same for all com-pounds, and one should not be misled by the similarities of the health effects due to the different toxic chemicals inventoried in this report.

The quantitative aspects of exposure are as important as the serious-ncss of the health consequences. Indeed, the geographical spread of the containuants and their temporal evolutions would also varty lead-ing us to nantrafly consider the seriousness of contamination as a function of quantity, consequences. and also temporal evolution.

Therefore, the notion of "acceptable' risk levels for a site goes much further than just establishing a list of contaminants and their legal dose limits.

Some of the reasons that make the understanding or 'acceptable' exposure more subtle than it firt appears are provided below.

Regulating Agencies and Guidelines The federal government is charged with developing regulations and recommendations to protect public health. These regulations can be enforced by law.

Federal agencies that develop regulations for toxic substances include the Environmental Protection Agency (EPA), the Occupational Safcty and Health Administration (OSHA), and the Food and Drug Admin-istration (FDA). Recommendations provide valuable guidelines to protect public health but cannot be enforced by law. Federal orpani-zations that develop recommendations for toxic substances include the Agency for Toxic Substances and Disease Registry (ATSDR) and the National Institute for Occupational Safety and Health (NIOSH).

It is important to remember in this regard that as far as radioactive materials are concerned, the Department of Energy (DOE) regulates NUREG-1437, Supplement 22 A-440 July 2005

Appendix A its own facilides. Through its contractors, DOE also operates these facilities. DOE funds health studies that determine the hazard of radioactive materials.

National Primary Drinking WaterRegulations are determined by the EPA for certain toxic and radioactive chemicals. These regulations.

known as the Maximum Contaminant Level (MCL), are legally en-forceable in the United States. These legal standards set limits to the amount of contaminadon in the public drinking water supply.

Many other agencies study the effects and patterns of some toxic materials. such as the World Health Organization (WHO). the Inter-national Agency for Research on Cancer (IARC). and the United States

.Decpartentof Health and Human Senvices (US DHHS).These orga-

-z- . uzations recomrmend limits on the coccentradons, or amounts, of contamination to be allowed in drinking water.

In this report. many of the chemicals discussed do not have assigned

-MCLs.In these cases, add itional guidelines are provided. The Amenri-ean Conference of Governmental Industrial Hygienists (ACGIH) has set Threshold Limit Values (ACGIH TLV); tiese values are time-

- weighted avnrages to which a worker can be exposed in a normal 8-hour day, 40-hour workweek without any effect on hunan health.

The NIOSH has determined Recommended Exposure LiUmits (REL) which are guidelines based on risk evaluations using human hcalth

- effects for levels feasibly achieved and measured by engincering con-trols. However, these two guidelines are difficult to compare. In ad-

- dition, the WHO has set its own recommended levels for contani-nants allowed In drinking water.

Standards Reguladons ad recommendations can be expressed in !not-to-ex-eed" levelsinairwatersoil,orfoodthatareusuallybasedonlevels that affect animals, then adjusted toprotectpeople. Sometimes thesc not-to-exceed' levels differ among federal organizations because of different exposure times (an 8-hour workday or a 24-hour day). the use of different animal studies, or other factors. Recommendations and regulations are also periodically updated and change as mnore information becomes available. Unfortunately, the number of new chemicals introduced into the workplace each year numbers in the hundreds or thousands. completely over-whelming thc ability or fcd-cal agencies to determine thc hazards of each. -

.2 July 2005. A-441 . NUREG-1 437, Supplement 22.

Appendix A So. it is not uncommon that different studies reach different conclu-sions about which contaminants are most prevalent or of highest pri-ority. Similarly. die Hazard Rating (HR) assigned to each material in the form of a number (1, 2. and 3) that briefly identifies the level of toxicity or hazard varies according to different agencies and organi.

zations.

Factors Vhien a substance is released from a large area, such as an industrial plant, or a container, such as a drum or bottle, it enters the environ.

ment. This release does not always lead to exposure. One can be exposed to a substance only when in contact with it by breathing.

eating, touching, or drinking. The consequences may vary in each case.

When exposed to achemical, many factors determine whether a per-son would likely be harmed or n. These facton include the dose (how much), the duration (how long), the form (which chemical com-pound). and the way the contact occus Other important parameters could be the presence ofotberchemicals that enhance ordiminish the toxicity, and the age, sex diet, family traits, lifestyle. and state of health of the person. Therefore. classifying the health hazards to humans becomes difficult and research-intensive. VaWng test envi-ronments and procedures will alterresulu in the patient Also. health effects for the majority of these chemicals are better known for ani-mals than humans. The same effects seen in animals may also be seen in humans to some extent However, humans do not react in the same way when exposed to the same chemicals and, therefore, more research is needed to determine the full extent of harn to human health.

In addition, medical tests on individuals todetect and evaluate expo.

sures to a chemical may have used *arious techniques' and resulted in contradictory results. Measurements in the blood, feces, or urine can determine if one has been exposed to larger-than-normal amounts of chemicals. But these measurements will obviously depend on each individual their overall health and how long after the exposure the measuremcnt is taken.

It is difficult to obtain information on target organs. For example, all the persons suspected of having died prematurely because of a pre-cise exposure have not necessarily been autopsicd so the inrirmation 3

NUREG-1437, Supplement 22 A-442 July 2005

Appendix A about which organs have been partially or completely damaged is lacking.

Furthe. correlations can be difficult to establish. An organ may not be lethally damaged. but its malfunction could aecclerate the dcterio-ration of another part of the body and lead to a fatality. For exampic.

-smoking or chronic bronchiis due to exposure to dust would make a

.person more sensitive to radioactivity.

-Fetses,children, and adults also exhibit different susceptibilities to various contaminants.

Cancer Reviews and Classifications Along with other agencies, the U.N. International Agency for Rc-search on Cancer (IARC) examines suspected potential carcinogens.

The results, which vary widely between anirals and humans, usually fall into one of three groups defined as follows:

1) Class I- Confirmed Carcinogens These substances are eapablc of causing cancerin exposed humans. . .

2) Class I - Suspected Carcinogens

- hesc substances may be capable of causing cancer in ex-

- posed humans. The evidence is suggestive, but not su.fi.

cient to convince expert review commirtees. Somee entries have not yet had expert review, but contain experimental reports of carcinogenic activity, As more studies are published, marny Class 11 carcinogens

.-- u I-V ul- uscune o U~AILruJXy "Iume a nn, uul

- somermay be judged non carcinogenic.

3) Class Ill - Questionable Carcinogens

- These entries have minimal published evidence of possiblc carcinogenic activity. The reported endpoint is often nco-plastic growth with no spread or invasion characteristic of

.:carcinogenic pathology.--

• It should be noted that these three categories refer only to the strength of the experimental cvidence that a chemical is carcinogenic, and not to the extent of its carcinogenic activ-4-

July'2005 A-443 NUREG-1437, Supplement 22

Appendix A i

I I

iI I

i ity nor to the mechanism involved. The classification of any chemical may change as new information becomes avail-able.

i i

For a substance to belong in Class ITT. the report may simply i have lacked control animals, may have used a very small sample size. lacked complete pathology reporting, or may have suffered other design defects. Many of these were de-signed for other than-earcinogenie evaluation, and the re-ported carcinogenic effect is a by-product of the study. not the goal. The data wore presented because some of the sub-stances may be carcinogens. There are simply insufficient data to afflum or deny the possibility. i Synergistic Effects of Multiple Contaminants Complicating the assessment of toxicity fora contaminated site is the presence of a mixture of contaminants. Aggregated chemicals could mean aggregated risks.

In a survey of 91 DOE waste sites, for example. Riley and Zachara (1992) found that tnmhtures of two or more compounds uere present at 65 % of the sites. In soils the most frequently occurring mixtures were metals combined with radionuclides. but various combinations of metals and radionuclides with organic contaminants were also ob-scrved at some sites. In groundwater. the most common mixtures were metals and chlorinated hydrocarbons.

The consequences of the synergy, linked to the presence of several contaminants at a time in a contaminated site, still need to be thor-oughly examined. Chemical and radioactive risks are generally in-creased if these substances are carcinogenic to the same organ.

Other auxiliary parameters may also interfere with the total toxic impact of chemicals. and should not be underestimated. For example.

a smoker with damaged cilia in his lung passages will not be able to properly expel radioactive materials, and therefore could be subject to greatly increased health effects. Weather and temperatue, for ex-ample. may also have favorable or deleterious consequences.

5 NUREG-1437, Supplement 22 A-444 July 2005

Appendix A Chlorinated Solvents A solvent is typically a Equid that dissolves another substance, thereby forming a solution. A chlorinated solvent is ouc that is a chlorine compound. As chlorinated solvents move through the ground, the materials act as an oily liquid. Groundwater flowing in the soil will dissolve only a small portion of the contaminant and the rest enters and contuminates the groundwater.

A dioxin is a specific type of chlorinated solvent; diokits ae-i group of 219 different toxic chlorinated solvents These solvents are fat-soluble and therefore accumulate in the tissucs of animals and humans in the food chain. Humans are typically exposed to these chemicals through the consumption of fish. meat, and milk.

Dioxins are formed through the burning of chlorine-based com-pounds. Dioxins may be transported great distances if airborne.:

Materials that enter the water vill bind to sediments and are transported along with marine wildlife through ingestion. Simi-lady, dioxins can settle on the leaves of plants and arm ingested by animals. . - -

Exposure results in a drop in sperm count. an increase in testicular and prostate cancer, endometriosis. and an increased risk of developing breast cancer. The toxicity of these chemicals varies but dioxins have sirnilarpotinckes.' Results of exposure to dioxins create adverse health effects and vary depending on the leel of exposure, time of exposure. and length of exposure. Typical cffects as a result of exposure to large amounts of dioxin include skin rashes.-skin discoloration. excessive body hair, and possibly mild liver damage. Cancer as a result of excessive dioxin cxposure is a main concern in adults.

Although the carcinogenicityof chlorinated solvents remns unknown, cancer as a result of exposure is a great concern.

Carbon ltrnachlorlde - *-

Carbon tetrachloride, also known as carbon chloride, methane tctra-chloride. perchloromethance tertrachlorocthane, or benziform. is a clear liquid with a sweet smcll that can be detected at low-levels.

This synthetic chemical was nost typically used in the production of refrigeration fluid and propellants for aerosol cans, as a pesticide, as July 2005: A-445 NUREG-1437, Supplement 22

Appendix A a cleaning fluid and degreasing agent, in fime extinguishers, and in spot removers. It is now only used in some industrial applications as a result of its harmful health effects. High-levels ofexposurethrougS inhalation and ingestion and possibly through exposure to the skin can cause live;, kidney, and ceniral nervous system damage. The liver and kidney cells are damaged or destroyed by this chemical.

Kidney and liver repair can occur when low-levels of exposure are stopped. High-levels of exposure affect the nervous system, includ-ing the brain. This chemical has been linked to brain cancer. Effects of exposure include headaches, intoxication, dizziness, drowsiness.

nausea, and vomiting, and can lead to coma and even death. The US DHHS has determined this chemical is a probable carcinogen. The MCL is set at 0.005 mgIL and the ACGI TLV is set at 5 ppm. The NIOSH REL is set at 2 ppm or 12.6 mgzn3'.

Chloride Chloride has a very low toxicity. Ingestion of large amounts of chlo-ride may lead to fluid retention and altered acid-base balance. Chlo-rine as agas orliquid is irritating and toxic. The main source of exposure is through the consumption of salt. Effects of long-term exposure are unknown.

Chlorobenzene Chlorobcnzenc. also known as benzene chloride, veas used to make other chemicals such as phenol and DDT. Currently, this chernical is used as a solvent to make other chenicals; This chemical is a strong narcotic with slight irritant qualities. Health effects from repeated low-levels of exposure are unknown. Symptoms ofexposure include-irritation to the eyes skin, and nose, drowsiness, incoordination, and central nervous system depression. The carcinogenicity of this chemi-cal is unknown. The ACGIH TLV is set at 10 ppm.

Chloroform Chloroform, also known as trichloromethane and methyl trichloride.

Is a colorless liquid with a plcasant, nonirritating odor and a slightly sweet taste. This chemical sill burn only when it reaches very high temperatures. Initially, chloroform was used as an anesthetic. Cur-rently, it is used to make othcrchemicals. Inhalation results in irrita-tion to the respiratory tract, and effects on the central nervous system including headache, drowsiness, and dizziness Results of inhalation may also lead to unconsciousness, liver injury, blood disorders, and even death. Ingestion results in severe burning to the mouth and 7

NUREG-1437, Supplement 22 A-446 July 2005

Appendix A throat, vomiting and similar results as inhalation. Sores develop on skin with contact to large amounts of chloroform. The US DHHS declares chloroform to be a probable carcinogen. The MCL is not determined for this chemical. but the ACGIH TLY is set at I0 ppm.

The NIOSH REL is set at 2 ppm or 9.78 mglm'.

Chloromethane - .

aMoromethane is also known as methyl chloride. Symptoms often seen includc: convulsions, nausca or vomiting, dziness, drowsinss, Incoordination, confusion, abdominal pains hiccoughs, diplopia.

delirium, convulsions. irritation to the eye, coma, and even death.

High levels of exposure greatly affect the nervous system, liver. ldd-neys, and hear. No evidence exists to Imply that chloromethane is a carcinogen. How.ever, the EPA has determined that it is a probable carcinogen. The ACGIH nLV is set at 50 ppm. The NIOSH REL is

setatl 0ppin -.

Dibromochloromethane

-Dibromocloromerhane is also known as chlorodibromomaehane.

Symptoms often seen include: irritation and narcoc effects. No cases of cancer are seen in hurmans exposed to this chemical. Mhc MCLforthischetnicalissctatO.lOppm.' - -

Dkhlorodifluornmethane- -

Dichlorodifluoromethane exposure symptoms often seen include:

dizziness, tremor, asphyxia. unconsciousness, cardia arrhythiias.

cardiac arresconjunctiva irritation. firosingaheolids, liverchanges, and narcotic effects. The ACGIH TLV and NIOSH REL are set at IOW pprn Freon-113 Freon-l 13, alsoknown as l,l,2-Trichloro-l,22-trifluorocthanc. is a mildly toxic chemical. Symptoms often seen Include. irritation to skin and throat, drowsiness, dermatitis, and central nerous system depression. Thc NIOSH REL is set at 1 OOO ppm.

Methylene Chloride Methylene Chloride, also know n as dichloromrihanc, is jnot found naunrally in the environment. This chemical is a colorless liquid vith a mild. sweet odor used as an industrial solvent and paint stripper.

Inhalation of low-lcvls results in a person becoming less attentive and less accurate. Effects of inhalation athigh-levels have a narcotic July 2005 A-447 NUREG-1437, Supplement 22

Appendix A effect. Symptoms often seen include: dizziness, nausea, mental con-fusion, fatigue, vomiting, headaches, and a tingling sensation in the fingers and toes. Contact with this chemical by skin results In irrita-tion, redness, pain and even buffing. The WHO declares methylene chloride as carcinogenic to hum=s. The US DHHS and the EPA have determined that this chemical is a probable carcinogen. The

.1CL has not been determined for this chenical, but the ACGIH *rLV has been set at 50 ppm.

Octschlorodibenzo-p-dioxin (OCDD)

Octacliorodibenzo-p-dioxin (OCDD) is an experimental teratogen and an Irritant to the eyc. Ingestion of this chemical results in poison-ing. These solvents are fat-soluble and therefore accumulate in the tissues of animals and humans in the food chain. Humans are tpi-cally exposed to these chemicals through the consumption of fish, nmat, and milk. Exposure to dioxins results in a drop in sperm count.

an increase in testicular and prostate cancer, endometriosis, and an increased risk of developing breast cancer. The NICL and ACGIH TLV have not been determined for this chemical.

Pentachlorinated dibenzofurans Pentachlorinated dibenzofhnns is a chemical with great health ef-fects to the human body. A significant reduction of thymus vweight and suppression of the activity of cytotoxic T lymphocytes, in addi-tion to a suppression on both cell-mediated and humorai immunity.

The .MCLand ACG2HTLV have not been determiuned for this chemi-caL Perchloroethytene (PCE)

PCE, also known as perrhloroethylene or tetrachloroethylene. is a moderately toxic chemical. Inhalation results in conjunctiva irrita-tion. general anesthesia, hallucinations, distorted perceptions, local anesthesia, coma, and pulmonary changes. Symptoms of exposure may include irritation to eyes, skin, nose, throat, and respiratory sys-tem, as well as nausea, dizziness, incoordination, headache, drowsi-nesS skin erythea, and liv damage. Ingestion results in irritation to the gastrointestinal tract. This chemical Is a potential carcinogen.

The .NCLhas not been determined for this chemical, but the ACGIH TLVis set at S0 ppm. The.NIOSH RELrecomnmends that workplace exposure is minimized.

_ 9 NUREG-1 437, Supplement 22 A-448 July 2f005

Appendix A Titanium tetrachloride Titanium tetrachloride is a colorless to pale yellow liquid that has fumes with a strong odor. If It comes in contact witwater, it rapidly forms hydrochloric acid, as well as titanium compounds. It is not found naturally in the environment and is made firom inicrals that contain titanium. It is used to make titanium metal and other tita-nium-containing compounds, such as titanium dioxide, which is used as a whitc pigment in paints and other products.

Titanium tetrachloride is very irritating to the eyes, skin, mucous rnembraDns, and the lungs. Breathing in large amcmnts can injure the lungs seriously enough to cause death. Therc is no evidence that chronic exposure to titanium tetrachloride causes cancer In humans.

The MCL and ACGIH TiV haven't been determined for this chemi.

cal. TheNIOSH RELisset at 0.001 mg/n'. ; .

1,2,4-TrichIorobtnzene 1,2,4-Trichlrobenzene is an experimental teratogen. This ehemical is an iritant to the eyes, skin, and mucous membrane. Symptoms often affect the liver, kidney. and adrenal gland. The carcinogenicity of this chemical is unknown. The MCS, is sct at 0.07 mglL. The ACGIH T1V is set at ppm.

Il,l-trichlorioethane -

1.ll-trichloroethanc is synthetic material that is alsown astnc-thyl chloroform. Symptoms often seen Include. dizziness, conjunc-tiva irritation, hallucinations or distorted perceptions. motor activity changes, irritability, aggression, hypermotility, diarrhea, poor equi.

brium, dermatitis, nausea or vomiting, cardiac arrhythmias, and other gastrointestinal changes. The IARC has determined the carcinoge-nicity of this chemical is not classifiable. The ACGIH TLV and NMOSH REL are sct at 350 ppm.

Trichloroethylene (TCE) -

TCE is also known as trichloroethylene. Symptomns of inhalation and ingestion are mildly toxic to humans and include: eye Irritation, somnolence, hallucinations or distorted perceptions, gastrointestinal changes, and jaundice. Addictionresults in those that work with the chemical. High-levels of exposure lead to headache and drowsiness.

and ecvntual vcntricular fibrillation resulting in cardixc failure, which in turn damages the liver and other organs. NIOSH has detcnnined this chemical to be a potential occupational earcidogen'. thc recom-

• 10 July 2005 A-449 NUREG-1 437, Supplement 22

Appendix A mended REL is2 ppm. The.%CL is set at 0005 mg/L and the ACGIH ILV is set at 50 ppm.

Tetrahydrofuran Tetrahydrofuran. also known as tetrametbylene oxide or 7lF is a mildly toxic chemical. Symptoms often seen include: general anes-thesi. irritant to eyes, mucous membrancS, and upper respiratory system, narcotie in high concentrations, liver and kidney damage.

and central nervous system depression. The NIOSH REL is set at 200 ppm.

Vinyl Chloride Vinyl Chloride is moderately toxic by ingestion and a severe irritant to skin, eyes, and mucous membranes. High concentrations of vinyl chloride act as an anesthetc and chronic exposure can lead to liver injury. The carcinogenicity of vinyl chloddeis conflrmed in produc-ing a ramz cancer in the liver and blood tumors. The production of vinyl chloride is also a source of dioxins." Th MCL is set at 0.002 mgtL and the ACGIH TLV is set at 5 ppm.

High Explosives Compounds Explosives are chemical compounds or mixtures that are typically used in detonators in bombs. Lage amounts of gas and heat are generated with the production of sudden pressure effects. As a re-suI4 the explosives vary in intensity and resistance.- fixing of chemni-cals produces varied effects and intensities upon explosion.

1,3-Dinitrobenzene 1,3-dinitroberene, also known as 2,4-dinitrobenzene. is a synthetic explosive formed as a by-product from the manufacturing of TNT.

Mixting this chemical with tesranitromethanc results in a high explo-sive that is very sensitive to sparks. No odor or tastc is associated with this chemical. This chemical is slightly soluble in waver and does not stick strongly to soil and as a resulttravls through the soil into the groundwater. Symptoms of exposure include headache, an-oxia, cyanosis, visual disturbance, central scotomas, bad taste, burn-ing mouth,dry throat thirst.anenia. liverdamage, nauseaand dizzi-ness Long-tcrtn exposurc results in a reduction of the numberof red blood cells. The carcinogenicity of this chemical is undetermined for humans. Thc NIOSH REL is set at I mg/nO.

t11 NUREG-1437, Supplement 22 A-450 July 2005

Appendix A Dinitrotoluene (DN7) - -

. Dinitrotoluene (DNT) is a poison that is carcinogenic with experi.

mental curnorigenic and terazogenicdata. Symptoms of exposure may include anozia, cyanosis, anemis jaundicc. and reproductive effects.

Tbc MCL has not been determined for this chemical but the ACOTH TLV is set at 1.5 mg/m'. The NIOSH REL is set at 1.5 mghrn'.

2,6.Dinitrotoluene - ' -

Z6-Dinirotolucne is a synthetic explosive that is one of the six forms of chemicals otdinitrotoluene. This chemical is a pale yellow solid with a slight odor. Health effects from exposure to this chemical arc uncertain. The nervous system and blood of exposed iosrkers may be affected. The IARC has determined that this chemical Is a poten-tial carcinogen. :

HMX -

HMX, also known as cyclotetramethylene tetranitrate, is an acronym for High Melting Explosive. Other names for this chemical include:

Octogcn and cydotetramethylene-tetanitramine. It is a colodess solid that dissolves slightly in water with an unknown taste itld smelL This chemical is made from other chemicals kn6%n as hexamine, miMno.

nium nitrate, nitric acid. and acetic acid. Thc high volatility of this chemical enabled its use in explosives, rockec fuels, and burster charg.

'crs No information is known on how you might be exposed to HMX in the environment and the information on adverse hcahih effects is linited. The EPA has concluded that the carcinogenicity to humans Is not classifiable. Tbe MCL and ACGIH TLV have not been deter-

.minedforthischernical.

4-Nitrotoluene 4-Nitrotoluenc is a poison that is moderately toxic by ingestion.

Contact with skin is mildly toxic. This chemical is combustible upon exposure to heat or flame.' Symptoms of expcsure may include an-oxia. cyanosis. hcadachc, wcakness and exhaustion, dizziness. ataxia.

difficulty breathing, tachycardiax niusca. and vorniting. When It is combined with ictranitromethanc a very sensitive high explosive is created. The NIOSH REL is set at II mg/m.

4-PETN (Pentser~ythrilol Tetranltrate)

PE-Nl, also'known as Pentacrydtritol Tctranitrate, Is a hazardous chemical that explodes when shocked or exposed to hcat.' Ingestion 12 77 July 2005 A-451 NUREG-1437,-Supplement 22

Appendix A results in dermatitis. Other symptoms of exposure include: head-aches, weakness, and fall in blood pressurec The.NICL and ACGIH TLV have not been determined for this chemical.

4-Perehlorate Perchlorate is synthetic and man-made. Perchlorates are incredibly unstable materials. Irritation to the body results in contact with any perchlorate. Mixtures of this chemical fonr explosives. This chemi-cal affects the functioning of the thyroid gland. Alteration to thyroid gland functions can potentially lead to the formation of tumors.

4-RDX RDX, otherwise known as Royal Demolition Explosive, is one of the most powerful high explosives in use today. Other names for this chemical include: cyclocrimcthylcne-tziiraminecyclonite, cyclonitc, and 1.3,5-trinitro 1,3,-triazine. As a synthetic, white powder, when RDX is burned fumnes are created. This chemoical is rarely used alone and is typically combined with other explosives, oils, or waxes. Syrnp-toms of exposure to RDX include seizures, nausea, headache, irrita-bility. weakness and exhaustion, tremor, dizziness, insomnia. and vomiting. Knowledge of birth defects or affects oa reproduction in humans is yet to bc discovered. The carcinogenic propertes of RDX are unknown. The MCL has not been determined for this chemical.

but the ACGIH TLV is set at 15 mg/ni. The NIOSH REL is set at 1.5 mg/r'.

Tetryl Tetryl is also known as nitramine and 2,4,6.trinitrophenyl-n.

methyinitramninc. This explosive is an extremely sensitive high ex-plosive, more so than TNTto shock and friction. When combined on contact with trioxygen difluoride the chemical explodes on contact.

This chemical is an irritant, sensitizer, and allergen. Symptoms of exposure may include sensitization derrnatitis, redness, inflamma-tion of the cornei, snecing. anemia, couSh. car)za. irritability, mal-aise, hcadache. weakness and exhaustion. insomnia, nausea, va.nit-ing. and liver and kidney damage. The MIOSH REL is set at 1.5 mngm'.

2,4,6-Trinitrololuene 2.4.6-Trinitrotoluene is an explosive commonly rcferred to as TN'T.

Ingestion results in hallucinations or distorted pcrmeptions. cyanosis.

and gastrointestinal changes. Contact with this chemical results in

- ~~ 13 NUREG-1437, Supplement 22 A-452 July 2005

Appendix A

skin irritation. Hcalth effects include jaundice, cyanosis. sneezing, cough. sore throat, peripheral ncuropathy, muscle pain, kidney dam-age. cataract, sensitization dermatids, headaches. weakness, anemia.

and liver injury. The NICL has not been determined for this cherni-cal, but the ACGIHTLV is set at O5 mfem'. The NIOSH REL is set at 0.5 mg/tn'.

Fuel Components and other Organic Cheniicals Toxic chemicals are known to disrupt normal bodily functions, in.

cluding the functions of hormones. Hormones provide a number of services ts natural chemicals to the human body including: act as messengers, travel through the blood stream, regulate vaious bodily processes, and coordinate the body's activities to maintain health through controlling grorwth. development, and bchavior.2 Acenapthylene  ;

Acenapthylkne is a Polycyclic Aromatic Hydrocarbon (PA)H. The presence of this chemical arises from the use of fuel components and other organic chemicals. This chemical is a danger to humans and enters In all tissues that contain fat. Acenapthylene is stored mostly in the kidneys, liver, and fat with smallerarnounts stored in the spleen.

adrenal glands, and ovaries. The US DHHS has determined that acenapthylene Is a known animal carcinogen: however. the EPA has determined that the human carcinogenicity Is not classifiable. The MCL and ACGIH TLV have not been determined for this chemical.

Acetone Acetone is a colorless liquid with a distinct smell and taste that is naturally found in the envirotment as well as manufactured. Other names for this chemical include: diimethylcetone, 2-propanone, and beta ketopropanc. In small amounts, the liver breaks acetone down into energy making chemicals used for normal body functions. Ex-posure results in entry of acetone into the blood stream and is subse-quently carried to the rest of the organs. Inhalation of moderate-to-high amounts for even short periods of time can result in nose, throat.

lung, and eye irritation, headaches, light-headedness, confusion, in-creased pulse rate, efrccts on blood. nausea, vomiting, unconscious-ness and possibly coma, and the shortening of the menstrual cycle in women. Ingestion of small amounts typically does not cause harm.

,Howevcr, ingestion ofhigh lcels results in nbdomninal pain, nausca, 14 July2005 A-453 NUREG-1 437, Supplement 22

Appendix A and vomiting. Effects of long-term exposure to acetone include kid-ney, liver. and nervc damage. increased birth defects, metabolic changes, and coma. The use of alcoholic beverages enhances the toxic effects of acetone. The US DHHS, the IARC. and the EPA have notclassifiled acetone forcarcinogenicity in humans. The MCL has not been determined for this chemical. The ACGIH 'TVis set at 750 ppm. The NIOSH REL is set at 0.1 ppm.

Ammonia Ammonia exposure symptoms often seen includc irritation to eyes and mucous membranes. Symptoms often seen include: breathing difficuky, wheezing, chest pain. pulmonary cdema, skin bums, liq-uid. and frostbite. High-levels of exposurc result in blindness, lung damage, heart attack. or death. The US DHHS, IARC, and the EPA have not classified the carcinogeniciry of ammonia. The ACGIH TLV and .NIOSH REL are set at 25 ppm.

Anthrmene Anthracene isaskin irritant and allergen. The carcinogenicity ofthis chemical is probable.

9,10-Anthracenedione 9,10-Anthracenedionc, also known as anthraquinone. is a mild aller-gen.

Asbestos Asbestos is comprised of six different minerals that are found in na-ture This chemical enters the drinking water from natural sources in addition to corroded asbestos worn away from cement pipes. Thc separabie, heat resistant fibers that make up the minerals are strong and flexible enough to be spun and woven. As a result, asbestos was widely used in building materials. frirteon'products, heat resistant fabrics, packaging, gaskets, and coatings, Inhalation of lower 1evels ofasbestos may result in changes called plaques in the linings. Long.

term inhalation of asbestos fibers may result in scar-like tissue in the lungs and in the Eining that surrounds the lung. Breathing'difficulties, restricted pulmonary function. and heart enlargements arise as a re-sult of exposure. eventually leading to disability and death. The US DHHIS, the WHO. and the EPA have determined that asbestos is a human carcinogen and produces lung rumors. The MCL is set at 7 million fibers/ and thc ACGIH TLV is set at 2 fibers/cubic centime-Mrs1 NUREG-1437, Supplement 22 A-454 July 2005

Appendix A Benzaldehyde Benzaldehyde is an allrgen. Symptoms often secn includc: derna.

titis, ccntnal nervous system depression, and anesthetic. The carino-genicity of this chemical is probable.

Benzene Benzene is a colorless liquid with a sweet odor that Is formed from natural processes as well as human activities. With is wide distribu-tion throughout the US, the uses of benzene are expansive, some of which include rubbers, Ibrcants dyesdegreascrs detcrgents. drugs, pesticides, and as a major component of gasoline. This chemical enters the drinking water through Icaking underground gasoline and petroleum tanks or improper waste disposal. Inhalation of high lev-els of benzene can result in drowsincss, dizziness, rapid heart rate.

headaches. tremors, confusion, unconsciousness, and even death.

Diseases that result from inhalation includc Hodgkin's Disease and lymphomras. Ingestion of benzene is moderately toxic and is a severe eye and moderate skin irritant. Long-term exposure results in harm-ful effects on the bone marrow, leading to mycloid lcukemia, as well as a decrease in red blood cells that leads to anemia. In addition excessive bleeding can occur and the immune system can be affected.

Long-term exposure of workers to this chemical is linked to brain cancer and leukemia. Additionally, other possible health cornplica-tions may arise in reproductive and developmental effects. Thc US DHHS has determined that benzene is a known human carcinogen.

The MCLis set at O.OQ5 mgIL and the ACGIH TLV is set at 10 ppm.

The NiOSH REL is set at 0.l ppm.

n-Butanol n-Butanol is also knovwn as n-butyl alcohol. Symptoms often seen Include: conjunctiva irritation, unspecified rcspiratory systmn and nasal effects, severe skin and eye irritant comea] inflanmition. slight headache and dizzness, slight irritation of the nose and throat, and dermatitis. The ACGIH TLV and NIOSH REL are set at SO pprm.

Delta-BIIC.

Delta-BHC is also known as dela-benzenehexachloride and is a moderately toxic chemical.

16 - - ..

July 2005 A-455 NUREG-1437, Supplement 22

Appendix A Gamma BHC Ganm BHCis alsoknown 6as the gammaiwerotoenzebc h=x lo-ride. Symptoms often seen include: Irritation to the eyes skin, nose.

and throat, headache, nausea, rmpsasory difficulty. convulsions, dys-pnea, and cyanosis. This chemical is a known carcinogen. Thc ACGIH TLV and NIOSH REL are set at 0.5 mng/rn.

Benzo(a)anthrcene Benzo(a)anthracene is a Polycyclic Aromatic Hydrocarbon (PAH).

The presence of this chemical arises from the use of fuel components and ocher organic chemicals. This chemical is a danger to humans and eaten all tissues that contain fat. PAHs arm stored nuoly in the kidneys, liver, and fat with smaller amounts stored in the spleen, ad-renal glands, and ovaries. This chemical is a poison by intravenous routes that is comimionly an air octaminant of foodL waer, and smoke.

The LRC and the EPA have determined it is a probable hurnan car-cinogen. The MCL and ACGIH TLV levels have not been deter-mined.

Benzo(a)pyrene Denzo(a)pyrene is a Polycyclie Aromatic Hydrocarbon (PAH). The presence of this cherrical aises from the use of fuel components and other organic chemicals This chemical is a danger to humans and enters all tissues that contain fat. PAHs are stored mostly in the kid-neys, liver, and fat with smaller amounts stored in the spleen, adrenal glands, and ovaries. This chemical is a poison via subcutaneous.

intraperitoneal, and intrarenal mrutes that is commonly an air con.

taminant of food, water, and smoke. Expedmental teratogenic and reproductive effects have been found. The IARC and the EPA have determined it is a probable human carcinogen. The M.CL is set at 0.0002 msg/L and the ACGIH nv has not been determined for this chemical.

Benzo(b)fluoranthene Benzo(b)ftiuornthene is a Polycyclic Aromatic Hydrocarbon (PAll).

The presence of this chemical arises frtm the use of fuel components and other organic chemicals. This chemical is a danger to humans and enten% all tissues that contain fas. PAHs ame stored mostly in the kidneys, liver, and fat with smaller amounts stored in the spleen, ad-renal glands, and ovaries. The LARC and the EPA have determined this chemical to be a possible human carcinogen. The NICL and ACGIH TLV have nor been determined for this chemicaL 17 A-456 July 2005 NUREG-1437, Supplement 22

Appendix A Benzo(k)fluoranthene Benzo(k)fluoamnthenc is a known carcinogen. ,

Benzo(gb,i)perylene Benzo(g,h~i)perykne is a Polycyclic Aromatic Hydrocarbon (PAH).

The presence of this chemical arises from the use of fuel components and other organic chemicals. This chemical is a danger to humans and enters all tissues that contain fat. PAHs arm stored mostly in the kidneys, liver, and fat %ithsmaller amounts stored in the spleen. ad-rcnal glands, and ovaries. The IARC and the EPA have determined this chemical not classifiable as to the carcinogenicity to humans.

The MCL and ACGIH TLV have not been determined for this cherni-

~cai.

Bensolc Acid

• Benzoic Acid is found naturally in resins and manufactured syntheti-cally. It is a colorless crystalline solid and Is used as a food preserva.

tive and in pharmaceuticals and cosmetics. Inhalation affects the human nervous system, dypsnea. and allergic dermatitis. This chemi-cal is a poison by subcutaneous route and is moderately toxic by in-gestion and intraperitoneal routes. In addition, it is a severe eye and skin irritant. The MCL and ACGIH TLV have not been determined for this chemicaL . - :

Bis-(2-ethylhexyl)phthalate Bis-(2-echylhexyl)phthalate. also knowu as di-sec-octylphthalate, is a poison upon entry into the blood stream. Ingestion affects the gas-trointestinal tract- In addition, this chemical is amild skin and eye irritant and can cause liver damage. This chemical Is a confirmcd carcinogen with experimental carcinogenic and tmorigcnic daaeThc MCL is set at 0.006 mgtLand the ACGIH TLV is set at 5 mg/m. The NIOSH REL is set at 5mgfmr.

Carbazole - '--  :.

Carbazole is a pesticide poisonous by intraperitoneal routes. Inges.

tion is moderately toxic. It Is a questionable carcinogen. The MCm and ACGITH TLV havc not been dctcrmincd for this chemicaL Carbon disulfide - - -

Carbon disulfide is found naiturally as well as a commercially made chemical. Symptoms often seen include: narcotic and ancsthetic cf-18 July 2005 A-457 . NUREG-1437,-Supplement 22

Appendix A fecus to the central nervous systcm dizziness, headache, poor sleep.

anorexis, weight loss, Parkinson-like syndrome, coronary heart dis-ease. gastritis. kidney, liver injury, eye and skin bums, respiratory failure, and even death. The US DHHS, the [ARC, and the EPA have not determined the carcinogenicity of this chemical. The ACGIH Tv is sct at 10 ppn. The NIOSH REL is set at I ppm.

Chrysene Chrysenc is a Polycyclie Aromatic Hydrocarbon (PAH). The prcs-ence of this chemical arises from the use of fuel components and other organic chemicals. This chemical is a danger to humans and enters all tissues that contain fax. PAHs are stored mostly in the kid-neys. liver, and fat with snaller amounts stored in the spleen, adrenal glands. and ovaries. The IARC has determined the carcinogenicity is not dassifiable fiorhuans The EPAhas deternmined that this chemical is a probable human carcinogen. The !ICL and ACGIH TLV have not been determined for this chemical.

Cyclohexane Cyclohexane is also known as benzene hexahydride and hexahydrobenzene. Symptoms often seen include irritation to eyes.

skin, and respiratory system, drowsiness, derrnatitis, narcosis, and coma. Th ACGIH nv and .NIOSH REL is set at 300 ppm.

Cyclohexsnone Cyclohexanone is a severe eye irritant. Symptoms often seen include changes in the sense of smell, headache, narcosis, coma, dermatitis, conjunctiva irritation, and unspecified respiratory system changes.

mild narcotic, and a skin and eye irritant The ACGIH TLV and NIOSH REL are set at 25 ppm.

Dlbmnz(a,h)anthracene DIbenz(ah)anthracene is a Polycyclic Aromatic Hydrocarbon (PAH).

The presence of this chemical arises from the use of fuel components and other organic chemicals. This chemical is a danger to humans and enters all tissues that contain fat. PAHs are stored mostly in the kidneys, liver, and fat with smaller amounts stored in the spleen, ad-renal glands. and ovaries. The US DHHS has determined that this chemical is a known animal carcinogen. The MCL and ACGIII TLV have not been determined for this chernical.

19 A-458 July 2005 NUREG-1437, Supplement 22

Appendix A Di-n-octylphthalater Di-n-octylphthalate is also known as'di-sec-octylphthalate. Ihis chemical affects the gastrointestinal tract, central ncrvous system liver, reproductive system, and gastrointestinal tract. This chemical is also a mild skin and eye Irritant. This chemical is a known carcinogen.

The ACGIH TLV and NIOSH REL are set at 5 mglmi.

1,2-Diphenylbydrazine 1.2-Diphcnylhydrazine. also known as Hydrazobenzene is a white solid with no information on smell or flammability. This manufac-tnred chemical does not dissolve easily in water and when placed in water it rapidly breaks down into other toxic chemicals. This chemi-cal is currently used in medicines to treat inflammation and a type of iarthritis. Effects of Ingestion lead to chemical joisoning.

Diphenythydrazine Is a confirmed carcinogen with expe'rimentail car-cinogenic and tumotigenic data Poison by ingesidon. 'The MCL and

-ACGIH TLV have not been'determined for this cher'ical. L-"

Ethyl Acetate Ethyl Acetate is a chemical that can cause dermatitis. Inhalation re-sults in severe irritation to mucous mniebrazies and tipper respiratory tractpoisoning, human systemic effects such as olfactory changes, eonjunctivairritation, and pulmonarychanges. Ingestionofthischemni-cal is mildly toxic in causing irritation to the gastrointestinal tract iwith symptoms such as nausea, vomiting, and diarrhea. Long-term exposure yields conjuncdval irritation and corneal clouding. conges.

dion of the liver and kidneys. High concentrations have a narcotic effect ini addition to resultant liver and kidney dimage. Chronic poi-soning may lead to anemia with kukocytosis (a transient in'cease in the white blood cell count), cloudy swelling, and fatty degeneration of the viscera. The MCL has not been determined for this chemical and the ACGIH TLV is set at 400 ppm. The NIOSH REL is sec at 400 ppmri ',

Ethylbenrcne Ethylbenzene is a moderately toxic chemical. Symptoms often seen Include: eye, sleep, and pulmonary changes, eye and skin irritation, headache, dermatitis, narcosis, coma. dizziness, irritation of the nose and throat, and a sense ofconstricion in thc chcst.' The ACGIIITLV and NOSH REL'are set at l00 ppm. ' -,-

July 2005 ' A-459 . NUREG-1 437, Supplement 22 .

Appendix A Fluoranthene Fluoranthene is a moderately toxic chemical. The carcinogenicity is probable.

n-Hexane n-Hexane is a slightly toxic chemical made from crude oiL Symnp-toms often seen includet irritation to the eyes, skin. respiratory sys-tern, central nervous system, and peripheral nervous system, paraly-sis and hallucinations. he US DHMS, the IARC, and tde EPA have not classified the carcinogenicity of this chemical. TheACGIHTLV and NIOSH REL are set at 50 ppm.

2-Hfexanone 2-Hexanone is also known as Butyl methyl ketone or Methyl butyl ketone. This chemical Is moderately toxic. Symptoms often seen include: irritation to the eyes and nose, peripheral neuropathy. weak-ness, exhaustion, paresthesia, vomiting, dermatitis, headache, and drowsiness. This chemtical is a skin and eye imitant. The ACGIH TLV is set at S ppm. TbeNIOSH REL is scs at I ppm.

Indeno(1,2,-cd)pyrtne Indeno(1,2.3-c.d)pyrene is a Polycyclic Aromatic Hydrocarbon (PAH). The presence of this chemical arises from the use of fuel components and other organic chemicals. This chemical is a danger to humans and enters all tissues that contain fat. PAHs are stored mostly in the kidneys, liver, and fat with smaller amounts storcd in the spleen, adrenal glands, and ovaries. The [ARC has determined this chemical to be a possible human carcinogen. The MCL and ACGIH TLV have not been determined for this chemicaL Mfethyl Ethyl Ketone (NIEK)

Methyl Ethyl Ketone (MEK) is a strong irritant that affects the pc-ripheral nervous system and central nervous systens Effects of in-halation at low.levels of exposure result in human systemic effects, including conjunctiva irritation and cffects on the nosc and respira-torysystem. Inhalation at high levels results in headachcs. dizzincss.

nausca, shortness of breath, and vomiting, in addition to central ncr-vous system depression and unconsciousness. Effects of ingestion result in abdominal pain and nausea. Contact by skin results in red-ness, itching, and pains; long-term exposure results in dermatitis. Thc M7CL has not been deternined for this chemical, but thc ACGIH TLV has been set at 200 ppnm The NIOSH REL is set at 200 ppm.

21 NUREG-1437, Supplement 22 A-460 July 2005

Appendix A Methyl methacrylate Methyl mnethacrylatc is a moderately toxic chemical. Symptons of-ten seen include: sleep effects, excitement, anorexia, and blood pres-sure decrease. 'Ihis chemical is a severe skin, eye, nose, and throat irritan. The ACG-H ILV and NIOSH REL arc set at 100 ppm.

2-Methyinapthalene 2-Methylnapthaliene is a white solid that is found naturally In fossil fuels. High-levels of exposure damages red blood cclls. Symptoms of acute poisoning include: fatigue, lackof appetite. restlessness, and pale skin. Symptoms of a higher exposure include: nause voriting, diazhea.'blood in the urine. and a yellow color to the skin. The US DHHS, the IARC, and the EPA have not classified the carcinogenic-ity of this chemical. The MCL and ACGIH TLV have not been de-termined for this chemical.

Nitrates Nitrates ingested in large amounts can result in death. Symptorns

often seen include- dizziness, abdominal cramps. vomiting. bloody diarrhea. weakness. convulsions, collapse, aMd even Mcntal impair-i ment. The carcinogenicity of this chemical is probable.

Nitrobenzene -

Nitrobenzene is an industrial chemical typically used to manufac-ture aniline. Symptoms often seen include general anesthetic, an-oxia. dernatitis, anemiaprespiatorysdmuladonand vascularchanges.

This chemical is also an eye and skin irritant and is absorbed rcadily through the skin. The IARC has determined this chemical to be a probable carcinogen. Thbe ACGIH TLV and NIOSH REL are sct at I ppn. -

N-nitrosodi-n-propylamine N-nitrosodi-n-propylamine is a manufactured chemical for use in re-scarch and as a weed killer. The effect on humans remains unknown for this chemical. The US DHHS has determined that n-nitrosodi-n-propylamine is a probable carcinogen. The MCL and ACGIH TLV have not been determined for this chemical.

Octadecanoic acid Octadecanoic acid is also known as stearic acid. This chemical is a skin irritant. The carcinogenicity of this chemical is probable.

22 July 2005 A-461 NUREG-1437, Supplement 22

Appendix A Pentachlorophenol (PCP)

Peatachlomphenol (PCP) occurs as a colorless crystal. The smell varies with the temperature of this manufactured chemicaL Uses of this chemical include use ass biocide and wood presrvative.

Symptoms of exposure may include sneezing, cough, weakness and exhaustion, anorexia. weight loss, sweating, hcadache, dizzi.

ness, nausea. voniting, dyspnea, chest pain, high fever, and damage to the liver, kidneys, blood, lungs, nervous system, immune system.

and gastrointestinal trat Contact with skin and eyes cause drmadtitis and irritation. The (ARC has determined that this chemical is a possible carcinogen to humans. The NICL is set at 0.001 mg/L and the ACGIH TLV is set at 0.5 mg/rn. The NIOSH REL is set ax0.5 mg/ni'.

Pheneanthrene Phencanthrene is a Polycyclic Aromatic Hydocarbon (PAH). The presence of this chemical arises from the use of fuel components and other organic chemicals. This chemical is a danger to humans and enters all tissues that contain faL PAHs are stored mostly in the kid-neys. liver, and fat with smaller amounts stored in the spleen. adrenal glands, and ovaries. The US DHHS has determined that phencanthrene is a known animal carcinogen; howcver, the EPA has detarmined not classirable to human cascinosenicity. The MCL and ACGIH nlV have not been determined for this chemicaL PCBs PCBs are also known as polychlorinated biphenyls.Of the 109 PCIBs, many affect hormones and are linked with brain cancer. Tlis cherni-cal is moderately toxic by ingestion and skin contacL The carcinoge-nicity of this chemical is probable. The MCL is set at 0.0005 mgfL.

but the ACGIH TLV has not been detertmined for this chemical.

Pyrcne Pyrene is a poison through inhalation. This chemical is a skin irri-tant. The carcinogenicity of this chemical is probable.

Sulfates Sulfates arc elements ombined with both sulfur and oxygen. These materials vary in toxicity.

NUREG-1 437, Supplement 22 A-462 July 2005

Appendix A Tbluene Toluene is a poison to hunans via various routes. Inhalation, Intra-venous and subcutancous routcs prove to be mildly toxic.' Effects of Inhalation result in hallucinations. distorted peceptions. tnotor ac-tivity changes. antipsychotic, pyschophysiological test changes. and bone marrow changes. Other Symptoms of exposure may include irritation to nose and eyes, weakness and exhaustion, confusion, di2-ziness, headache. anxiety, muscle fatigue, insomrnia, paresthcsia, der-matitis, and liver and kidney damage. This chemical is an irritant to the eyes and skin and is linked to brain cancer. The MCL is set at I mglLand the ACGIH TLV Is set at 100ppm. The NIOSH REL is set at lOOppm..

1,3,S-Trinitrobenzene 1.3,S-Trinitrobenzenc is a powerful explosive that has more power for shattering than TNT but less sensitive to impacL This chemical is difficult to produce. Ingestion has proven moderately toxic. The MCL ndACGIH TLVhave not beea determined for this cheuical.

Metals Metals are found naturally in the environmcnt and tend to remain for a long time, thereby increasing a greater likelihood for expo-sure. Some metals are useful in small amounts and even necessary for good health. Metals can accumulate in vegetables. grains, fruits, fish, and shellfish from surrounding soil and water. .Health effects caused by heavy metals includc reduced growth and developmnnt, cancer, and organ damtage, which can lead to -

autoinmunity, rheumatoid arthritis, and diseases ofthe kidnevs.

circulatory system. and nervous system. Metals have a greater effect on children and exposure can result in learning difficulties, memory impairment, damage to the nervous system. and behavioral problems? -

Aluminum - . -

Aluminum occurs naturally and makes up about 8% of the surface of the earth. It is always found combined with other elerments such as oxygen, silicon and fluorine. This mctal is silver-whitc and nlexible.

Uses primarily include cooldng utensils, containers. appliances, build-July 2005 A-463 NUREG-1437, Supplement 22

Appendix A ing materials, paints. fireworks. glass, rubber, ceramics and consum-ers products such as antacids, astringents, buffered aspirins. food additives and antiperspirants. Low-level exposure to aluminum from food, airn water, or contact with skin is not thought to harmyourhealth.

Aluminum. however, is not a necessary substance for our bodies and too much may be harmfuL People who are exposed to high lcvels of aluminum may have respiratory problems, bone diseases and skeletal problems, skin rashes and delays in neurological development. The DepartnmentotHealth and Human Services, the International Agency for Research on Cancer. and the EPA have not classified aluminum forcardcnogenicity.The SNILC is set at 0.05-0.2 mg/L. Both ACGIF and NsIOSH have established guidelines values from 2 mgrnS for soluble salts to 10 mgttn' for aluminum for total dust.

Antimony Antimony is a silvery-white. corrosive metal found naturally in the eanth's crusL Thpically, antimony is brought into the United States for processing, mixed with alloys for strength, and used in the flame retardant industry. Other uses of this chemical include: ceramics, glass, batties. fireworks, and explosives. Antimony enters the drink-ing water through natural weathering of rock. industrial production, municipal waste disposat ormanufacritng processes. Inhalation of high-levels will result in lung problems. Ingestion of high-levels of antimony will result in heart problems, stomach pain. diarrhea, vom-iting. and stomach ulcers; other unknow n effects may result from in-gestion. Contact with this chemical results in inration and bums.

Medicinal uses of antimony exist in treating people infected with parasites. The US DHHS. the [ARC, and the EPA have not classified antimony as to its human carcinogenicity. The .CL is set at 0.006 mg&L and the ACGIH TLV is set at 0.5 mgrnm. The NTOSH RE!L is set at 0.5 mg/m'.

Arsenic Arsenic is a naturally occurring clement widely distributed in the earth's crust In the environment. arsenic is combined with oxygen.

chlorine and sulfur to form inorganic compounds. Arsenic in animals and plants combines with carbon and hydrogen to form organic ar-senic compounds. It is mainly used to preserve wood. Its use in pes-ticides has been canceled or restricted.

It cannot be destroyed in the environment; it can only change its form.

Organic arsenic compounds are less toxic than inorganic arsenic com-pounds.

25 NUREG-1437, Supplement 22 A-464 July 2005

Appendix A Arsenic was listcd as the most dangerous substance In the Top 20 hazardous substances on the CERCLA priority List of Hazardous Substances for 2001.

Ingesting high levels of inorganic arsenic can result in death. Lower levels of arsenic can cause nausea and vomiting, decreased produc.

tion of red and white cells, abnorral heart rhythm, damage to blood vessels. darkening of the skin, and a sensation of 'pins and needles" in hand and feet. Arsenic is a human carcinogen and can notably Increase the risk of cancer in the lung, sidn. bladder, liver, kidney and prostate. The ?MLC is set at 0.05 mg/L, the ACGIH TLV at 0.5 mg/

m', and the NIOSH RE3L at 0.002 mng/ns. The WHO has established a provisional guideline value of 0.01 mglL for arsenic in drinking water Barium -. i Barium is a silvery-white netal found in nature nd can be produced synthetically. This chemical Is typically found in compounds com-bined with sulfur. carbon, or oxygen and eaters the dinking water afterdissolving from naturally occurring mirals in the ground. Uses of bariut include: oil and gas drilling muds, auto paint, bricks, tiles and jet fuels. The effect on a person's heakh is greatly dependent on how well the compound dissolves in water. Compounds that do not dissolve well in water are not generally harmful and are oft en used for medicinal purposes. Ingestion of high-levels result in difficulties in breathing, increased blood pressure changes in heart rhythin, stcmn-ach Irritation, brain swelling, muscle weakness. damage to the liver.

'kidney, heart, and spleen. Symptoms of barium contamination in-clude voitding, colic, diarrhea. slow irregularpulse, transient hyper-tension, and convulsive tremors and muscular paralysis. Death may occur in a few hours to a few days. The US DHHS, the IARC, and the EPA have not classified barium as to its human carcinogenicity.

The MCL is set at 2 mgtL and the ACGIH LV is set at 0.5 mg/m'.

Beryllium Beryllium in Its purc form is a hard, grayish mceta vith no particular smeU. Naturally, it can be found in compounds within mineral rocks, coal, soil, and volcanic dust and enters the drinking water from run-off from mining operations, discharge from processing plants and improper waste disposal. This chemical is often used in electrical equipment and electrical componentsc Effects of inhalation depend on exposure possibly causing lung damage and a disease resembling pneumonia leading to death. Ingestion of beryllium Is not known to July 2005 . A-465 NUREG-1437, Supplement 22

Appendix A cause effects in humans due to the restriction of movement from the stomach and intestines into the bloodstream However, it is a deadly poison by intravenous routes. Rashes or ulcers arise from direct con-tact. The US DHHS has determined that this chemical is a probable human carcinogen. The MCL is set at 0.004 mg/L and the ACGIH TLV is set at 0.002 mg/m'. The NIOSH REL is set at 0.0005 mg/rn'.

Bismuth Bismuth is poisonous to humans. Symptoms often seen include: kid-ney damage, malaise, albuminuria. diarrhea, skin reactions, exodermnatids, and even death Boronl Boron is an incredibly toxic materiaL Symptoms often seen include:

irtitation of the nose, throat, and eyes, depression of the circulation, persistent vomiting and diarrhea, shock, coma. and even death. In-gestion of large amounts may damage the stomach, intestines, liver, kidney, and brain. Health effects for long-term exposure are not known. The US DHHS, the IARC, and the EPA have not classified the carcinogenicity of boron.

Cadmium Cadmium is found naturally In the crust. typically as a mineral com-bined with other elements. This c1emkal does not corrode easily and is used in batteries, pigments, metal coatings. and plastics. Inha-lation of high levels of cadmium will severely damage the lungs and can lead to death. Ingestion of high levels of cadmium irritates the stomach, leading to vomiting and diarrhea. Cadmium will build up in the kidneys, cause damage to the lungs, and creates fragile bones through long-term exposure to lower levels of cadmium. Skin con-tact with cadmium is not known to cause health effects in humans or animals. Beneficial effects of cadmium are unknown. The US DHHS has determined cadmium and cadmium compounds are probable car-cinogens. The.MCL is set at 0.Q05mgL and the ACGIH TLV is set at 0.005 mg/th'.

Chromium Chromium occurs naturally in the ground with no taste or smell asso-ciated with this element. This element is found in a few different forms, namely chromium (II1) as an essential nutrient and chromium (VI) and chromium (0) typically produced industrially for use in ekc-troplatingofmetals. Runofffromold mining operations and improper NUREG-1 437, Supplement 22 A-466 July 2005

Appendix A waste disposal re the modes in which chromium typically enters the groundwater. Inhalation of high-levels of chromium (VI) causes irri-tations to the nose, such as runny nose, nosebleeds, ulcers, and holes in the nasal septum. Ingestion of high-levels of chromium (VI) can cause stomach upsets and ucers, convulsions, kidney and iverda m-age. and even death. Skin contact also results in skn ulcers. Other symptoms to exposure include severe redness and swelling of the skin in addition to an increased risk of lung cancer. The'World Health Organization has determined that chromium (VI) is a bumitan eareino-gen. The MCL is set at 0.1 mg/L and the ACGIH TLV is set at 0.5 g/rngm.The NIOSH REL is set at 0.5 ng/r'.

Cobalt Cobalt is a naturally occurring metal that may cause dermatits or pulmonary'damage. This metal is important to hunian health as a part of vitamin B12 and used to treatanenia. However.high levels of exposure severely affect the lungs. Symptoms often seen from inhalation include: cough, breathing diff iculty. wheezing, decreased pulmonary function. weight loss, dermatitis, respiratoryhypersensi-tivity. and asthma. Ingestion of soluble salts produces nausea and vomiting. The IARC has determined that cobalt is a probable car-cinogen. The ACGIH TLV and NIOSH REL are set at 0.05 mgWm'.

Copper Copper is an essential element forafl living things. This metal is also a potentially explosive chemrical. Liquid copper explodes on contact with water. Symptoms often seen include: nausea and vomiting. di-anrhea, stomach cramps, irritation to the eyes and respiratory system.

cough, difficulty breathing. and wheezing. The IARC has determined the earcinogenicity of this chemical Is unknown. ThecACGIH TMV and NIOSH REL are set at I mg/m'. --

Fluoride Fluoride is a pale, yellow-green gas that has a strong sharp odor. Fluo-rides are found throughout the environment at very low levels. Inha-lation of high-levels of hydrogen fluoride gas causes damage to the lungs and heart and can even lead to death. Low-levels of hydrogen fluoride gas can irritate the eyes, skin, and lungs. Low-leveis of so-dium fluoride do help reduce tooth cavities, while high levels of so-dium fluoride are dangerous to one's health. The earcinoginicity of fluoride has not been determined. The MCL is set at 4 mg/L. but the ACGIi TL"' has not been determined..

28 July 2005 '.- A-467 NUREG-1437, Supplement 22

Appendix A Lead Lead naturally occurs in the crust and is found throughout the envi-ronment. This clement is used for many purposes and can affect nearly every organ and system of the body. It typically entcc the drinking watersupply through contact of wntrvwith corroded materi-als containing lead. The effects of inhalation and ingestion are the samc; however. the major systerns affected by lead poisoning include the nervous system, blood system, and kidneys. Symptoms of lead poisoning include decreased reaction time, muscle wcakness, loss of appetite, anemia, malaise, insomnia, headache, irritability. muscle and joint pains, tremors, flaccid paralysis without anesthesia. hallucina-tions, and distorted perceptions. Lead poisoning greatly diminishes the intellectual capacity o chlldren. creates delays in normal physi-cal and mcntal development in babies and young children, and slight deficits in attention span. T1he LUS DHHS has determined that more information is needed to determine the carcinogenicity in humans.

Te ,MCL has not been determined for this chemical, but the ACGIH TLV has becn set at 0.1S tngml. The NIOSH REL is set at 0.05 mgtm'.

Manganese Manganese is a naturally occuning metal that is critical to human health in tracc amounts. This chemical reacts violently with certain compounds. Symptoms often seen include: degenerative brain changes, change in motor activity, muscle weakness, insomnia, mcn-tal confusion, metal fume fever, dry throat, cough, chest tightness, breathing difficulty. vomiting, malaise, kidney damage. and a skin and eye irritant. The carcinogenicity of this chemical is probable.

High levels of exposure include mental and emotional disturbances and slow and clumsy body movements. The EPA has determined the carcinogenicity to be unclassifiable. TheACGIHTLV is set at 5 rig/

i. The NIOSH REL is set at I mgtrn?.

Mercury Mercury occurs naturally in the environment occupying several rms.

The nervous system is greatly affected by this element. High-klvels ofexposure can lead to permanent damage of the brain, kidneys, and developing fetus. Other limited effects of long-term effects result in irritability, shyness, and tremors, changes in vision or heating and memory problems, This chemical is corrosive to skin, eyes, and mu-cous membrancs. Symptoms of cxposure may include gastrointcs-NUREG-1437, Supplement 22 A-468 July 2005

Appendix A tinal disturbance, muscle weakness, anorexia, weight loss, headache, tinnitus, hypermoHity, diardwha, liverchanges. derratitis. and fevers.

Mercury builds up in the tissues of fish and can then be ingested by humans. The carcinogenic effect of all forms of mercury is unknown.

However. the EPA has determined that mercuric chloride and meth-ylmercury are possible humaucarcinogens. The MCLis set at .002 mg/Land the ACGIH TLV is set at O.05 mg/m. The NIOSH RELis set at 0.05 mg/rn'.

Molybdenum Molybdenum isi a poison and an experimental teratogcn. Syniptoms often seen in animals include irritation to the eyes, nose, and throat.

anorexia, diarrhea, weight loss, listlessness, liver, and kidney dam-age. This chemical reacts violently with oxidants. The ACGIH TLV is set at5 rngm'. - -

Nicekd Nickel is an abundant, hardsilvery-white metal found in nature with no characteristic odor or taste. Uses for nickel are expansive and include platingjwelry, and as catalysts forchemical reactions. Small amounts of nickel are possibly essential to human life. - Contact to skin may include allergic contact dermatitis, pulmonary asthma, con-junctivids, and inflammatory reactions. Inhalation of high-levels of nickel affects the lungs, including chronic bronchitis and reduced lung function. Ingestion ofhigh-evels of nickel affects the stomach. blood, and kidneys. The US DHHS has determined that nickel isaprobable carcinogen. The MCL has not been determined for this chemical, but theACGIHTLVissetat I mg/Wr. TbeNIOSHRELissetat0.0lS mgfmi. - '-- 1 Potassium - T c  ;

Potassium is an essential dietary element. This chemical is a danger-ous rim hazard. Ingestion of excessive amounts results in kidney failure. nausea, vomiting, abdominal discomfort, diarrhea, heart ar-rhythmia leading to cardiac arrest, muscular weakness, and tempo-rary paralysis.. -

Selenium - - - ... -

Selenium is found in the environment in rocks and soil. Inhalation of sclenium can result in soreness, coughing. labored breathing, and lung edema. Symptoms of exposure to high-levels include: dizziness, fa-tigue. irritation, collection of fluid in the lunes. and severe bronchi:

30-July 2005 .A-469 J 5NUREG-1 437, Supplement 22

Appendix A uis. Ingestion ofhigh-levels could rcsult in irritadoa to the mouth and throat, in addition to nausea gastrointestinal disturbance, and vornit-ing. Other results of exposure include brittle hair. anemia, cirrhosis, deformed nail, and even dcath Contact with skin results in rashes, swelling, and pain. Chronic exposure might result in pallor, nervous-ncss, depression, garlic odor orbreath and swvar, gastrointestittal dis-turbances, and dermatitis. The US DHHS has declared that seleniumn sulfide is a probable carcinogen. The EPAhas declared that the car-cinogenicity of selenium compounds is not classifiable. Thc MICL is set at .05 mg/L and theACGlH lLV is set at .2 mgrn?. The NIOSH REL is set at 0.2 mg/rn.

Silver Silver occurs naturally and is typically found in the environrmnt com-bined with other elements. Uses primarily inchudc jcwelry, brazing alloys and solders, disinfectant of drinking water and water in swim-ming pools, and as an antibacterial agent Inhalation of Ngh-kvels may lead to lung and throat irritation, and stomach pains. Ingestion of high-levels may result in death. Skin contact may result in a rash.

swelling, and inflammation. Exposure at low-levels may result in the deposition of silvc into the ski Long-tenm exposure at high-levels may lead to arygria. a discoloration of the skin and other body tis-sues. The earcinogenicity of silver is unknown for humans. The MCL is not determined for this chemical, but the ACGIH TnV isset at 0.1 mgtm. The NOSi REL is set at .l mgrni.

T'in Tin is a natural element in the earths crust. It is a soft. white, silvery metal that doesn't dissolve in watcr, 1in is used mainly to make cans.

The EPA has limited Its use in paints. Large amounts of tin com-pounds can cause stomachaches. anemia, liver and kidney problems.

Breathing or swallowing this chemical can cause breathing problem.

eye irritation, and can interfere with the way yotr brain and nervous system wodt In severe cases, it can cause death.

There is no evidence that tin or tin compounds cause cancer in hu-mans or animals. and tin hasn't been classified for carcinogenicity.

The .MLChasn't been determined for this chemical. Both the ACGIH TLV and the NIOSH REL are set at 2 mg/mr'.

Thallium Thalliutn is a radionuclide found in nature. Ingestion of this chemical results in nerve or sheath structural changes, extra-ccular muscle "4

A-470 July 2005 NUREG-1437, Supplement 22

Appendix A changes, sweating. and other efftcts. The MCL is set at 0.002 mg/L

.. and thc ACGIIl TLV isst at 0.1 mg/m.-

Vanadium  ;

Vanadium has a variable toxicity. Exposure to this chemical results in conjunctivitics, rhinids, reversible irritationism of the respiratory tract. bronchitis. bronchospasms. and asthma-like diseases in more severe cascs. Thc MCL and ACGIH TLV have not been detcrrined for this chemical. .  : -

Z7inc.

Zinc is a skin irritant. Symptomsn often seen include: cough dyspnca, sweating, throat dryness. swcet taste in mouth,eough,k eakncss. aches, chills. fever, nausea, and vomiting.

Pesticides After the publication of Rachel Carson's book Silent Spring In J 962, concern arose for the use of chemical pesticides entering the food chain. Pesticides are toxic to living organisms and yet little Is lknown about the extent of health effects on humans. Despite the obvious benefit to eradicating disease-carrying and crop-eating insects, the behavior ofsuch chemicals is not completely understood. It is known that pesticides accumulate in fat deposits in the body. 'A mode of excretion occurs through breast milk, thereby trantferring the harm-ful chemicals ingested from mother to child. Pesticides greatly affect the developing fetus, infants and young children. Health effects re-sulting from exposure cause serious diseases and disorders, damage to the nervous system, reproductive system and other organs. devel-opmental and behavioral abnormalities. disruption of normal honmonal function. and immune dysfunction. - ..

Acrylonirile Acrylonitrile is synthetic material used to taike other chcmicals. In the past. acrylonitrile was combined with carbon tetrachloride for use as a pesticide. Symptoms often seen include: conjunicive kritza.

don. somnolence, general anesthesia, cyanosis, diarrhca,'incicased salivation, photophobia, deepened respiration. nausei, vomiting.

weakness, headachejaundice, anemia, nose and eye irritant. and Icu.

eocytosis. The effect that this chemical has on the human body in-32 July 2005 A-471- NUREG-1 437, Supplement 22..

Appendix A hibits respiratory enzymes of tissue and renders the tissue cells inca-pable of oxygen absorption. This chemical is carcinogenic The US DHHS has determined that acrylonitrile is a probable carcinogen.

The ACGIH LV is set ax2p Thc leNIOSH REL is set at I ppm.

Aldrin and DieIdrin Aldrin and DieIdrin are chemicals that arm similar in nature and in effect on humans. In pure form, both are white powders with a mild chemical odor and do nor occur nantrally in the environment Aldrin quickly breaks down into diciduin in the body and in the environ-ment. By 1957 all uses of these chemicals were banned. including the use as a pesticide and for termite control. These chemicals mainly affect the central nervous system. Ingestion of significantly high-levels of these chemicals results in buildup, convulsions, coma and even death. The effects of low-levels of exposure include headaches, dizziness, vomiting, irmtability, uncontroled muscle movements. The IARC has determined that both aidrin and dieldrin are not classifi-able as to their carcinogenicity to humans. The MCL has not been determined for these chemicals. TheACGIH TLV and NIOSH REL for both aldrin and dicldrin is set at 0.25 mginr.

Alpha BIIC Alpha BHC. also known as Benzene Hexaehloride-aipha-isomer. is a poison by ingestion. This chemical is a confrumed carcinogen with experimental carcinogenic. tumorigenie. and neoplastigenie data. The MCL and ACGIH TiV have not been determined for this chemical.

Beta BHC Beta BHC is also known as trans-alpha-benzenchexschloride. This chemical is a conrumcd carcinogen with xperimental neoplastigenic data. Ingestion of Beta BHC is mildly toxic. The MCL and ACGIH TLV have not been detennined for this chemical.

Chlordane Chlordane is a thick liquid whose color ranges from colorless to am-ber with a mild and irritating smell that was manufactured for use as a pesticide. Uses of this chemical were completely banned in 19SS by the EPA. Although chlordane is not very mobile in soils, it is known to enter the drinking water after application on crops near the water supply intakes or well. Exposure to this chemical affects the nervous system. digestive system, and the liver. It has been found that chlordane Lcks the ability todisrupt hormones by itself but gratly 33 NUREG-1 437, Supplement 22 A-472 July 2005 I

Appendix A magnifies the ability of other chemnicals to disrupt hormoncs. Inhala-tion of high-levels of chilordane include: headaches, irritability, con-fusion, weakness, vision problems. vomiting. stomach cramps, diar-rhea, andjaundice have occurred in people who breathed air contain-ing high concentrations ofchlordanc or accidentally swallowed small amounts of chlordane. Ingestion of high-levels leads to convulsions and death. The IARC has determined that chlordane is not classifi-able as to its carcinogeniciy tohumans. The MCLisseetat O.02mg/ 3 L and the ACGIH TlV and NIOSH REL are set at 0.5 mgfm .

DDD DDD, also known as 1,1-bis(4-chloropbenyl)-2.2-di-chloroethane, was once used asapessicide. Uses for this chemical have been banned.

This chemical contaminates DDTprodus and DDT typically breaks down into DDE or DDD. The nervous system is greatly affected.

Symptoms often seen include: excitability, tremors, and seizures.

Ingestion results in poisoning. The US DIHHS has not determined the carcinogenicity for DDD. This pesticide is a known carcinogen.

DDE DDE, alsoknovn as Z2-Bis(p-Chkonpheyl)l:I.-Di-Chloroethylcne, sometimes is a contaminant for DDT products with no commercial use. The US DHHS has not classified DDE as to the carcinogeniciry to humans. The EPA has determined that this chemical is a probable carcinogen. The MCL and ACGIH TLV have not becri determined for ths chemical. "

DDr -r DDT, also called 1,1,1-trichloro-2.2-bis(p-chlorophenyl)cthane, is a manufactured chemical used as a pesticide. This chemical is a white, crystalline solid with no odor or taste. The use of this chemical was banned in the United States, aside from public health emergencies.

Symptoms of exposure may include irritation to the eyes and skin, anxiety, dizziness, confuslon, discomfort, headache, veakness and exhaustion convulsions. onmiting. excitability, tremors, and seizures.

Long-term exposure to this chemical affects the nervous system and results In changesin the levels ofliver enzymes: Tbe US DHHS has determined that this 6hemical is a probable human carcinogen. Thc MCLhas noi been determined forthischemical,buithe'ACGIH nLV 3

issetatlngIm . The NIOSHRELis setatO.Smgim'n. ' <

34 July 2005 A-473 - NUREG-1437, Supplement 22

Appendix A DI-n-butyl phthalate Di-n-butyl phthalate exposure symptoms often seen Include: cye. stom-ach. and upper respizatory irritation, hallucinations, distorted percep.

dons. nausea orvomiting, and kidney. ureteror bladderchanges. The ACGIH TLV and NIOSH REL arm set at 5 mg/m`.

Dicambs Dicamba. also known as 2-.Maethoxy-3,6-Dichlorobcozoic Aeid, is rnoderately toxic by ingestion. The tCL and ACGIH TLV have not been deternmined for this chemical.

1,2-Dlchloroethane 1,2-Dichloroethane, also known as ethylene dichloride, is a synthetic chemical that is used to make otherchemicals. Symptoms often seew include: somnolence, cough. jaundice, nausea or vomiting.

hypermotlty, diarrhea. ulceration orobelding from the stomach. farty liver degeneration, change in cardiac rate, cyanosis, coma, dermad-ds. edema of the lungs, toxic effects on the kidneys, and severe cor-neal effects The US DHHS, the IARC and the EPA have not classi.

fied the carcinogenicty oi'this chemical. The ACGIH TLY is st at 10 ppm. The NIOSH REL is set at I ppm.

Dinoseb Dinoseb, also known as 2-sec-Butyl-4,6-dinitrophenol, is a widely used herbicide. This chemical enters the drinicing water after appli-cation on orchards. vineyards. and other crops. This chemical is a poison by ingestion and a severe irritant to the eyes. Pathways the chemical may travel into the body include. skin contact, subcutane-ous, and intraperitoneal routes. The carcinogenicity is questionable with experimental tumorigenic dat. The .NCL is set at 0.007 mg/L for the chemicaL while the ACGIH TLV has not been detcrmined.

Endosullan n Endosulfan 11is a pesticide and wood preservative found in solid formn as erystals or flakes. This chemical smells similar to turpentine and does not burn. This chemical affects the central nervous system but does not accumulate significantly in human tissue. Symptoms of exposure may include irritation to the skin, hyperactivity. nausea.

dizziness, headache, tremors, or convulsions, and even death may occur. The carcinogenicity of this chemical is unknown. The M1CL has not been determined for this chemical, but the ACGIH TLV and NIOSH REL are set at 0.1 mgrnm.

35 NUREG-1437, Supplement 22 A-474 July 2005

Appendix A Endothall Endothall is a poison extremely irritating to skin. eyes, and mucus membranes. Symptoms often include: diarrhea.

Endrin  :

Endrin is a pesticide that is i solid, white, almost odorless substance that is banned from use in the United States. This chemical accumu-lates in sediments and aquatic and terrestrial biota.' Exposure to en-drin can cause various harmful effects including death and severe central nervous system (brain and spinal cord) injury. Ingestion of this chemical may cause convulsions and will kill you In a matter of minutes to a maner of hours. This chemical does not accumulate in human tissue. Symptoms resulting from exposure include headaches.

dizzincss, nervousness, confusion, nausea, vomiting. and convulsions.

Effects of inhalation or contact are not known. The EPA has dc-clared the human carcinogenicity to be unknown. The MCL is set at 0.002 mngL and the ACGIH TLV and NIOSH RELare set at 0.1 mg/

in1 .

Gamma-chiordane Gammhachlordanc is no longer permitted for use as a tcnriticide or pesdcide.- Symptoms often seen include. tremors, convulsions, ex-citemeni. diarrhea, jaundice, vomiting, stomach cramps, vision prob-Jerns. ataxia. central nervous system stimulant. and gastritis. The IARC has not determined the carcinogenicity of this chemical. The ACGIH ThLVandNIOSHRELaresetatO.5 mgtm'.

fieptachlor and Heplachior Epoxide (Epoxyhcptachioris),

Heptachior and Hcptachlor Epoxide (Epoxyheptachloris) are manu-factured chemicals found as a white powder that smeD like camphor (mothballs). Heptachlor breaksdoin intohepachlorepoxide. These chemicals were used primarily as insecticides until 1988. Ingestion of heptachlor results in dizziness, confusion, or convulsions. hbe full extent of heptachlor and heptachlor epoxide poisoning are un-Iknown for humans, other than damage to the nervous systenL. Low-levels of exposure have caused liver damage and the symptoms in-clude tremors, convulsions. kidney damage. respiratory collapse, and death. The IARC has determined that heptachlor and heptachlor ep-oxide are not classifiable to their carcinogenicity to humans.-:The MCL for hepmchlor is set at 0.0004 rng1L and the MCi. for hep.

tachlor epoxide is set at 0.0002 rngL The ACGIH TLV has not been determined for these chemicals. The NIOSH REL is set at 0.5 momr.

36 July 2005* A-475 NUREG-1 437, Supplement 22

Appendix A Heptnchlorinated dibenzo-p-dioxins Heptachlorinated dibenzo-p-dioxins is a type of dioxin. Dioxins aw understood to function in a similar manner as a steroid hormone. This implies that the dioxins enter the body and bind to a protein. Acorn.

plex is then formed that attaches to the cell's chromosomes, thereby altering the genetic material and affecting the body in many different ways. The MNICL and ACGIH TLV have not been determined for these chemicals.

Isopropanol Isopropanol is also known as Isopropyl alcohol and is a moderately toxic chemical. Symptoms often seen include: flushing, pulse rate decrease, blood pressure lowering. anesthesia, narcosis, headache, dizziness. mental depression, drowsiness, hallucinations, distorted perceptions, dyspnea respiratory depression. nausea or vomiting, and coma. The ACGIH TLV and NIOSH REL are set at 400 ppm.

Lindane Undanc, also known as benzene hexachloridc. is a pcsticide that mim-ics natural bormones Under favorable soil and climatic conditions, lindane enters the drinking water through runoff of contaminated raterials into surface water or by leaching into the groundwater. In-halatioe results human systemic effects by headache, nausea or vom-iting, and fever. Pathways taken by this chemical into the body in-clude: ingestion, skin contact, and subcutaneous routes. This chemi-cal is more toxic than DDT or dieldrin and is shown to damage the nervous system and circulatory system. Undane is a confirmed car-cinogen with experimental carcinogenie, neoplastigenic, and tumori-genie damt by ingestion and skin contact. The .MCI is set at 0.0002 mg/E, but the ACGIH n.V has not been determined for this hchmi-cal.-

Methykne chloride Methylene chloride is a synthetic material that is also a severe skin and eye irritant Symptoms often seen include:- dizzincss. naisea, decreased attentiveness, paresthcsia. somnolence, altered sleep time, convulsions, euphoria, change in cardiac rate, and a severe eye and skin irritant; The US DHHS. the WHO, and the EPA have deter-mrined that nethylene chloride is a probable carcinogen. lhis chemi-cal is a knomn carcinogen. The ACGIH TLV is set at SO ppm.

37 NUREG-1437, Supplement 22 A-476 July 2005 I

Appendix A Napthalene Napthalcne is a naturally occurring material typically used to make dth insecticide carbaryL Symptoms often seen include: damage to red blood cells, fatigue, lack of appetite, resdessncss, nausca, skin and eye irritant, headache, diaphorcsis, hemannia, fever, anrnia, liver damage. vomiting,renal shutdown.corneal damagc convulsions, and coma. The US DHHS, the IARC, and the EPA have determined the carcinogenicity of this chendcml is not classifrable. TbeACGrHTLV and N1OSH REL ar set at 10ppm.

Pentachlorophenol Pentachlorophenol is a synthcdc chemical that is extremely dangcr-ous and was used as a pesticide. Symptoms often seen include: acute poisoning marked by weakness, changes in respiration, blood pres-sure, and urinary output, dcrmatitis, convulsions and collapse. anor-exa, weight loss, sweating, headache, dizziness, nausea, vomiting, breathing difficulty, chest pain, and livcr and kidncy injury. The EPA and the IARC have determined this chemical to be a probable car-cinogen. This chemical is a known carcinogen. The ACG[H TLV tm and NIOSH REL are set at 0.5 rnmg . - .

Phenol --

Phenol is a synthetic chemical that was widely used as a pesticide.

Symptoms often seen include: severe eye and skin irritation, kidney, liver, pancreas, and spleen damage, edemna of the lungs;'anorexia, weight loss, weakness and exhaustion, muscle ache, pain. corrosion of the lips, mouth. duat,esophagus and stomach, gangrene and even deiad. The careinogenicity of this chemical is unknown. The ACGIH TLV andI.IOSH RELare set at 5 ppmt.

Toxaphene Toxaphene, also known as Ctlorinated Camphene, is ari insecticide that mimics natural hormones. Ingestion and skin contact result in somnolence, convulsions or effect on seizure thOshold coma. and illergic'skindermatitis. Symptoms of exposur may Include nausxa, confusion, agitation, tremor. convulsions. unconsciousness, or dry and redskin. Carcinogenicityoftoxaphencis probablc.The MCLis set at 0.003 mglL and the ACGIH TLV is sct at 0.5 mgmg.

2,4,S-Tn - - -

2,4,5-TP, also known as (2.4.5-Trichlorophcnoxyl)Propmionic Acid,

'is comin6nlytreferrcd to as Silvex. Ingesiion results in poisoning.

July 2005 .. A-477 NUREG-1437, Supplement 22 -

Appendix A The carcinogenicity of Silvex is probable. The NICL is set at 0.05 mngi.. but the ACGIHI ThV has not been determined.

2,4,5.T 2.J.5.T, also known as Z,4.S-trichlorephenoxyactic acid, is readily absorbed through inhalation and ingestion and slowly through con-tact. Effects ofcexposure include: weakniess, letharg. anorexia, diar-:

rhtea. rentricular fibrillation. Chronic exposure can result in cardiac atrest and even death. The NICL has not been determined, but the ACGIH TLV and NIOSH REL are set at 10 mrgrn1.

Xylene Xylemi is a naturally occurring material in petroleurn and coal tar.

This chemnical is a severe skin and eye irritant and greatly affects the brain. Symptoms often seen include: olfactory changes, conjunctiva irritation, puilmonary changes, headaches, lack ot muscle coordina-Lion, dizziness, confusion difficulty breathing. and gastrointestinal discomfort 'This chemical is a dangerous frut hazard when exposed '

to heat or flamne. T'he IARC has determined the carcinogenicity of this chemical is not classifiable. The ACGIHTMY is set at 1 00 ppm.r o-Xylene o-Xylene. also known as 1.2.Dimethylbenzese. is a mildly toxic chemnical. This chernical is a very dangerous fire hazar when ex-posed to heat or flame. Symptoms often seen include: irritation to the eyes, sgin. nose, and throat, dizziness, excitement, drowsiness.

incoordination. staggering gait. corneal vacuolization, anorexia. nau-Sea, vomiting, abdominal pain and dermatitis. T'he ACGIJH TLV and NlOSH REL aresewat IOU ppm.

Radionuclides RPadlonuclides are atoms with structures that are out of balance.

The atoms are continually changing, or decaying, into a mor stable form. The decay process releases energy. otherwise known ais radiation, Any alteration to the delicate balance that atoms maintain affects the structure and stability of the cell, As radiation strikes an atom, die balance is disrupted and the atom, gains a positive or negative charge. These stoma are called ions and the ionizaion of atoms and molecules inside a living cell results in damage to the cell.

39 NUREG-1 437, Supplement 22 A-478 July 2005 I

Appendix A Ionizing radiation results in health problems. There are three _

important types of radiation that cause ionizing radiation: alpha and beta particles, and gamma rays. Alpha particles are large enough particles that the outer layer of dead skit wil prevent the penetra-tion of alpha particles into the human body. -However. if an alpha particle does indeed enter into the lungs. the ionizing energy will -

break through cell walls. These particles have a charge of I2. The positive charge enables these particles to be effective ionizers that travel at relatively slow speeds and short ranges. -

Beta particles are smaller negatively charged particles thiat are the equivalent to electrons. These particles originate in the nucleus whereas electrons originate outside the nucleus. Although beta particles are not radioactive, the atoms that emit the particles re.

The energy and speed result in damage to cells. Solid objects stop these particles easily.

Gamma rays have incredibly high energy and can easily pass through lead and several feet of concrete. These parices don't need to be ingested or inhaled to seriously damage the human body.

Damage brought aboutby exposure to radioactivity results in cancer. All radionudides are known carcinogens. In regards to other chemicals, the carcinogenicity is not always certain.

Plutonium Plutonium is a radionuclide that is extremely dangerous. Pluto-nium-236 is an alpha cmitter. The high radiotoxicity of plutonium determines the toxicity of plutonium compounds in addition to other atoms in the compounds they formn. Any event that fizther spreads this radionuclide into the environment is dangerous to the life and land. This chemical was created expansively in nuclear weapons production and nuckar power plants. -The MCL Is set at 15 pCi/L fl...* .

Strontium  ; - -

Strontium isa radionuclide with similai properties to calciurn.a-Strondurm-90 is a beta emitter The stable form has low toxicity and ignites spontaneously in air. N'Vhen strontium is combined with water or steam. it reacts vigorously to evolve into hydrogen. The MCL is set at 50 pCifL.

July 2005 A-479 NUREG-1 437, Supplement 22.

Appendix A

'torium Thorium is a radionuclide found in nature. Thorium .232 is an alpha emitter. The carcinogenicity of thorium is probable. The MCL.is set at 15 pCi/L Titium Tridtum is a radionuclide that is not an external radiation hazard.

This radionuclide is an alpha ernitter. When tridated water is ingested. the blood distributes the materials equally among all of the body fluids. As a human is exposed to tritium, the soft tissues are irradiated. The MCL is set at 20.000 pCIIL Uranium Uranium is a radionuclide found in the envimonment that is highly toxic on an acute basis. Uranium-238 is an alpha eminer Expo-sure at higb-levels to uranium results in kidney damage, acute arterial lesions, and cancee Soluble uranium compounds can be absorbed rapidly into the body. The MCL is set at 20 pg/L and the ACGIH TLV is set at 0.2 mg/rnm.

ENDNOIES

' Rachel-s Environmental Health News. #640 - Chlorine Chemistry News. March 04. 1999.

2 Rachel's Environmnental Health News. 4498 - Dangers of Chemi-cal Combinations, June 13, 1996 3

htrtn/N.'w cnv mroelrhnctbnn otrhoxics'hreawv rmertal 41 NUREG-1437, Supplement 22 A-480 July 2005 I

Appendix A APPENDIX 1. Abbreviations and Acronyms -

ACGIH- American Conference of Governmental Industrial Hygienists ATSDR -Agency forToxic Substances and Disease Registry DHHS - Department of Health and Human Services DOE - U.S. Department of Energy EPA - Environmental Agency FDA - Food and Drug Administration HR-HazardRating , .

IARC - International Agency for Research on Cancer MCL -Maximum Contaminants Levels (mg/L)

NIOSH - National Institute for Occupational Safety and Health OSHA - Occupational Safety and Health Adminis-tration The OSHA scts permissible exposure limits (PELs) to protect workers against adverse health effects resulting from exposure to hazardous substances.

PAH - Polycyclic Aromatic Hydrocarbon PCB - Polychlorinated biphenyl pCi - pico-Curies. measurement of radioactivity PELs - Permissible Exposure Limits The PELs determined hazardous substances are enforceable, regulatory limits on allow-able indoor air concentrations.

PETN - Pentaerythritol tetranitrate REL - Recommended Exposure Level SMCL - Secondary Maximum Contaminants Levels (mgIL)

TLV -Threshold Limit Value WHO - World Health Organization 42 July 2005 A-481 ^~ NUREG-1437, Supplement 22

Appendix A APPENDIX 2. Glossary i

• Anemia: A decreased ability of the blood to transport oxygen

• Carcinogen: Any substance that produces i or promotes cancer

• Carcinogenldty- Ability to cause cancer

• Irritant. Abnormal reaction to a substance

• Long-term: 365 days or longer i

• Milligram (mg): One thousandth of a gram i

• Ibmor: An abnormal mass of tissue 43 NUREG-1437, Supplement 22 A-482 July 2005

Appendix A APPENDIX 3. Bibliography BWXT.Pantex, LLC. "2000 Site Environmental eport for Pantex Plant", DE-AC04-00AL66620, May 2001: Tables 6.1-62..

Lxwis, Richard J. "Hazardous Chemicals Desk Reference,"

1993.

Olflce or the Federal Registry Nationsl AmThives an eRecords Administration. Code of FedelRguhlations: Pmreciionof EniironmentVolume 40, Parts 100 to 149. Revised as of July 1, 1994: p. 722.742.

Offlce of Water, US EPA: "Drinking WaterStandards and Health Advisories", EPA 822-B1-00001, Summer 2000.

SAM Stoller Corporation. "Final FY 2000 Summary and Progress Report for Groundwater Investigations at DOE Pantex Plant", Volume L.January 29,2001.

,websites:

ATSDR. "lb2FAQs: Frequently Asked Questions about Contaminants Found at Hazardous WVaste Sites5, <htt!Q1I w-,'w~atsdr.cdcIrovhoxfaq.hfmr.

ESER Program. "Gross Alpha Radiation", "Gross Beta Radiation". <hlt;AwstoneresrcmtFactShee#>.

National Institute for Occupational Safety and Health.

"NIOSH Pocket Guide to Chemical Hazards", Pdtt

-vw.cdc.gov/nkioshn tnrpgh1mlm.

US EPA. "Chemicals in the Environment: OPPT Chemical Fact Sheets", April 25,2001, <.cwwwepa.govopptintr/

ractswhtrn>.

US EPA. "Current Drinking WaterStandards", January 23, 2002, <httpl/www.epa.gov/satewvaterlmcl.html>.

July 2005 A-483 NUREG-1437, Supplement 22

Appendix A US EPA. "IRIS Substance List", <hit l//wwwp2a.eovAri' substlnde%,htm>.

US EPA. "List of Contaminants and MCLs", 4tita-s pa2ov/safe2Atr/nwIhImI,<http' /v- - ena IovL

.rtewtedrekcfrrIS .ndf>.

WHO. "Gnideiines for drinking waterquality." <Ich tte wwwewhopInt/water uniantlon hen1t2IGDWO/. -

Reigart, J. & Roberts, J. "Recognition and MAnagement or Pestidde Poisonings", Fiflh Edition, 1999: <h1g:/t wwwmenar Ipvloeav IhretbvhidIhcahandbookW handy p L/dfr. el httpil/vrgis~usioedut-sanduktdpaperigisca/flodC14.htmI 45r NUREG-1437, Supplement 22 A-484 July 2005

Appendix A Radiation Chart Page 1 of 4 Pemet

---  : IeasinCnerIaide, CbuPrtaiyarndOtbi He2tEffects of HurnmEzposueto lonimigRwidikm ltXDO 1.1 _ . r _

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• 5 is 9 10 1 67 1aid Is 16 tola t9 tz221 22 25D25 Z s29 32 33 Jo asX D Jr tat

-m Seiacdtozreupor& ztee ;isu ~r & ~fII (@

Legend for "Percent Increase in Cancer Incidence, Cancer Mortality, and Other Healtl Effects of Human Exposure to Ionizing Radiation"  ;

1. 15 00% increase in incidence of testicular and ovarian cancer in children on Navaho reservation in uranium mining area

2. :S00% increase in bone cancer in children afeeted by uranium .

3. 2500/. increase in leukemia (all ages) in the Navaho population' -

4. 200% increase in each of the following non-cancer effects: miscarriage, infant death, congenital defects, genetic abnormalities, learning disorders.

Baseline for 1-4: Navajo residents living near Uranium facilities were compared to Navajo resider in non-uranium areas

5. 5000/c increase in bith'defects when compared to the national average.

(Southwest Research and Information Center. "Uranium Legacy." The 1%'orkbooA, v 8, no 6.

.Albuquerque,NM: 1983.) - . . v..

6. 4000,o increase in leukemia incidence in the population living downwind of the Pilgrim nuclear poi reactor in Massachusetts in the first 5 years after fuel *as know to have leaked excess radioactivit%

Baseline: Discase in population before and after Pilgrim radioactive releases and comparison to htp://wwnwv.nirs.org/radiation/radcbart.htm 03113/2005 July 2(005 A-485 NUREG-1437, Supplement 22

Appendix A Radiation Chart Page 2 of4 upwind population.

(Morris M. Knorr R. The Southeastern m assachusellsHealth Study 1978-1986-Report of the A'fassacihusents Departmentof PublicHealth.October 1990. See also: Clapp R. Cobb S. et al.

"Leukemia Near Massachusetts Nuclear Power Plant." Letter in Lancer. December 5, 1937.)

7. 300-400% increase in lung cancer in the general population within the plume of the Three Mile Island accident releases S. 600-700%/a increase in leukemia in the general population within the plume of Three Mile Island accident releases Baseline: Disease in population upwind (out of the radiation plume path) is compared to disease in population downwind (in the pollution plume.)

(Wing S. Richardson D. et al. "A Reevaluation of Cancer Incidence Near the Three Mile Island Nuclear Power Plant: The Collision of Evidence and Assumptions." EnvironmentalHealth Perspectives, v 105, no 1. National Institutes of Health. Bethesda, Maryland. January 1997.)

9. 50% increase in childhood cancer incidence in the Three Mile Island area for each 10 millirern increase in radiation exposure per year.

Baseline: Children living with different radiation levels are compared for evidence of disease.E (Hatch M. et al. 'Background Gamma Radiation and Childhood Cancers Within Ten Miles of a U.'

Nuclear Power Plant." InternationalJournalofEpidemiology,v 19, no 3. 1990.)

10. 8000 0h0increase in thyroid cancer in Belarussian children living near Chernobyl, reported 6 years a the meltdown.

Baseline: Comparison of population health before and after the Chemobyl explosion.

(Hudson RL. 'Child Cancers Found to Rise Near Chernobyl." The Wall Street Journal.-September 1992. The article they quote waspublished inMature on the same day and was researchedby the WlVorldHealth Organization.)

Further effects found in victims of the Chernobyl accident less than ten years after the meltd.

II. 500% increase in thyroid cancer in Ukrainian children.

12. 75% increased incidence of heart disease

13. 200% increase in respiratory and digestive disease

14. 200% increase in birth defects

15. 200% increase in spontaneous abortions Baseline: Comparison of population health before and after the Chemobyl explosion (Rupert J. "Illness Tied to Disaster Still on Rise." The Washington Post. June 24, 1995.Ihe reportu was quotingBritain'sImperialCancerResearch Fund The UkrainianHealthMinisoy and the U.:

Nations.)

16. 63% increase in leukemia incidence among workers at Oak Ridge National Laboratories(US) who received very low doses of external (gamma) radiation on the job.

17. 123% increase in leukemia incidence in the same population where there wvere also very low intern doses of radioactivity Baseline: Cohort comparison of worker deaths and radiation exposure levels (Wing S. Shy C. et al. "Mortality Among Workers at Oak Ridge National Laboratory: Evidence of Radiation Effects in Follow-up Through 1984." JAVA, v 265 no 11. March 20, 1991.)

IS. 80%1 increase in eight types of cancer deaths in Department of Energy atomic workers exposed to httpiJ/wwwav.nirs.orgfradiation/radchart.him 03/13/2005 NUREG-1 437, Supplement 22 A-486 July 2005

Appendix A Radiation Chart Page 3 or4 external doses of radiation. Baseline: Various baselines. Usually cohort comparison of workers wi various doses and their deaths from resulting diseases were used. -:

(Mancuso TF. Stewart A. Kneale G. "Radiation Exposures of Hanford Workers Dying From Canci and Other Causes." HealthPhysics, v 33. Pergamon Press,-Great Britain. November 1977.)

19. 200% increase in leukemiain children ofatomicworkers Baseline: The parents of children -%ith cancer were compared for occupation to discern if those adults who worked with radiation hid moi children with cancer than those who worked in otherjobs. - -

(Roman E. et al.2Case-control Study of Leukemia and Non-Hodgkin's Lymphoma Arong Childn Aged 04 years Living in West Berkshire and North Hamnpshire Health Districts." Boot 1993 #306.

20. 287% increase in cancer incidence in children of nuclear workers who received internal radiation ii England Baseline: Theparents of children with cancerwere compared foroccupation to discern if thoseadt who worked with radiation had more children with cancer than those who worked in other jobs.

(Sorahan T.-Roberts PJ. Childhood Cancerand Patemal Exposure to Ionizing Radiation: Prelirnin Findings From the Oxford Survey of Childhood Cancers."AmericanJournalofIndustrialMedicin 23: 343-354. 1993.)

21. 2500/o increase in all cancers among atomic workers

22. 190%/o increase in leukemia incidence ,

-Baseline: General Population  ;

(Kendall. GM. et a]. "Mortality and Occupational Exposure to Radiation: First Analysis of the National Registry for Radiation Workers." BMJv 304: 220-5. 1992.);

23. 500% increase in childhood leukemia in children visiting the beach once a week near the French nuclear reprocessing facility at LaHague - . -  : .

24. 760% increase in childhood leukemia if they ate the local fish regularly

25. 345% increase in childhood leukemia associated with drinking well water from the vicinity of the nuclearfacility

- Baseline: Observed leukemia cases were compared to expected leukemia cases.

(Viel JF. Pobel D. Incidence of Leukaemia in Young People Around the La Hague Nuclear Waste Reprocessing Plant: A Sensitivity Analysis." Statisticsin Medicine. v 14: 2459-2472. 1995.) --

26. 1200% increase in all cancers exist around the Sellafield, (formerly Windscale) reprocessing facilil and of these,

27. 600-1000% increase in leukemia of children whose fathers were exposed to certain amounts of radiation prior to conception

28. 1000% increase in lymphoma was found in children near a reprocessing facility in Cumbria.

Baseline: Local and Area Controls - . ,.

(Gardner et al. Results of Case-control Stud) of Leukemia and Lymphoma Among Young People Near Sellafield NuclearPlant in West Cumbria." RB.Jv 300. February 17, 1990.)

29. 1000% increase in leukemia incidence in children living near a nuclear reprocessing facility Baseline: Children of the same age in the same area prior to the facility's operation.

(Heasman et al. "Childhood Leukemia in Northern Scotland." Lancet, v 1:266. 1986.)

30. 27.3% increase in all cancer deaths among atomic wvorkers exposed to internal doses of radiation Baseline: Comparison of worker deaths and radiation exposure levels.

(Morgenstern H. Froines J. Epidemiologic Study to Determine Possible Adverse Effects to Rocketdyne/Atomics International Workekrs from Exposure to Ionizing Radiation. State of Califorr hnp://S snirs.orglradiation.radchart.htm- -. 0311312005 July 2005 A-487 , NUREG-1 437, Supplement 22

Appendix A

• . Radiation Chart Page 4 of 4 Health and Welfare Agency. June 1997.)

31. 500%,49 increase in leukemia among Utah nuclear bomb test Dowvnwinders

32. 121% increase in thyroid cancer incidence in the same group

33. 200%/a increase in breast cancer

34. 700%rO increase in bone cancer Baseline: Utah Mormons exposed to bomb fallout are compared to'all Utah Mormons.

(Johnson Cl. "Cancer Incidence in an Area of Radioactive Fallout Downwind From the Nevada Te Site." JAMA, v251 n 2: 231-6. January 13, 1984.)

35. a greater then 120%/e increase in thyroid cancer in those who drank milk laced with Iodine-I 31 fron atmospheric nuclear weapons tests Baseline: Estimated cases are based on dose reconstruction where estimated exposures were betwe 6-112 raids per individual child in the bombs' plumes.

(Ortmeyer P. Makhijani A. "Let Them Drink Milk." The Bulletin ofthe Atomic Scientists, Nov/Det 1997.)

36. 200% increase in lung cancer in women who received radiation treatments for breast cancer Baseline: Breast cancer patients treated with radiation were compared to those who were treated o, by other methods.

(Bishop JE. 'Study Links Breast Cancer Treatment to Higher Risk of the Disease in Lungs." The V Street Journal, May 14, 1993: B6.)

37. 66-96% increase in early cancer deaths due to background radiation Baseline: Deaths of children living with different radiation levels are compared for cancer.

(Kneale GW. Stewart AM. 'Childhood Cancers in the UK and their Relation to Background Radiation." Radlationamd Health. 1987.)

This list was compiled by Cindy Folkers & Mary Olson on 4/24/98, Nuclear Information & Resource Service, 1424 16 th St, NW Suite 404, Washington, DC 20036 (202)328-0002 - it is arbitrarily based on what studies are on file at NIRS.

A partial list of non-cancer health effects of human exposure to radiation:

Downs Syndrome Hydrocephaly Microhydrocephaly Cleft Lip and Palate Epilepsy Kidney and Liver Damage Thyroid Disease Low Birthweight Increased Infant Mortality Increased Stillbirth Genetic MutationsiChrom osom al Aberrations Spinal Defects Congenital Malformations http: /Azovnv.nirs.org'radiation/radchart.htm 03/13/2005 NUREG-1437, Supplement 22 A-488 July 2005

Appendix A Richard Emch AMillstone - Notice of Intent to Sue Pane I I

}D7 A6A7e--

From: .cNancyBurtonEsq~aol.comr To: <rftonrc.gov>

/.1 Date: 3121105 12:13PM

Subject:

Millstone - Nolce of Intent to Sue - --

Mr. Emch 1 af0C;'- X/-/-

Please Include this message and the attachmnent In your EIS review.

Thank you. - .1...1 Nancy Burton

. . 7 CONNECTICUT COALITION AGAINST MILLSTONE -

_www.mothbalmlllstone.org_ (httprAlvwwmothbanmfllstoneorg)

COALITION ANNOUNCES SUIT AGAINST MILLSTONE: -

CHARGES ILLEGAL DISCHARGES ENDANGER HEALTH AND ENVIRONMENT

. ;,. ,. .. -  ;':- ^-.

For Immediate Release: March 21, 2005

Contact:

Nancy Burton 203.938-3952 Waterford--The Connecticut Coalition Against Millstone announced today It will bring a federal lawsult to slop alleged Illegal discharges of chemical and radioactive waste Into the Long Island Sound by the Millstone Nuclear PowerStatkin. -

The Coalition served Dominion Nuclear Connecticut, Inc.. owner and operator of the nuclear facility, with a formal notice of Intent to sue, a legal pre-requishe to bring a federal lawsuit under the provisions of the Federal Clean Water Act.

The Coalition's notice alleges that permits Issued by Connecticuts Department of Environmental Protection have expired, were issued beyond DEPis authority and were illegally transferred to Dominion by Northeast Utlilles In 2001.

Dominion and its predecessor, Northeast Utilities, have treated the Long Island Sound as If It were their private nuclear and toxic waste dump.'

sald Nancy Burton, a Coalition leader.

'With this lawsuit, Dominion's dumping days wilt be over. Burton said.

The CoaRition tisled 38 radioactive Isotopes and 146 metals and chemicals - many of them carcinogens - which are believed to be routinely discharged Into the Long Island Sound under permits which have expired or aro illegal.

The Long Island Sound would be spared contamination by these deadly radioactive and toxic agents If the government ordered Millstone to convert to a closed cooling system such as we have advocated since 1999." Burton said.

The links between Millstone's effluent discharges - which are washed by the tides and currents onto the shorelines of Waterford and East Lyme -

and human health effects are established." Burton said.

On March 10. 2005. at a press conference convened by the Coalition. Dr.

Helen Caldicott, a world-recognized authority on the health effects of low-level Ionizing radiation, publicly linked Millstone effluents with the rare jawbone cancer found In Zachary M. Hartley when he was born on December 16.

6 i a Z.,"r July 2005 . A-489 .'- NUREG-1437, Supplement 22 -

Appendix A Richard Emch - Millstone - Notice of Intent to Sue Page 2 1997.

Zachary's mother swam daily during critical months of her pregnancy at the HoleI~n-the-Wall beach on Niantic Say 1.5 miles from Millstone's discharge point Under the permits which the Coalition says have expired and were illegally issued. Millstone Is permitted to discharge radioactive and toxic chemical effluents at heightened concentrations to a 'mixing zone' which Is defined as the area in Long Island Sound within 8.000 feet - or roughly 1.5 miles -

from Its discharge point.

One radfnuclide - cesium-1 37. which Dr. Caldicott Identified as a possible factor In Zachary's jawbone cancer-was found In a fish caught by NU In Niantic Bay In 1997. the year of Zachary's gestation. NU admitted the contamination originated fom= Its effluent releases.

The Coalition is investigating other Instances of cancers which have developed in people who have swum and sunbathed on the Niantic and Watertord shorelines near Millslone.

Note to Editors: The Coalition's Notice od Intent to Sue (10 pages) Is attached.

CC: <ajkl Onrcmgov>. <secyOnrc gov, NUREG-1437, Supplement 22 A-490 July 2005

Appendix A i Rkhard Emch -CCAMNoaicelntentTo~ueDominion32105.cfoc Pa elT CONNECTICUT COALITION AGAINST MILLSTONE

- . - www.mothballmillstone.orp March 21, 2005 Dominion Nuclear Connecticut, Inc.

Millstone Nuclear Power Station 314 Rope Ferry Road -

Waterford CT 06385 Dominion Generation P.O. Box26666 Richmond VA 23261 Re: Notice of Intent to Sue

Dear Sirs:

The Connecticut Coalition Against Millstone ("the Coalition" is an organization uniting statewide clean-energy groups, Millstone.

whistleblowers and families and individuals who reside In Connecticut and elsewhere, Including within the emergency evacuation zone of the Millstone Nuclear Power Station ("Millstone*).

Section 505(b) of the Clean Water Act ("CWA"), 33 U.S.C.

Section 1365(b) requires that sixty days prior to filing a citizen suit In federal court under section 505(a) of the CWA; 33 U.S.C. Section i

1365(a), the alleged violators, the U.S. Environmental Protection Agency and the state In which the alleged violations occur be given notice of the alleged violations.

MPS-83-1 The Coalition hereby places Dominion Nuclear Connecticut, Inc.

and Dominion Generation and their related Dominion corporate i entitles (collectively, "Dominion) on notice pursuant to section 505(b) of the CWA, 33 U.S.C. section 1365(b), that it believes that Dominion has violated and continues to violate "an effluent standard or

• t limitation" under section 505(a)(1)(A) of the CWA, 33 U.S.C. Section 1365(a)(1)(A), by failing to comply with National Pollution Discharge I Elimination System ("NPDES") permit nuimber CT0003253, issued July 2005., A-491 NUREG-1 437, Supplement 22 -

Appendix A i Richard Emche CCAMNoliceintentToSueDomnon32tO5.doc Page 2 MPS-83-1 pursuant to section 402(b) of the CWA, 33 U.S.C. Section 1342(b) by the Connecticut Department of Environmental Protection ('DEP")

pursuant to authority delegated to It.

MPS-83-2 Based on records maintained by the DEP, the Coalition believes that Dominion has discharged and will continue to discharge pollutants into the Long Island Sound in violation of effluent standards or limitations of the NPDES permit Issued on December 15, 1992 in one or more of the following ways:

1. NPDES permit number CT0003253 expired on December 14, 1999 and has been of no lawful effect since such date; accordingly, all effluent discharges otherwise permitted under the terms of the permit since such date have occurred in violation of the CWA effluent standards and limitations;

2. The DEP, commencing on or about 1998 and consistently thereafter, has Issued and renewed 'emergency authorizations for indefinite periods purportedly pursuant to Connecticut General Statutes Section 22a-6(k) for purposes of permitting effluent discharges otherwise disallowed by the 1992 NPDES permit which expired on December 14, 1997 and all in the absence of notice to the public and an opportunity for meaningful public comment; accordingly, all effluent discharges released pursuant to said "emergency authorizations" since 1998 have occurred in violation of CWA effluent standards and limitations. The most recent such "emergency authorization'

("EA"), which Is of indefinite duration, was issued by DEP on October 20, 2000 and has been 1in effect" since such date;

3. On or about April 1, 2001, DEP purported to authorize the transfer of NPDES permit number CT0003253 and the 'EA" from the Northeast Nuclear Energy Company ("NNECO') to Dominion; subsequent thereto, NNECO 'transferred" the expired NPDES permit number CT0003253 and the EA to Dominion;

4. Insofar as DEP lacked lawful authority to transfer the expired NPDES permit and to transfer the EA, insofar as such EA had been issued initially in the absence of legal authority, all 2

NUREG-1 437, Supplement 22 A-492 July 2005 I

Appendix A Richard Emch - CCAMNoticelntentToSueDornknion32105.doc Page 3 effluent discharges reledsed by Dominion since April 1, 2001 Into the Long Island Sound have occurred without legal authority and in violation of CWA effluent standards and limitations; -

5. It appears that DEP issued the EA and Its'predecessor "emergbncy authorizations' In knowing violation of the law, Connecticut General Statutes Section 22a-6(k), which limits the Issuance of emergency authorizations to address discrete events Involving "an Imminent threat to human health or the environment" and not for terms of unlimited duration;

6. On or about December 20, 1999, Arthur J. Rocque, Jr., then-DEP Commissioner, authorized renewal of one such "emergency authorization" concerning discharges from the Millstone Unit 3 nuclear reactor after noting as follows:

HI really hate these [NNECO requests for renewal of emergency authorizations]. Statutes are very limited In what thely) define as 'emergency.' Continuing emergency Is not even contemplated." (Emphasis In original)

A copy of the Internal DEP memorandum on which Rocque wrote such statement in his own handwriting is attached hereto;

7. In September 1999, NNECO pleaded guilty in the U.S. District Court for the District of Connecticut to committing environmental felonies in violation of the terms and conditions of the said NPDES permit number CT0003253;

8. Dominion, through Its corporate-related entities, recently settled an environmental lawsuit brought by the U.S. Department of Justice and the U.S. Environmental Protection Agency for violations of the Clean Air Act for $1.2 billion;

9. On or about March 11, 2005, the Conservation Law Foundation announced Its Intent to sue Dominion's corporate related entities for alleged Illegal discharges of mercury Into the 3

July 2005' A-493 NUREG-1437, Supplement 22

Appendix A IRichard Emch - CCAMNoticolntenZToSueDominion32lO5.doc - Page 4I environment;

10. In consideration of these and other illegal activities carried out by NNECO at Millstone and by Dominion's corporate related entities at Millstone and elsewhere.

Connecticut DEP lacks legal authority to renew the NPDES permit; lI. Dominion routinely discharges radioactive and toxic chemical and metal discharges into the Long Island Sound through its Millstone operations and it has done so continuously since on or about April 1, 2001 to the present;

12. Dominion routinely discharges some or all of the following radionuclides, chemicals and metals into the Long Island Sound, all in knowing and continuing violation of the CWA:

Ag Be-7 Ce-144 Co-57 Co-58 Co-60 Cr-51 Cs-134 Cs-1 37 Fe-55 Fe-59 1-131 1-133 Kr-85 Kr-88 La-140 Mn-54 Mo-99 Na-24 Nb-95 Nb-97 Ru-1 05 NUREG-1437, Supplement 22 A-494 July 2005

• Appendix A IRichard Emrch - CCAMNoltcelntentToSueDominion32105.doc . Pa go 51 Sb-122 Sb-124 Sb-125 Sn-113 Sr-89 Sr-90 Sr-92 TC-99M TC-101 TC-104 Tritium Xe-133 Xe-135 Zn-69M Zr-95 Zr-97 Aluminum Antimony Ammonia Ammonium Hydroxide Arsenic Barium Beryllium Boric Acid Boron Bromide Bulab 6002 Cadmium Carbohydrazide Chlorine Chromium Cobalt Conquor 3585 (methoxypropylamine and diethylhydroxylamine).

Copper Cyanide Dietylhydroxylamine Epichlorohydrin *y-.-

Ethanolomine Fluoride - -

Freon:

July 2005 A-495 .r J NUREG-1437, Supplement 22

Appendix A Richard Emch - CCAMNoticeIntentToSueDominion32105.doc Page 6 Hexavalent Chromium Hydrazine Hydrogen Peroxide Iron Methoxypropylamine Molybdate Molybdenum Nalcolyte Nickel Nitrogen Oil & Grease Phosphorus Selenium Silver Styrene Sulfate Sulfide Sulfite Surfactants Thallium Tin Titanium Tolyltriazole Xylene Zinc Zirconium Acrofein Acrylonitrile Benzene Bromoform Carbon Tetrachloride Chlorobenzene Chlorodibromomethane Chloroethan6 2-Chloroethylvinyl Ether Chloroform Dichlorobromomethane 1, 1-Dichloroethane 1, 2-Dichloroethane 1, 1 -Dichloroethylene NUREG-1437, Supplement 22 A-496 July 2005

Appendix A IRichard Emch - CCAMNolicelntentToSueDominion32105.doc _Page 7 1, 2-Dichloropropane 1, 3-Dichloropropylene Ethylbenzene Methylbromide . . j I

Methylchforide Methylene Chloride I 1, 1, 2, 2, -Tetrachloroethane Tetrachloroethylene Toluene 1, 2-Trans-Dichloroethylene I 1, 1, 1-Trichloroethane 1, 1, 2-Trichloroethane Trichloroethylene Vinyl Chloride i

2-Chlorophenol 2, 4-Dichlorophenol 2, 4-Dimethylphenol 4, 6-Dinitro-O-Cresol 2, 4-Dinitrophenol 2-Nitrophenol i

4-Nitrophenol P-Chloro-M-Cresol I V.

Pentachlorophenol Phenol 2, 4, 6-Trichlorophenol i Acenaothylene Benzidine t Benzo(a)anthracene f, .

Benzo(a)pyrene Benzo(ghi)perylene I . I - I.. i Benzo(k)fiuoranthene . I . . ,- I Bis(2-Chloroethyl) Ether r -, -, -,.j  : ,

4 Bis(2-Ethylhexylphthalate Chrysene r -'-:

Dibenzo(ah)anthracene 1,2-Dichlorobenzene 1.3-Dichlorobenzene r 1.4-Dichlorobenzene 3.3-Dichlorobenzidines Diethyl phthalate 7

July 2005 A-497 NUREG-1437, Supplement 22

Appendix A Richard Emch - CCAMNoticelnteniToSueDominion32105.doc Page a Dlmethyl phthalate Di-n-butyl phthalate 2,4-Dinitrotoulene 1,2-Diphenylhydrazine Fluoranthene Fluorene Hexachlorobenzene Hexachlorocyclopentadiene Hexachloroethane Indenoll ,2,3-ed)pyrene Isophorona Nurobenzene N-Nitrosodimethylamine N-Nitrosodiphenylamine Phenanthrene Pyrene Aldrin Chlordane DDT DDE Dieldrin Endosulfan(alpha)

Endosulfan (beta)

Endosulfan Sulfae Endrin Endrin Aldehyde Heptachlor Heotachlor epoxide Arochlor 1016(PCB)

Arochlor 1232(PCB)

Arochlor 1242(PCB)

Arochlor 1248 (PCB)

Arochlor 1254 (PCB)

Arochlor 1260 (PCB)

Toxaphene Ammonia Benzo(b)fluoranthene Chlorine Hexachlorocyclohexane (Alpha)

Hexachlorocyclohexane (Beta)

NUREG-1437, Supplement 22 A-498 July 2005

Appendix A Richard Emch - CCAMNoticelntentToSueDominion32105.doc Pago 9I Hexachlorocyclohexanie (Gamma) -.

2,3,7,8-TCDD

13. The conduct described herein may involve knowing and

deliberate violation of federal law by Dominion, NNECO and DEP.

R-; -- < .

The Coalition believes that the Millstone discharges as described MPS-83-3 above are causing grave and irreparable harm to the marine environment and to human health and that such conduct Imperils the health and safety of its membership.

MPS-83-4 The Coalition further represents that some or all of the discharges to the Long Island Sound as listed hereinabove are unnecessary; if the Millstone Nuclear Power Station were to convert from a once-through7 to a 3closed" cooling system, some or all of these harmful discharges to the Long Island Sound would be eliminated.

MPS-83-5 The Millstone discharges as described above are believed to be directly associated with the rare jawbone cancer found in Zachary M.

Hartley at his birth on December 16, 1997. The Millstone discharges as described above are believed to be directly associated with a high and increasing Incidence of cancer and related diseases among the human population that resides near the Millstone Nuclear Power Station and utilizes the surrounding beaches at Niantic Bay and Jordan Cove, if not beyond.

The Coalition hereby places Dominion on notice of its grounds for Initiation of legal action pursuant to the Clean Water Act. The Coalition reserves its rights to include any additional violations in the forthcoming complaint. If you have any questions or wish to discuss this matter with us, please do not hesitate to contact us.

Very truly yours, Nancy Burton Please reply to:

Nancy Burton 147 Cross Highway 9

July 2005' A'-499- NUREG-1437, Supplement 22

Appendix A

.Richard Emch - CCAMNoticelntentToSueDominion32105.doc PagioinI Redding Ridge CT 06876 Tel. 203-938-3952 cc:

Northeast Nuclear Energy Company Northeast Utilities Service Company Connecticut Ught & Power Company P.O. Box 270 Hartford CT 06141-0270 Attorney General Department of Justice 10h Street and Constitution Avenue NW Washington DC 20530 Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington DC 20460 Regional Administrator Environmental Protection Agency I Congress Street.

Suite 1100 (RAA)

Boston MA 02114-2023 Hon. Gina McCarthy Commissioner Department of Environmental Protection 79 Elm Street Hartford CT 06106 10 NUREG-1437, Supplement 22 A-500 July 2005 I

Appendix B Contributors to the Supplement

- - Appendix B ' ' ---

Contributors to the Suppleineint The overall responsibility for the preparation of this supplement was assigned to the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Comisioi (NRC). The statement was prepared by members of the Office of Nuclear Reactor Regulation with assistance from other NRC organizations, the Los Alamos National Laboratory, and the Pacific Northwest National I Laboratory.

Name Affiliation Function or Expertise NUCLEAR REGULATORY COMMISSION Richard Emch, Jr. Nuclear Reactor Regulation Project Manager Leslie Fields Nuclear Reactor Regulation Backup Project Manager John Tappert Nuclear Reactor Regulation Section Chief Andrew Kugler Nuclear Reactor Regulation Section Chief Barry Zalcman Nuclear Reactor Regulation Program Manager Michael T. Masnik Nuclear Reactor Regulation Ecology James Wilson Nuclear Reactor Regulation Ecology Jennifer Davis Nuclear Reactor Regulation Project Support Stacey Imboden Nuclear Reactor Regulation Project Support I Harriet Nash Nuclear Reactor Regulation Project Support I Meghan Thorpe- Nuclear Reactor Regulation Project Support I Kavanaugh Samuel Nuclear Reactor Regulation Project Support Hernandez-Quinones Mark Rubin Nuclear Reactor Regulation Severe Accident Mitigation Alternatives, Section Chief Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation Alternatives Nina Barnett Nuclear Reactor Regulation Administrative Support Los ALAmOS NATIONAL LABoRATORY1a)

Ted B. Doerr Task Leader Keeley Costigan Air Quality Brian Colby Decommissioning, Radiation Protection Bruce Gallaher Water Use, Hydrology Samuel R. Loftin Terrestrial Ecology Lisa J. Henne Aquatic Ecology W. Bruce Masse Cultural Resources Dan Pava Socioeconomics, Land Use, Related Federal Programs Vin LoPresti Technical Editor Teresa Hiteman Document Design Jolene Catron Document Design PACIFic NORTHWEST NATIONAL LABORATORYlb)

Jeffrey Ward Aquatic Ecology July 2005 Bali NUREG-1437, Supplement 22

Appendix B Name Affiliation Function or Expertise INFORMATION SYSTEMS LABORATORY Kim Green Severe Accident Mitigation Alternatives Bob Schmidt Severe Accident Mitigation Alternatives (a) Los Alamos National Laboratory is operated for the U.S. Department of Energy by the University of California.

(b) Pacific Northwest National Laboratory is operated for the U.S. Department of Energy by Battelle Memorial Institute.

NUREG-1 437, Supplement 22 B2Jl20 B-2 July 2005 I

Appendix C Chronology of NRC Staff Environmental Review Correspondence Related to Dominion Nuclear Connecticut, Inc.'s Applications for License Renewal of I Millstone Power Station, Units 2 and 3

Appendix C Chronology of NRC Staff Environmental Review Correspondence Related to-Dominion Nuclear Connecticut, Inc.'s Applications for License Renewal of Millstone Power Station, Units 2 and 3 This appendix contains a chronological listing of correspondence between the U.S. Nuclear Regulatory Commission'(NRC) and Dominion Nuclear Conn-cticiut, Inc. (DNC) and other-correspondence related to the NRC staff's-envirorimental review, inder 10 CFR Part 51, of DNC's applications for renewal of the Millstone'Power Station '(Millstone), Units 2 and 3, operating licenses. All documents, with the exception of-those'containing proprietary information, have been placed in the Commission's Public Document Room, at One White Flint North, 11555 Rockville Pike (first floor),-Rockville, MD, and are available electronically frorh the Public Electronic Reading Room found on the Internet at the following Web address:

<http.//www.nrc.gov/reading-rrn.html>. From this site, the public can gain access to the NRC's Agencywide-Documents Access and Management System (ADAMS), which provides text and image files of NRC's public documents in the publicly available records component of ADAMS.

The ADAMS accession number for each document is included below.

January 20,2004 Letter from Mr. David A. Christian, DNC, to NRC submitting the

-m -- -'

-' - applications for the renewal of theropeiating licenses for Millstone Power Station, Units 2 and 3 (Accession No. ML040260070).

January 23,2004 <'NRC Press Release No.04-011 "NRC Makes License Renewal

-. ' Application Available for the Millstone'Nuclear Power Plant"

- (AccessioriNo';ML040230280).

January 28, 2004 NRC staff letter to Mr. David A. Christian regarding the receipt and

' availability of the license renewal apjlidations for Millstone Power Station',

- Units 2'and 3 (Accession No. ML040280258).

..  :  :,. .. . -  : .. ; - i, e . .. ; ; i February 5,2004 NRC staff letter t6 Ms. Mildred Hodge, Library Director, Thames River Campus, Norwich, Connecticut, regarding the maintenance of reference material for public access related to the'Millstone'Power Station license renewal 'environmental review (Accession' No. ML040400181).

July 2005 -- C-1 NUREG-1437, Supplement 22 '

Appendix C February 5, 2004 NRC staff letter to Ms. Judy Liskov, Assistant Director, Waterford Public Library, Waterford, Connecticut; regarding the maintenance of reference material for public access related to the Millstone Power Station license renewal environmental review (Accession No. ML040400209).

February 6, 2004 NRC Press Release No.04-002 UNRC to Hold Public Meeting in Connecticut on License Renewal Application for Millstone 2 and 3" (Accession No. ML040370209).

March 8, 2004 NRC staff letter to Mr. David A. Christian regarding the determination of acceptability and sufficiency for docketing, proposed review schedule, and opportunity for hearing regarding the license renewal applications for Millstone Power Station, Units 2 and 3 (Accession No. ML040680968).

March 17, 2004 NRC staff letter to Ms. Patricia A. Kurkul, Regional Administrator, National Marine Fisheries Service (NOAA Fisheries), Request for List of Protected Species Within the Area Under Evaluation for the Millstone Power Station, Units 2 and 3, License Renewal (Accession No. ML040770760).

March 18, 2004 NRC staff letter to Mr. Marvin Moriarty, Regional Director, U.S. Fish and Wildlife Service, Request for List of Protected Species Within the Area Under Evaluation for the Millstone Power Station, Units 2 and 3, License Renewal (Accession No. ML040780653).

March 25, 2004 Memo from Mr. Richard Gallagher, Dominion, regarding telecommunication on March 22, 2004 to NRC requests for Documents which Pertain to the Study of the Winter Flounder Population in the area around Millstone (Accession No. ML040930048).

March 29, 2004 Memo from Mr. Richard Gallagher, Dominion, regarding telecommunication on March 22, 2004 to NRC requests for Documents Pertaining to the Study of the Winter Flounder Population in the area around Millstone (Accession No. ML040930259).

March 30, 2004 NRC staff letter to Mr. Paul Loether, Director, Connecticut Historical Commission, regarding Millstone Power Station, Units 2 and 3, License Renewal Review (Accession No. ML040900503).

NUREG-1 437, Supplement 22 C-2 July 2005 I

Appendix C March ~31, 2(oX4 - -' 'NRC staff letter to Mr. David A. Christian' Senior Vice President and Chief Nuclear Officer, DNC, Notice of Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process for License Renewal for the Millstone Power Station, Units 2 and 3 (Accession No. ML040920231).

I April 8, 2004 NRC staff letter to Mr. Dona Klima; Dir6ctor, Office of Federal Agency Programs, Advisory Council on Historic Preservation, Regarding Millstone Power Station, Units 2 and 3, License Renewal Review (Accession No. ML041000158). - -

iI April 12, 200)4 Notice of Public Meeting'to Discuss Environmental Scoping Process for Millstone Power Station, Units 2 and 3, License Renewal Application

'(Accession No. ML041050788).

April 14, 200 4 NRC staff letter to the Honorable Matthew Thomas, Chief Sachem, Narragansett Indian Tribe, Request for Comments Concerning Millstone Power Station, Units 2 and 3, Operating License Renewal (Accessiorn No. ML041050878)-.

April 14, 200 4 NRC staff letter to the Honorable Michael J.'Thomas, Chairman, Mashantucket Pequot Tribal Nation, Request for Comments Concerning Millstone Power Station, Units 2 and 3, Operating License Renewal (Accession No. ML041050880).

April 15, 2004 Letter from Mr. Michael J. Amaral, U.S. Fish and Wildlife Service, providing a response to the March 18, 2004, NRC staff letter requesting information regarding threatenied and endarigered species in the vicinity of the Millstone Power Station, Units 2'and'3'(Accession No. ML041190230). -'

April 16, 2004 Memo from Mr. Richard Gallagher, DNC to NRC, regarding email on April 15,2004, requesting documents pertaining to the study of the winter

flounder population in the area around Millstone (Accession No. MLO41120271). -

April 19, 2004 Email to Mr Ted B. Doerrfrori NRC, providing comments regarding the Site Audit Needs (Accession N.'NMLO41240396).

July 2005 C-3 NUREG-1437.. Sunolement

,, . 22_

Appendix C April 26, 2004 Email to Mr. Richard Gallagher from NRC, regarding questions and comments on the List of Onsite Data Needs (Accession No. ML041240402).

April 27, 2004 Letter from Mr. Charles H. Evans, Director, Connecticut Department of Environmental Protection, Office of Long Island Sound Programs to NRC and Dominion regarding coastal zone consistency concurrence (Accession No. ML041320497).

i April 29, 2004 Email from Richard Gallagher, Dominion, to NRC, requesting additional II I

information regarding severe accident mitigation alternatives review for I Millstone (Accession No. ML041240405).

I May 11, 2004 NRC Press Release No.04-030 "NRC Seeks Public Input On Environmental Impact Statement For Proposed Millstone Nuclear Plant License Renewal" (Accession No. ML041320568).

I May 18, 2004 NRC Public Meeting Feedback Form "Public Scoping Meetings to Discuss Environmental Issues Pertaining to the Application for License Renewal of Millstone Power Station, Units 2 and 3" (Accession No. ML041700578).

I May 24, 2004 Note to file regarding the docketing of additional documents pertaining to winter flounder in support of the environmental review of Millstone Power Station, Units 2 and 3 license renewal application (Accession No. ML041460138).

May 24, 2004 Note to file regarding the docketing of additional documents pertaining to winter flounder in support of the environmental review of Millstone Power Station, Units 2 and 3 license renewal application (Accession No. ML041460283).

May 24, 2004 Note to file regarding the docketing of emails sent to DNC in support of the environmental review of Millstone Power Station, Units 2 and 3 license renewal application (Accession No. ML041460250).

May 24, 2004 Comment letter from the Honorable Fred W. Thiele, Jr., Assemblyman, regarding the environmental review of Millstone Power Station, Units 2 and 3 license renewal application (Accession No. ML041620373).

NUREG-1437, Supplement 22 C-4 July 2005

Appendix C June 1, 2004 Note to file regarding the docketing of documents pertaining to winter

- flounder in support of the environmental review of Millstone Power Station, Units 2 and 3 license renewal application'(Accession No. ML041560169). -

June 1,C. 2004  ; Email from Mr. Charles D. Stephani providing scoping comments regarding Millstone Power Station, Units 2 and 3 license renewal review (Accession No. ML041770290). -' ' -

June 2, 2004' '7' Email from Hortense and Ralph'Carpenter providing scoping comments

- ; regarding Millstone 'Power Station,- Units 2 and 3 license renewal review

'Accession'No.' ML041770288).

June 3, 2004 Email from Kelly L. Streich providing scoping comments regarding Millstone Power Station, Units 2 aid 3 license renewal review (Accession

-No. ML041770177).

June 4, 2004 Email from Mr. Douglas Schwartz providing scoping comments regarding Millstone Power Station,' Units 2 and 3 license renewal review

- (Accession No. ML041770175).

June 4, 2004 '- Letter from Ms. Nancy Burton, Esq., to NRC staff regarding the Millstone Power Station, Units 2 and 3 license renewal review (Accession No.

MIL041770182).

I IJune 22, 2004' NRC sitaff letter to Mr. David A. Christian,'DNC, forwarding request for additional information 'regarding severe accident mitigation alternatives for the Millstone Power Station, Units 2 and 3 license renewal review (Accession No. ML041740175). -' '

. -  !- -.... **_I IJune 24, 2004 Summary of Public Scoping Meetings'to Support Review to support the review of Millstone Power Station, Units 2 and 3 license renewal review

- (Accession No. ML041830272). -' - K "- -'-

I .July 27, 2004 NRC letter to DNC forwardirig the summary of site audit to support the review of Milstone Power Station; Units 2 and 3 license renewal review (Accession No. ML042100293).

I' July 28, 2004 Letter from First Selectman Paul B. Eccard, Town of Waterford, to NRC regarding Millstone Power Station, Units 2 and 3 license renewal review (Accession No. ML042160111).

July 2005 C-5" NUREG-1437, Supplement 22

Appendix C I

I August 13, 2004 Letter from Leslie N. Hartz, DNC, to NRD forwarding response to request for additional information regarding Millstone Power Station, Units 2 and 3 license renewal review (Accession No. ML042320613).

August 17, 2004 NRC staff letter to Mr. Paul B. Eccard, acknowledging receipt of comments regarding Millstone Power Station, Units 2 and 3 license renewal review (Acces-,on No. ML042320342).

I August 27, 2004 NRC staff letter to Mr. David A. Christian, DNC, forwarding the environmental scoping summary report associated with the staff's review of Millstone Power Station, Units 2 and 3 applications (Accession No. ML042400543).

September 16, 2004 Email correspondence between NRC staff and DNC regarding the SAMA review for Millstone Power Station, Units 2 and 3 applications (Accession No. ML042710222).

I I September 21, 2004 Letter from Ms. Mary A. Colligan, NOAA Fisheries, to P.T. Kuo, NRC, providing a response to the March 18, 2004, NRC staff letter requesting information regarding threatened and endangered species in the vicinity of the Millstone Power Station, Units 2 and 3 (Accession No. ML042810294).

September 24, 2004 Summary of telephone conference conducted with the Town of Waterford regarding Millstone Power Station, Units 2 and 3 applications (Accession No. ML042710257).

September 24, 2004 Summary of telephone conference regarding the SAMA review of Millstone Power Station, Units 2 and 3 applications (Accession No. ML0427110529).

October 6, 2004 Letter from Mr J. Paul Loether, Connecticut State Historic Preservation Officer, to P.T. Kuo, NRC, providing comments regarding Millstone Power I Station, Units 2 and 3 License Renewal Application effect on historic properties (Accession No. ML042880497).

NUREG-1437, Supplement 22 C-6 July 2005.~

Appendix C October 6, 2004 Letter from First Selectman Paul B. Ec6ard, Town of Waterford,-to

-Richard L. Emch, Jr., NRC, response to September 24, 2004, letter from NRC regarding Millstone Power Station, Units 2 and 3 license renewal review (Accession No. ML043210191).

October 25, 2004 4 Note to File from Richard L. Emch, Jr.','NRC.

Subject:

Summary of Telephone Conference Regarding SAMA Analyses Conducted on October 7, 2004, with Dominion'Conne6ticut'Nuclear, Inc. In Support'of the Environmental Review of the License Renewai Application for Millst6oe Power Station Units 2 and 3.-(Accession No. ML043000449).

October 29, 2004 Note to File from Richard L. Emch,-Jr.,;NRC.

Subject:

Correction of Summary Dated September 24, 2004,'of Telephone Conference Regarding SAMA Analyses Conducted on September 13, 2004, with Dominion Connecticut Nuclear,]Ind.-in-Support of the Environimental'--

Review of the License Renewal Application'for'Millstone Power Station Units 2 and 3. (Accession No. ML043030362).

November 9, 2004 NRC staff letter to Ms. Patricia A. Kurkul, Regional Administrator, NOAA Fisheries, Request for Concurrence - Biological Assessment for Millstone Power Station, Units 2 and 3 (Accession No. ML043170594).

November 9, 2004 NRC staff letter to Mr. Marvin Moriarty, Regional Director, U.S. Fish and Wildlife Service, Request for Concurrence - Biological Assessment for Millstone Power Station, Units 2 and 3 (Accession No. ML043170643).

December 2, 2004 NRC staff letter to U.S. Environmental Protection Agency, Filing of Draft

- ':: i- - Supplement 22 to NUREG-1437 (Accession No. ML043370472).

December 2, 2004 NRC staff letter to Mr. David A. Christian, Senior Vice President and

-- -

--- Chief Nuiclear Officer, Dominion Nuclear Connicticut, In., Notice of Availability'of Draft Supplement 22 to NUREG-1 437 (Accession No. ML043370478).

December 9, 2004 NRC press release announcing the publidcmeeting regarding the Draft Supplement 22 to NUREG-1437 (Accession No. ML043440093).

December 20, 2004 NRC memorandum regarding the publi6 meeting for the Draft Supplement 22 to NUREG-1437, including the meeting agenda and I- .  :

-*notice (Accession No: ML043560137) .'- - ' . -

July 2005 C-7 NUREG-1437,'Supplement 22

Appendix C January 5, 2005 Letter from Mr. Michael J. Amaral, Endangered Species Specialist, U.S.

Fish and Wildlife Service, to Mr. P.T. Kuo, NRC, Concurrence and consultation closure (Accession No. ML050210354).

January 11, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, requesting copies of RAls and RAI responses (Accession No. ML051330301).

January 12, 2005 Letter from Ms. Patricia A. Kurkul, Regional Administrator, NOAA Fisheries, to P.T. Kuo, NRC, Millstone Power Station, Units 2 and 3 license renewal (Accession No. ML051021054).

January 23, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, submitting a FOIA request (Accession No. ML051330300).

January 31, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding FOIA response schedule (Accession No. ML-051330298).

February 2, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions about the DSEIS (Accession No. ML051330296).

February 2, 2005 NRC staff letter to Mr. Joshua Y. Horton, Supervisor, Southold Town, response regarding Millstone Power Station, Units 2 and 3 license renewal review (Accession No. ML050340609).

February 4, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions about the DSEIS (Accession No. ML051330292).

February 8, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions about the DSEIS (Accession No. ML051330285).

February 10, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions about the DSEIS (Accession No. ML051330297).

February 10, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions about the DSEIS (Accession No. ML051330293).

February 15, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions about the DSEIS (Accession No. ML051330290).

February 18, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding the schedule for meeting transcripts (Accession No. ML051330286).

NUREG-1437, Supplement 22 C-8 July 2005

Appendix C February 18, 2005 Email from R. Emch, NRC, to Ms. Nancy Burton including attached transcripts from the public meeting (AccessionNo. ML051330034).

February 21, 2005 Email from Ms. Nancy Burton to A. Kugler, NRC, regarding questions about the DSEIS (Accession No. ML051330352).

February 23,'2005 Email from R. Emch, NRC, to Ms- Nancy Burton regarding questions

- about the DSEIS (Accession No. ML-051330072).

February 23, 2005 Email from R. Emch;-NRC, to Ms. Nancy Burton regarding questions about the DSEIS (Accession No. ML051330077).

February 24, 2005 Email from Ms. Nancy Burton to A. Kugler, NRC, regarding questions if about the DSEIS (Accession No. ML051330349).

February 24, 2005 Email from Ms. Nancy Burton to R. Ernch, NRC, regarding questions about the DSEIS (Accession No. ML051330141).

February 24, 2005 '

Email from A. Kugler, NRC, to Ms. Nancy Burton regarding'questions about the DSEIS (Accession No. ML051470090). -

February 24, 2005 Email from R Erch, NRC, to Ms. Nancy Burton regarding questions about the DSEIS (Accession No. ML051330083).-

February 24, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions about the DSEIS (Accession No. ML051330138).

February 25, 2005 Summary of the public meeting for the Draft Supplement 22 to-NUREG-1437 (Accession No. ML050610357).'

February 28,'2005 Ermail from Ms. Nancy Burton to' A: Kugler,'NRC, requesting extension of

-:  ;- - the comment period (Accession No.' ML051330135).

February 28, 2005 ' Email from Ms. Nancy Burton to the NRC Commissioners requesting

-- extension of the comment period (Accession No. ML050670486).

I _ ' -, ~- ' C 'C '-E!'

February 28, 2005 Email from R.-Emch, NRC,' to Ms.' Nncy Burton regarding request for extension of the comment period (Accession No. ML051330040).

March 9, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions about the DSEIS (Accession No. ML-051330132).

July 2005 I _-

C-9 NUREG-1437. Sunplement 22

---

-- - --- w -- rr--

Appendix C March 9, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, inviting the NRC to a press conference (Accession No. ML051330126).

March 9, 2005 Email from R. Emch, NRC, to Ms. Nancy Burton regarding her FOIA request (Accession No. ML051330143).

March 10, 2005 Email from A. Kugler, NRC, to Ms. Nancy Burton declining her invitation to the press conference (Accession No. ML05133032).

March 11, 2005 Email from Ms. Nancy Burton to A. Kugler, NRC, sending a news article about Millstone (Accession No. ML051330118).

March 11, 2005 Email from Ms. Nancy Burton to A. Kugler, NRC, sending a news article about Millstone (Accession No. ML051330115).

March 11, 2005 Email from Ms. Nancy Burton to A. Kugler, NRC, sending a news article about Millstone (Accession No. ML051330110).

March 12, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding comments on the DSEIS (Accession No. ML051330097).

March 13, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, requesting a cited reference from the NRC (Accession No. ML051330095).

March 14, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding comments about the DSEIS (Accession No. ML051330088).

March 15, 2005 Email from R. Emch, NRC, to Ms. Nancy Burton regarding questions about the DSEIS (Accession No. ML051330050).

March 16, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, indicating that her supplemental comments are attached (Accession No. ML051330082).

March 16, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, including the supplemental comments that were not attached to previous email (Accession No. ML051330078). [Ms. Burton submitted a corrected version of these comments on March 22, 2005, by email; the corrected version is included in Appendix A.]

NUREG-1437, Supplement 22 C-10 July 2005

Appendix C March 21,2005 -Email from Ms. Nancy Burton to R. Emch, NRC, notifying the NRC of the

- Connecticut Coalition Against Millstone's intent to sue Dominion (Accession No. ML051330092).- - ':- - - I1

-I March 27, 2005 Email from Ms.- Nancy Burton to R. Errich, NRC, requesting information -^

-- -about NRC's offsite visits (Accession No. ML051330075). -I March 28, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions about the DSEIS (Accession No. ML051330079).

March 28, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, requesting a document

-(Accession No. ML051330089).

f , I - . . I . - ,. . .- , , ,

March 28,2005 Email from Ms. Nancy Burton to Commissioner McCarthy, Connecticut I Department of Environmental Protection, regarding the coastal zone I management consistency review (Accession No. ML051330100). I March 28,2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding comments on the DSEIS (Accession No. ML051330103).

March 28, 2005 Email from R. Emch, NRC, to Ms. Nancy Burton regarding closure of the comment period (Accession No. ML051330063).

March 28, 2005 Email from R. Emch, NRC, to Ms. Nancy Burton sending her a requested document (Accession No. ML051330057).

March 30, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, with her attached letter to the editor sent to The New London Day (Accession No. ML051330107).

March 30,2005 Email from R. Emch, NRC, to Ms. Nancy Burton regarding the closure of the comment period (Accession No. ML051330090).

March 30, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding comments on the DSEIS (Accession No. ML051330113).

March 30, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, submitting a press release about Millstone (Accession No. ML051330119).

July 2005 - C-11 NUREG-1437, Supplement 22

Appendix C April 8, 2005 Email from Ms. Nancy Burton to C. Santos, NRC, notifying the Advisory Committee on Reactor Safeguards of documents submitted to the NRC (Accession No. ML051330125).

April 14, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, providing copy of letter from Ms. Burton to Donald W. Downes, Connecticut Department of Public Utility (Accession No. ML051330137).

May 17, 2005 Note to file from R. Emch summarizing telephone conference with EPA, Region 1, on April 5, 2005 (Accession No. ML051380272).

May 17, 2005 Note to file from R. Emch summarizing telephone discussion with representative of Connecticut Tumor Registry on April 8, 2005 (Accession No. ML051380488).

NUREG-1 437, Supplement 22 C-12 July 2005 I

Appendix D Organizations Contacted

Appendix D Organizations Contacted..

During the course of the staff's independent review of environmental impacts from operations during the renewal term, the following Federal, State, regional,]local, and Native American tribal agencies were contacted:'

Chamber of Commerce of Eastern Connecticut, Inc., Gales Ferry, CT Connecticut Commercial Realty, New London, CT Connecticut Department of Environmental Protection, Bureau of Air Management, Division of Radiation, Hartford, CT Connecticut Department of Environmental Protection, Bureau of Waste Management, Hartford, CT Connecticut Department of Environmental Protection, Bureau of Water Management, Hartford, CT Connecticut Department of Environmental Protection, Marine Fisheries Division, Old Lyme, CT Connecticut Department of Environmental Protection, Office of Long Island Sound Programs, Hartford, CT Connecticut Department of Public Health, Connecticut Tumor Registry, Hartford, CT Connecticut Historical Commission, Hartford, CT National Oceanic and Atmospheric Administration, National Marine Fisheries Service, Northeast Fisheries Science Center, Milford Laboratory, Milford, CT Southeastern Connecticut Council of Governments, Norwich, CT Southeastern Connecticut Enterprise Region, New London, CT Town of Waterford, CT U.S. Environmental Protection Agency, Region 1, Boston, MA.

July 2005 -. D-1 NUREG-1437, Supplement 22

Appendix D U.S. Geological Survey, Woods Hole, MA United Way of Southeastern Connecticut, Gales Ferry, CT University of Connecticut, Department of Physiology and Neurobiology, Storrs, CT Waterford Public Schools, Waterford, CT NUREG-1437, Supplement 22 D-2 July 2004

Appendix E Millstone Compliance Status and Consultation Correspondence

Appendix E

. Millstone Compliance Status and Consultation Correspondence Correspondence received during the process of evaluation of the application for renewal of the operating licenses for Millstone Power'Station Units 2 and 3 (Millstone) are identified in Table E-1. Copies of the correspondence are included at the end of this appendix.

The licenses, permits, consultations, and other approvals obtained from Federal, State,- -

regional, and local authorities for Millstone are listed in Table E-2.

Table E-1. Consultation Correspondence Source Recipient Date of Letter U.S. Nuclear Regulatory NOAA Fisheries (P.-A. Kurkul) March 17, 2004 March 2004 18, Commission (P. T. Kuo)

U.S. Nuclear Regulatory U.S. Fish and Wildlife Service March 18, 2004 Commission (P. T. Kuo) (M. Moriarty)

U.S. Nuclear Regulatory Connecticut Historical Commission March 30. 2004 Commission (P. T. Kuo) (Paul Loether)

U.S. Nuclear Regulatory Advisory Council on Historic April 8, 2004 Commission (P. T. Kuo) Preservation (D. Klima)

U.S. Nuclear Regulatory Narragansett Indian Tribe April 14,2004 Commission (P. T. Kuo) (M. Thomas, Chief Sachem)

U.S. Nuclear Regulatory Mashantucket Pequot Tribal Nation April 14,2004 Commission (P. T. Kuo) (M. J. Thomas)

U.S. Fish and Wildlife Service U.S. Nuclear Regulatory April 15,2004 (M. J. Amaral) Commission (P. T. Kuo)

Connecticut Department of U.S. Nuclear Regulatory April 27, 2004 Environmental Protection Commission (R. Emch)

(C. H. Evans)

NOAA Fisheries U.S. Nuclear Regulatory September 21, 2004 I (M. A. Colligan) Commission (P.T. Kuo) I July 2005 E NUREG-1437, Supplement 22

Appendix E Table E-1. Consultation Correspondence (contd.)

Source Recipient Date of Letter State of Connecticut U.S. Nuclear Regulatory October 6, 2004 Commission on Culture and Commission (P. T. Kuo)

Tourism (J. Paul Loether)

U.S. Nuclear Regulatory NOAA Fisheries November 9, 2004 Commission (P. T. Kuo) (P. A. Kurkul)

U.S. Nuclear Regulatory U.S. Fish and Wildlife Service November 9, 2004 Commission (P. T. Kuo) (M. Moriarty)

U.S. Fish and Wildlife Service U.S. Nuclear Regulatory January 5, 2005 (M. Amaral) Commission (P. T. Kuo)

NOAA Fisheries U.S. Nuclear Regulatory January 12, 2005 (P. Kurkul) Commission (P. T. Kuo)

NUREG-1437, Supplement 22 E-2 July 2005

C-

--C Table E-2. Federal, State, Local, and Regional Licenses, Permits, Consultations, and Other Approvals for Millstone 0

0 I Issue Expiratlon

. U, Agency Authority Description Number Date Date Remarks NRC 10 CFR Part 50 Operating license, DPR 09/26175 07/31/15- Authorizes operation of Unit 2.' I Millstone Unit 2 NRC 10 CFR Part 50 Operating license, NPF-49 01/31(86 11/25/25 Authorizes operation of Unit 3. I Millstone Unit 3 USACE, Section 10, River and Permit -- CT-NIAN-78-507 10/11178 No expiration Install andimaintain Harbor Act (33 USC date sandbag dike for ecology 403) laboratory mariculture work.

USACE Section 10, River and Permit CT-NIAN-77-377 09/19177X No expiration Install and maintain Harbor Act (33 USC (LOP) date ecology laboratory seawater 403) intake pipes.

USDOT. 49 USC 5108 Registration l 061202550034KL 06/13/02 06/30/04 Shipment of hazardous materials. I

,m FWS Migratory Bird Treaty Act Depredation Permit MB728673-0 06/07/03 06/30/04 Removal of birds, eggs and (16 USC 703-712) nests from utility structures and property. -

FWS Section 7 of the Consultation 01/05/05 Requires a Federal agency to Endangered Species Act consult with FWS regarding I f (16 USC 1536)

Con sl ato.

whether a proposed action would affect endangered or' I

.I , . ,. , _ threatened species.- K';'"-

NMFS Section 7 of the Consultation 01/12/05 Requires a Federal agency to z Endangered Species Act consult with NOAA Fisheries C

=1 (16 USC 1536) regarding whether a proposed m action would affect endangered G) or threatened species.

-- It

. C c;

CD -a CD , f

-3 CD ED x

. . !- m

z -1 Table E-2. (contd.) W I Ct I, CD Issue Expiration Agency Authority Description Number Date Date

• Remarks 0.

-4 Connecticut Section 106 of the Consultation The National Historic X Historical National Historic m7 cn Preservation Act requires C Commission Preservation Act CA) Federal agencies to take into (16 USC 470f) account the effect of any undertaking on any district, site, building, structure, or object that is included in or eligible for Inclusion in the National Register of Historic Places.

Connecticut Section 307 of the Coastal Consistency The Connecticut Department of Department of Zone Management Act [16 determination with Environmental Protection waived Environmental USC 1456(c)(3)(A)] the Connecticut the review to coordinate with the Protection Coastal State NPDES permit review (CTDEP) Management process.

Program m

CTDEP CGS 4-182, 22a-430, 22a- National Pollution NPDES permit 12/14/92 Renewal application submitted 430-1 et seq. Discharge CT0003263 6113/97; plant discharges to Elimination System Long Island Sound.

Permit CTDEP CGS 22a-430b General Permit for GS1001430 09/25/03 Stormwater discharges; stormwater industrial activities.

discharges CTDEP CGS 22a-6K Emergency EA 0100176 10/13/00 Transferred 3/31/01: plant Authorization discharges to Long Island I Sound.

CTDEP CGS 22a-430 General Permit for GPHOO0354 10/20/95 10/20/05 Discharge of minor photographic Discharge of Minor process wastewater to municipal Photographic sewer Processing Wastewater C-I CTDEP CGS 22a-430 General Permit for GWT 000175 03/26/01 05/01/05 Water treatment wastewater.

C the Discharge of Water Treatment 0 Wastewater 0

01

C_

vC-Table E-2. (contd)

.0 Issue Expiration  : ' - ;

0 I31 Agency Authority - Description Number Date Date Remarks CTDEP CGS 22a-430 General Permit for GM1000012 03/13/02 04/30/11 Wastewater discharaes from Miscellaneous Fire Training Facility. I Discharges of . I,:  :

Sewer Compatible Wastewater CTDEP Ct. P.A.82-402. Registration 2000-018-PWR-SU 07/12/83 Transferred on 03/31/01; Section 4 (Unit 2) - No expiration date; Divert large volume of i . I . . water from Long Island Sound for steam -

condenser cooling water.

CTDEP Ct. P.A.82-402, Registration 2000-019-PWR-SU 07/12/83 Transferred on 03/31/01; Section 4 (Unit 3) No expiration date; m Divert large volume of n water from Long Island Sound for steam condenser cooling water. .

CTDEP CGS 22a-174 Permit 199-0003-0043 08/10/00 Emissions from fire training mock-up facility and two propane-fired water pumps.

- i ,i -v i s-tt;-he CTDEP CGS 22a-174 Permit 199-0003-0044 04/27/99 Emissions from diesel-fired trash

~

,.., . : f water pump.

z

-C CTDEP CGS 22a-174 Permit 199-0003-0045 04/27/99 Emissions from diesel-fired

- m m motorpool air compressor CTDEP CGS 22a-174 Permit 199-0003-0046 04/27/99 Operate diesel-fired motorpool air compressor.

.,n (4-CGS 22a-174 I CTDEP Permit 199-0004-0056 11/09/99 Emissions from Unit 2 CD emergency diesel generator (1 3 of 2).

CD1 I CD a.

X I an m

z C Table E-2. (contd.)

M 'O G) Issue Expiration CD Agency Authority Description Number Date Date I _ Remarks IA) CTDEP CGS 22a-174 Permit 199-0003-0055 11/09/99 Emissions from Unit 2 X

-1 m emergency diesel generator (2 of 2).

VI CTDEP CGS 22a-174 Permit 199-0003-0007 01/24/86 Emissions from Unit 3 auxiliary boiler (1 of 2).

CTDEP CGS 22a-174 Permit 199-0003-0008 01/24/86 Emissions from Unit 3 auxiliary boiler (2 of 2).

CTDEP CGS 22a-174 Permit 199-0003-0009 05/21/85 Emissions from Unit 3 emergency diesel generator (1 of 2).

CTDEP CGS 22a-174 Permit 199-0003-0010 05/21/85 Emissions from Unit 3 emergency diesel generator m I (2of 2).

a)

CTDEP CGS 22a-174 Permit 199-0003-0017 08/25/92 Emissions from station blackout emergency diesel generator (3of3)

CTDEP CGS 22a-174 Permit 199-0003-0053 05/27/99 Emissions from Unit 3 ESF I diesel compressor.

CTDEP CGS 22a-449 Notification Site ID 170-8414 03/27/01 Unit 3 emergency generator underground storage tank E6, I #2diesel oil.

CTDEP CGS 22a-449 Notification Site ID 170-8414 03/27/01 Unit 3 emergency generator underground storage tank E7,

1. 2 diesel oil.

CTDEP CGS 22a-449 Notification Site ID 170-8414 03/27/01 Unit 3 auxiliary boiler underground storage tank F8, #4 I heating oil.

C-CTDEP CGS 22a-449 Notification Site ID 170-8414 03/27/01 Unit 3 auxiliary boiler underground storage tank F9, #4 0

0 I heating oil.

MI

C-Table E-2. (contd.)

• 0 Issue Expiration Ul Agency Authority Description Number Date Date Remarks CTDEP CGS 22a-449 Notification Site ID 170-8425 03/27/01 Simulator building underground storage tank, #2 heating oil.

CTDEP CGS 22a-449 Notification Site ID 170-8486 03/27/01 Unit 2 emergency diesel underground storage tank, #2 fuel oil. This tank has been retired.

South Carolina South Carolina; Permit - 0013-06-04 - 12110/03 12/31/04 Transport radioactive wastes.

Department of Radioactive Waste Health and Transportation and:;'

Environmental Disposal Act (Act No. 429 -

Control of 1980)

Tennessee Rule 1200-2-10.32 License T-CT003-L04 12/02/03 12/31(04 Ship radioactive materials.

Department of m Environment and Conservation CTDEP CGS 26-60 Scientific Collector 219 01/17/03 01/16/06 Collect fish and lobsters.

Permit CTDEP CGS Title 22a, Chapter Permit (Part A not applicable- 12/22/00 Store radioactive hazardous 445C - application) - (i.e., mixed) waste.

CGS 22a-174* Permit -- 199-0038-TV / 01/29/03- 01/29/08 Emissions (Title V permit).

CFR = Code of Federal Regulations * -

USACE = U.S. Army Corps of Engineers USDOT = U.S. Department of Transportation FWS = U.S. Fish and Wildlife Service G)

NRC = U.S. Nuclear Regulatory Commission

-PJ EPA = U.S. Environmental Protection Agency NOAA = National Oceanic and Atmospheric Administration en USC = United States Code

_0 CGS = Connecticut'General Statutes ESF = Engineered Safeguards Features CD 0.

mL

Appendix E UNITED STATES

- tNUCLEAR REGULATORY COMMISSION iBWASHINGTON, D.C. 20555-01 March 17, 2004 Patricia A. Kurkul. Regional Administrator NOAA Fisheries Northeast Regional Office One Blackburn Drive Gloucester, MA 09130-2298

SUBJECT:

REQUEST FOR LIST OF PROTECTED SPECIES WITHIN THE AREA UNDER EVALUATION FOR MILLSTONE POWER STATION, UNITS 2 AND 3, LICENSE RENEWAL

Dear Ms. Kurkul:

The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application submitted by Dominion Nuclear Connecticut Inc. (DNC) for the renewal of the operating licenses for Millstone Power Station, Units 2 and 3 (MPS). MPS Is located on the north shore of Long Island Sound In Waterford. Connecticut. approximately 40 miles southeast of Hartford, Connecticut. As part of the review of the license renewal application, the NRC is preparing a Supplemental Environmental Impact Statement (SEIS) under the provisions of the National Environmental Policy Act (NEPA) of 1969, as amended, which include an analysis of pertinent environmental issues, Including endangered or threatened species and impacts to fish and wildlife. This letter Is being submitted under the provisions of the Endangered Species Act of 1973, as amended, and the Fish and Wildlife Coordination Act of 1934. as amended.

The proposed action would include the use and continued maintenance of existing plant facilities and transmission lines. The MPS site covers approximately 525 acres, of which approximately 220 acres are industrial. The area surrounding MPS is characterized by old field.

mesic hardwood forest, coastal marsh and beach habitats. DNC also maintains a 50-acre wildlife refuge In the eastem portion of the MPS site.

Each MPS unit uses a once-through open-cycle cooling system with intakes on Niantic Bay and surface discharges to an old quarry cut, which empties into Long Island Sound. Occasional dredging or de-muclong at the intakes is performed as a normal part of operation.

For the specific purpose of connecting MPS to the regional transmission system, there is a total of approximately 91 miles of transmission line corridors that occupy approximately 3.052 acres of land. These transmission line coridors are being evaluated as part of the SEIS process.

The transmission line corridors traverse New London, Toland, Hartford. Middlesex, and New Haven Counties. The corridors pass through land that is primarily agricultural and forest land.

The enclosed transmission line map shows the transmission system that is being evaluated In the SEIS. Four 345-kilovolt (kV) lines connect MPS to the electric grid. All four transmission lines run northward from the plant In a common corridor (415 to 500 feet wide) for 9.1 miles to Hunts Brook Junction. At Hunts Brook Junction, the lines diverge, with two lines running north NUREG-1 437, Supplement 22 E-8 July 2005

Appendix E P. Kurkul 2 to the Card and Manchester Substations, one line running east to the Montville Station, and one line running west to the Southinglon Substation. These four lines share corridors with other previously existing transmission Ones.

To support the EIS preparation process and to ensure compliance with Section 7 of the Endangered Species Act of 1973. the NRC requests a fist of endangered, threatened.

candidate, and proposed species. and designated and proposed critical habitat under the' jurisdiction of NOAA Fisheries, that may be In the vicinity of MPS site and its transmission line corridors. In addition, please provide any Information you consider appropriate under Ihe provisions of the Fish and Wildlife Coordination Act The NRC has also contacted the Fish and Wildlife Service and requested a list of species and Information on protected, proposed, and candidate species and critical habitat that may be in the vicinity of MPS and Its associated transmission lines.

We plan to hold two public NEPA scoping meetings on May 18 2004. at the Waterford Town Hall Auditorium 5i Rope Ferry Road In Waterford. Connecticut. On May 19,2004. we plan to conduct a site audit You and your staff are Invited to attend both the site audit and the public meetings. Your office will receive a copy of the draft SEIS along with a request for comments.

The anticipated publication date for the draft SEIS is December 2004.  ;

If you have any questions concerning the NRC staff review of this license renewal application, please contact Mr. Richard L Emch. Jr.. Senior Project Manager at 301-415-1590 or RLE@nrc.gov. -

Sincerely,

./2 Pao-Tsin Kuo, Program Director

"-License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-336 and 50-4 23

Enclosures:

1. MPS Transmis!sion Line Map

2. MPS Site Layout cc wdend.: See next page en_..~ .. .

July 2005. - E-9 NUREG-1437, Supplement 22

Appendix E Millstone Power Station. Units 2 and 3 Application for Renewed Operating Licenses Chapter 3 Appendix E - Environmental Report Figure 3-2 Transmission Line Map Mm. Peen M Be,".

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Appendix E 9 pUNITED STATES Ng-UCLEAR REGULATORY COMMISSION

,WASHIVGTOlk D.C.:D0S5OOOI flarch 18, 2004

• we Marvin Moriarty. Regional Director Northeast Regional Office U.S. Fish and Wildlife Service 300 Westgate Center Drive Hadley, MA 01035-9589

SUBJECT:

REOUEST FOR LIST OF PROTECTED SPECIES WITHIN THE AREA UNDER EVALUATION FOR THE MILLSTONE POWER STATION, UNITS 2 AND 3 UCENSE RENEWAL Dear Mr. Moriarty.

The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application submitted by Dominion Nuclear Connecticut Inc. (DNC) for the renewal of the operating licenses for Millstone Power Station. Units 2 and 3 (MPS). MPS Is located on the north shore of Long Island Sound in Waterfond, Connecticut. approximately 40 miles southeast of Hartford, Connecticut As part of the review of the license renewal application, the NRC is preparing a Supplemental Environmental Impact Statement (SEIS) under the provisions of the National Environmental Policy Act (NEPA) of 1969. as amended, which includes an analysis of pertinent environmental issues, including endangered or threatened species and Impacts to fish and wildlife. This letter is being submitted under the provisions of the Endangered Species Act of 1973. as amended, and the Fish and Wildlife Coordination Act of 1934. as amended.

The proposed action would include the use and continued maintenance of existing plant facilities and transmission lines. The MPS site covers approximately 525 acres, of which approximately 220 acres is Industrial. The area surrounding MPS is characterized by old field, mesic hardwood forest, coastal marsh and beach habitats. DNC also maintains a 50-acre wildlife refuge in the eastern portion of the MPS site.

Each MPS unit uses a once-through open-cycle cooling system with Intakes on Niantic Bay and surface discharges to an old quarry cut, which empties into Long Island Sound. Occasional dredging or de-mucking at the Intakes is performed as a normal part of operation.

For the specific purpose of connecting MPS to the regional transmission system, there Is a total of approximately 91 miles of transmission line corridors that occupy approximately 3,052 acres of land. These transmission line corridors are being evaluated as part of the SElS process.

The transmission line corridors traverse New London, Toland, Hartford, Middlesex, and New Haven Counties. The corridors pass through land that Is primarily agricultural and forest land.

The enclosed transmission line map shows the transmission system that is being evaluated in the SEIS. Four 345-kilovolt (kV) lines connect MPS to the electric grid. All four transmission mines run northward from the plant in a common corridor (415 to 500 feet wide) for 9.1 miles to Hunts Brook Junction. At Hunts Brook Junction, the lines diverge, with two lines running north NUREG-1437, Supplement 22 E-12 July2005 I

Appendix E M. Moriarty to the Card and Manchester Substations, one line running east to the Montville Station, and one line running west to the Southington Substation. These four lines share corridors with other previously existing transmission lines.

To support the SEIS preparation process and to ensure compliance with Section 7 of the Endangered Species Act, the NRC requests a list of species and Information on protected, proposed. and candidate species and critical habitat that may be In the vicinity of MPS and Its associated transmission lines. In addition, please provide any Information you consider appropriate under the provisionis of the Fish and Wildlife Coordination Act.

We plan to hold two public NEPA scoping meetings on May 18. 2004, at the Waterford Town Hall Auditorium, 15 Rope Ferry Road in Waterford, Connecticut. On May 19. 2004, we plan to conduct a site audit. You and your staff are invited to attend both the site audit and the public meetings. Your office will receive a copy of the draft SEIS along with a request for comments.

The anticipated publication date for the draft SEIS Is December 2004.

If you have any questions concerning the NRC staff review of this license renewal application, please contact Mr. Richard L Emch, Jr., Senior Project Manager at 301-415-1590 or RLEOnrc.aov. . ,-

Sincerely,

' -4,.' .. ',,

- Pao-Tsin Kuo, Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-336, 50-423

Enclosures:

1. MPS Transmission Line Map

2. MPS Site Layout cc w/encl.: See next page -

July 2005 E-13 NUREG-1 437, Supplement 22

Appendix E Millstone Power Station. Units 2 and 3 Application for Renewed Operating Licenses Chapter 3 Appendix E - Environmental Report Figure 3-2 Transmission Line Map H-I-a

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Appendix E so9' UtI1TED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Match 30, 20O.

Mr. Paul Loether. Director Connecticut Historical Commission 59 South Prospect Street Hartford. CT 06106

SUBJECT:

MILLSTONE POWER STATION. UNITS 2 AND 3 LiCENSE RENEWAL REVIEW Dear Mr. Loether The U.S. Nuclear Regulatory Comrrission (NRC) staff Is reviewing an application to renew the operating licenses for Millstone Power Station, Units 2 and 3 (MPS), which Islocated on the north shore of Long Island Sound In Waterford. Connecticut, approximately 40 miles southeast of Hartford. Connecicut MPS is operated by Dominion Nuclear Connecticut Inc. (DNC). The application for renewal was submitted by DNC on January 22. 2004, pursuant to NRC requirements at Tide 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54). The NRC has established that, as pat of the stall review of any nuclear power plant license renewal action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its *Generio Environmental Impact Statement for License Renewal of Nuclear Plants' (GEIS),

NUREG-1437, will be prepared under the provisions of10 CFR Part 51. the NRC rules that implement the National Environmental Policy Act of 1969 (NEPA). In accordance with 36 CFR 800.8. the SEtS will include analyses of potential impacts to historic and archaeological resources.

In the context of the National Historic Preservation Act of 1968, as amended, the NRC staff has determined that the area of potential effect (APE) for a license renewal action Is the area at the power plant site and its Immediate environs that may be Impacted by post-lcense renewal land-disturbing operations or projected refurbishment activities associated with the proposed action.

The APE may extend beyond the Immediate environs in those Instances where post-license renewal land-disturbing operations or projected retunbishment activities, specifically related to license renewal. may potentially have an effect on known or proposed historic sites. This determination Is made irrespective of ownership or control of the lands of Interest.

While preparing its application, ONC contacted your office by letter dated July 31, 2003. In its letter. DNC stated there are no plans to significantly alter current operations over the license renewal period. DNC further stated that no expansion of existing facilities is planned, and no major structural modifications have been Identif led for the purpose of supporting license renewal. In addition, no land-disturbing activities are anticipated beyond those required for routine maintenance and repairs. Your office responded in a letter dated August 5 2003, stating that the proposed undertaking will have no effect on historic, architectural, or archaeological resources listed on or eligible for the National Register of Historic Places.

NUREG-1437, Supplement 22 E-1 6 July 2005

Appendix E P. Loether 2 On May 18, 2004, the NRC wit! conduct two public NEPA scoping meetings at the Waterford Town Hall Auditorium, 15 Rope Ferry Road in Waterford. Connecticut. You and your staff are invited to attend. Your office will receive a copy of the draft SEIS along with a request for comments. The anticipated publication date for the draft SEIS Is December 2004. If you have any questions or require additional Information, please contact Mr. Richard L Emch. Jr., Senior Project Manager at 301-415-1590 or RLE@nrc rov.  ;

Sincerely, nAKuo. Irector Division Kof P gra Ll~ense Renewa and Environmental Impacts of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-336,50-423

Enclosure:

As stated cc wlo encl.: See next page July 2005: E-1 7 NUREG-1437, Supplerment 22 -

Appendix E 0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055S-0001 Aprol 8, 2004 Mr. Don Kluima, Director Office of Federal Agency Programs Advisory Council on Historic Preservation Old Post Office Builcding 1100 Pennsylvania Avenue. NW, Suite 809 Washington, DC 20004

SUBJECT:

MILLSTONE POWER STATION. UNITS 2 AND 3 LICENSE RENEWAL REVIEW

Dear Mr. Klima:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an application to renew the operating licenses for Millstone Power Station. Units 2 and 3 (MPS), which is located on the ncrh shore of Long Island Sound in Waterford, Connecticut, approximately 40 miles southeast of Hartford, Connecticut. MPS is operated by Dominion Nuclear Connecticut Inc. (DNC). The application for renewal was submitted by DNC on January 22,2004, pursuant to NRC requirements at Title l1ot the Code of Federal Regulations Part 54(10 CFR Part 54). The NRC has established that, as part of the staff review of any nuclear power plant license renewal action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its Generic Environmental Impact Statement for License Renewal of Nuclear Plantse (GElS).

NUREG-1437, will be prepared under the provisions of 10 CMA Part 51. which Implements the National Environmental Policy Act of 1969 (NEPA). In accordance with 38 CFR 800.8. the SEIS will include analyses of potential impacts to historic and cultural resources. A draft SEIS is scheduled for publication in December of 2004, and will be provided to you for review and comment If you have any questions or require additional information, please contact the Senior Project Manager for the Millstone project, Mr. Richard L Emch, Jr.. at 301-415-1590 or RLE@nrc.gov.

Sincerely.

PIo.Tsin Kuo, rogram Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-336, 50-423 cc: See next page NUREG-1437, Supplement 22 E-18 July 2005

Appendix E April 14. 2004 - - *:

The Honorable Matthew Thomas, Chief Sachem Narragansett Indian Tribe -

P.O. Box 268 - -

Charlestown, RI 02813

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION REVIEW OF MILLSTONE POWER STATION, UNITS 2 AND 3 UCENSE RENEWAL APPUCATIONS

Dear Chief Thomas:

The U.S. Nuclear Regulatory Corntission (NRC) Is seeking Input for Its envkonmental review of applications from the Dominion Nuclear Connecticut. Inc. (DNC) to renew the operating licenses for the Milsiona Power Station, Units 2 and 3 (UPS). - UPS is located on the north shore of Long Island Sound in Waterford, Connecticut, approximately 40 niles southeast of Hartford. Connecticut. MPS Is In close proximity to lands that may be of Interest to the Narragansett Indian Tribe. As described belovK the NRC process includes an opportunity for pubic and hiter-governmental participation In the environmental review. We want to ensure that you are aware of our efforts and. pursuant to 10 CFR 51.28(b). the NRC invites the Narragansett Indian Tribe to provide input to the scoping process relating to the NRC's environmental review of the application. A copy of this letter Is also being forwarded to M.r John Brown, your Tribal Preservation Officer. In addition, as outlined in36 CFR 800.8. the NRC plans to coordinate cormpliance with Section 108 of the National Historic Preservation Act of 1968 through the requirements of the National Environmental Policy Act of 1969.

Under NRC regulations, the original operating loens fora nuclear power plant is issued for up.

to 40 years. The license may be renewed for up to an additional 20 years If NRC requirements are met. The current operating licenses for MPS Units 2 and 3 wll expirehI July2015 and November 2025. respectively. DNC submitted its application for renewal of the MPS operating licensesonJanuary22.2004. , *.-

The NRC Isgathering Information for a MPS-speclfc supplement to ts *Generic Environmental Impact Statement for Ucense Renewal of Nuclear Plants (GEIS), NUREG-1437. The supplement WI1contain the results of the review of the environmental lnpects on the area surrounding the MPS site that are related to terrestrial ecology, aquatic ecology, hydrology, historic and archaeological resources, and socioeconomic issues (among others) and will cont in a recorrendation regarding the environmental acceptabilty of the icense renewal action. ,. -

The NRC vWI hold two public scoping meetings for the MPS license renewal supplement to the GElS on May 18,2004, at the Waterford Town Hal Auditorium, 15 Rope Ferry Road in Waterford Connecticut 06385. There will be two sessions to cconmnodate intrested partes.

The first session will convene at 1:30 p.m. and vil continue until 4:30 pm., as necessary. The second session will convene at 7:00 p.m.. with a repeat of the overview portions of the meeting, and will continue until 10;00 p.m., as necessary. Additionally, the NRC staff will host informal discussions one hour before the start of each session. To be considered, comments must be provided either at the transcrbed public meetings or in writing. No formal conmments on the proposed scope of the supplement to the GEIS will be accepted during informal discussions.

July2005.. E-19 - NUREG-1437, Supplement 22;'

Appendix E Chief M. Thomas The application is electronically available for inspection from the Publicly Available Records component of NRC's Agencywide Documents Access and Management System (ADAMS) under Accession Number ML040260070. ADAMS is accessible at httpto/w nrc govo readin-nmVadams.htmj which provides access through the NRC's Public Electronic Reading Room (PERR) link. If you do not have access to ADAMS or if there are problems in accessing the documents located in ADAMS. contact the NRC's Pubic Document Room (PDR) Reference staff at 1-800-397-4209, 1-301 415-4737. orby e-mail at pdrsnrc.gov. In addition, the application can be viewed on the Internet at Nito 11wmw nrc.govlreactors.ooeratin9.licensingJ renewalfaoplicalions html A paper copy of the application can be viewed at the NRC's PDR. located at One White Flint North, 11555 Rockville Pike (first floor), Rockville, Maryland, 20852-2738: the Waterford Public Library, located at 49 Rope Ferry Road, Waterford, Connecticut. 06385: and at the Thames River Campus Library at Three Rivers Community College. 574 New London Turnpike, Norwich. Connecticut. 06360. The GEIS. which assesses the scope and impact of environmental effects that would be associated with license renewal at any nuclear power plant site, can also be found on the NRC's 'ebsite or at the NRCs PDR.

Please submit any written comments that the Narragansett Indian Trbe may have to offer on the scope of the environmental review by June 4, 2004. Comments should be submitted by mad to the Chief, Rules and Directives Branch, Division of Administrative Services. Mail Stop T-6D59. U.S. Nuclear Regulatory Commission, Washington D.C. 20555-0001. or by e-mail to MitstoneEIS@nrcngov. At the conclusion of the scoping process, the NRC staffwill prepare a summary of the significant issues identified and the conclusions reached and will mail a copy to you.

The NRC wilt issue the draft supplemental environmental impact statement (SEIS) for publc comment (anticipated publicabon date. December 2004), and lt hold another set of public meetings in the site vicinity to solicit comments on the draft A copy of the draft SEIS wil be sent to you for your review and cornment. After con sideration of public comnments received on the draft, the NRC will prepare a final SEIS. The issuance of a final SEIS for MPS is planned forJuly 2005. If you need additional information regarding the environmental review process.

please contact Mr. Richard L. Emch, Jr.. Senior Environmental Project Manager, at (301) 415-1590.

Sincerely, IRAI Pao-Tsin Kuo, Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-338, 50-423 NUREG-1 437, Supplement 22 E-20 July 2005

Appendix E Chief M. Thomas The application is electronically available for inspection from the Publicly Available Records component of NRC's Agencywide Documents Access and Management System (ADAMS) under Accession Number ML040260070, ADAMS s accessible at http .vww nrc aovI readin-rnriadams himl which provides access through the NRC's Public Electronic Reading Room (PERR) link. If you do not have access to ADAMS or if there are problems in accessing the documents located In ADAMS, contact the NRC's Public Document Room (PDR) Reference staff at 1-800-397-4209, 1-301415-4737. or by e-mail at pdrtgnrc.gov. In addition, the application can be viewed on the Intemet at htlprfwwv nrc.govreactorslooeratinp'licensing!

renewalra olications html, A paper copy of the application can be viewed at the NRCs PDR. located at One White Flint North, 11555 Rockville Pike (first floor), Rockville, Marytand. 20852.2738: the Waterford Public Library, located at 49 Rope Ferry Road, Waterford, Connecticut. 06385; and at the Thames River Campus Ubrary at Three Rivers Community Colege, 574 New London Tumpike.

Norwich, Connecticut, 06360. The GElS, which assesses the scope and impact of environmental effects that would be associated with license renewal at any nuclear power plant site, can also be found on the NRC's website or at the NRCs PDR.

Please submit any wntten comments that the Narragansett Tribal Community may have to offer on the scope of the environmental review by June 4. 2004. Comments should be submitted by mall to the Chief. Rules and Directives Branch, Division of Administrative Services. Mail Stop T-6D59. U.S. Nudear Regulatory Commission, Washington D.C. 20555-0001, or by e-mail to Mi~stoneEIS@nrrg-ov. At the conclusion of the scoping process, the NRC staff will prepare a sumvmary of the significant issues Identified and the conclusions reached and will mail a copy to you, The NRC wilt issue the draft supplemental environmental impact statement (SEIS) for public comment (antcipated publication date. December 2004), and will hold another set of public meetings in the site vicinity to solicit comments on the drafL A copy of the draft SEIS wl be sent to you for your review and conment. After consideration of public comments received on the draft, the NRC will prepare a final SEIS The issuance of a final SEIS for MPS is planned for July 2005. If you need additional information regarding the environmental review process.

please contact Mr. Richard L Emch, Jr.. Senior Environmental Project Manager, at (301) 415-1590.

Sincerely, IRAf Pao-Tsin Kuo, Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-336 and 50423 Distrbulion: See next page Accession No ML041050878 C %ORPCheckoutFiIeNETWlL041050878 wpd OFFICE LA:RLEP GS: LEP PM RLEP OGC (NLO) SCRLEP PD RLEP NAME MJenkins- JOavis REmch Chlarco' JTappen PTKuo DATE 03r29.04 03.29.04 03429:04 0417104 04f1 3104 04214204 OFFICIAL RECORD COPY July 2005 - E-21 -.- NUREG-1437, Supplement 22

Appendix E DISTRIBUTION LUr to The Honorable IChief) M Thomas Rep Minsione Dated: AOil 14 2004 Accession No. ML041050875 DMatthewsFGlilespie PTKuo REmch JTappert LFields JOavis RArighi JEads CMarro VNerses JTrapp. RGN I MSchenider. RGN I SKennedy. RGN I KManagan. RGN I TDoerr (LANL)

RLEP R/F NUREG-1437, Supplement 22 E-22 July 2005

Appendix E I

Millstone Power Station, Units 2 and 3 cc Lilian M, Cuoco, Esquire Nianbc, CT 06357 Senior Counsel Dominion Resources Services, Inc, Mr. G. D. Hicks Rope Ferry Road Director- Nuclear Station Safety Waterford, CT 06385 and Ucensing Dominion Nuclear Connecticut, Inc.

Edward L Wilds, Jr., Ph D. Rope Ferry Road Director. Division of Radiation Waterford, CT 06385 Department of Environmental Protection 79 Elm Street Ms. Nancy Burton Hanford, CT 06106-5127 147 Cross Highway Redding Ridge. CT 00870 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Mr. Wiliam D. Melnert 475 Allendale Road Nuclear Engineer King of Prussia. PA 19406 Massachusetts Municipal Wholesale Electric Company Paul Eccard Moody Street First Selectman P.O. Box 426 Town of Watefford Ludlow, MA 01056 15 Rope Ferry Road Waterford, CT 06385 Mr. J. Alan Pricei -

Site Vice President Mr. P. J. Parulbs Dominion Nuclear Connecticut, Inc.

Manager- Nuclear Oversight Rope Ferry Road Dominion Nuclear Connecticut, Inc. Waterford, CT 06385 Rope Ferry Road Waterford, CT 06385 Mr. Chris L. Funderburk Director, Nuclear Licensing and Mr. W. R. Matthews Operations Support Senior Vice President- Nuclear Operations Dominion Resources Services. Inc.

Dominion Nuclear Connecticut, Inc. Innsbrook Technical Center Rope Ferry Road 5000 Dominion Boulevard Waterford, CT 06385 Glen Allen, VA 230604711 Mr. John Markowcz Mr. David W. Dodson - --

Co-Chair Licensing Supervisor -

Nuclear Energy Advisory Council Dominion Nuclear Connecticut, Inc.

9 Susan Terrace Rope Ferry Road Waterford, CT 06385 Waterford, CT 06385 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, CT 06070 Senior Resident Inspector Millstone Power Station cdo U.S Nuclear Regulatory Commission P.O. Box 513 July 2005 E NUREG-1437, Supplement 22

Appendix E Millstone Power Station, Units 2 and 3 cc Mr. S E. Scace Mr. John Brown Assistant to the Site Vice President Tribal Preservation Officer Dominion Nuclear Connecticut, Inc. Narragansett Indian Tnbe Rope Ferry Road P 0. Box 700 Waterford. CT 06385 Wyoming, RI 02898 Mr. M. J. Wilson Manager - Nuclear Training Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 08385 Mr. A. J. Jordan. Jr.

Director - Nuclear Engineering Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford. CT 06385 Mr. S. P. Sarver Director - Nuclear Station Operations and Maintenance Dominion NuclearConnecticut. Inc Rope Fenry Road Waterford, CT 06385 Mr. Charles Brinkman, Director Washington Operations Nuclear Services Westinghouse Electric Company 12300 Twinbrook Pkwy. Suite 330 Rockville, MD 20852 Mr. David A Christian Sr. Vce President and Chief Nuclear Officer Dominion Nuclear Connecticut. Inc.

Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-8711 Mr. Fred Emerson Nuclear Energy Institute 1776 1 Street. NW, Suite 400 Washington. DC 20006-3708 Ms. Judy Liskov, Assistant Director Waterford Public Library 49 Rope Ferry Road Waterford. CT 06385 Three Rivers Community College Thames River Campus Library 574 New London Tumpike Norwich, CT 06360 NUREG-1437, Supplement 22 E-24 July 2005

Appendix E AprIl 14,2004 The Honorable Michael J. Thomas, Chairman Mashantucket Pequot Tribal Nation - - .

P.O. Box 268, Indian Town Road --

Mashantucket, CT 06339-3060 -

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION REVIEW OF MILLSTONE POWER STATION, UNITS 2 AND 3 LICENSE RENEWAL APPUCATIONS

Dear Chairman Thomas:

The U.S. Nuclear Regulatory Comnission (NRC) Is seeking input for as environmental review of applications from the Dominion Nuclear Connecticut. Inc. (DNC) to renew the operating licenses for the Millstone Power Station. Units 2 and 3 (MPS). MPS is located on the north shore of Long Island Sound in Waterford, Connecticut, approximately 40 miles southeast of Hartford, Connecticut. MPS is in close proxirity to lands that may be of Interest to the Mashantucket Pequot Tribal Nation. As described below, the NRC process includes an opportunity for public and inter governmental participation in the environmental review. We want to ensure that you are aware of our efforts and, pursuant to 10 CFR 51.28(b), the NRC invites the Mashantucket Pequot Tribal Nation to provide input to the scoping process relating to the NRC's environmental reviewof the application. In addition, as outlined In 36 CFR 800.8, the NRC plans to coordinate compliance with Section 106 of the National Historic Preservation Act of 1966 through the requirements of the National Environmental Policy Act of 1969. -

Under NRC regulations, the original operating license for a nuclear power plant is issued for up to 40 years. The license may be renewed for up to an additional 20 years if NRC requirements are met. The current operating licenses for MPS Units 2 and 3 wil expire in July 2015 and November 2025, respectively. DNC submitted its application for renewal of the MPS operating lIcenses on January 22,2004.

The NRC Is gathering information for a MPS-specific supplement to its 'Generic Environmental Impact Statement for License Renewal of Nuclear Plants' (GEIS), NUREG-1437. The .:

supplement wil contain the results of the review of the environmental Impacts on the area surrounding the MPS site that are related to terrestrial ecology, aquatic ecotogy, hydrology, historic and archaeological resources, and socioeconomic issues (among others) and will contain a reconmnendation regarding the environmental acceptability of the license renewal action.

The NRC wiN hold two publie scoping meetings for the MPS icense renewal supplement to the GEIS on May 18, 2004. at the Waterford Town Han Auditonum. 15 Rope Ferry Road in Waterford, Connecticut, 06385. There wil be two sessions to accommodate interested parties.

The first session vill convene at 1:30 p.m. and wi1l continue until 4:30 pm., as necessary. The second session will convene at 7.00 p.m., with a repeat of the overview portions of the meeting.

and will continue untl 10:00 p.m., as necessary. Additionally, the NRC staff will host informal discussions one hour before the start of each session. To be considered, comments must be provided either at the transcribed public meetings orin writing. No formal comments on the proposed scope of the supplement to the GEIS will be accepted during informal discussions.

July 2005- E-25 5 NUREG-1437, Supplement 22

Appendix E Chairmlan M. Thomas The application is electronically available for inspection from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS) under Accession Number ML040260070. ADAMS is accessible at httpI./NW# nrc gov!

reading-rmladams hitml Which provides access through the NRC's Public Electronic Reading Room (PERR) link. If you do not have access to ADAMS or if there are problems in accessing the documents located in ADAMS, contact the NRC's Public Document Room (PDR) Reference staff at 1-800-397-4209. 1-301-415-4737. or by e-mail at pdnrnrcrgov. In addition, the application can be viewed on the Internet at htto twvw,.nrc govlreactorsfooeratingflicensingI renewallapplications html.

A paper copy of the application can be viewed at the NRC s PDR, located at One White Flint North. 1 1555 Rockville Pike (first floor). Rockville, Maryland. 20852-2738, the Waterford Public Library. located at 49 Rope Ferry Road, Waterford. Connecticut. 08385; and at the Thames River Campus Library at Three Rivers Community College. 574 New London Turnpike.

Norwich, Connecticut. 08360. The GEIS, which assesses the scope and impact of environmental effects that would be associated with license renewal at any nuclear power plant site, can also be found on the NRC's website or at htto:Itwv.nrc.povfreadin-rmvodr.html NRC's PDR.

Please submit any wntten comments that the Mashantucket Pequot Tribal Nation may have to offer on the scope of the environmental review by June 4. 2004. Comments should be submitted by mail to the Chief, Rules and Directives Branch. Division of Administrative Services. Mail Stop T-6D59. U.S. Nuclear Regulatory Commnission, Washington D.C. 20555-0001, or by e-mail to M1IistonegiS@nrcgov,. At the conclusion of the scoping process, the NRC staff will prepare a summary of the significant issues identified and the conclusions reached and will mail a copy to you.

The NRC will issue the draft supplemental environmental impact statement (SEIS) for public comment (anticipated publication date, December 2004), and silt hold another set of public meetings in the site vicinity to solicit comments on the dralt. A copy of the draft SEIS wilt be sent to you for your review and commient. Afler consideration or public comments received on the draft. the NRC will prepare a final SEIS. The issuance of a final SEIS for MPS is planned for July 2005. If you need additional information regarding the environmental review process, please contact Mr. Richard L Emch. Jr.. Senior Environmental Project Manager, at 301-415-1590.

Sincerely.

/RAI Pao.Tsin Kuo. Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-336.50-423 NUREG-1437, Supplement 22 E-26 July 2005

Appendix E Chairman M. Thomas The application is electronically available for inspection from the Publicly Available Records component of NRC's Agencywide Documents Access and Management System (ADAMS) under Accression Number ML040260070. ADAMS is accessible at htto/mhvw nrc gov!

reading-rm/adarms html which provides access through the NRC's Public Electronic Reading Room (PERR) link. If you do not have access to ADAMS or If there are problems in accessing the documents located In ADAMS. contact the NRC's Public Document Room (PDR) Reference staff at 1-800-3974209. 1-301-4154737, or by e-mail at pdrtnrc.gov. In addition, the applcation can be viewed on the Internet at htlo 11wyw nrc gooyreactors/ooeratingolicensinal renewal-apoicationsnmillstone htni A paper copy of the application can be viewed at the NRCs PDR. located at One While Flint North, 11555 Rockvifle Pike (first floor), Rockville, Maryland. 20852-2738; the Waterford Public Library. located at 49 Rope Ferry Road, Waterford, Connecticut. 06385; and at the Thames River Campus Ubrary at Three Rivers Community Coflege, 574 New London Tumpike.

Norwich, Connecticut, 06360, The GEIS, which assesses the scope and Impact of environmental effects that would be associated with license renewal at any nuclear power plant site, can also be found on the NRCs website or at htto:Ivww nrc.oovtreadina-rm!odr.html NRC's PDR.

Please submit any written comments that the Mashantucket Pequot Tribal Community may have to offer on the scope of the environmental review by June 4,2004. Comments should be submitted by mail to the Chief. Rules and Directives Branch, Division of Administrative Services. Mail Stop T-6 059. U.S. Nuclear Regulatory Commission, Washington D.C. 20555-0001, or by e-mail to MiktsfoneE1S~nrcgov. At the conclusion of the scoping process, the NRC staff wiU prepare a summary of the significant issues identified and the conclusions reached and will mail a copy to you.

The NRC wil ssue the draft supplemental environmental impact statement (SEIS) for public comment (anticipated publication date, December 2004). and Wil hold another set of public meetings in the site vicinity to solicit comments on the draft A copy of the draft SEIS Will be sent to you for your review and comnent. After consideration of public conmments received on the draft, the NRC will prepare a final SEIS. The issuance of a final SEIS for MPS Is planned forJuly 2005. If you need additional information regarding the environmental review process.

please contact Mr. Richard L Emch, Jr.. Senior Environmental Project Manager, at 301-415-1590 or by e-mail at RLE~nrc.gov.

Sincerely.

Pao-Tsin Kuo, Program Director Lcense Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-336 and 50-423 Distribution: See next page Accession No-ML041050880 C:IORPCheckouf.FileNE1tLO41t 0508 wpd OFFICE LA:RLEP GS:RLEP PM:RLEP OGC (NLO) SC-RLEP PD RLEP NAME MJenkins JDavls - REmch' CMarco- JTappert PTKuo DATE 03.12504 03r254204 O2504 0407104 0413M4 04114.'04 OFFICIAL RECORD COPY July 2005 .;. E-27` NUREG-1437, Supplement 22

Appendix E DISTRIBUTION: Lr. to the Honorable M. Thomas Re: Millstone Dated Avril 14 2004 Accession No.ML041050380 DMatthews/FGillespie PTKuo REmch JTappert LFields JDavis RArnighl JEads CMarco VNerses JTrapp. RGN I MSchwnider, RGN I SKennedy. RGN I KManagan. RGN I TDoerr (LANL)

RLEP RIF NUREG-1437, Supplement 22 E-28 July 2005

Appendix E i

Millstone Power Station, Units 2 and 3 cc Lillian M Cuoco. Esquire Senior Resident Inspector Senior Counsel Millstone Power Station Dominion Resources Services. Inc. vo U.S. Nuclear Regulatory Commission Rope Ferry Road P. 0. Box 513 Waterford, CT 06385 Niantic, CT 06357 Edw'ard L Wilds, Jr., Ph D. Mr. G. D. Hicks Director, Division of Radiation Director. Nuclear Station Safety Department of Environmental Protection and Licensing 79 Elm Street Dominion Nuclear Connecticut. Inc.

Hartford, CT 06106-5127 Rope Ferry Road Waterford, CT 06385 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Ms Nancy Burton 475 Allendale Road 147 Cross Highway King of Prussia. PA 19406 Redding Ridge. CT 00870 Paul Eccard Mr. Wiliam D. Meinert First Selectman Nuclear Engineer Town of Waterford Massachusetts Municipal Wholesale 15 Rope Ferry Road Electric Company Waterford, CT 06385 Moody Street -:

P.O. Box 426 Mr. P. J. Parubs Ludlow, MA 01056 Manager . Nuclear Oversight Dominion Nuclear Connecticut, Inc. Mr. J. Alan Price Rope Ferry Road Site Vice President Waterford, CT 06385 Dominion NuclearConnecticut, Inc.

Rope Ferry Road -

Mr. W. R. Matthews Waterford, CT 06385 Senior Vice President - Nuclear Operations Dominion Nuclear Connecticut, Inc. Mr. Chris L Funderburk Rope Ferry Road Director, Nudear Licensing and Waterford, CT 06385 Operations Support -

Dominion Resources Services, Inc, Mr. John Markowicz Innsbrook Technical Center Co-Chair 5000 Dominion Boulevard Nuclear Energy Advisory Council Glen Allen, VA 23060-6711 9 Susan Terrace Waterford. CT 06385 Mr. David W. Dodson -

Licensing Supervisor Mr. Evan W. Woollacott Dominion NuclearConnetcut. Inc.

Co-Chair Rope Ferry Road Nuclear Energy Advisory Council Waterford, CT 06385' 128 Terry's Plain Road Simsbury, CT 06070 July 2005. E-29 . NUREG-1 437, Supplemnent 22

Appendix E Millstone Power Statlion, Units 2 and 3 cc Mr. S. E. Scace Three Rivers Community College Assistant to the Site Vice President Thames River Campus Library Dominion Nuclear Connecticut. Inc. 574 New London Turnpike Rope Ferry Road Norwich. CT 06360 Waterford, CT 06385 Mr. M. J. Wilson Manager - Nuclear Training Dominion Nuclear Connecticut, Inc.

Rope Feny Road Waterford, CT 06385 Mr. A. J. Jordan. Jr.

Director. Nuclear Engineering Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 08385 Mr. S. P. Sarver Director. Nuclear Station Operations and Maintenance Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Walerford. CT 06385 Mr. Charles Brinkman. Director Washington Operations Nuclear Services Westinghouse Electric Company 12300 Twinbrook Pkwy. Suite 330 Rockville, MD 20852 Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen. VA 23060-6711 Mr. Fred Emerson Nuclear Energy Institute 1776 I Street. NW. Suite 400 Washington. DC 20006.3708 Ms. Judy Liskov. Assistant Director Walerford Public Library 49 Rope Ferry Road Waterford, CT 06385 NUREG-1437, Supplement 22 E-30 July 2005

Appendix E

'United States Department of the Jnterior FISH AND WILDLIFE SERVICE kNey England Field Office 70 Commercial Street. Suite 300

-,Concord, New Hampshire 03301-5087 RE: License Renewl, Millstone Pover Station Units 2 3 l npr I152004 Waterford, CT Pao-Tsin Kuo O11ce of Nuclear Reactor Regulation U.S. NuclearRegulatory Commission Washington, D.C. 20555-0001

DearMr. Kuo:

I have reviewed your request for information on endangered and threatened species and their habitats for the above-referenced project. The following commnents are provided in accordance with Section7 oftheEndangered Species Act (ESA) of 1973, as amended (16U.S.C. 1531-1543) and the Fish and rlddlife Coordination Act (48 Stat, 401. as amended; 16 U.S.C. 661 et seq.).

The following is a list of federally-prolected and candidate species that may be in the vicinity of MPS and the associated transmission lines: the federally-endangered roscaletem(Strnadowgallii dougallih) nests on the Atlantic eoastfislands. federally-threatened piping plover (Cizaradrius inelodus) nests on the Atlantic coast, the federally-threatened puritan tiger beetle (Cicindela purflana)is found inMiddlesex County' the federally-threatened small whorled pogonia (Isolrla riedeololdes) is found in Hartford/New Haven/Fairfield/New London/Windhartnolland

/Middlesex and Litchfield Counties, and the federally-thteatened bald eagle (Haliaecius leucocepiaalus)uses the entire state for migratory/nesting purposes. In addition theNewvEngland cottontail (Syldilagtstirasitlotatls)has been proposed as a canditatefor federal listing. TheNew England cottontail may be found in the vicinity of the MPS and associated transmission lines.

With regard to our cofinefnsbunder the provisioniof tlicish and WVildlifkCoofdinati5nAct. we are unable to provide detailed comments on the potential effects of the proposed action on fishand wildlire resources at this time. %Vewill provide further comments afterwe review the Supplemental Environmental Impact Statement.

July 2005 .' E-31 NUREG-1437, Supplement 22

Appendix E Tharggyou for your-cooperationand plcasecontactm-rnear 6O3-223-2541 -extendsion 23. fo1 cdangcred species questions, and contact GregMannesto ofour Rhode Island oficeat401-364-9124 for any other concerns you night have. In the future, in order to expedite your reply, please direct any inquiries br iihis nature to this orlice at the above address.

Sincerely yours.

Michael J. Amaral Endangered Species Specialist New England Field Office NUREG-1437, Supplement 22 E-32 July 2005

Appendix E DE- STATE OF CONNECTICUT ,

DEPARTMENT OF ENViRONINMENTAL, PROTECTION April 27, 2004 -

Mr. Richard Ernch Environmental Project Manager USNRC OWFN 11555 Rockville Pike Rockville,MD 20852 and Ms. P. F. Fugger.

ViP. and Chief Env. Officer Dominion 5000 Dominion Blvd.

Glen Allen, VA 23060 RE. Request to reew the opcrating licenses for Units 2 and 3 of the Millstone Power Station in Waterford, Connecticut Dominion NucIear Connecticut, applicant

Dear Mr. Emch and Ms. Faggert:

We are in receipt of a request for Federal coastal consistency concurrence for renewal of the operating licenses for Units 2 and 3 at the Millstone Power Station in Waterford. Connecticut.

This consistencyconcuffence request was submitted pursuant to 15 CFR 930.50.

Continued operation of the Millstone Nuclear Power plant requires renewal of the NPDES pernit previously issued for the discharge of cooling waters. A request for that permit renewal was submitted by the applicant in a timely fashion and is currently pending befure the Dcpailtrnent.

In the interest of permit coordination, we have elected to waive the separate Federal coastal consistency review for this particular operating licensc application. However, this waiver should not be construed as our determination that the proposed activities arm consistent with Connecticut:s approved coastal management program. Instead. the State of Connecticut will evaluate the consistency or this proposed activity for conformance with the relevant coastal management policies, standards and criteria in conjunction with the State's NPDES permit review process as required by the Connecticut Coastal Management Act [Connecticut General Statutes (CGS) sections 22a-90 through 22a-l 121.

Phone 60.424.3034 Fa SG0.424A054 79 El. Sulaml

• HaIfod. CT 06106r-12?

Al Le.. Opp.....;ty Epr..p, July 2005 E-33 NUREG-1437 Supplement 22

Appendix E April 27,2004 Page 2 This waiver is provided in response to the Federal coastal consistency concurrencc request and the supporting documentation submitted to this Office on January 27.2004. Any subsequent modification. addition or deletion to the proposed activity. regardless of its magnitude or impact, constitutes a new application for the purposes of federal consistency certification. Accordingly.

all such modifications, additions or deletions must be submitted to the State of Connecticut for a coastal consistency concurrence pursuant to 15 CFR 930.50.

If you have any questions regarding this matter, you may contact Margaret Welch of this Offce via e-mail at marmarct welch( oo state.ct.us or by phone at 860.424.3034. Thank you.

Charles H. Evans. Director Office of Long Island Sound Programs CHE(MLWT v cc, Allison Castellan Charles Nezianya Edward Wilds NUREG-1 437, Supplement 22 E-34 July 2005 .

Appendix E

% , UNtTED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATION MARNE FrS4IERES SERV=

\ 1 ') .F NORTEAST REGION

- ela 0,r rbl DNO

" -. ucnerr.NA a2298 "-.

SEP, 2.1 t3:l' PsO-Tsin Kuo Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Otfice of Nuclear Reactor Regulation US Nuclear Regulatory Commission MS T-1I Fl

%Vashinzton.DC 20555 Re: Millstone Power Station Units 2 and 3 license renewal Dcar Mr. Kuo, This is in response to your letter dated March 17,2004 requesting infornation on the presence of threatened, endangered, candidate and proposed species listed under the jurisdiction of the National Marine Fishcries Service (NOAA Fisherics) in the vicinity of the Millstonc Powvcr Station located ott the north shorc ofLong Island Sound I; Vaterford. Connectcut. The US Nluciea'Regulatory Commrision (NRC) is reiewving n application submitted by Dominion NudleakCodnbeciicut Jnc:(DNC)for the rcnefal of the operadng licenses forMillstone Powcr Statioui.Units 2'ndB3(bPS).:In-support'f6thWisreview; theNRC is curnnily'preparnnga., -

Supplemental Environmental Impact Statement (EIS).

Four'specis'of federally thrcatencd br endangered sca turtlcs urnder the jurisdiction'of the"'

National Marine Fisheries-Service (NOAA Fisheries) may oefound seasonally in the wvaters of Long Island.- Sea turtles are expected to be in the vicinity of the project area In warmer months.

typically from May I to November 15. The sea turtles in northeastern nearshore waters are typically small juveniles with the most abundant being the federally threatened loggerhead (Carittacaretto followed by the federally cndangercd Kemp's ridley (Lupidoclielys kemps).

Loggerhead turtles have been found tobe relatively abundant off thc Northeast (from tear Nova Scotia. Canada to Cape Hatteras, North Carolina). From November to March in 19SS through 1988, 130 cold-stunned turtles were collected along the Long Island shoreline, Including 97.*.

Kemp's ridleys. The waters of Long Island Sound have also been found to be warm enough to support federally endangered green sea turtles (Cihelonia mydas) from June through October.

The three species ofchelonid turtles found in the Northeast remain very briefly In open occan witcrs.spending mostof their time'during !hpsummer months in habors and estuarine watcrs.

Fdd'ially.etadangercdteatherbaikscaturties (Dfrmnqclaeys coriacta)n)ybe found in the waters b'fLdIsandSound during the sarrndr:months-as 'well

, .S ..

July 2005- E-35 --- NUREG-1437, Supplement 22

Appendix E Federally endangered North Atlantic right whales (Eubalbenaglaclatis). humpback whales (Afegapteranovacangtiae).and Ein whales (Bolaenopteraphlysalas)may all also be found seasonally in Northeast waters. North Atlantic right whales have been documented in the nearshore waters of New York from January through September. Humpback whales feed during the spring, summer, and fall over a range that encompasses the eastern coast of the United States.

Fin whales are common in waters of the United States Exclusive Economic Zone, principally offshore from Cape Hatteras northward. While these whale species are not considered residents of Long Island Sound. it is possible that transients may enter the area during seasonal migrations.

The entrainment and impingement of sea turtles at several nuclear power plants on the East-Coast has been documented. As sea turtles may be seasonally present in the vicinity of the intakes associated with the )SPS. NOAA Fisheries recommends that this impact be fully addressed in the SEIS being prepared in anticipation of license renewal actions. NOAA FIsheries staff look forvard to reviewing the SEIS and will be available to NRC staff to discuss any potential impacts on listed species. Please contact Julie Crocker of my staff ((978)281;932 x6530 or iulie.crockernonn -ov) if you would like to set up a conference call or meeting.

Section 7(a)(2) or the Endangered Species Act (ESA) of 1973. as amended, states that each Federal agency shall, in consultation with the Secrctary, insure that any action they authorize, fund, orcarry out is not likely tojeopardize the continued existence of a listed species orresult in the destruction or adverse modification of designated critical habitat. Any discretionary federal action that may affect a listed species must undergo Section 7 consultation. As listed species may be present in the project area, the NRC is responsible for determnininjwhethcr the proposed action is likely to affect any listed species. The NRC should then submit their determination along wvith a request for concurrence, to the attention of the Endangered Species Coordinator, NOAA Fisheries. Northeast Regional Office, Protected Resources Division, One Blacklbum Drive, Gloucester, MA 01930. After reviewing this inforrnation, NOAA Fishedes would then be able to conduct a consultation under section 7 of the ESA.

Should you have any questions about these comments or about the section 7 consultation process in general, please contact Julie Crocker at (97S)281-9328 ext. 6530.

Sincerely.

Assistant Regional Administrator for Protected Resources Cc: Ludwig, FINER4 MneCon Sm 7.RCNXtiAkms Norkw Nv'u Pt8 NUREG-1437, Supplement 22 E-36 July 2005. :

Appendix E STATE OF CONNECTICUT COMMISSION ON CULTURE AND TOURISM October 6,2004 Mr. Pao-Tsin Kuo License Renewal and Environmental Impacts Division of Regulatory Improvement Programs '

Office of Nuclear Reactor Regulation .

Nuclear Regulatory Commission WVashington, DC 20555-0001

Subject:

Millstone Power Station Units 2 and 3 License Renewal Waterfurd, CT '

Dear Mr. IKuo:

The State Historic Preservation Office has reviewed the above-named project. This office expects that the proposed undertaking %ill have effet on historic, architectural, or archaeological resources listed on or eligible for the National Register orHistoric Places.

This office appreciates the opportunity to have reviewed and comrmented upon the proposed undertaking.

We recommend that the responsible agency provide concerned citizens with the opportunity to review and comment upon the proposed undertaking in accordance with the National Historic Preservation Act and the Connecticut Environmental Policy Act.

For further information please contact Dr. David A. Poirier, Staff Archaologlst.

J. Paul Loether Division Director and Deputy State Historic Preservation Officer

.A10%.

Hlistorie Preservntion and Mluseum Division -  :

Amos MIt Hlouse.59 South Prospeci Street, 1lartrord, Conneelicut 06106 860-566-3005 . 860-566-5078 [ax An Equal OppontnIly E*ploevr July 2005 E-37 NUREG-1437, Supplement 22

Appendix E UNIT ED STATES NUCLEAR REGULATORY COMMISSION WAkS4HOTOH. D.C. 2M5541I lNovember 9, Z004 Ms. Patricia A. Kurkul, Regional Administrator NOMA Fisheries Northeast Regional Office One Blackburn Drive Gloucester, MA 09130-2298

SUBJECT:

REQUEST FOR CONCURRENCE- BIOLOGICAL ASSESSMENT FOR MILLS;TONE POWER STATION, UNITS 2 AND 3 LICENSE RENEWAL

Dear Ms. Kurkul:

The U.S. Nuclear Regulatory Comnission (NRC) has prepared the enclosed biological assessment (8A) to evaluate whether the proposed renewal of the Milstone Power Station, UnIts 2 and 3 (MPS) operating icanses for a period of an additional 20 years would have adverse effects on listed species. The proposed action (license renewal) is not a major.

constrction activity. MPS Is located on the north shore of Long island Sound in Waterford.

Connecticut approxImately 40 mles southeast of Hartfoid, Connecticut.

By letter dated March 17, 2004. to the National Oceanio and Atmospherb Administratlon (NOAA) - Fisheries, the NRC requested a list of Federally threatened or endangered aquatic specles that may be In the vicinity of MPS and Its assocIated transmission lines. Ina letter dated September 21 2004, NOM Fisheries provided a lIst of Federally threatened or endangered specbs. Your office Identified one threatened and three endangered species of sea turtles that may be seasonally found In the waters of Long Island. These include the loggerhead (Cara careta), Kemp's ridley (Lspkiochelys kwrpon green turtles (Choks mydas). and leatherback turtles (Deinnochelys corhacea).- The letter also Identified three other endangered species known to occur seasonally In Northeast waters, the North Atlantic right whales (Eubalsfna glacialis) hurspback whales (MFog e rnovaeenglie), and fin whales (Baelactera physahs). The NRC has also included h its evaluation the andangered shornose sturgeon (Acipeser brovmswrum); this species b known to occur in the Connecticut River, which flows into Long Island Sound approxirnately 10 rifles east of the MiRstone site.

In addition the staff also contacted U.S. Fish and WildUle Service (FWS) by letter dated March 18, 2004, requesting a flst of Federally threatened or endangered terrestrial specles that may be in the vicinity o( MPS. In a letter dated April 15. 2004, FWS Identified the foblowing terrestrial species: the endangered roseate tem (Stema dLgai dougaNih); the threatened piping plvr (Chracdkus mefodkis), puritan tiger beetle (Ckindela purfana). small whorled pogonla (Jsotnla medaoldoes), and bald eagle (Harlateus heucophalus); and one caoddate species the New England cottontai (Sy'Msgw transfitons).

The staff has determined that license renewal for MlIstone would have no effect on the puritan tiger beetle. shortnoss sturgeon, loggerhead sea turtle, green sea turtle leatherback sea turtle, Kemp's ridley sea turtle. piping plover, right whale, finback whale, and humpback whale.

License renewal may affect, but Is not likely to adversely affect, the bald eagle, roseate tem, New England cottontail, and small whorted pogonla.

NUREG-1437, Supplement 22 E-38 July 2005 I

Appendix E P. Kurkul We are requesting your concurrence with our determilnationr In reaching our conclusion, the NRC staff relied on information provided by the licensee, on literature research and Interviews with experts performed by NRC staff, and on Information provided by FWS (i.e.. Including current listings of species provided by the FWS. Concord, New Hampshire, New England Field Office) and NOAA Fisheries (Northeast Regional Office).

If you have any questions regarding this BA or the staffs request, please contact Mr. Richard L Emch, Jr., Senior Environmental Project Manager, at 301.415-1590 or via e-mall at reoOnrc.gov.

Sincerely.

• cense Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-336 and 50-423

Enclosures:

As stated I . i .

cc wlenctL: See next page July 2005 E NUREG-1437, Supplement 22

Appendix E UNITED STATES NUCLEAR REGULATORY COMMISSION W:

WAStTOK DC. 20585.0W1 November 9, 2004 Mr. Marvin Moriarty. Regional Director Northeast Regional Offlce U.S. Fish and Wildlife Service 300 Westgate Center Drive Hadley. MA 01 035.9589

SUBJECT:

REQUEST FOR CONCURRENCE- BIOLOGICAL ASSESSMENT FOR MILLSTONE POWER STATION, UNITS 2 AND 3 LICENSE RENEWAL Dear Mr. Moriarty.

The U.S. Nuclear Regulatory Commission (NRC) has prepared the enclosed biologIcal assessment (BA) to evaluate whether the proposed renewal of the Millstone Power Station, Units 2 and 3 (MPS) operating flcenses for a period of an additional 20 years would have adverse effects on listed species. The proposed action (license renewal) Is not a major construction activity. MPS Is located on the north shore of Long Island Sound In Waterford, Connecticut, approximately 40 miles southeast of Hartford, Connecticut.

By letter dated March 18, 2004, to the U.S. Fish and Wildlife Service (FWS). the NRC requested a l1st of Federally threatened or endangered terrestrial species that may be in the vicinity of MPS and its associated transmission lines. In a letter dated April 15. 2004, the FWS provided a list of Federally threatened or endangered species. The FWS Identified the following terrestrial species: the endangered roseate tern (Stoma dougalfi dougaillo; the threatened piping plover (Charadrus melodus), puritan tiger beetle (Cicindela purilana), small whorled pogonia (Isotrla medoololdes), and bald eagle (Harlaeatus Ieucophalus); and one candidate species, the New England cottontail (Syhlagus transitlonalls).

In addition the staff also contacted the National Oceanic and Atmospheric Administration -

Fisheries (NOAA Fisheries) by latter dated March 17,2004, requesting a list of Federally threatened or endangered aquatic species that may be In the vicinity of MPS. In a letter dated Septenter 21, 2004, NOAA Fisheries identified one threatened and three endangered species of sea turtles that may be seasonally found In the waters of Long Island. These are the loggerhead (Caretta caretta), Kemp's ridley (Lepidochelys kemp4, green turtles (Chelonia mydas) and leatherback turtles (Dermochelys corlacea). The letter also Identified three other endangered species known to occur seasonally In Northeast waters, North Atlantic right whales (Eubalaena glacialls), humpback whales (Magaptera novaoangllae), and fin whales (Balaenopteraphysalus). The NRC has also included In Its evaluatin the endangered shortness sturgeon (Aciponserbrevirostrum); this species is known to occur in the Connecticut River, which fiows into Long Island Sound approximately 10 miles east of the Millstone site.

The staff has determined that license renewal for Millstone would have no effect on the puritan tiger beetle, shortnose sturgeon, loggerhead sea turtle, green sea turtle, leatherback sea turtle.

Kemp's ridley sea turtle, piping plover, right whale, finback whale, and humpback whale.

License renewal may affect, but is not likely to adversely affect, the bald eagle, roseate tern, New England cottontail, and small whorled pogonia.

NUREG-1 437, Supplement 22 E-40 July 2005

Appendix E M. Moriarty We are requesting your concurrence with our determination. In reaching our conclusion. the-NRC staff relied on Information provided by the licensee, on literature research and Interviews with experts performed by NRC staff, and on Information provided by FWS (i.e., Including current listings of species provided by the FWS, Concord, New Hampshire, New England Field Office) and NOAA Fisheries (Northeast Regional Office).

If you have any questions regarding this BA or the staff's request, please contact Mr. Richard L Emch, Jr:, Senior Environmental Project Manager, at 301-415-1590 or via e-mail at rdefnrc.gov.

Sincerely, P Ku&, Program Director Lense Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-336 and 50-423

Enclosures:

As stated cc w/encl.: See next page July 2005 !,,.. E-41 NUREG-1437, Supplement 22

Appendix E ENCLOSURE 1 BIOLOGICAL ASSESSMENT NUREG-1 437, Supplement 22 E-42 July 2005

Appendix E Biological Assessment .

Millstone Power Station'-

License Renewal Review USNlrer Commissio

'- 'October 2004 '-','

Docket Numbers

- 50-336

50423:

. I. . .

U.S.,,Nuclear Regulatory. Commission- ,-

,-'-Rockville, Maryland,._q,_. -

July 2005 E-43 NUREG-1 437, Supplement 22-

Appendix E 1.0 Introduction The U.S. Nuclear Regulatory.Cominission (NRC) issues operating licenses for domestic nuclear power plants in accordance with the provisions of the Atomic Energy Act of 1954, as amended, and NRC Implementing regulations. The purpose and need for the proposed action (that is, renewal of an operating license) is to provide an option that allows electric power generation to continue beyond the term of the current nuclear power plant operating license, so future generating needs can be met if the operator and State regulatory agencies pursue that option.

Dominion Nuclear Connecticut. Inc. (Dominion) has prepared an environmental report In conjunction with its application for renewal of the Millstone Nuclear Plant. Units 2 and 3 (Millstone) operating licenses, as provided for by the following NRC regulations:

• Title 10, Energy, Code of Federal Regulations (CFR) Part 54, Requirements for Renewal of Operating Ucenses for Nuclear Power Plants," Section 54.23, Contents of application - environmental information (10 CFR 54.23).

• Title 10, Energy. CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions," Section 51.53, Postconstnrction environmental reports, Subsection 51.53(c), Operating license renewal stage 110 CFR 51.53(c)].

The NRC Is reviewing an application submitted by Dominion (the applicant) for the renewal of the operating licenses for Millstone for a period of an additional 20 years. There will be no major construction, refurbishment, or replacement activities associated with this action. This biological assessment examines the potential effects of the continued operation of Millstone on 14 Federally listed species and one species proposed for candidate listing that could occur within the Millstone site, near the site, or along is associated transmission line rights-of-way (ROWs). This consultation is pursuant to Section 7(a)(2) of the Endangered Species Act.

In letters dated March 17 and 18. 2004, the NRC requested that the National Oceanographic and Atmospheric Administration (NOAA) - Fisheries (also known as the National Marine Fisheries Service or NMFS) and the U.S. Fish and Wildlife Service (FWS), respectively to provide lists of Federally listed endangered or threatened species and infornation on protected, proposed, and candidate species, as well as any designated critical habitat, that may be In the vicinity of Millstone and its associated transmission line ROWs (NRC 2004a, 2004b). The project area is defined as the Millstone site, its sssociated transmission line ROWs, and adjacent areas of Long Island Sound. In letters from the FWS (FWS 2004a) and the NMFS (NMFS 2004a), the NRC was provided a list of Federally protected species In the project area.

A total of eight aquatic and six terrestrial species afforded protection under the Endangered Species Act of 1973 or candidates for such protection were identified that could potentially inhabit the project area.

.2-NUREG-1437, Supplement 22 E-44 July 2005

Appendix E .

2.0 Proposed Action The proposed action Isthe renewal of the operating licenses for Millstone. The current operating license for Unit 2 expires on July 31, 2015, and for Unit 3 on November 25, 2025.

Dominion has submitted an application to the NRC to renew these operating licenses for an additional 20 years of operation (.e.. until July 31, 2035. for Unit 2 and November 25, 2045, for Unit 3). The renewed licenses, If Issued, will be effective from their date of issuance until 20 years after the expiration date of the current operating licenses.

Millstone Is located on Millstone Point In Niantic Bay, between the Nantic and Thames Rivers on Long Island Sound, near Waterford In New London County, Connecticut (Figure 1). The nearest large cties are New Haven. approximately 64 km (40 ml) to the west, and Hartford, approximately 64 km (40 ml) to the northwest The site Is situated on the edge of Long Island Sound and Niantic Bay and Is approximately 32 km (20 ml) west of Rhode Island. At one time, there were three operating nuclear power plants at the Millstone site. Construction on Unit 1 began In 1966. on Unit 2 In 1970, and on Unit 3 hI 1974. Unit I was a boiling-water reactor that was permanently shut down In 1995. The facility Is In long-term storage awaIting decontamination and dismantlement as part of station decommissioning. Unit I Is not part of this license renewal application. Millstone Unit 2 is a two-loop, dosed-cycle, pressurized-water nudear reactor with a calculated electrical output of approximately 870 megawatts electric (MW[eJ): while Millstone Unit 3 Is a four4oop, dosed-cycle, pressurized-water nuclear reactor with a calculated electrical output of approximately 1.154 MW(e) (Dominion 2004a).

Long Island Sound Is the source of water for the once-through turbine condenser cooling systems at Milistone. The system withdraws salt water from Long Island Sound though Intakes, pumps the water through the condenser for cooling, and surface discharges heated water to Long Island Sound approximately 610 m (2000 if) southeast of the withdrawal points (Dominion 2004a).-

Intake structures for Units 2 and 3 are located on the eastern shore of Niantic Bay. which Is fed by Long Island Sound (Figure 2). The structures consist of four reinforced-concrete bays for Unit 2 and six bays for Unit 3. When both Units 2 and 3 are operating at full power, the 10 pumps (one for each bay) pump a total of 92 mrIs (1.46 million gpm) Into 2-m (7-fn) diameter conveyance pipes. Cooling water then moves through the condensers. After passing through each unit's condensers, cooling water Is discharged to the former granite quarry. The heated discharge water then flows through two cuts excavated from the bedrock at the eastern end of the quarry Into Long Island Sound. Figure 2 shows the Intake structures. quarry, and discharge points for the Millstone drculating water system.  ;

The Intake structures are designed to minimize the possibility of dogging or Impingement of aquatic organisms. Before the Intake water reaches the circulating water pumps, the water passes through trash racks consisting of 1-cm (3/8-1n. thick) metal bars spaced horizontally on 5-cm (24n.) centers. The water then flows through vertical traveling screens with 1-cm (3/84n.)

mesh that prevent debris and large organisms from entering the cooling system. A cutoff wall In front of the Intake extends 2.7 in (9 ft) below the surface to prevent surface water debris and organisms from entering the Intake. Individual trash and fish return troughs collect and sluice debris and fish from the screens. Unit 3 was originally constructed with a fish return trough; July 2005 :- E NUREG-1437, Supplement 22

Appendix E Figure 1. Location of Millstone. 80-km (50-mi) Region NUREG-1437, Supplement 22 E-46 July 2005

Appendix E

• /'

k

- I

.7-

'\ 1' 7S Uni:.

-,O IDW ft FIGURE 2 Millstone Po6it Location of 500 ft Millstone Cooling Water Scale 15 approx1mate.

Intakes and Discharges Figure 2. Millstorie Point Location of Millstone Cooling Wator Inlakeland Discharges July.2005 E-47 NUREG-1 437, Supplement 22 -

Appendix E a fish return trough was added to Unit 2 in 2000. Water velocity in front of the Unit 2 structure is estimated to be about 0.2 mis (0.6 ftWs) (Dominion 2004a).

Biocides are added to the Intake water to prevent biofouling. Sodium hypochlorite is injected on a periodic basis, and the system Is designed to maintain a 0.2 parts per million (ppm) chlorine concentration (Dominion 2004a). Residual chlorine is monitored in the effluent water. Thermal backwashlng is also performed to prevent mussels from fouling the Intake structure pump bays.

3.0 Environmental Setting 3.1 Terrestrial Resources The Millstone silo Is located In the Southern New England Coastal Plains and Hills of the Northeastern Coastal Zone ecoreglon (U.S. Environmental Prolection Agency [EPA) 2004a).

Pre-settlement vegetation would have consisted primarily of winter deciduous hardwood forests with some salt marsh and beach habitat types. Out of approxrmately 212 ha (525 ar) that comprise the Millstone site, current land use Includes approximately 89 ha (220 ac) of developed area, a 20-ha (50-ac) natural area, and a 12-ha (30-ac) ballpark licensed to the town of Waterford. Until 1960, the site was used as a granite quarry. which operated for 200 years (Dominion 2004a).

The current terrestrial environment Indudes old field habitats dorinated by eastern red cedar (Juniperus virgWana), scarlet oak (Quercus coccines), black cherry (Prunus serotlna), and.

blackberry (Rubus spp;) (Dominion 2004a). Comrnmon invasIve exotics In this habitat Include multflora rose (Rosa multPflors) and Japanese honeysuckle (Lonicerajaponica). Winter deciduous hardwood forest dominated by various species of oak (Quarcus spp.), pignut hickory (Carya glabra), black birch (Befula fenta). red maple (Acerrubrum), and American beech (Fagus grandifoia) Is the most common undisturbed habitat type. Along the coast, beach and coastal marsh habitats are dominated by beach grass (Ammopla brevgulata), toadflax (Linaria vwugads), evening primrose (Oanothera blennis), seaside goldenrod (Soiidago semperviens), salt meadow grass (Spartina patens), salt grass (DistichIs spicata),B8gelows gtasswort (Salcomfa b~gelovii), and smooth cordgrass (Sparline alfemfflora). Ponds and wetlands in the eastern portion of the site are managed as a wildlife refuge.

Terrestrial habitats on the Millstone silo support common wildlife species sudi as white-tailed deer (Odocofleus vk'glnlanus), gray squirrel (Scmurus carolinensls), cottontail rabbits (Sytv71agus spp.), red fox (Vulpes vuipes), woodchucks (Mammota monax), and wild turkey (Mefeagrds gagopevo). Coastal marshes and the wildlfe refuge on the site contain habitat that supports waterfowl such as mallard ducks (Anss platyrnynchos), wood ducks (Aix sponsa), Canada geese (Bmnta canadensis), common mergansers (Mergus merganser,) black ducks Onas rubrfpes), herons, and egrets. Osprey (Pandlon hallaetus) nest platforms have been maintained at Millstone for over 35 years and 173 fledglings have been produced over that time period (Dominion 2004a).

Four 345-KV transmission lines connect Millstone to the power grid (Table 1) (Dominion 2004a).

The ROWs traverse New London, Middlesex, Hartford, Tolland, and the northeast comer of New Haven counties. The four lines share a common ROW for 14.5 km (9 ml) north to Hunts NUREG-1437, Supplement 22 E-48 July 2005 I

Appendix E Brook Junction (Figure 3). At Hunts Brook Junction two lnes run north In the same ROW to the Card Street Substation where one line continues on to the Manchester Substation, one line runs east to the Montville Station and one line runs west to the Southington Substation. All Millstone lines share'ROWs with lines from other sources and would be maintained If Millstone ceased operating. Transmission lines traverse abandoned fields, pasture, cultivated fields, forests, and wetlands as well as a number of conservation areas (Dominion 2004a). The Card Street/Manchester line crosses the Pease Brook Wildlife Management Area. The Southington line crosses the Nehantic State Forest, Cockaponset State Forest, and Hartman Park, a municipal park owned by the town of Lyme, Connocticut.

Table 1. Mfllstone Transmission Une Corridors.

- Length Width Max Areaa Substation kV km (ml) m (t) ha (ac)

HuntsBrookJunction 345 14 (9) 152 (500) .220 (545)

Montville 345 6 - (4) 99 (325) 64 (158)

Card Street 345/ 32 (20) 91 (300) '294 (727)

Manchester 345 61 (38) 91 (300) 559 (1382)

Southington 345 71 (44) 76 (250) 539 (1333)

'4 Max area calculations use marimum right-ol-way width estimates (Dominion 2004a).

Connecticut Ught and Power (CL&P), a subsidiary of Northeast Utilities rconducts maintenance activities on these transmission lines and ROWs. These activities Include, but are not restricted to, maintenance of vegetation In each ROW, replacement of poles ortowers, Installaton of lightning arresters and counterpoise, and upgrading of existing equipment.

CL&P manages vegetation within the ROWs with an approach It cals two-zone maintenance' (NU 2004). The area directly beneath the transmission lines and extending out 4.5 m (15 ft) on either direction Is called the 'wire zone.' Most vegetation In the wire zone Is kept short except for the occasional clusters of eastern red cedar that are maintained for nesting habitat. The area from the edge of the wire zone to the outside edge of the ROWe Is called the 'aide zone' The side zone acts as a transition between the towers and conductors of the wire zone and the forest. The side zone Is maintained as a multi-layered habitat with low growing trees and shrubs. ;

Vegetation Is managed through a combination of mowing, trimming, and herbicide treatments.

An personnel applying herbicides are required to possess a valid applicator's lic6nse (NU 2004).

Wetlands and other water bodies are protected from herbicides by a 3-m (10-ft) vegetative border (NU 2004). Mowing Is conducted only between the months of November and April to minimize Impacts to wet soils, nesting birds, and widlife forage. The Connecticut Department of Environmental Protection (CTDEP) reviews all ROW management plans to assure protection July 2005:, E-49 NUREG-1 437, Supplement 22

Appendix E Figure 3. Millstone Site and Associated Transmission Lines NUREG-1437, Supplement 22 E-50 July 2005

Appendix E of threatened and endangered species. CL&P personnel work closely with maintenance crews to ensure that treatments are implemented properly.

CL&P encourages collaboration with conservation groups to use the ROWs for wildlife habitat Improvement. It has also developed a list of plant species and wildlife habitat types that It attempts to promote through Its vegetation management actions. Contractors are required to Identify and target non-native, InVasive plant species (NU 2004). -.

3.2 Aquatic Resources '

Aquatic resources In the vIcinity of Millstone are primarily associated with marine and estuarine environments that are part of Long Island Sound. Millstone Is bordered on the west by Niantic Bay, to the east by Jordan Cove. and to the south by the Twotree Island Channel (Dominion 2004b). The plant Is located approximately 1.6 km (1 ml) southeast of the mouth of the Niantic River, and approximately 6.5 km (3.5 mi) west of the Thames River. 'Cooling water Intakes are located In Niantic Bay on the western shoreline of Millstone Point and are situated approximately 4.6 to 7.6 m (15 to 25 A) below mean sea level. Once-through' cooling water Is discharged Into an abandoned granite quarry located In approximately the center of Millstone Point Water then flows from the quarry over a weir Into Long Island Sound near the Twotree Island Channel (Figure 2). Rated flows for Millstone Units 2 and 3 are 36 and 59 m1 s' (1275 and 2097 ftle s1) respectively. -

Long Island Sound Is a large water bbdy. with a surface area of 3420 km2 (1320 mi)). and 965 km (600 ml) of coastline. The drainage area associated with the water body is approximately 27,070 kn9 (18,820 riP). The average depth of the sound Is 19 m (63 ft); and the approximate volume Is 68 trillion L (18 trillon gallons). Milstone Point Des on the western shore of Long Island Sound, near the mouth of the sound. This area of Long Island Sound experiences a salinity of approximately 23 parts perthousand due to the Influence of three major rivers: the Thames. the Housatonic, and the Connecticut Rivers. Ambient water temperature near the Millstone cooling water Intakes can range from VIC to 22*C (34*F to 72'F) over the course of a year. Unear regression performed on daily and annual seawater temperatures near Millstone over a 25-year period revealed a significant long-term Increase In watertemperature of 1.55*C (2.8'F) based on daily means and 1.01 C (1.8F) based on annual means (Keser et al. 2003).

Millstone Point Is situated approximately 5.6 km (3.5 ml) west of the Thames River,'In an area that experiences strong tidal currents that Influence the nearshore ecosystem,rwhich Include rocky coastlines and boulder and gravel substrate beaches that support a variety of fish.

Invertebrate, and marine plant life . The average tidal fow through Twotree Island Channel Is approximately 3400 m' s (1.2 x j08 W ft3 t ) with a maximum flow of about 8500 mn's' (3.0 ix 10 ft' s'). This translates Into current velocities of about 1.8 to 3.30 km hr' (1 to 1.8 knots), with slightly lower velocities near the plant Weak currents predominate In both' the Niantic River and Jordan Cove. Tidal fluctuation In this -area Is not severe, with mean and maximum ranges of 0.8 and 1.0 m (2.8 to 3.3 ft). respectively (Dominion 2004b).

J uly 2005 - E-51 NUREG-1437, Supplement 22

Appendix E EPA Region 1 has identified Long Island Sound as an estuary of national signiflcances and listed six problem areas of concern associated with water quality (EPA 2004b):

1. Low dissolved oxygen (hypoxia)

2. Toxic contamination

3. Pathogen contamination

4. Floatable debris

5. Habitat degradation and loss, and living resource health associated with Items 1-4

6. Land use and development resulting In habitat loss and degradation of water quality These problem areas have resulted in a variety of long-term. Integrated studies of Long Island Sound by both state and Federal agendas.

• Chemical Contarninants Near Millstone Specifc chemical data associated with sediment, water, or blota near the Millstone study area were not available for review; but in general. surficlal sediment associated with the eastern portion of Long Island Sound exhibits lower levels of common contaminants (heavy metals, polycydlic aromatie hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), pesticides) than the western portion. United States Geological Survey (USGS) data (Mecray et al. 2004) showed regional patterns of high metals concentrations In the western sound, with relatively low concentrations associated with the eastern sound in the vidnity of Millstone. Draft data (Battelle 1999) associated with surfidal samples from the Thames River Indicated most metals were below NOAA effectserange-median (Long et al. 1998). and organic constituents were at or near detection limits with the exception of the PAH, perylene. which was detected at concentrations ranging from approximately 20 to 1200 pg/kg dry weight. Ills suspected the source of this compound Is blogenic rather than anthropogenic.

A citzens' group conducted limited chemical and radiological monitoring of bottom sediments in the vicinity of Millstone and reported possible elevated levels of hydrazine and uranium In the bottom sediments of Jordon Cove (CTDEP 2002). The chemical compound 1,1-dimethylhydrazlne (UMDH) was reported as detected In two sediment samples at low levels.

It was postulated that the UMDH might be due to hydrazine used at Millstone for corrosion control. CTDEP reviewed available Informatlon and concluded that the detections likely were false positives because of questionable quality of the analytical procedures, and It was unlikely that hydrazine could accumulate In bottom sediments because It degrades rapidly Into water and nitrogen. In addition, the particular chemical form of hydrazine used at Millstone Is different than UMDH. There are also industrial facilities In the area that commonly use hydrazine.

CTDEP also concluded that the types and levels of uranium measured In sediments near Millstone reflected naturally occurring background levels (CTDEP 2002). Neither concern was Judged by CTDEP to be sufficlenty credible to warrant further Investigation.

a Important Fish and Shellfish Communities Near Millstone A variety of commercially, recreatlonally. or environmentally Important fish and shellfish live or spend a portion of their life cycle In the vicinity of Millstone, and also commonly occur In Long

-10 1

NUREG-1437, Supplement 22 E-52 July 2005 I

Appendix E Island Sound (Table 2). Many of these species live In the waters near Millstone, travel through the area during their seasonal migrations in and out of Long Island Sound, or pass close'to the plant as they enter rivers adjacent to Millstone during their spawning seasons. Because of their proximity to Millstone, they may be susceptible to entrainment. Impingement, or to lethal or sublethal effects associated with Olant operations. In order to assess relative species abundance near Millstone operations, a variety of collection and enumeration methods have been employed, Including sampling cooling water discharge using plankton nets to determine Ichthyoplankton (fish eggs and larvae) abundance, shore-zone seines to capture small fish, and bottom trawls to capture larger, demersal fish (Dominion 2004b). In general, assessments of fish and shellfish have Included sampling stations in direct proximity to the plant (e.g., within a radius of approximately 3 km 12 mi). Sampling stations have Included a station located near the Unit 2 and 3 cooling water discharge, stations in the Niantic River and Bay, and stations In Jordan Cove.' Far-field reference sites were not Included In the fish and shellfish monitoring programs, nor were sampling grids located al varying distances from the area of interest to Identify environmental gradient effects. Plume dynamic studies and assessments of Intertidal ecosystems, however did use far-field reference or control sites. - ' -

Table 2. Important Fish and Shellfish Species.

Common Name Scientific Name winter founder Pseudopleuronocies ainuricanus lobster Homards emericanus -

'American sandlance Ammodytes amerkcanus anchovy - Anchoe spp. - -.

sflversldes Menidlaspp. '  :

grubby Myoxocephalusaenaeus -

cunner : .utogolebrus adspersus-.

tautog Tautogs on' Eelgrass Community Eelgrass (Zosfera marina) Is one of the dominant seagrasses In coastal regions of the northern hemisphere, and common in eastern Long Island Sound near the Millstone facility. This seagrass Is Important because of its significant Influence on the nearshore environment.

Eelgrass beds provide habitat and cover for many larval and juvenile forms of fish and Invertebrates, support significant primary and secondary production, and serve as a food source for numerous waterfowl or planktonic grazers (Kesar et al., 2003). Eelgrass beds In the vicinity of Millstone have been monitored for many years to evaluate population dynamics and document change over time. - Sampling locations Included areas associated with thermal plume discharge (Jordan Cove. White Point). and reference locations associated with the Niantic River (Dominion 2004b). ' Studies near Millstone and In Long Island Sound have shown considerable variation In the extent of eelgrass beds at all locations, probably due to water body temperature

-1 1- *'-

iuly'200: E-53 NUREG-1437, Supplement 22

Appendix E fluctuations, eutrophicatlon. sedimentation, turbidity, the presence of nuisance organisms (mussels and green algae blooms) and possible changes associated with nearshore hydrodynamics. Studies conducted at Millstone have suggested that eelgrass abundance and distribution at Jordan Cove and White Point has been affected by the thermal plume discharge.

but have observed relative stable biomass and distribution over the past 16 years at other locations adjacent to the facility (Dominion 2004b). Studies have also noted dramatic changes in eelgrass populationsIn the Nlantic River, resulting In multiple relocations of reference sites over the past 20 years due to die-off thatIs attributable to poor water quality and potential biological disturbances (Dominion 2004b).

Rocky Intertidal Communities A rich and varied rocky intertidal habitat exists in the region surrounding Millstone, and indudes marina alga. polychaeteous annelids, crustaceans, and molluscs. All of these organisms are Important contributors to the structure and function of nearshore ecosystems. Environmental studies conducted by Dominion have included sites at Fox Island, Millstone Point, White Point, and a reference location near Giants Neck (Figure 2). Cooling water discharge stations have Included a location dose to the quarry cuts and one location approximately 200 m (660 ft) southeast of the quarry cut. Millstone monitoring programs have been In effect since 1979 and are intended to provide 1) an environmental baseline of abundance ofImportant species, and

2) a means to detect change In community structure and function near the Millstone facility.

Algal studies have been conducted since 1979, and have identified over 140 species that occur or have occurred in the area during the study duration. Dominion scientists have data on organisms that represent the more common marine flora or fauna, including barnacles, the algae Fucus spp., the red alga Chondius spp.. and the marine mussel ytus edulfs.

Community analyses using clustering techniques suggest that plantImpacts are generally limited to approximately 150 m (490 ft) of shoreline on the east side of the discharge to Long Island Sound (Dominon 2004b). Detectable changes at the comrnunity level have been observed In the study area, as have ecosystem-level changes (e.g. water temperature fluctuations, nutrient concentrations, light Intensity). Of particular note Is the presence of the red alga AntUthamnkin pecUnatum, an exotic species native to the Pacific Ocean that was not previously reported In the Atlantic.

Benthic Infauna Benthic infaunal communities near Millstone are consistent with soft-bottom. nearshore environments associated with New England. These communities typically contain a diverse assemblage of species that collectively contribute to the stability of the nearshore food web.

Subtidal communities In the vicinity of Millstone and at a reference sie located near Giants Neck have been sampled and studied since 1980. During the 2003 sampling, marine polychaetes were the most abundant taxa, followed by oligochaetes, arthropods, and molluscs (DomInion 2004b). The following lnfaunal taxa were selected as representative of sites affected by Millstone: oligochaetes. the polychaetes ArkIdea catherinae, Medlomastus ambisets, Thayry spp., Polycikrus exdmius, Protodorvilea gaspeensIs, Parmpionosylls longkirrata, and the bivalve mollusc Nuculana annulata (Dorminion 2004b). Monitoring studies have been helpful In detecting changes In benthic infauna community structure and linking the observed changes to NUREG-1437, Supplement 22 E-54 July2005 I

Appendix E both natural and anthropogenic disturbances.' Milstone activities relating to cooling water discharge and required maintenance dredging have produced observable effects to the structure of benthic communities In the Immediate vicinity of the plant. 'This was clearly evident by the response of the benthic community during extended shutdowns during 1996-1998.

4.0 Assessment of Federally Usted Species Several Federally Iistid spacies are known to occur in the vicinity of the Millstone site or associated transmission line ROWs. No FWS-designated critical habitat Is found within the site or associated ROWs. '- -

4.1 Aquatic Species Eight Federally listed marine species could occur In Long Island Sound in the vicinity of Millstone. These Indude three species of whales and four species of turtle (NMFS 2004a.

FWS 2004b) (Table 3). The staff has also evaluated the potential Impacts of continued Millstone operation on the shortnose sturgeon (Acipenserbrvirorstrum). The shortnose sturgeon is a Federally listed endangered species that Is found In the Connecticut River, which flows Into Long Island Sound approximately 10 miles east of the Millstone site.

Table 3. - Aquatic Endangered and Threatened AquaticSpecles' Scientific Name Common Name Federal Statue

. . -. - -FUH - -::

Aclpenserbevirostrum - shortnose sturgeon Endangered TuRTLEs Caretta cwrefta - loggerhead - = '-Endangered Chelonla mydas

• green turtle -Threatened Denmochelys corfacea leatherback turtle - Endangered Lepldochefys kempfl Kemp's Ridley - ' Endangered WHALU . -

Baleena glaciais right whale - - Endangered Balaenoptere physsas ' f' back whale _-Endangered Megaptera novaengnae humpback whale Endangered (a)FWS 2004b, NMFS 2004a.

Shortnose Sturgeon (Acipenser brevirostrum)

The shortnose sturgeon Is Federally listed as endangered In the entire range (FWS 2004b).

Two populations of shortnose sturgeon are present In the Connecticut River. One of these Is landlocked In the upper part of the river between the Holyoke dam and Turners Faas dam In Massachusetts, and the other population Is located In the lower Connecticut River from the Holyoke Dam to Long Island Sound. An estimated 1200 to 1500 shorlnose sturgeon are found In freshwater and estuarine portions of the Connecticut River and are presumed to occasionally July 2005 E-55 NUREG-1437, Supplement

.. 22

Appendix E range Into adjacent areas of Long Island Sound (FWS. 2001). No shortnose sturgeon have been impinged or captured In more than 30 years of sampling at Millstone (Dominion 2004a).

The primary threats to this species are dam building, water pollution, and dredging (NatureServe 2004).

Although this species has not been recorded for the area and It Is highly unlikely that Individuals could even occasionally be present. The Intake structures at Dorninion have been fitted with fish sluiceways that return fish and other organisms that become Impinged during cooling water Intake. It is unknown how impingement and returns affect mortality of shortnose sturgeon but It Is expected that the mortality rate would be low. The species has a bottom orientation, It Is a strong swimmer and its robustness would likely minimize the potential for impingement.

The staff reviewed the design, operation, and location of the intake and discharge structures at Millstone and the Impingement and entrainment data collected during plant operation. The staff also visited the she and reviewed the life history information about the shortnose sturgeon. On the basis of this information, the staff has determined that the continued operation of Millstone over the 20-year renewal period will have no effect on the shortnose sturgeon.

Loggerhead (Caretta caretta)

The loggerhead sea turtle Is Federally fisted as threatened throughout Its range (FWS 2004b).

There are currently no critical habitats designated for this species, although the NMFS Is currently working on a status review based on a 2002 petition to redassify the Northern and Florida Panhandle subpopulations with endangered status and to designate critical habitat for both subpopulations (NMFS 2004b). The range for the Atlantic population of loggerheads extends from Newfoundland to Argentina, with primary nesting areas located In florida, Georgia, and the Carolinas.

The NMFS (2004b) has noted that loggerheads can become impinged on Intake structures of coastal power plants and estimates the mortality rate for impingement Is 2 percent (NMFS 2004b). The applicant has not reported any incidences of Impingement of loggerheads or Incidental takes during trawling studies In over 30 years of sampling operations.

The staff reviewed the design, operation, and location of the Intake and discharge structures at Millstone and the impingement and entrainment data collected during plant operation. On the basis of this information, and that previously provided for the aquatic resources in the vicinity of the plant, the staff has determined that continued operation of Millstone over the 20-year renewal period will have no effect on the loggerhead sea turtle.

Green Turtle (Chelonla mydas)

The green sea turtle Is Federally listed as endangered in the breeding colony populations In Florida and on the Pacific coast of Mexico and threatened for all other areas (FWS 2004b).

The western Atlantic population of green turtles ranges from Massachusetts south to the U.S.

Virgin Islands and Puerto Rico. with important feeding grounds In Florida, and primary nesting sites on the east coast of Florida. the U.S. Virgin Islands and Puerto Rico (NMFS 2004c).

NUREG-1437, Supplement 22 E-56 July 2005 I

Appendix E NMFS (2004c) has noted that green sea turtles can become impinged on Intake structures of coastal power plants and estimates the Impingement mortality for green sea turtles at 7 percent (NMFS 2004c). The applicant has not reported any Incldences of Impingement of green turtles or Incidental takes during trawling studies In over 30 years of sampling operations.

The staff reviewed the design, operation. and location of the Intake and discharge structures at Millstone and the Impingement and entrainment data collected during plant operation. On the -.

basis of this information, and that previously provided for the aquatic resources In the vicinity of the plant, the staff has determined that continued operation of Millstone over the 20-year renewal period WUfhave no effect on the green turtle:

Leatherback Turtle (Dermochelys corlacea)

The leatherback sea turtle Is Federally listed as endangered throughout Its range (FWS 2004b).

The western Atlantic population of leatherback sea turtles ranges from Nova Scotia to Puerto Rico and the U.S. Virgin Islands. During the summer. leatherbacks are typically found along the east coast of the U.S. from the Gulf of Maine to central Florida. Critical habitat designated in the area around the U.S. Virgin Islands, with nesting sites located from Georgia to the U.S.

Virgin Islands (NMFS 2004d).

The primary threats to the survival of leatherback sea turtles Include habitat destruction, Incidental catch in commercial fisheries, and harvest of eggs and meat (NMFS 2004d).

Impingement of leatherback sea turtles is not listed by NMFS as one of the human Impacts on this species (NMFS 2004d). The applicant has not reported any Incidences of Impingement of leatherback turtles or incidental takes during trawling studies In over 30 years of sampling operations.

The staff reviewed the design, operation, and location of the Intake and discharge structures at.

Millstone and the impingement and entrainment data collected during plant operation. On the' basis of this Information, and that previously provided for the aquatic resources in the vicinity of the plant, the staff has determined that continued operation of Millstone over the 20-year renewal period will have no effect on the leatherback turtle.'

Kemp's Ridley (Lepldochelys kempl) -

The Kemp's rldley sea turtle Is Federally listed as endangered throughout its range (FWS 2004b). This species is found primarDy in coastal areas of the Gulf of Mexico and the northwestern Atlantic, wlth-a major nesting beach on the northeastern coast of Mexdco (NMFS 2004e).

Habitat degradation, pollution, and Ingestion of floating debris are among the most significant threats to Kemp's rMdlay sea turtles (NMFS 20040). Impingement of Kemp's ridley was not listed In NMFS (2004e) as one of the human irnpacts on this species. The applicant did not report any Incidences of Impingement of Kemp's ridley or incidental takes during trawling' studies in over 30 years of sampling operations.  ; -

July 2005 E-57 NUREG-1437, Supplement 22

Appendix E The staff reviewed the design. operation, and location of the Intake and discharge structures at Millstone and the Impingement and entrainment data collected during plant operation. On the basis of this Information, and that previously provided for the aquatic resources In the vicinity of the plant, the NRC concludes that continued operation of Millstone over the 20-year renewal period will have no effect on the Kemp's ridley.

Right Whale (Eubalaena gladalls)

The right whale Is Federally listed as endangered throughout its range (FWS 2004b). With a population estimated at 291 Individuals In 1998, the North Atlantic right whale Isconsidered to be one of the most critically endangered populations of large whales In the world (NMFS 2002).

This population ranges from wintering and calving grounds In the coastal waters of the southeastern United States to summer feeding and nursery grounds In New England waters and Northward (NMFS 2002). In 1994. the NMFS designated three critical habitats for the North Atlantic right whale: Cape Cod BaylMassachusetts Bay. Great South Channel, and the Southeastern USA. At the present time, Injuries and mortality caused by ship strikes are the primary source of human impacts to right whales, with some additional impacts from fishery entanglements. Right whales have been sighted near Long Island Sound (NMFS 2004ay, but are not known to move Into the shallow waters Immediately offshore of the Millstone site (Dominion 2004b).

On the basis of this Information, and that previously provided for the aquatic resources In the vicinity of the plant, the staff has determined that continued operation of Millstone over the 20-year renewal period will have no effect on the Tight whale.

Flnback Whale (Balaenoptera physalus)

The finback (fin) wthale Is Federally listed as endangered throughout its range (FWS 2004b).

The current minimum population estimate from a 1999 survey for the western North Atatic fin whale was 2382 (NMFS 2002). Fin whales are found principally In waters from North Carolina north to Nova Scotia. New England waters provide an Important feeding ground for this spedes. There are no critical habitats designated for the fin whale, although a recovery plan has been drafted. At the present time, Injuries and mortality caused by ship strikes are the primary source of human Impacts to fin whales. It Ispossible that fin whales could enter Long Island Sound, but they are not known to move Into the shallow waters Immediately offshore of the Millstone site (Dominion 2004b).

On the basis of this information, and that previously provided for the aquatic resources In the vicinity of the plant, the staff has determined that continued operation of Millstone over the 20-year renewal period will have no effect on the fin whale.

Humpback Whale (Megaptera novaengllae)

The humpback whale Is Federally Usted as endangered throughout Its range (FWS 2004b).

The overall abundance for the North Atlantic humpback whale population was estimated in 199211993 at 11,570 Individuals (NMFS 2002). North Atlantic humpback whales are found during the spring, summer, and fall over a range covering the eastern coast of the United NUREG-1 437, Supplement 22 E-58 July 2005 I

Appendix E States. New England waters are an Important feeding ground for this species. A recovery plan.

for humpback whales has been developed and Implemented.' Injuries and mortality from fishery entanglements and ship strikes are the primary human Impacts on humpback whales.

Disturbance from whale watching traffic Is also of concern, particularly In coastal New England waters. It Is possible that humpback whales could enter Long Island Sound, but they are not known to move Into the shallow waters Immediately offshore of the Millstone site (Dominion 2004b).

On the basis of this Information, and that previously provided for the aquatic resources In the vicinity of the plant, the staff has determined that continued operation of Millstone over the 20-year renewal period will have no effect on the humpback whale. ,

4.2 TerrestrIal Species -

A total of five Federally fisted and one potential candidate terrestrial species was Identified (FWS 2004a) as having the potential to occur In New London county or counties traversed by transmission line ROWs (Middlesex, Hartford, Tolland. and the northeast corner of New Haven):

(Table 4).

Table 4. -. Terrestrial Endangered and Threatened Species: -; - i Scientific Name Common Name Federal Status" INSECTS ClcIndela purftana Puritan Uger beetle -- -- e Threatened BIRDS Charaddus nelodus piping plover Threatened Hafiaeets JeucocephaA's bald eagle  ; Endangered Sterna dougaIN doug& roseate tern Endangered MAMMALS1 S/megus transitknvls New England cottontail Proposed for Candidacy

• - PWL S .

isobra mnedelokas small whorled pogonla* - Threatened (a) FWS 2004a, 2004b. - . .-. ---- . . -- .

Puritan Tiger Beetle (Cicindela purltana)

The Puritan tiger beetle Is Federally listed as threatened. This species Is krnown from two disjunct populations, one along Chesapeake Bay In Maryland and one along the Connecticut River, In northern Connecticut (CTDEP 2004). Although this species Is reported to occur In'-

Middlesex County (FWS 2004b), CTDEP distribution maps clearly show the Connecticut population to be centered primarily along the Connecticut River In Hartford County (CTDEP 2004). tThe Millstone ROW for the Manchester transmission line does not cross the Connecticut River In Hartford County. The Puritan tiger beetle is restricted to sandy habitats typically found along river banks. Habitat has been depleted through riverbank stabilization and July 2005 E-59r NUREG-1437, Supplement 22

Appendix E flood control practices. There is no known habitat for this species near the Millstone site or within associated transmission line ROWs.

The staff has determined that continued operation of Millstone over the 20-year license renewal term will have no effect on the Puritan tiger beetle.

Piping Plover (Charadrifus melodus)

The piping plover Is Federally listed as threatened. This species Is a shorebird that Is found nesting in sandy beach habitats along seacoasts (CTDEP 2004). Piping plovers nest from North Carolina north to Nova Scotia. Nesting generally occurs from March through July.

Historically, these birds were killed for consumption and the feathers used for adomment.

Current threats Include development and beach stabilization.

CTDEP range maps (CTDEP 2004) show piping plover habitat extending no further east than the east side of the mouth of the Connecticut River. There have been no reported sitings of piping plovers at the site. It is not likely that the necessary beach habitat for nesting Is present In the vicinity of the site.

For these reasons. the staff has determined that continued operation of Millstone over the 20-year license renewal term will have no effect on the piping plover.

Bald Eagle (Hallaeetus leucocephalus)

The bald eagle Is Federally listed as threatened. This species Is a large raptor that is found along the coastline and around lakes and rivers. Eagles generally nest In tall trees or on cliff faces near water and away from human disturbance. Eagle populations have declined In the Connecticut due to loss of habitat. human disturbance, and pesticide contamination. There are reported to be up to 100 eagles wintering along major rivers and reservoirs In Connecticut (CTDEP 2004). There are no known nesting pairs near the Mi~lstone site or along transmission corridors. However, indviduals have been seen foraging In the area.

Although no bald eagles are known to nest at the Millstone site, Dominion does maintain a raptor reporting program and will follow CTDEP recommendations should bald eagles nest on the Millstone site. For these reasons, the staff has determined that continued operation of Millstone over the 20-year license renewal term may affect, but Is not likely to adversely affect, the bald eagle.

Roseate Tern (Sterna dougatill dougallll)

The roseate tern Is Federally listed as endangered. This species Is a seabird that Is found almost exclusively on saltwater coastlines. Roseate terns nest In colonies on coastal beaches and offshore Islands. Historically, tern populations in Connecticut have been Impacted by unrestricted market hunting and more recently by the expansion of predatory great black-backed and herring gull populations throughout their range In the state (CTDEP 2004).

NUREG-1437, Supplement 22 E-60 July 2005

Appendix E Fox Island (Figure 2) Is a small promontory extending off the Millstone site and Into Long Island Sound. This site Is used by multiple'species of seabirds and It Is known to be used by roseate tems during the fall migration period. Roseate tems are not known to nest In the vicinity of the Millstone site (Dominion 2004a). Fox Island Is managed as a tern sanctuary In the fall and access is strictly controlled. For these reasons, the staff has determined that continued operation of Millstone over the 20-year license renewal term may affect, but Is not likely to adversely affect the roseate tern.

New England Cottontail Rabbit (Sylvilagus translitonalis)

The FWS Is In the process of determining It the New England cottontail rabbit will be proposed for listing as a candidate species. Populations In Connecticut were considered abundant through the mid 1930s, but competition from Introduced Eastern cottontails (SyMlagus t7ofidanus) and loss of agriculture-related habitat has led to a decline Is numbers (CTDEP 2004). This species Is found In brushy habitats associated wIth fencelines and edges of fields and forests. Transmission line corridors are not considered high quality habitat due to the abundance of perching raptors and other predators that use the corridors. However, the '

species may use corridors for dispersal from one site to another. Surveys of eastern and New England cottontail rabbits have found New England cottontail rabbits near the Millstone site and '

In areas crossed by transmission lines (Goodie et al. 2004). Considering the population trends of this species It Is likely to be listed before or during the period of license renewal.

Vegetation management techniques used on the Millstone site and associated transmission line corridors maintain the early successional habitat types that the New England cottontail requires.

The CTDEP reviews aN ROW management plans to assure protection of threatened and endangered species. CL&P personnel work closely with maintenance crews to ensure that treatments are Implemented properly. The staff has determined that with Implementatlon of current management procedures and safeguards, continued operation of Millstone over the 20-year license renewal term may affect, but Isnot likely to adversely affect, the New England cottontaiL-Small Whorled Pogonla (Isoida medeololdes) -

The small whorled pogonla Is Federafly listed as threatened. This species occurs In Isolated populations throughout the eastern United States. In Connecticut t is reported to occur in New London, Middlesex. Tolland, Hartford, and New Haven counties. New England populations of this orchid are found almost exclusively on acidic, well drained, fragipan (a subsurface Impermiable layer) soils (NatureServe 2004). Common plant associates Include red maple, eastern hemlock (Tsuga canadensis), paper birch (Betula papyritera). northern red oak (Quercus rubra), eastern white pine (Pinus strobus), and American beech (Fagus grandifolia).

Isotria populations are found In second growth and mature forests. The major threats to this species are habitat destruction through development and forestry. ' --

Habitat for the small whorled pogonia may exist at the Millstone site or along associaled transmission line ROWs. The Millstone she is covered by glacial soils (Dominion 2004a) which '

can have subsurface fragipan layers. Some of the common plant associates'are found on the site (red maple. American beech). This plant has been recorded In the towns of Lyme and -

July 2005 E E-61 -- NUREG-1437, Supplement 22

Appendix E Glastonbury, Connecticut but Is not known to currently occur at these sites (NRC 1984). ROW maintenance activities should not greatly impact the small whorled pogonia as long as soil disturbance is minimized. Mowing of some portions of the transmission line ROWs Is only conducted between the months of November and April to minimize Impacts to wet soils (NU 2004).

The CTDEP reviews all ROW management plans to assure protection of threatened and endangered species. CL&P personnel work closely with maintenance crews to ensure that treatments are implemented properly. The staff has determined that with Implementation of current management procedures and safeguards, continued operation of Millstone over the 20-year license renewal term may affect, but is not likely to adversely affect, the small whorled pogonia.

5.0 Conclusions The staff Identified six terrestrial and eight aquatic species listed as threatened, endangered, or proposed for candidate under the Endangered Species Act that have a reasonable potential to occur In the vicinity of Millstone, along associated transmission line ROWs, or In adjacent areas of Long Island Sound. The Millstone site and the transmission line ROWs may cross or contain suitable habitat for some of these species. Glven this possibility. Northeast Utilities has designed and Implemented maintenance procedures for Its transmission line rIghts-of-way that protect listed species and their habitats.

The staff has determined that license renewal for Millstone would have no effect on the Puritan tiger beetle, shortness sturgeon, loggerhead, green turtle, leatherback turtle. Kemp's ridley, piping plover, right whale, finbackc whale, and the humpback whale. Lcense renewal may affect, but is not likely to adversely affect, the bald eagle, the roseate tem, the New England cottontail, and the small whorled pogonia.

6.0 References Atomic Energy Act of 1954, 42 United States Code (USC) 2011, et seq.

Battelle Duxbury Operations (Battelle). 1999. Draft Final Data Report for Thames River Vibratoly Core Samplfg at Uncesviyle, CT. Duxbury. Maryland.

Connecticut Department of Environimental Protection (CTDEP). 2002. Letter from Water Management Bureau, Robert L Smith, Chief, to Scott Mb Cullen, STAR Foundation.

Connecticut Department of Environmental Protection (CTDEP). 2004. Whilff In Connecticut Endangered and Threatened Species Sedes. Accessed at httplJIdep.state.ct.us/bumatrhAvikidfe/factshts on April 27 through Sept 21, 2004.

Dominion Nudear Connecticut (Dominion). 2004a. Applicants Environmental Report-Operating Ucense Renewal Stage, Millstone Power Station Units 2 and 3, Dominion Nuclear.

Connecticut. Docket No. 50.338, License No. DPR-65; Docket No. 50-423, License No.

NPF-49. January 2004.

NUREG-1437, Supplement 22 E-62 July 2005

Appendix E Dominion Nudear Connectcut (Dominion). 2004b. Annual Report 2003. Monitoring the Marine Environment of Long Island Sound at Millstone Power Station, Waterford, Connecticut.

Millstone Environmental Laboratory, Dominion Nudear Connecticut April 2004.

Goodie. TJ.. MA Gregonis. and H.J. Kllpatrick. 2004. Preliminary assessnnent of New England cottontail (Sytvilagus fransltlonalis) and eastern cotiontail (Sytlvtagus floddanus) distribution In Connecticut, October 2000-March 2004. Connecticut Department of Environmental Protection. '

Keser. M., J.T. Svwenaarton. J.M. Vozarik ,and J.F. Foertch. 2003. 'Decline In eelgrass (Zostera marina L) In Long Island Sound near Millstone Point, Connecticut (USA) unrelated to thremal Input. Journal of Sea Research 49, 11-26. - . -. -

Long, E.R.. L.S. Field. D.P. MacDonald. 1998. Predicting toxrdy In marine sediments w1th numerical sediment quality guidelines. Environmental Toxicology and.

Chemistry 17(4):714-727.

Mecray, E.L., M.R. Buchholtz ten Brink, and S. Shah. 2004. Metal Distributions In the surface sediments of Long Island Sound. U.S. Geological Survey (USGS), USGS OFR 00-304:

Chapler 6. http 1/pubs.usgs.govlof/ofo30034/htmldocs/chap06/indexbhrnNRESULTS National Marine Fisheries Service (NMFS). 2002. U.S. Atlantic and Gulf of Mexico Marine Mammal Stock Assessments - 2002. Accessed ate . -

http:/lwww.nmfs.noaa.gov/proLres/PR2/StockAssessmentProgramrisars.html#Overvlew. on June 24,2004.-.

National Marine Fisheries Service (NMFS). 2004a. Letter from National Marine Fisheries Service, providing a response to the March 17,2004 NRC staff letter requesUing Inforrnation regarding threatened and endangered species In the vicnity of the MPS. UnIts 2 and 3.

(Accession No. ML042810294)

National Marine Fisheries Service (NMFS). 2004b. Loggerhead Sea Turtles (Caretta caretta).

Accessed at: httplAvw.nrnfs.noaa.gov/protreslspeleslturtleslloggerhead.html on June 24, 2004.

National Marine Fisheries Service (NMFS). 2004c. Green Sea Turtle (Chelonia mydas)

Accessed at; http:/lwww.nrrifsnoaa gov/proLres/specles/lurtres/green.htrnl. on June 24. 2004.

National Marine Fisheries Service (NMFS). 2004d. Hawksbtll Sea Turtle (Eretmochelys Imbricasta). Accessed at http:/lw'w.rirfs.noaa.gov/prot res/specdesturtles/hawksbil.htmL. on June 24. 2004. - - ;, -

National Marine Fisheries Service (NMFS). 2004e. Kemp's Ridlay Turtle (Lepidochelys kempl)

Accessed at: http:/iww.nrnfs.noaa.gov/Lprotes/specleslturtiesikenps.htmnl. on June 24, 2004.

July 2005 E-63 NUREG-1437, Supplement 22

Appendix E NatureServe 2004. NatureServe Explorer an Online Encyclopedia of Life. Version 3.1.

NatureServe, Arlington. Virginia. Accessed at http twww.natureserve.org. on September 17-21,2004 Northeast Utilities (NU). 2004. Section 111, Technical Requirements. Specificatlon forRights-of-Way Vegetation Management U.S. Environmental Protection Agency (EPA). 2004a. Ecoregiens of Massachusetts, Connecticut, and Rhode Island. Accessed at http:/jvww.epagovtwedlpageslecoreglonslrnactrLeco.htm on September 21. 2004.

U.S. Environmental Protection Agency (EPA). 2004b. Long island Sounrd An Estuary of Natonal Significance. U.S. Environmental Protection Agency, Region 1: New England Access at: httpwiwww.epa.govkregionOl/econlslccrnp.intro.html. on June 24. 2004.

U.S. Fish and Wildlife Service (FWS). 1999. Title 50- Wildlife and Fisheries, Part 17-Endangered and Threatened Wildlife and Plants, Subpart i3- Lists. U.S. Fish and Wildlife Service, December 21. 1999.

U.S. Fish and Wildlife Service (FWS). 2001. Fish Facts- Shorinose Sturgeon. Connecticut River Coordinator's Office website. Accessed at httpJiwvw.fws.govrScTtishIzf acbr.htrmL on June 24, 2004.

U.S. Fish and Wildlife Service (FWS). 2004a. Letter from U.S. Fish and Wildlife Service.

providing a response to the March 18, 2004 NRC staff letter requesting information regarding threatened and endangered species In the vicinity of the MPS. Units 2 and 3. (Accession No. ML0411190230)

U.S. Fish and Wildlife Service (FWS). 2004b. Species Information, Threatened and EndangeredAnimals and Plnts website. Accessed at httpl/endangered.iws.govlwildflfe.html.

Accessed August 2. 2004 through September 23, 2004.

U.S. Nuclear Regulatory Commission (NRC). 1984. Final Environmental Statement related to operation of Millstone NuclearPower Station. Unit No. 3. Docket No. 50-423. NUREG.1064.

Washington, D.C.

U.S. Nuclear Regulalory Commission (NRC). 2004a. NRC staff letter to Ms. Patricia A. Kurkul.

Regional Administrator, National Marine Fisheries Service (NOAA Fisheries). Request for Ust of Protected Species Within the Area Under Evaluation for the MPS. Units 2 and 3, Ucense RenewaL (Accession No. ML040780653)

U.S. Nuclear Regulatory Commission (NRC). 2004b. NRC staff letter to Mr. Marvin Moriarty, Regional Administrator. National Marine Fisheries Service (NOAA Fisheries). Request for List of Protected Species Within the Area Under Evaluation for the MPS, Units 2 and 3, Ucense Renewal. (Accession No. ML040770760)

NUREG-1 437, Supplement 22 E-64 July 2005 I

Appendix E Millstone Power Station, Units 2 and 3 cc:

Lillian M. Cuoco, Esquire - Senior Resident Inspector Senior Counsel Millstone Power Station Dominion Resources Services. Inc. clo U.S. Nuclear Regulatory Commission Rope Ferry Road P. 0. Box 513 Waterford, CT 06385 Niantic, CT 06357 Edward L Wilds, Jr., Ph.D... Mr. G. D. Hicks Director, Division of Radiation Director - Nuclear Station Safety Department of Environmental Protection and Licensing 79 Elm Street Dominion Nuclear Connecticut. Inc.

Hartford. CT 061 6-5127 Rope Ferry Road Waterford, CT 06385 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Ms. Nancy Burton 475 Allendale Road 147 Cross Highway.-

King of Prussia. PA 19406 Redding Ridge, CT 00870 Paul Eccard - Mr. William D. Meinert First Selectman Nuclear Engineer Town of Waterford Massachusetts Municlial Wholesale 15 Rope Ferry Road Electric Company Waterford, CT 06385-2886 Moody Street P.O. Box 426 Mr. P. J. Parulls Ludlow, MA 01056 Manager - Nuclear Oversight Dorrinion Nuclear Connecticut, Inc. Mr. J. Alan Price a, Rope Ferry Road Site Vice President Waterford. CT 06385 Dominion Nuclear Connecticut, Inc.

Rope FerryRoad Mr. W. R. Matthews - -Waterford, CT 06385 Senior Vice President - Nuclear Operation s Dominion Nuclear Connecticut, Inc. Mr. Chris L. Funderburk Rope Ferry Road -- Director. Nuclear Licensing and

• Waterford,-CT 06385 Operations Support Dominion Resources Services. Inc.

Mr. John Markowicz Innsbrook Technical Center Co-Chair '5000 Dominion Boulevard Nuclear Energy Advisory Council Glen Agen. VA 23060-6711 9 Susan Terrace Waterford, CT 06385 Mr. David W. Dodson Licensing Supervisor, Mr. Evan W. Woollacott Dominion Nuclear Connecticut, Inc.

Co-Chair Rope Ferry Road Nuclear Energy Advisory Council Waterford, CT 06385 128 Terrys Plain Road Slmsbury, CT 06070 July 2005E E-65 NUREG-11437. Supplement 22 -

Appendix E Millstone Power Station, Units 2 and 3 Mr. S. E. Scace Ms. Roslyn Rubenstein, Director Assistant to the Site Vice President Waterford Public Library Dominion Nuclear Connecticut, Inc. 49 Rope Ferry Road Rope Ferry Road Waterford, CT 06385-2899 Waterford, CT 06385 Mildred Hodge, Director Mr. M.J. Wilson Three Rivers Community College Manager - Nudear Training Thames River Campus Ubrary DominIon Nuclear Connecticut, Inc. 574 New London Turnpike Rope Ferry Road Norwich, CT 06360 Waterford, CT 06385 Ralph Bunge Mr. A. J. Jordan, Jr. NRC Proceedings Representative Director - Nuclear Engineering for Waterford, CT Dominion Nuclear Connecticut, Inc. 510 Carr Ave Rope Ferry Road Rockville, MD 20850-Waterford, CT 06385 Thomas V. Wagner, AICP Mr. S. P. Saiver Planning Director Director - Nuclear Station Operations Town of Waterford and Maintenance 15 Rope Ferry Road Dominion Nuclear Connecticut, Inc. Waterford, CT 06385 Rope Ferry Road Waterford, CT 06385 David R. Lewis Shaw Pittman, LLC Mr. Charles Brinkman. Director 2300 N Street. NW Washington Operations Nuclear Services Washington. DC 20037 Westinghouse Electric Company 12300 TwInbrook Pkwy. Suite 330 Mr. William D. Corbin Rockville, MD 20852 Director - Nuclear Projects Department Innsbrook Technical Center Mr. David A. Christian 5000 Dominion Boulevard Sr. Vice President and Chief Nuclear Officer Glen Allen, VA 23060-6711 Dominion Nuclear Connecticut, Inc.

Innsbrook Technical Center Mr. William R. Watson. Jr.

5000 Dorninlon Boulevard Supervisor - Ucense Renewal Project Glen Allen. VA 23080-B711 Building 47515 Millstone Power Station Mr. Fred Emerson Rope Ferry Road Nuclear Energy Institute Waterford, CT 06385 1776 1 Street, NW, Suite 400 Washington, DC 20008-3708 NUREG-1437, Supplement 22 E-66 July 2005 I

Appendix E Millstone Power Station. Units 2 and 3 cc:

Robert A. Avena Town Attorney for Waterford. CT Kepple. Morgan & Avena, P.C.

Box 3A Anguilla Park 20 South Anguilla Road Pawcatuck, CT 06379 Michael J. Amaral U.S. Fish and Wildlife Service New England Field Office I . . . .

70 Commercial Street. Suite 300 Concord, NH 03301-5087

• * - s---

July 2005. E NUREG-1 437, Supplement 22

Appendix E United States Department of the Interior FISH AND WILDLI SERVICE New Enland Field Olfioe 70 Commercial Stt, Sufte 300 Concord. New Hampshins 03301-5087 Januay 5. 2005 Pbo-Tsan Kuo Office of Nuclar Reaco Reuastion U.S. Nudear Regulosy Comnniizon Wasnton, D.C 205SS-0001 Der Mr. Kuo.

We are in rectipt of your biological assessment and requlst ror conacrrence for the proposed re iwalofthe is61hne Power Stao, Urds 2 and 3. Waterford. Connecticu. The following comments are provided in acrdance with Section 7 of the Etdingered Spcies Act (ESA) of 1973. as amended (Q6 U.S.C I 531-1543).

Based on inbnnation currently mailable to us, and the hfonmation contained widin the biological assessmesm, the U.S. Fish and Wildirei Service coats that the proposed acoc wil hav no e~va on threae pi tigertbeesad i plove. We also ncur thathe prposed icense is not likely to advasey er the bald asle, roseate ten and smal w red pogoa.

Further constation with us under Section 7 oftbe Endangered Species Act is not required. Ths owArOes our review of Usted species and critical habitat in the project location and aevirons referenced above. No fRther E idangered Species Act ecordiraion ofrhis type is necesy fora period ofone year from the dae of h leter, unes ao tional informationon liaed or proposed species becomes awvfaible Thank you for your coordlstion Please contact us at 60-223-2541 if we can be of & aher tn fhe tutnre, h erder Is expedite your re*,please direct any Inqures of this nature to this eflice at the above addres.

Sincereyyours, Michad J. Amand Endangered Species Specialist New Englad Field Office NUREG-1437, Supplement 22 E-68 July 2005

Appendix E I

UNITED STATES DEPARTMENT OF COMMERCE JAN 12 200 PnoTsln Kuo Prorm Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs:

Office of Nuclear Reactor Regulation US NuclearRegulatory ComZiission -'

MST1ll P1 Washington, DC 20555 Re: Millstone Power Station Units 2 and 3 license renewal

.DenrMr.K 3o, -

Thisiss in rsponse to your lette daed November 9. 2004 regaing the pposed r iewal ofthe opeting licenses for Units 2 and 3 of theMillstonePower Station for a period of 20 years. Mhr Millstone Power Station is located on tbe wrth shore of Loninsld Sond In the twa of Waterford, Cl. Included with your letter was a Biological Assessment (BA) which evluates whedther the propoied license renewal of the Millstonc Power Station would have an adverse affect on listed species in Long Island Sound. The US. Nuclear Regulatory Conmission (NRC) has made a preliminarydetemnination that the prposed action wiU have no efoct on llsted species under the jurisdico r te National Mine Fisheries Service (NOAA ;

FiShed:es.

In akttcr datd September21.2004.NOAAFisheries provlded te NRC with a list of federally thratened and endangered species that ase known tobe seasonally present in th watersa of Long Island Sound. Four species of federally threatened or endangerod sea turtles may be found seasonaly In the witers of Long Islad Sound.'

Sea turtles are expected to be In the vicinity of the project Wra In vrnner months.

typically fron May ! to November 15. The sea turtles in Long land waters are typically small juveniles with the most abundant being the fedally threatened loggerhead (Carefa coarei) followed by the federally endazrierd Kemp's sidley (Lrpldcedks AepO. The waters of Long lIsland Sound have also heen founed to be  :

warm enough to support federlly endanged i sa cnturts(Cheonla mda) from June through October. The three species of chelonid turtles found In thc Northeast remain very briefly in open ocean waters, spending most of their tI]e during the summer months in hanbors and estuarine wateri, such as those found in

.0 July 2005 E-69 NUREG-1437, Supplement 22

Appendix E Long Island Sound. Federally endangered kathebaock sea twtles (Dennochalys coriacca)mny be found in the waters of Long Island Sound during die wanmer months as well.

Ibree species of federally endangered whales, North Atlantic right whales (EubaalagalacaWLs).humpback whales (Bfcgaptera noawt8gliac). and fin whales (Bdaenopterrphysalhts). may also be found seasonally in Northeast waterS, although it rarn that these species will travel Into Long Island Sound. Pederally endangered shortnose sturgeon (Acnsrbrevirstrum)ae bnow to occur in the Connecticut River which flows Into Long Island Sound approximately 10 miles cast of the Millstone site; however. shortnose sturgeon are not known to parti;ipzte in coastal migratIons and no shonaose sturgeon arm likely to occur near the project ste.

The entrainment and impingement of sen turtles has been documented at several nuclear power plants on the East Coast The Milstone system withdraws water freom Long Island Sound through intakes. Wer withdrawn from Lag Istand Sound is filtered through trash and debris screens at a rate of 0.2 mWs. The debris screens ame an effectiv mechanism to reduce the likelihood that aquatic orpnism;, including turtles, win be Impinged or entrained on the intakes. The MilstoW e operalors hve been monitoring the intakes for over 20 years and no sea turtles have been documented to be impinged or entrained during that time. Based on the size of the screens. the rawe of intake and the lack of sea turtle Impingements or entrainments in the past, it is unikelythat sea trties will be affected by th inakes through the term otthe new license-Water taken into the plant Is pumped thmough a turbinc condensercooling system which causes the water temperature to Increase The heated wotw then surfacec discharges through a former granite qumny and flows out two cuts excavated form the bedrock into Long Island Sound. At full discharg flow the wwer temperature will have Increased 9 to 14 0 C from Its intake tempenkc. The National Pollutant Discharge Ellminktion System (NPDES) permit for the Millstone PowerStation limits the discharge temperature to 40C and limits the maxinum increase in water temperature from intakl to discharge to 18°'C. Based an the volumna of waler in the discharp area. Lhe ability for sea turtles to avoid the ara of healed water. and the known tolerance of sa tuntes to tropical water tmperstures, It is unlikely that sea

• turtles -ill be affected by the discharge of hcated water into Long Island SoundL' Based on the analysis abov4 NOAA Fisherfes is able to concur with the NRC's determination dint this prject will have no effect on shortnose sturgeon, fin whales, humpback whales. or right Odties. NOMA Fisheries Is not able to concur with a no effect determination for the fourspecies of sea tutles; how1va based on the .

• asscssment above, it has been determined that the proposed action Is not likely to ndversely alfect sea turtles. Therefore, no fixther consultation pursuant to section 7 of the ESA is required. Should pmject plans change or new laformatdon become NUREG-1437, Supplement 22 E-70 July 2005

Appendix E I

availabl tha changes the basis for this determination, consultation should be reinitiated. Should you have any questions about these comments, please contact Sara McNulty st.(978) 281-9328 CXL 6520.

sicaccely.

Adiiirlo ti* ionPatrici KRegionul Adminisuvaor Cr:Sdd2.FftNER3 wVilliaMs, OWNE Rusnowvsky, F7NER4 July 2005 E-71 NUREG-1437, Supplement 22

Appendix F GEIS Environmental Issues Not Applicable to Millstone Power Station, Units 2 and 3

Appendix F GEIS Environmental Issues Not Applicable to Millstone Power Station, Units 2 and 3 Table F-1 lists those environmental issues listed in the Generic Environmental Impact Statemient for License Renewal of Nuclear Plants (GEIS) (NRC 1996; 1999)(a) and 10 Code of Federal Regulations (CFR) Part 51, Subpart A; Appendix B, Table B-i, that are not applicable--

to Millstone Power Station,' Units 2 and 3, because of plant or site characteristics.

-Table F-1k -- GEIS Environmental Issues Not Applicable to Millstone Power Station,

- Units 2 and3 3 ISSUE-10 CFR Part 51, Subpart A, GEIS Appendix B, Table B-1 Category Sections Comment

- SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered thermal stratification of lakes 1 4.2.1.2.3 Millstone does not discharge I 4.4.2.2 into a lake.

Temperature effects on sediment 1 4.2.1.2.3 Millstone does not discharge transport capacity ' : 4.4.2.2 into a small river.

Eutrophication 1 4.2.1.2.3 Millstone does not discharge 4.4.2.2 into a lake.,

Water-use conflicts (plants with cooling 2 4.3.2.1 The Millstone cooling' system -

ponds or cooling towers using makeup 4.4.2.1 does not use make-up' water' -

water from a small river with low flow) from a small river with low flow.

AQUATIC ECOLOGY (FOR ALL PLANTS)

Premature emergence of aquatic insects 1 4.2.2.1.7 'Aquatic insects are only present

• - - .4.4.3 in freshwater environments.

AoUATIC ECOLOGY (FOR PLANTS WITH COOLING TOWER BASED HEAT DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early 1 4.3.3 This issue is related to life stages' . heat-dissipation systems that are not installed at Millstone.

Impingement of fish and shellfish 1 4.3.3 This issue is related to heat-dissipation systems that are not installed at Millstone.

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references to the "GEIS" include the GEIS and its Addendum 1.

July 2005, F-1 NUREG-1 437, Supplement 22

Appendix F Table F-1. (contd)

ISSUE-10 CFR Part 51, Subpart A, GEIS Appendix B, Table B-1 Category Sections Comment AoUATc ECOLOGY (FOR PLANTS WITH COOLING TOWER BASED HEAT DISSIPATION SYSTEMS)

Heat shock 1 4.3.3 This issue is related to heat-dissipation systems that are not installed at Millstone.

GROUND-WATER USE AND QUALITY Ground-water use conflicts (potable and 2 4.8.1.1 Millstone uses <100 gpm of service water, and dewatering; plants 4.8.2.1 groundwater.

that use >100 gpm)

Ground-water use conflicts (plants using 2 4.8.1.3 This issue is related to cooling towers withdrawing makeup 4.4.2.1 heat-dissipation systems that water from a small river) are not installed at Millstone.

Ground-water use conflicts (Ranney 2 4.8.1.4 Millstone does not have or use wells) Ranney wells.

Ground-water quality degradation 1 4.8.2.2 Millstone does not have or use (Ranney wells) Ranney wells.

Ground-water quality degradation 1 4.8.3 Millstone does not use cooling (cooling ponds in salt marshes) ponds.

Ground-water quality degradation 2 4.8.3 Millstone is not located at an (cooling ponds at inland sites) inland site.

TERRESTRIAL RESOURCES Cooling tower impacts on crops and 1 4.3.4 This issue is related to a ornamental vegetation heat-dissipation system that is not installed at Millstone.

Cooling tower impacts on native plants 1 4.3.5.1 This issue is related to a heat-dissipation system that is not installed at Millstone.

Bird collisions with cooling towers 1 4.3.5.2 This issue is related to a heat-dissipation system that is not installed at Millstone.

Cooling pond impacts on terrestrial 1 4.4.4 This issue is related to a resources heat-dissipation system that is not installed at Millstone.

NUREG-1437, Supplement 22 F-2 July 2005

Appendix F Table F-1. (contd)

ISSUE-10 CFR Part 51, Subpart A, GEIS Appendix B,Table B-1 Category Sections Comment HUMAN HEALTH Microbial organisms (occupational 1 4.3.6 This issue is related to a health)(plants with cooling towers) heat-dissipation system that is not installed at Millstone.

Microbial organisms (public health) 2 4.3.6 This issue is related to a (plants using lakes or canals, or cooling heat-dissipation system that is towers or cooling ponds that discharge to not installed at Millstone.

a small river).

F.1 References 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions."

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Main Report, Section 6.3, Transportation, Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

July 2005 G-3 NUREG-1437, Supplement 22

Appendix G Connecticut State-Listed Terrestrial Species for Hartford, Middlesex, New London, and Tolland Counties with the Potential to Occur at the Millstone Site or Along Associated Transmission Line Rights-of-Way

Appendix G Connecticut State-Listed Terrestrial Species for-Hartford, Middlesex, New London, and Tolland Counties with the

---

Potential to Occur at the Millstone Site or Along Associated---

-Transmission Line Rights-of-Way -

Table G-1. Connecticut State-Listed Terrestrial Species for Hartford, Middlesex, New London, and Tolland Counties with the Potential to Occur at the Millstone Site or Along Associated Transmission Line Rights-of-Way

- -State Scientific Name - Common Name Status(a)

-:AMPHIBIANS Ambystoma jeffersonianum -Jefferson salamander SC IAmbystoma laterale - blue-spotted salamander -- T-Gyrinophilus porphyriticus northern spring salamander T Rana pipiens northern leopard frog SC Scaphiopus holbrookii <- . eastern spadefoot -E

.-BIRDS ----

Aegolius acadius northern saw-whet owl SC Ammodramus caudacutu s ----saltmarsh sharp-tailed sparrow SC Ammodramus henslowii Henslow's sparrow - SC Ammodramus maritimus seaside sparrow SCI- I Ammodramus savannaru m grasshopper sparrow E Anas discors

• blue-winged teal T Asio flammeus short-eared owl T Asio otus long-eared owl E Bartramia longicauda upland sandpiper E Botaurus lentiginosus - American bittern E Caprimulgus vociferus whip-poor-will -SCII .

Cistothorus platensis sedge wren -E Corvus corax -common raven SCII July 2005;- G-1 NUREG-1 437, Supplement 22

Appendix G Table G-1. (contd)

State Scientific Name Common Name Status(a)

BIRDS Egretta caerulea little blue heron SC Empidonax alnorum alder flycatcher SC Eremophila alpestris horned lark E Falco peregrinus peregrine falcon E Falco sparverius American kestrel T Galinula chloropus common moorhen E Gavia immer common loon SC Haematopus palliatus American oystercatcher SC Ixobrychus exilis least bittern T Laterallus jamaicensis black rail E Melanerpes erythrocephalus red-headed woodpecker E Parula americana northern parula SC Passerculus sandwichensis savannah sparrow SC Passerculus sandwichensis ssp. princeps Ipswich sparrow SC Plegadis falcinellus glossy ibis SC Pooecetes gramineus vesper sparrow E Progne subis purple martin T Rallus elegans king rail E Sterna hirundo common tem SC Stumella magna eastern meadowlark SC Toxostoma nufum brown thrasher SC Tyto alba barn owl E Vermivora chrysoptera golden-winged warbler E INVERTEBRATES Acronicta lanceolaria a noctuid moth SC*

Apamea burgessi a noctuid moth SC Apodrepanulatrix liberiaria New Jersey tea inchworm SC NUREG-1 437, Supplement 22 G-2 July 2005 I

Appendix G Table G-1. (contd)

State

-Scientific Name -- "  : Cornirnon 'Name Status(a)

---

.-- - :INVERTEBRATES Callophrys henrici Henry's elfin SC Callophrys irus frosted elfin Calopteryx dimidiata sparkling jewelwing SC Catocala pretiosa .precious underwing moth 50*.

Chaetaglaea cerata a noctuid moth Sc SC-Cicindela formosa ssp. generoswa pine barrens tiger beetle Cicindela hirticollis beach-dune tiger beetle Cicindela lepida dune ghost tiger beetle E Cicindela purpurea tiger beetle SC*

Cicindela tranquebarica dark-bellied tiger beetle SC.

E -

Citheronia regalis regal moth SC Cordulegaster erronea tiger spiketail Cucullia speyeri a noctuid moth Eacles imperialis ssp. imperialis imperial moth SC*

Enallagma doubidayi Atlantic bluet SC Enallagma minusculum little bluet ~Sc_

,. , ,SC*,

Enallagma pictum; scarlet bluet SC Erynnis brizo sleepy duskywing T.

Erynnis lucilius columbine duskywing E Erynnis martialis mottled duskywing Etynnis persius ssp. persius persius duskywing E

.. . T;C .

Eucoptocnemis fimbriaris a noctuid moth , SC Euphyes bimacula two-spotted skipper T Exyra rolandiana pitcher plant moth SC Geopinus incrassatus a ground beetle SC Gomphus adelphus mustached clubtail dragonfly July 2005. t. G-3 NUREG-1 437, Supplement 22.'

Appendix G Table G-1. (contd)

State Scientific Name Common Name Statusca)

INVERTEBRATES Gomphus descriptus harpoon clubtail dragonfly T Gomphus fraternus midland clubtail dragonfly T Gomphus vastus cobra clubtail dragonfly SC Gomphus ventricosus skillet clubtail dragonfly SC Grammia phyllira phyllira tiger moth SC*

Hetaerina americana American rubyspot SC Hemileuca maia maia buckmoth E Hybomitra frosti a horse fly T Hybomitra typhus a horse fly SC Ladona deplanata blue corporal dragonfly SC Lepipolys perscripta scribbled sallow SC Leptophlebia bradleyi a mayfly SC Leucorrhinia glacialis crimson-winged whiteface dragonfly T Lycaena epixanthe bog copper SC Lycaena hyllus bronze copper SC Merycomyia whitneyi tabanid fly SC Mitoura hesseli Hessel's hairstreak E Papaipema duovata seaside goldenrod stem borer SC Paraleptophlebia assimilis a mayfly SC Pomatiopsis lapidaria slender walker SC Psectraglaea camosa pink sallow T Schinia spinosae a noctuid moth SC Speyeria idalia regal fritillary SC*

Sphodros niger purse-web spider SC Stylurus amnicola riverine clubtail dragonfly T Tabanus fulvicallus horse fly SC Williamsonia lintneri banded bog skimmer E NUREG-1437, Supplement 22 G-4 July 2005-I

Appendix G Table G-1. (contd)

-: State

~- - Scientific Name i- bommon Name Status° INVERTEBRATES Zale curema a noctuid moth SC Zale obliqua a noctuid moth . I . SC -

Zale submedia a noctuid moth I . - T ..-

MAMMALS Cryptotis parva least shrew Lasiurus borealis eastern red bat SC Lasiurus cinereus hoary bat SC Puma concolorssp. couguar eastern cougar -SC*

Synaptomys cooped southern bog lemming SC.

PLANTS Acalypha virginica Virginia copperleaf SC Agalinis acuta sandplain gerardia E Agastache nepetoides yellow giant hyssop SC*

Agastache scrophularifolia purple giant hyssop E Alopecurus aequalis orange foxtail E. -

Amelanchier sanguinea roundleaf shadbush Andromeda glaucophylla bog rosemary T - .

Angelica lucida sea-coast angelica E Angelica venenosa .-. .. hairy angelica SC*

Aplectrum hyemale ,puttyroot Arenaria glabra .smooth mountain sandwort T Arenaria macrophylla large-leaved sandwort Arethusa bulbosa arethusa S*sc Aristida longespica needlegrass Aristida purpurascens .... arrowfeather SC.

Aristolochia serpentaria Virginia snakeroot SC July 2005 G-5 NUREG-1437, Supplement 22

Appendix G Table G-1. (contd)

State Scientific Name Common Name Status(3)

PLANTS Asclepias purpurascens purple milkweed SC Asclepias variegata white milkweed SC*

Asplenium montanum mountain spleenwort T Asplenium ruta-muraria wallrue spleenwort T Aster nemoralis bog aster E Aster prenanthoides crooked-stem aster SC*

Aster radula rough-leaved aster E Aster spectabilis showy aster T Aster X blakei Blake's aster E Aster X herveyi Hervey's aster SC Bidens eatonji Eaton's beggar-ticks T Blephilia ciliata downy woodmint SC*

Blephilia hirsuta hairy woodmint SC*

Calystegia spithamaea low bindweed SC*

Cardamine longYi Long's bitter-cress SC*

Carex aestivalis summer sedge SC Carex alata broadwing sedge E Carex barrattil Barratt's sedge E Carex bushii sedge SC Carex buxbaumii brown bog sedge E Carex collinsti Coilins' sedge SC*'

Carex crawfordii Crawford sedge SC*

Carex cumulata clustered sedge T Carex davisdi Davis' sedge E Cares exilis sedge E Carex hitchcockiana Hitchcock's sedge SC Carex limosa sedge E NUREG-1437, Supplement 22 G-6 July 2005

Appendix G Table G-1. (contd)

I- -._ state Scientific Na e Comnmon Name Status(s)

Carex lupuliformis false hop sedge SC Carex nigromarginata black-edge sedge SC*

Carex oligocarpa eastern few-fruit sedge -SC Carex oligosperma few-seeded sedge Sc*

Carex polymorpha variable sedge E

E Carex pseudocyperus cyperus-like sedge Carex squarrosa sedge SC Carex sterilis dioecious sedge SC Carex tuckermanfi Tuckerman sedge SC Carex typhina sedge SC SC*. .-

Castilleja coccinea indian paintbrush E Cercis canadensis eastern redbud Chamaelirium luteum devil's-bit E Chenopodium rubrum coast blite sC*

E Chrysopsis falcata sickle-leaf golden-aster Cirsium horridulum yellow thistle E

-. .SC*.-

Coeloglossum viride var. virescens, long-bracted green orchid SC, .

Corollorhiza trifida early coralroot SC Corydalis flavula yellow corydalis T Crassula aquatica ,pygmyweed E.

Cuphea viscosissima blue waxweed SC*

Cuscuta coryli hazel dodder Sc Cypripedium parviflorum yellow lady's-slipper E-Cypripedium reginae showy lady's slipper Deschampsia caespitosa tufted hairygrass SC Desmodium glabellum Dillen tick-trefoil SC July 2005_ NUREG-1437, Supplement 22

Appendix G Table G-1. (contd)

State Scientific Name Common Name Status~a)

PLANTS Desmodium humifusum trailing tick-trefoil SC Desmodium sessilifolium sessile-leaf tick-trefoil SC*

Dicentra canadensis squirrel-corn T Diplachne maritima saltpond grass E Diplazium pycnocarpon narrow-leaved glade fern E Draba reptans whitlow-grass SC Dryopteris goldiana Goldie's fern SC Echinodorus tenellus var. parvulus bur-head E Eleocharis equisetoides horse-tail spikerush E Eleocharis microcarpa var. filiculmis spike-rush SC*

Eleocharis quadrangulata var. crassior spike-rush E Elymus trachycaulus var. subsecundus slender wheatgrass SC Elymus wiegandii Wiegand's wild rice SC Equisetum palustre marsh horsetail SC*

Equisetum pratense meadow horsetail E Eriocarpon parken Parker's pipewort E Eriophorum vaginatum var. spissum hare's tail T Eupatorium album white thoroughwort E Eupatorium aromaticum small white snakeroot E Gaultheria hispidula creeping snowberry T Gaylussacia dumosa var. bigeloviana dwarf hucklberry T Geranium bicknellfi Bicknell northern crane's-bill SC*

Gnaphalium purpureum purple cudweed SC*

Goodyera repens var. ophioides dwarf rattlesnake plantain SC*

Helianthemum propinquum low frostweed T Hemicarpha micrantha dwarf bulrush E Hottonia inflata featherfoil SC NUREG-1437, Supplement 22 G-8 July 2005

Appendix G Table G-1. (contd)_

-- State Scientific Name Common Name Statusca)

PLANTS Houstonia longifolia longleaf bluet E Hudsonia ericoides golden-heather E Hudsonia tomentosa false beach-heather SC Hydrastis canadensis golden-seal E Hydrocotyle umbellata water pennywort -E Hydrocotyle verticillata whorled pennywort E Hydrophyllum virginianum Virginia waterleaf SC Hypericum adpressum creeping St. John's wort - SC*,

Hypericum pyramidatum great St. John's wort - SC llex glabra ink-berry T Isanthus brachiatus false pennyroyal E Juncus debilis weak rush SC*

Lachnanthes caroliana Carolina redroot E Ledum groenlandica ,Labrador tea -T Liatrisscariosavar. novae-anglica blazing star SC Ligusticum scothicum scotch lovage E Lilaeopsis chinensis lilaeopsis SC Limosella subulata mudwort SC Linnaea borealis var. americana twinflower E Linum intercursum sandplain flax :SC*

Linum sulcatum yellow flax -SC Liparis liliifolia lily-leaved twayblade E Liquidambar styraciflua sweet gum - -SC---

Ludwigia polycarpa many-fruit false-loosestrife -- SC*

Ludwigia sphaerocarpa globe-fruited false-loosestrife E Lycopus amplectens clasping-leaved water-horehound - , SC July 2005 G NUREG-1437, Supplement 22

Appendix G Table G-1. (contd)

State Scientific Name Common Name Status(a)

PLANTS Lygodium palmatum climbing fern SC Malaxis unifolia green adder's-mouth E Megalodonta beckii water-marigold T Milium effusum tall millet-grass SC*

Mimulus alatus winged monkey-flower SC Moneses uniflora one-flower wintergreen E Myriophyllum pinnaturn cutleaf water-milfoil E Nuphar advena large yellow pond lily SC*

Nuphar microphylla small yellow pond lily SC Nymphaea odorata var. tuberosa water lily SC*

Onosmodium viginianum gravel-weed E Ophioglossum pusillum adder's tongue T Opuntia humifusa eastern prickly-pear SC-Orontium aquaticum golden club SC Oryzopsis pungens slender mountain-ricegrass SC Oxalis violacea violet wood-sorrel SC Panax quinquefolius American ginseng SC Panicum amarum panic grass T Panicum commonsianum panic grass SC Panicum rigidulum var. elongatum tall flat panic grass SC*

Panicum scabriusculum panic grass E Panicum xanthophysum panic grass SC*

Paronychia fastigiata hairy forked chickweed SC*

Paspalum laeve field paspalum E Paspalum setaceum var. psammophilum bead grass SC*

Pedicularis lanceolata swamp lousewort T Phaseolus polystachios var. aquilonius wild kidney bean SC*

NUREG-1437, Supplement 22 G-10 July 2005

Appendix G Table G-1. (contd),,. _ _. _

State Scientific Name Common Name Status(a)

PLANTS Pinus resinosa :red pine E Plantago virginica hoary plantain SC Platanthera blephariglottis white-fringed orchid T Platanthera ciliaris yellow-fringed orchid Platanthera dilatata tall white bog orchid SC*

Platanthera flava pale green orchid -- S C _r-Platanthera hookeri Hooker orchid SC*

Platanthera orbiculata large roundleaf orchid SC*

Podostemum ceratophyllum threadfoot SC Polygala cruciata field milkwort 'SC Polygala nuttalij Nuttall's milkwort E

Polymnia canadensis small-flowered leafcup Populus heterophylla swamp cottonwood E Potamogeton confervoides pondweed SC*-.

Potemogeton pusillus var. gemmiparus capillary pondweed -

Potamogeton vaseyi Vasey's pondweed E Potentilla arguta .tall cinquefoil SC ..,

Prunus alleghaniensis Alleghany plum SC* .

Puccinellia langeana ssp. alaskana 'goose grass SC*

Pycnanthemum clinopodioides basil mountain-mint Pyrola secunda one-sided pyrola .,:

Ranunculus ambigens water-plantain spearwort Ranunculus cymbalaria seaside crowfoot - SC*

Ranunculus pensylvanicus bristly buttercup Ranunculus sceleratus cursed crowfoot SC Rhynchospora macrostachya beaked rush - ..-T. . -.

July 2005, G NUREG-1437,'Supplement 22

Appendix G Table G-1. (contd)

State Scientific Name Common Name Status~a)

PLANTS Rhynchospora scirpoides long-beaked baldrush E Ribes glandulosum skunk currant T Ribes rotundifolium wild currant SC*

Ribes triste swamp red currant E Rosa nitida shining rose SC Rotala ramosior toothcup T Rubus cuneifolius sand bramble SC Rumex maritimus var. fueginus sea-side dock SC*

Sabatia stellaris marsh pink E Sagittaria cuneata waputo SC*

Sagittaria subulata arrowleaf SC Salix exigua sandbar willow T Salix pedicellaris bog willow E Salix petiolaris slender willow SC*

Saururus cemuus lizard's tail E Scheuchzeria palustris pod grass E Schizachne purpurascens purple oat SC Schwalbea americana chaffseed SC*

Scirpus cylindricus salt-marsh bulrush SC Scirpus hudsonianus cotton bulrush SC*

Scirpus longii Long's bulrush SC*

Scirpus paludosus var. atlanticus bayonet grass SC Scirpus torreyi Torrey's bulrush T Scleria pauciflora var. caroliniana few-flowered nutrush E Scleria reticularis reticulated nutrush E Scleria triglomerata nutrush E Scutellaria integrifolia hyssop skullcap E NUREG-1437, Supplement 22 G-12 July 2005

I Appendix G Table G-1. (contd)

State Scientific Name Common Name Status(a)

PLANTS Senecio pauperculus ragwort *E Senna hebecarpa .- wild senna SC Silene stellata starry campion S.c Smilacina trifolia -,three-leaved false Solomon's-seal Solidago elliottii Elliott goldenrod SC Solidago rugosa var. sphagnophila early wrinkle-leaved goldenrod *SC*

Spergularia canadensis -Canada sand-spurry T, Spiranthes tuberosa var. grayi little ladies'-tresses SC*

Sporobolus clandestinus rough dropseed E

":._ _S.

Sporobolus neglectus small dropseed E

Stachys hyssopifolia hyssop-leaf hedge-nettle Stachys tenuifolia smooth hedge-nettle SC Stellaria borealis northern stitchwort ---

Streptopus amplexifolius var. americanus .,white mandarin Thuja occidentalis > - : - . northern white cedar T.

Trichomanes intricatum Appalachian gametophyte SC Triosteum angustifolium narrow-leaved horse gentian SC*

SC*

Triphora trianthophora nodding pogonia SC*

Trisetum spicatum var. molle spiked false oats SC*

Utricularia fibrosa fibrous bladderwort SC*

Utricularia resupinata bladderwort E Uvularia grandiflora large-flowered bellwort E SC*

Vaccinium myrtilloides velvetleaf blueberry SC*

Vaccinium vitis-idea var. minus mountain cranberry SC*

Valerianella radiata var. femaldii beaked corn-salad SC*

Verbena simplex narrow-leaved vervain July 2005, G-13 NUREG-1437,-Supplement 22

Appendix G Table G-1. (contd)

State Scientific Name Common Name Status(a)

PLANTS Vibemum nudum possum haw SC*

Viola canadensis Canada violet SC Viola selkirkii great-spurred violet SC Vitis novae-angliae New England grape SC Waldsteinia fragarioides barren strawberry SC Xyris montana northern yellow-eyed grass T Xyris smalliana Small's yellow-eyed grass E Zizia aptera golden alexanders E REPTILES Clemmys insculpta wood turtle SC Crotalus horridus timber rattlesnake E Eumeces fasciatus five-lined skink T Heterodon platirhinus eastern hognose snake SC Terrapene carolina eastern box turtle SC Thamnophis sauritus eastern ribbon snake SC (a) E=endangered, T = threatened, SC = species of concern, (^) = believed extirpated (CTDEP 2004)

NUREG-1437, Supplement 22 G-14 July 2005

Appendix H NRC Staff Evaluation of Severe Accident Mitigation Alternatives (SAMAs) for Millstone Power Station, Unit 2, in Support of the License Renewal Application Review

Appendix H NRC Staff Evaluation of Severe Accident Mitigation Alternatives (SAMAs) for Millstone Power Station, Unit 2, in Support of the License Renewal App!ication Review-H.1 Introduction -.

Dominion Nuclear Connecticut, Inc. (Dominion) submitted an assessment of SAMAs for Millstone Power Station, Unit 2 (MPS2) as part of the Environmental Report (ER) (Dominion'-'

2004a). This assessment was based on the most recent MPS2 Probabilistic Risk Assessment (PRA) available at that time, a plant-specific off-site consequence analysis performed using the

• MELCOR Accident Consequence Code System 2 (MACCS2) computer program, and insights from the MPS2 Individual Plant Examination (IPE) (NNECO 1993) and Individual Plant '

Examination of External Events (IPEEE) (NNECO 1995). In identifying and evaluating potential SAMAs, Dominion considered SAMA analyses performed for other operating plants, as well as industry and NRC documents that discuss potential plant improvements, such as NUREG-1 560 (NRC 1997a). Dominion identified 196 potential SAMA candidates. This list was reduced to 44 unique SAMA candidates by eliminating SAMAs that were not applicable to MPS2 due to -

design differences, had already been implemented, or were related to a reactor coolant pump (RCP) seal dependency on charging pumps. Dominion assessed the costs and benefits associated with each of the remaining SAMAs and concluded in the ER that one of the candidate SAMAs evaluated would be cost-beneficial for MPS2.

Based on a review of the SAMA assessment, the NRC issued a request for additional information (RAI) to Dominion by letter dated June 22, 2004 (NRC 2004). Key questions concerned the following areas: peer reviews of the PRA, dominant risk contributors at MPS2 and the SAMAs that address these contributors,-the mapping of Level 1 PRA results into the -

Level 2 analysis, the potential impact of external event initiators and uncertainties on the assessment results,-detailed information on some specific candidate SAMAs, and consideration of additional SAMAs. Dominion submitted additional information by letter dated -

August 13, 2004 (Dominion 2004b) including, summaries of peer review comments and their - -

impact on the SAMA analysis; importance measures and corresponding SAMA candidates; information regarding the Level 2 analysis; information related to the resolution of IPEEE outliers and the impact of external events in the risk analysis; an assessment of the impact of uncertainties; and additional information regarding specific SAMAs.^ Dominion's responses,-.-

addressed the staff's concerns. -As a result, Dominion identified one SAMA that is cost-beneficial, and a second SAMA that would be cost-beneficial if it can be accomplished via a severe accident management guideline, without a hardware modification. -

An assessment of SAMAs for MPS2 is presented below.

July 2005;, H-1 NUREG-1437, Supplement 22 -'

Appendix H H.2 Estimate of Risk for MPS2 Dominion's estimates of offsite risk at MPS2 are summarized in Section H.2.1. The summary is followed by the staff's review of Dominion's risk estimates in Section H.2.2.

H.2.1 Dominion's Risk Estimates Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA analysis: (1) the MPS2 Level 1 and 2 PRA model, which is an updated version of the IPE (NNECO 1993), and (2) a supplemental analysis of offsite consequences and economic impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The identification of candidate SAMAs was based on Revision 2 of the PRA model, dated April 2001; the quantification of SAMA benefits was based on Revision 3, dated October 2002 (Dominion 2004b). The scope of the MPS2 PRA does not include external events.

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is approximately 7.17x10-5 per year. The CDF is based on the risk assessment for internally initiated events. Dominion did not include the contribution to risk from external events or internal flooding within the MPS2 risk estimates; however, it did account for the potential risk reduction benefits associated with external events by increasing the estimated benefits for internal events by 30 percent. This is discussed further in Sections H.4 and H.6.2.

The breakdown of CDF by initiating event is provided in Table H-1. As shown in this table, loss of coolant accidents (LOCAs), loss of cooling water to the primary side components (COOL) including service water (SW) and reactor building closed cooling water (RBCCW), loss of DC power, and transients including anticipated transients without scram (ATWS) are dominant contributors to the CDF. LOCAs are dominated by small-break LOCAs which make up about 36 percent of the total CDF. Bypass events [i.e., steam generator tube rupture (SGTR) and interfacing systems loss of coolant accident (ISLOCA)] contribute less than 4 percent to the total internal events CDF. In response to an RAI, Dominion estimated the contribution to CDF from internal floods to be approximately 2x1 0 7 per year (Dominion 2004b).

The Level 2 PRA model is based on the original Level 2 model of the IPE (NNECO 1993). The model has been revised to reflect modified plant damage states and new release categories.

These revisions were made to make the plant damage states (PDSs) and release categories consistent with those used for Millstone Power Station, Unit 3 (MPS3). The result of this analysis is a matrix that transforms the PDS frequencies to the release category frequencies.

The source terms for each release category (also termed the source term category) were obtained from the results of MAAP 3.0B analyses of the dominant core damage sequences in the IPE.

NUREG-1437, Supplement 22 H-2 July 2005 I

Table H-1. MPS2 Core Damage Frequency

- Initiating Event or -CDF  % Contribution to Accident Class . (Per.Year) .-- . - ... -. CDF. -a -- -

LOCA 2.66 x1 04 37.1 COOL-(SW+Seal LOCA+ RBCCW)(a) - -1.44 x 1 - 20.1 --- - - -I Loss of DC power 1.03 x 1 F-5 14.4 ATWS 8.68 x 10o6 12.1 Transients 4.66 x 106 6.5 SGTR 2.22 x 106 3.1 Station blackout (SBO) 2.15 x 106 3.0 Steamline and main feed line breaks 1.72 x 10-6 2.4 Loss of offsite power (LOOP) - - -- 8.60 x 10 7 ---- - 1.2 - -

ISLOCA - - - -- 1.43x10-7 0.2 - - -- - -

Total CDF 7.17x104 100 (a)COOL represents the loss of cooling water to the primary side components, leading to an I eventual degradation of the reactor coolant pump seal integrity. .

The offsite consequences and economic impact analyses-use the MACCS2 code to determine the offsite risk impacts on the surrounding environment and public. Inputs for this analysis include plant-specific and site-specific input values for core radionuclide inventory, .source term and release characteristics, site meteorological data, projected population distribution within a 80 kilometer (km) (50-mile [mui) radius for the year 2030, emergency response evacuation modeling, and economic data. The core radionuclide inventory is based on the generic pressurized water reactor (PWR) inventory provided in the MACCS2 manual, adjusted to',

represent the MPS2 power level of 2700 megawatts thermal (MW[t]). The magnitude of the onsite impacts (interms of clean-up and decontamination costs and occupational dose) is based on information provided in NUREG/BR-0184 (NRC 1997b). l In the ER, Dominion estimated the dose to the population within 80 km (50 mi) of the MPS2 site, to be approximately 0.174 person-sieverts (person-Sv) (17.46perso'-roentgen'equivalents main

[person-rem]) per year. The breakdown of the total population dose by containment release mode is summarized in Table H-2. Intermediate containment failures dominate the population dose risk at MPS2, followed by SGTR and late-containment faiiures. 'Early-containment failures and ISLOCAs make 'relativelysmall contributions, each being less than 3 percent of the total.

Containment'isolation and basemat failures 'are'each indicated to be zero contributors to risk.

As indicated in the response to anrRAI,' these release modes are incorporated into other release modes with similar characteristics (Dominion 2004b).

July 2005 H-3' NUREG-1 437, Supplement 22

Appendix H Table H-2. Breakdown of Population Dose by Containment Release Mode (Unit 2)

Population Dose Containment Release Mode (Person-rem(') Per Year)  % Contribution Intermediate failure 12.4 71 SGTR 2.5 14.4 Late failure 1.63 9.4 Early failure 0.48 3 ISLOCA 0.42 2.4 Containment isolation failure 0 0 Basemat failure 0 0 Total Population Dose 17.4 100 (a) One person-rem = 0.01 person-Sv H.2.2 Review of Dominion's Risk Estimates Dominion's determination of offsite risk at MPS2 is based on the following three major elements of analysis:

• the Level 1 and 2 risk models that form the bases for the 1993 IPE submittal (NNECO 1993) and the 1995 IPEEE submittal (NNECO 1995),

• the major modifications to the IPE models that have been incorporated in the MPS2 PRA, and

• the MACCS2 analyses performed to translate fission product source terms and release frequencies from the Level 2 PRA model into offsite consequence measures.

Each of these analyses was reviewed to determine the acceptability of Dominion's risk estimates for the SAMA analysis, as summarized below.

The staff's review of the MPS2 IPE is described in an NRC report dated May 21, 1996 (NRC 1996). Based on a review of the original IPE submittal, the staff concluded that IPE submittal met the intent of Generic Letter 88-20 (NRC 1988); that is, the IPE was of adequate quality to be used to look for design or operational vulnerabilities. The staff did, however, NUREG-1437, Supplement 22 H-4 July 2005 I

identify a number of weaknesses in the IPE analysis. In response to an RAI, Dominion indicated that all of th6se' weaknesses have been addressed in the PRA used for the SAMA analysis (Dominion 2004b).- -

A comparison of internal events risk profiles between the IPE and the PRA used in' the SAMA analysis indi6ates an increase of approximately 3.8x105 per year in the total CDE.(from 3.4x10 5 per year to 7.1 7x1 05 per year).' The change is a net result of m6deling changes'and some minor plant design changes that have'been implemented at MPS2 since the IPE. A summary listing of those changes that resulted in'the greatest impact on the total CDF was provided in the ER and in" response t6'RAls (Dominion 2004a, 2004b), ard include the following: '

added credit for passive ventilation in the intake structure i-

• updated'the loss of normal power event frequency '-

• added new cross-tie to Unit 3 AC power sources to mitigate SBO conditions at Unit 2

• modified the total loss'of coolirig event tree by updating nodes for failure of the operator to

trip the reactor coolant pumps' and reactor coolant pump seal LOCA

• modified the AC power distribution logic by adding the MPS2 normal station service transformer as the power source (not previously modeled)

• modified the DC logic to (1) transfer to the loss of DC when emergency diesel generators and DC buses are not available, and (2) add a loss of DC bus A and B event as first event to be considered in'the'SBO event tree. ' ' '-

An additional change that has a significant impact on the CDF value is the truncation value used in the PRA model.- For the PRA version used for the'SAMA analysis, Do'miniorn'used a

truncation value of 1.0 x 10-11. In contrast, use of a trurictiornvalue of 2.0 x 109 (as used in previous versions of the PRA) would result in a ODE of aboit 5'x iO per year. Thisaalone '

' would account for approxirnately'half of the noted increase in CDF since the IPE.

The IPE CDF value for MPS2 is comparable to the CDF values reported in the IPEs for other Combustion En'gineering (CE) PWR plants. Figure 11.6 of NUREG-1 560 shows that the" IPE-based total internal events CDF for CE PWRs' ranges fror'm1 x 10-5 to 3 x 104 per year (NRC 1997a). It is recognized that'other plants have reduced their' values' for CDF after the IPE '

submittals due to inodeling and hardware changes. The currert internal events CDF results for MPS2 remain'comparable to'the' resuIts for other plants of sin'ilai Vintage -andcharacteristics The staff considered the' peer review performed for the MPS2 PRA, and the&potential impact of the' review findings on the SAMA evaluation.' In r'espronse to arnRAI, Dominion described the July 2005 H-5 NUREG-1437, Supplement 22

Appendix H external peer review, which was the Combustion Engineering Owners Group (CEOG) Peer Review of PRA Revision 0 performed in 1999 (Dominion 2004b). The review resulted in 25 Level A facts and observations (extremely important and necessary to address to ensure technical adequacy) and 59 Level B facts and observations (important and necessary to address but may be deferred until next PRA update). The majority of the recommendations from this review were addressed or reflected in Revision 3 of the MPS2 PRA. Seven of the Level A recommendations are yet to be resolved, while 25 of the Level B recommendations are yet to be resolved. Those Level A recommendations not yet incorporated are in the areas of accident sequence analysis, human reliability analysis, dependency analysis, and quantification.

The Level B recommendations not yet incorporated affect all PRA elements. Dominion has reviewed all of the unresolved facts and observations and concluded that they have negligible impact on the SAMA analysis (Dominion 2004b). The staff has also reviewed Dominion's assessment of the impacts of the outstanding peer review comments and has come to the same conclusion.

Given that (1) the MPS2 PRA has been peer reviewed and the potential impact of the peer review findings on the SAMA evaluation has been assessed, (2) Dominion satisfactorily addressed staff questions regarding the PRA (Dominion 2004b), and (3) the CDF falls within the range of contemporary CDFs for CE plants, the staff concludes that the Level 1 PRA model is of sufficient quality to support the SAMA evaluation.

The licensee submitted an IPEEE in December 1995 (NNECO 1995), in response to Supplement 4 of Generic Letter 88-20. While the IPEEE submittal did not specifically state a criterion for identifying a vulnerability to severe accident risk in regard to the external events related to seismic, fire, or other external events, a number of outliers or 'opportunities for safety enhancements" were identified. The current status of these outliers was provided by Dominion in response to a staff RAI. In the response, Dominion stated that of a total of 29 items, 21 were resolved prior to 2003. The remaining eight items were closed in August 2003 (Dominion 2004b). In a letter dated January 12, 2001, the staff concluded that the IPEEE submittal met the intent of Supplement 4 to Generic Letter 88-20, and that the licensee's IPEEE process is capable of identifying the most likely severe accidents and severe accident vulnerabilities (NRC 2001).

The seismic portion of the IPEEE consisted of a 0.3g (the acceleration due to the gravitation force [g]) focused-scope seismic evaluation using the Electric Power Research Institute (EPRI) methodology for Seismic Margins Assessment (SMA). A total of 16 components were initially estimated to have high-confidence low-probability of failure (HCLPF) capacities less than the review level earthquake peak ground acceleration of 0.3g. The lowest of these were included in the list of outliers to be resolved. The actions taken by the licensee to resolve seismic outliers included modification of the RBCCW and chilled water surge tanks supports, and modification.

to anchorage of battery racks. Other items were resolved by verifying component adequacy by NUREG-1437, Supplement 22 H-6 July 2005

calculation or by correcting housekeeping problems. After resolution of these outliers, three components remained with HCLPF values less than the 0.3g review level earthquake: the turbine building housing the auxiliary feedwater (AFW) pumps (0.25g), the 125 VDC vital bus 201 B (0.26g), and the RBCCW heat exchangers'(0.29g). Dominion 'concluded that because of adequate seismic margins and the complexity associated with increasing the seismic capacity of a structure, no cost-effective SAMAs related to seismic events could be identified (Dominion 2004b). The staff agrees that it is unlikely that cost-effective SAMAs that address seismic vulnerabilities will exist. This is due to high cost of structural modifications compared to

• the benefits expected. --

The MPS2 IPEEE does not provide numerical estimates of the CDF contributions from seismic initiators. Section F.2.4 of the ER indicates that the seismic CDF is 9.1 x106 per year. Since the SMA does not result in a numerical value, the staff asked Dominion to provide'the basis for the seismic CDF value given in the ER (NRC 2004). In response, Dominion indicated that the value 'used is the seismic CDF for Millstone Power Station, Unit 3 (MPS3) obtained from the MPS3 seismic PRA. The staff notes that for MPS3 all of the plant components or structures whose failure would significantly impact CDF have HCLPF values equal to or greater than the review level earthquake acceleration of 0.3g, whereas MPS2 has three components/structures with HCLPF values that are below 0.3g. This'would indicate that the seismic CDF for MPS2 may be greater than that for.MPS3. -

Even though the MPS2 seismic CDF may be larger than that used to estimate the added benefit of SAMA candidates due to their impact on seismic risk,'the staff believes that the!

seismic CDF would remain a relatively small contributor to the'total CDF. This'is'due to the small contribution that low-magnitude earthquakes make to the'CDF. The impact of low-magnitude earthquakes (in the range of 0.1 to 0.3 g) is principally in causing initiating events and for a LOOP reducing the likelihood of offsite power recovery. The frequency of these seismic initiating events is several orders of magnitude less than that due to random failures' Even a station blackout following a seismic LOOP has a frequency considerably less than that due to internal events. For higher-magnitude earthquakes, the impact of structural failures '

starts to become more important. However, as indicated above, SAMAs to mitigate these'risk

contributors are not expected to be cost effective.-

The licensee's IPEEE fire analysis was based on EPRI's Fire Induced Vulnerability Evaluation methodology. This methodology employs a graduated focus on the most important fire zones using qualitative and quantitative screening criteria: The fire zones or compartments were -

subjected to at least two screening phases. In the first phase, a zone was screened out if a fire'-'

could not cause an initiating event and if the zone contained no'equipment or cables needed to mitigate an initiating event. In the second-phase screening, three quantitative'criteria were':

used: (1) a zone is screened out if the CDF is less than 1 x 10- per year from evaluating the plant model assuming all equipment in the zone is lost, (2) a zone is screened out if contains a single train of safety equipment and the fire induced unavailability is small compared to that due July 2005 .- H-7 NUREG-1 437, Supplement 22

Appendix H to internal events, and (3) a zone is screened out if the effect of a fire is similar to but less severe than that in another analyzed zone. Of a total of 87 fire zones, 13 zones comprising five fire areas were not screened out and were subjected to a more detailed quantitative analysis.

These areas are as follows:

Fire Area Description CDF (per year)

AUXB-1 auxiliary building 2.76 x 10-A-24 cable vault 2.83 x 10-A-25 main control room 6.57 x 10-7 I-1A intake structure pump room 9.66 x 1-TB turbine building general areas 1.63 x 1V0!

The fire CDF for MPS2 is approximately 6.3 x 10- per year or about nine percent of the MPS2 internal events CDF.

In an RAI, the staff asked Dominion to explain, for each important fire area, what measures were taken to further reduce risk, and explain why these CDFs cannot be further reduced in a cost-effective manner (NRC 2004). For each area, Dominion provided a discussion of the major fire contributors assumed in the analysis and the existing plant features to address fire events. Dominion identified several improvements that have been implemented to address fire-related issues and confirmed that all fire-related plant outliers identified in IPEEE were implemented prior to the SAMA analysis. Dominion also discussed the potential for further cost-effective hardware changes to address the fire-related matters listed above, including improvements to detection systems, enhancements to suppression capabilities, and changes that would improve cable separation and train separation (Dominion 2004b). Dominion concluded that no further modifications would be cost-effective for any of the fire areas.

The staff notes that although additional SAMAs to reduce the fire risk contributors might be viable, given the low level of risk from fires and the improvements that have already been implemented, it is unlikely that further modifications would both substantially reduce risk and remain cost-beneficial.

The risk associated with other external events at MPS2 is small. While the CDFs due to high winds, floods and other events were not estimated since they were screened out using the NUREG-1407 approach (NRC 1991), a number of possible enhancements were identified in the IPEEE. These enhancements, primarily related to high winds and external flooding, have all been resolved (NRC 2001).

NUREG-1437, Supplement 22 H-8 July 2005

In the SAMA analysis, Dominion accounted for the additional risk contribution due to external events by increasing the benefit derived from the internal events model by 30 percent. This was determined by summing the following CDF contributions:'-'

• Fire 6.3 x 10- peryear.

Internal flooding '0.2 x 10- per year.

^ Seismic - ' 9.1 x 106peryear -

The fire contribution is discussed above. The internal flood contribution is based on the IPE analysis, but has subsequently been dropped from' the internal events model. The total external events CDF from the above is 1.6 x 1O per year, or approximately 22 percent of the CDF due to internal events. 'This was rounded up to 30 percent for the.SAMA analysis. -

The MPS2 Level 2 PRA analysis is based on the IPE. The IPE results were transformed to reflect new plant damage state and release category definitions. This process is described in Section F.2.3 of the ER (Dominion 2004a), and further clarified in response to RAIs (Dominion 2004b, 2004c). The resulting plant damage state'torelease category transformation matrixand release category-frequencies are provided in Tables F.2-4 and F.2-6 of the ER, respectively (Dominion 2004a). The release fractions for each release category were obtained'.

i from MAAP 3.OB analysis for the dominant sequences in the IPE and are provided in Table F.1 -2 of the ER (Dominion 2004a). In response to an RAI concerning the use of !PE dominant sequences to determine the release fractions used in the SAMA analysis, Dominion provided a discussion and a comparison of the plant damage states and release categories for the IPE and SAMA analyses (Dominion 2004b). The staff reviewed Dominion's source term estimates for the major release-categories and found the release fractions to be within the range of the release fractions for similar plants. Dominion also provided the results of several sensitivity studies relative to the source term and release characteristics including doubling the plume release height, doubling the duration of source term release time,' setting source terrr for M9 and MI 1 (late and baseemat failures with sprays) equal to Ml 0 (basemat failure without -

sprays), and using the MPS3 data for release category MiA (ISLOCA sequence). The results showed that these parameter variations had only a minor imnpact (less than 10 percent) on the estimated dollar benefits for the candidate SAMAs.- The'staff cbncludes that the process used for determining'the release category frequenciesand source terms is reasonable and

appropriate for the purposes of the SAMA analysis.

As discussed previously, the fissi6n'product inventory used in the consequence analysis is' based on a fission pr~6duct inventory scaled from generic information. In response to an RAI concerning the impact of current and future fuel managerndnt practices, Dominion described a, conservative bounding analysis of core fission produ-ct inventory 'onsidering a range of enrichments and burnups (Dominion 2004b). Using this inventory would result in a 22-percent increase in total benefit from eliminating all risk; Using realistic mid-life or average-conditions July 2005 H-9 -: NUREG-1437, Supplement 22

Appendix H would result in a smaller increase in the maximum benefit. The staff concludes that the scaling based on the plant-specific power level yields sufficiently accurate and reasonable results for the dose assessment.

The staff reviewed the process used by Dominion to extend the containment performance (Level 2) portion of the PRA to an assessment of offsite consequences (essentially a Level 3 PRA). This included consideration of the major input assumptions used in the offsite consequence analyses. The MACCS2 code was utilized to estimate offsite,consequences.

Plant-specific input to the code includes the source terms for each release category and the MPS2 reactor core radionuclide inventory (both discussed above), site-specific meteorological data, projected population distribution within a 80 km (50 mile) radius for the year 2030, and emergency evacuation modeling. This information is provided in Appendix F to the ER (Dominion, 2004a).

Dominion used site-specific meteorological data processed from hourly measurements for the 2000 calendar year as input to the MACCS2 code. The hourly data (wind direction, wind speed, and stability class) were collected from the onsite meteorological tower. Precipitation data were recorded at the Green Airport near Providence, Rhode Island, the closest weather station to Millstone. Morning and afternoon mixing height values were obtained from the National Climatic Data Center. The applicant also considered the impact on SAMA benefits of using meteorological data for 1998 and 1999. The results of these sensitivity cases showed that the benefits increased by an average of about five percent. The staff considers the use of the 2000 data in the base case to be reasonable.

The population distribution the applicant used as input to the MACCS2 analysis was estimated for the year 2030, based primarily on SECPOP90 (NRC 1997c). U.S. Census Bureau Year 2000 population data, projected to year 2030, was then used to update the SECPOP90 population data (Dominion 2004a). The staff questioned the difference between the use of SECPOP90 and SECPOP2000, and what the impact would be if the latter was used. In response, Dominion noted that the expected impact of using SECPOP2000 would be negligible since census data from 2000 were used to update the SECPOP90 file. The staff considers the methods and assumptions for estimating population reasonable and acceptable for purposes of the SAMA evaluation.

The emergency evacuation model was modeled as a single evacuation zone extending out 16 km (10 mi) from the plant. It was assumed that 100 percent of the population would move at an average speed of approximately 1.49 meters per second with a delayed start time of 7200 seconds from the offsite alarm reference time point (Dominion 2004a). Dominion performed sensitivity studies exploring the impact of the fraction of population that evacuates and the evacuation speed. The results demonstrated that the total dose and economic cost NUREG-1437, Supplement 22 H-10 July 2005 I

results are insensitive to these parameters (Dominion 2004a). The staff concludes that the evacuation assumptions'and analysis are reasonable and acceptable for the purposes of the SAMA evaluation.' '

Much of the site-specific economic data was provided from SECPOP90 (NRC 1997c) by specifying the data for counties surrounding the plant to a distance of 50 miles. The SECPOP90 input file was updated to 2001 using cost of living and other data from the Bureau of the Census and the Department'of Agriculture '(Dominion 2004a). The agricultural economic data were updated using available data from the 1997 Census of Agriculture (USDA 1998).

The staff coricludes that the 'imethodology used by Dominion to estimate the offsite

consequences f6r'MPS2 provides an acceptable basis'from'which to proceed with an assessment of risk reduction potential for candidate SAMAs. Accordingly, the'staff based its assessment of offsite risk on the CDF and offsite doses reported by Dominion.

Potential Plant Improvements The process for identifying potential plant improvements, an evaluation of that process, and the improvements evaluated in detail by Dominion are discussed in this section.

H.3.1 Process for Identifying Potential Plant Improvements

- 4. ,.J* -

Dominion's process for identifying potential plant improvements (SAMAs) consisted of the following elements:  ;

• review-of the most significant basic events fr6m the MPS2 PRA Model, Rev. 2 (April 200i),

• 'review of items not already evaluated and/or implemented during the IPE and IFEEE,

• review of SAMA analyses' submitted in support of originral licensing arid license renewal activities'f6r other operating nuclear p6wer plants, a1nd

• review of other NRC -

and i !

industry documentation discussing I

potential plant improvements.

-x -*

• e' 1 _ i h,. In Pase the Based on this process, an initial set of 196 'carididate SAMAs ws identified. In Phase 1 of the eva!uation,'Dominion performed a' qualitative screening of thehinitial list of SAMAs and eliminated SAMAs fromrfurther consideration using the followingjbriteria:

• 'the SAMA is not applicable at MPS2,  :

• the SAMA has already been'implemented at MPS2, or the MPS2 design meets the intent of the SAMA, or July 2005 H-1 1 NUREG-1437, Supplement 22

Appendix H

• the SAMA is related to a RCP seal vulnerability stemming from charging pump dependency on component cooling water (CCW). (MPS2 does not have this vulnerability because it relies on the RBCCW system rather than CCW for RCP seal cooling.)

Based on this screening, 152 SAMAs were eliminated leaving 44 for further evaluation. Of the SAMAs eliminated, 53 were eliminated because they were not applicable, 91 were eliminated because they already had been implemented, five were eliminated because they were related to RCP seal vulnerability, and three were similar to and combined with other SAMAs. A cost estimate was prepared for each of the 44 remaining candidates to focus on those that had a possibility of having a net positive benefit. To account for the potential impact of external events, the estimated benefits based on internal events were multiplied by a factor of 1.3 for all SAMAs except those related to ISLOCA and SGTR-initiated events.

Of the 44 SAMAs evaluated, one was identified as potentially cost-beneficial. Other SAMAs were evaluated and subsequently eliminated, as described in Sections H.4 and H.6.1 below.

H.3.2 Review of Dominion's Process Dominion's efforts to identify potential SAMAs focused primarily on areas associated with internal initiating events. The initial list of SAMAs generally addressed the accident categories that are dominant CDF contributors or issues that tend to have a large impact on a number of accident sequences at MPS2.

The preliminary review of Dominion's SAMA identification process raised some concerns regarding the completeness of the set of SAMAs identified and the inclusion of plant-specific risk contributors. The' staff requested additional information 'regarding the top 30 cut sets and certain sequences (NRC 2004). In response to the RAI, Dominion provided a listing of the top contributors to risk, the associated plant damage state, and a cross-reference between the top contributors to risk from a later version of the PRA and the SAMAs that addressed those risk contributors (Dominion 2004b).

The staff noted that Dominion based the SAMA identification process on PRA Revision 2 (dated April 2001) and the SAMA quantification on Revision 3 (dated October 2002). The staff questioned Dominion regarding the impact on the SAMA identification process if the later version of the PRA was used to identify potential SAMAs (NRC'2004). In response, Dominion reassessed the SAMA identification process considering the later PRA revision. The basic events not included in the initial Unit 2 PRA importance list were identified. Those events with a risk reduction worth greater than or equal to 1.005 from the more recent PRA model were specifically evaluated. These events were compared to the SAMA list to determine which events were already addressed by a SAMA. Dominion determined that all of the additional basic events map to previously identified SAMAs. As a result, no new SAMAs were created NUREG-1437, Supplement 22 H-1 2 July 2005

(Dominion 2004c). Based on these additional assessments, Dominion concluded that the set of 196 SAMAs evaluated in the ER addresses the major contributors to CDF and offsite dose, and

' that the review of the top risk contributors does not reveal any new SAMAs.

The staff questioned Dominion regarding use of the second screening criterion (i.e., screening out a SAMA on the basis that it has already been implemented at MPS2) to eliminate SAMAs that were identified based onreview of the PRA (NRC 2004). In response, Dominion provided qualitative or quantitative details on the plant-specific SAMAs that were screened using this criterion (SAMAs 161,162,-163,-164, 167, 168,169,171,:177,178,180,181, 188, and 196).

None of these SAMAs were determined to be cost-beneficial based on this further evaluation.

The staff questioned Dominion about lower-cost alternative'stb some of the SAMAs evaluated,:

including the use of portable'battery chargers and a direct-dr e diesel AFW pump' (NRC 2004).

In response, Dominion identified several lower-cost alternatives,rall of which are covered by an existing procedure or severe accident management guideline (SAMG), or could be instituted'-.'

following evaluation and guidance by the Technical Support Center (Dominion 2004b). -This is discussed further. in Section H.6.2. - -

The staff also questioned Dominion about several other candidate SAMAs that were found to be potentially cost-beneficial at another CE plant but not addressed by MPS2 (NRC 2004). In response, Dominion provided an evaluation of the applicability and/or costs and benefits for these SAMAs at MPS2.- Based on this assessment,'all of the SAMAs were dismissed except -

one involving adding a capability to flash the field on the emergency diesel generator to -

enhance SBO event recovery (Dominion 2004b). This is discussed further in Section H.6.2.

The staff notes that the set of SAMAs submitted is not 'all inclusive, since additional, possibly even less expensive,'design alternatives can always be postulated. However, the staff',-

concludes that the benefits of any additional modifications are unlikely to exceed the benefits of the modifications evaluated and that the alternative improvements would not likely cost less than the least-expensive alternatives evaluated, when the subsidiary costs associated with maintenance, procedures, and training are considered.

t;  ;- -'- '. .- . ...'-; .....

,-'-7.-.. -... ..':. ... .............

The staff concludes that Dominion used a systematic and comprehensive process for -

identifying potential plant improvements forMPS2, and that the set of potential plant. -.

improvements identified by Dominion is reasonably comprehensive and, therefore, acceptable.

This search included reviewing insights from the IPE and IPEEE and other plant-specific studies, reviewing plant improvements considered in previous SAMA analyses, and using the, knowledge and experience of its PRA personnel.. While explicit treatment of external events in the SAMA identification process was limited, it is recognized that the prior implementation of plant modifications for seismic events and the absence of external event vulnerabilities reasonably justifies examining primarily the internal events risk results for this purpose.

July 2005' H-13 NUREG-1 437, Supplement 22

Appendix H H.4 Risk Reduction Potential of Plant Improvements Dominion evaluated the risk-reduction potential of the 44 remaining SAMAs that were applicable to MPS2. A majority of the SAMA evaluations were performed in a bounding fashion in that the SAMA was assumed to completely eliminate the risk associated with the proposed enhancement. Such bounding calculations overestimate the benefit and are conservative.

Dominion estimated the potential benefits for each SAMA by generating a revised set of plant damage state frequencies. Using these revised frequencies, a revised Level 3 (dollars averted) calculation was performed. The benefit was calculated using the fault trees, event trees, and databases from Revision 3 of the MPS2 PRA. The assumptions made to evaluate the benefit were provided in response to an RAI (Dominion 2004b, 2004c). Table H-3 lists the assumptions considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk reduction in terms of percent reduction in CDF and population dose, and the estimated total benefit (present value) of the averted risk (including the 1.3 multiplier to account for benefits in external events). The determination of the benefits for the various SAMAs is further discussed in Section H.6.

The staff has reviewed Dominion's bases for calculating the risk reduction for the various plant improvements and concludes that the rationale and assumptions for estimating risk reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what would actually be realized). Accordingly, the staff based its estimates of averted risk for the various SAMAs on Dominion's risk reduction estimates. The estimated risk reduction for several of the SAMAs was negligible or zero. In these instances, the SAMA either affects sequences or phenomena that do not contribute to risk at MPS2, or represents an ineffective plant improvement. As such, a minimal impact on risk is not unreasonable in those cases.

H.5 Cost Impacts of Candidate Plant Improvements Dominion personnel experienced in estimating the cost of performing work at a nuclear plant estimated the costs of implementing the 44 candidate SAMAs. For some of the SAMAs considered, the cost estimates were sufficiently greater than the benefits calculated such that it was not necessary to perform a detailed cost estimate. Cost estimates typically included procedures, engineering analysis, training, and documentation, in addition to any hardware.

The staff reviewed the bases for the applicant's cost estimates (presented in Section F.3 of Appendix F to the ER). For certain improvements, the staff also compared the cost estimates to estimates developed elsewhere for similar improvements, including estimates developed as NUREG-1437, Supplement 22 H-14 July 2005

z C

M

'C

-Do Table H-3. SAMA Cost-Benefit Screenina Analvsis for Millstone Power Station, Unit 2 CA)

- - - -% Risk Reduction SAMA Assumptions Po uain T tlB nft() Cost()

--- ,,--- -CDF Dose 3 - Enhance loss of RBCCW Set RCP seal failiure and loss of the 7.8 4.9 173,300 100,000 procdedure to ensure cool down of -RBCCW system to zero ---

_0 reactor coolant system (RCS) prior to (This SAMA Is bolded because Itwas seal LOCA, determined to be cost-beneficial)

I 8 Eliminate R'C-P thermal barrier

- Set ioss of the RBCCW system to zero 6.9 4.6 155,500 5,000,000 dependence on RBCCW such that loss of RBCCW does not result directly In -

core damage 10 - Create an Independent RCP seal Eliminate the need for RCP cooling, 6 3.9 135,400 6,000,000

'- coolin6 syst~n, with dedliated diesel from the fault tree - --- ----

CD 11 - Create an Independent RCP seal Same as SAMA #10: -- - 6 3.9 135,400 5,000,000 cooling system, without dedicated diesel -.

22-a6elbi~heat Set RI3CCW heat exchanger failures to 0.3 0.3 7,300 2,500,000 removal heat exchangers zero 34 - Inistalle co6ntainiment v'ent.lar-g'e Set the electrical and mechanical 9.9 4.0 204,300 10,000,000 enough to remove ATWS decay heat reactor trip probabilities to zero 35 - Install a filtered containment vent to Set the containment spray component 16.2 16.0 414,300 12,000,000 remnove decay heat - failures to zero, 36 - Install an unfiltered hardened - Same as SAMA #35 -16.2 160414,300 10,000,000 containment ventf N) - -- I I - - . .

Table H-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 2 (Cont.)

0 a  % Risk Reduction en SAMA Assumptions P Total Benefit (S) Cost ($)

CDF Dose 43 - Create a reactor cavity flooding Re-bin Intermediate and late 0 16.4 84,700 18,000.000 system containment failures without sprays Into corresponding release categories with sprays 44 - Create other options for reactor Same as SAMA #43 0 16.4 84,700 18,000,000 cavity flooding 75 - Create a water backup for diesel Set loss of emergency diesel generator 1.5 2.8 44,600 10,000,000 cooling (EDG) 'A' and 'B' and common cause failure (CCF) of EDG 'A' and 'B' to zero I 77 - Provide a connection to alternate Remove cutsets containing loss of the 8.3 13.9 234,900 6,000,000 a) offsite power source (the nearby dam) Unit 3 cross-tie and grid and weather related losses of normal power from the base case. Set Unit 3 cross-tie and grid and weather related initiators to zero 81 - Install a fast acting motor generator Set 125 VDC Buses 201A and 201 B 1.0 1.7 29,200 3,000,000 output breaker Initiators to zero z

C 87 - Replace steam generators with new Set steam generator tube rupture 3 12.7 126,900 200,000,000 m design Initiating event frequency to zero v 93 - Install additional instrumentation Set the ISLOCA containment release 0.2 2.4 22,100 12,000,000 W and inspection to prevent ISLOCA category frequency to zero Cn sequences In C

' 94 - Increase frequency of valve leakage Same as SAMA #93 0.2 2.4 22,100 2,000,000 m testing n 99 - Ensure all ISLOCA releases are Same as SAMA #93 0.2 2.4 22,100 4,000,000 (D W scrubbed C

Table H-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 2 (Cont.)

rn C SAMA -Assumptions.CF Pplto ~a eei $ Cost($

100 I -Add redundant anddiverse limit Same as SAMA #93 0.2 2.4 28,700 18,000,000 CD switch to'ea'ch containment isolation, (D valve' 123 -,Provide capability for diesel-driven, Set failure of the low pressure safety 0 0 0 7,500,000 low pressiure vessel makeup.*-. Injection (LPSI) pumps and CCF of the LPSI pumps to zero 124/125 -Pirovide ani addition~al high Set failure~of the high pressuresafeity 10.5 13.0 286,100 10,000,000 pressure injection pump withIneto HS)pmsadCFfth Independent diesel_ njectionu(pstopupsaner f h 17 127 - Implement a reactor water storage Set probability of RWST rupture and 0.2 0.5 7,400 50,000

.. ~tank (RWST) makeup procedure RWST unavailability to zero 150 -~Prov'Ide an additional Set electrical reactor trip and turbine 8.7 3.5 177,900 600,000 instrumentatlo'n&c66ntrol syifem-(:e~g. trip to z'ero,*,

ATWS Mitigati6~f Syste'm Actuation-Circuitry) - .:-,: i4 159 lintill 6idr& iwpu~m'p' Set failure 'ofthe' tu'rb'n~e'driven&AF 8.0 5.1 178,100 12,000,000 pumps to zero (71

C_

Table H-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 2 (Cont.)

0 0

CA  % Risk Reduction SAMA Assumptions Populaton Total Benefit Cost (5)

CDF Dose 165 - Install independent air-operated Set failure of RBCCW/ESFRS AOV 2- 0.2 0.3 4,900 4,000,000 valve (AOV) around existing RB-68.1A to open to zero RBCCW/engineered safeguards feature room service (ESFRS) AOV in 'A' train to improve reliability of engineered safety feature room cooler 166 - Install additional motor-driven AFW Set failure of the motor driven AFW 2.2 1.1 47,400 12,000,000 pump pumps A' and 'B to zero 170 - Install redundant parallel Set failure of MOV 2-CS-1 6.1A to open 6.0 5.3 146,900 2,000,000 containment sump motor-operated valve to zero (MOV) to provide additional flow path I during containment swapover in recirculation 172 - Add a redundant 125 VDC bus Set loss of 125 VDC buses 201A and 0.1 0.3 4,100 5,000,000 201 B initiators and bus faults to zero z

173 - Install diverse valve around Set failure of AOVs 2-SW-8.1A/B/C to 8.0 4.6 175,000 1,000,000 24 existing service water AOV in each train open and CCF to open to zero to improve reliability of cooling water supply to RBCCW heat exchangers C 174 - Install additional AOV in series with Set failure of AOV 2-RB-8.1A to close 3.4 2.1 748900 2,000,000 m existing AOV in each train to Improve to zero C:

isolation of RBCCW supply to non-M c0 V

essential Spent Fuel Pool heat exchanger co ED.

-a CD 0X Ir

.. . . __- .- ___ ___1 -. .. - _. . . - - - - .. . .- ..- - - - __ - - , __- - -,- __-, - ,

zC Table H-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 2 (Cont.) -a M

% Risk Reduction CD a.

SAMA Assumptions Total Benefit ( Cost (S)

Population Ir CA CDF Dose 176 - Install additional AOV around Set failure of AOV 2-SW-8.1A to open 2.2 1.3 48,600 3,000,000 existing service water AOV In 'A' train to to zero improve reliability of cooling water supply to RBCCW heat exchanger 179 - Automate RCP trip circuitry on loss Set failure of operator to trip RCPs on 6.0 3.9 135,400 3,000,000 of seal cooling loss of thermal barrier cooling to zero (0

182 - Automate the start and alignment Set failure of operator to align stand-by 0 0 0 1,000,000 of the RBCCW pump RBCCW pump to zero . .... -

183 - Automate isolation feature of Set failure of operator to Isolate faulted 1.3 0.6 27,400 5,000,000 faulted steam generator' steam generator to zero 184 - Install redundant AFW regulating Set failure of operator to open AFW 0.7 0.4 15,900 2,000,000 valve following regulating valve fail to regulating bypass valve on failure of CD-open -. AFW regulating valve to open to zero CD R~3 185 - Install redundant ESFRS fan *' - ElmiInate the need for ESFRS fin F- 0.2 0.3 4,900 450,000 S.,,.;. r..'.* i';+ -'X L M 3 15B frfithe fa'ulttree'andsetthe" -

i. . .unavailability of ESFRS fans F-I5A and F-15B as well as their CCF to zero 186 - Install diverse strainers L-1A, B, C Set failure'of CCF of all 3 SW pump 0.5 0.7 13,200 2,000,000 to all three SW pump discharge lines to strainer initiator asiw6ll as CCF of prevent CCF strainers to operate to zero- .-:

I ',.  ! l, 187 - Automate start capability of Terry Set failure of operator to start the Terry 0.2 0.3 4,500 1,500,000 turbine .. ...- - turbine to zero*

189 - Automate emergency boration of Set the electrical and mechanical 0.9 0.5 18,700 2,000,000 RCS reactor trip probabilities to zero 0

(J

C-.

Table H-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 2 (Cont.)

0 o %Risk Reduction LA SAMA Assumptions Total Benefit(S) Cost(S)

CDF Dose 190 - Install redundant parallel valve in Set failure of the RWST isolation valve 1.0 0.5 22,100 1,000,000 charging pump suction line to RWST AOV 2-CH-192 to open to zero 192 - install additional MOV on volume Set all failures relating to MOV 2-CH- 0.7 0.4 15,500 2,000,000 control tank outlet line similar to MOV- 501 to close to zero CH-501 for closure to assure boric acid flow to charging pump 193 - Install additional AFW bypass line Set failure of the AOVs 2-FW-43A/B to 1.0 0.5 21,700 1,000,000 with diverse check valves and regulating open, their CCF to open, their air valves similar to check valves 2-FW-1 2A accumulators to operate, as well as and 12B and regulating valves 2-FW- CCF of CVs 2-FW-12A/B to open to 43A and 43B to steam generators zero o 195 - Install an MOV around existing Set failures of AOVs 2-RB-68.1A/B to 0.4 0.7 11,600 500,000 RBCCW/ESFRS AOV in each train to open and CCF to open to zero improve reliability of ESF room coolers z

C M

rn G)

CA) r CD 3 C o  :

r~3 I

part of other licensees' analyses of SAMAs for operating reactors and advanced light-water reactors. The cost estimates provided were in the form of rariges.; For purposes of evaluating specific SAMAs, the staff selected the low end values from the range to represent the costs.

For some SAMAs, the costs appeared to be overestimated.' Therefore, the staff asked the' applicant to justify the costs for those SAMAs that had significant benefits (NRC 2004). In response to the staff's request, Dominion provided a discussion of the components and activities that were considered in estimating the costs of those SAMAs for which the benefit was determined to be $50,000 or more. The discussion included a description of the modification, if any procedure changes and training would be required, and if any new instrumentation and maintenance would be required (Dominion 2004b). The staff reviewed the costs and subsequent explanations and found them to be reasonable and generally consistent with estimates provided in support of other plants' analyses. -

The staff concludes that the' cost estimates provided by Dominion are sufficient 'and adequate for use in the SAMA'evaluation. ' ' - . -

H.6 Cost-Benefit Comparison.

Dominion's cost-benefit analysis and the staff's review are described in the following sections.

H.6.1 Dominion Evaluation The methodology used by Dominion was based primarily on NRC's guidance for performing cost-benefit analysis, i.e., NUREG/BR-01 84, Regulatory Analysis 'Technical Evaluation Handbook (NRC 1997b). The guidance involves determining the net value for each SAMA according to the following formula:

NetValue=(APE+-AOC+AOE+AOSC)-COE;  ; - : --

., . . . ........... ~~~~~~.. . -*..- -.

where, - - -I .a .. '

APE = present value of averted public exposure ($)

AOC = present value of averted offsite property damage costs ($) '  :

AOE = present value of averted occupational exposure costs ($)

AOSC = present value of averted onsite costs ($) - -: .

COE = cost of enhancement ($).

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the benefit associated with the SAMA and it is not considered cost-beneficial. Dominion's derivation of each of the associated costs is summarized below. ,-

- ,,Joj {

• x July 2005 - '- H-21 NUREG-1437, Supplement 22

Appendix H Averted Public Exposure (APE) Costs The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (Aperson-rem/year) x monetary equivalent of unit dose ($2,000 per person-rem) x present value conversion factor (10.76 based on a 20-year period with a 7-percent discount rate).

As stated in NUREG/BR-01 84 (NRC 1997b), it is important to note that the monetary value of the public health risk after discounting does not represent the expected reduction in public health risk due to a single accident. Rather, it is the present value of a stream of potential losses extending over the remaining lifetime (in this case, the renewal period) of the facility.

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an accident could occur at any time over the renewal period, and the effect of discounting these potential future losses to present value. For the purposes of initial screening, Dominion calculated an APE of approximately $375,000 for the 20-year license renewal period, which assumes elimination of all severe accidents.

Averted Offsite Property Damage Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction x offsite economic costs associated with a severe accident (on a per-event basis) x present value conversion factor.

For the purposes of initial screening, which assumes all severe accidents are eliminated, Dominion calculated an annual offsite economic risk of about $13,700 based on the Level 3 risk analysis. This results in a discounted value of approximately $147,500 for the 20-year license-renewal period.

Averted Occupational Exposure (AOE) Costs The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction x occupational exposure per core damage event x monetary equivalent of unit dose x present value conversion factor.

Dominion derived the values for averted occupational exposure from information provided in Section 5.7.3 of the regulatory analysis handbook (NRC 1997b). Best estimate values provided NUREG-1437, Supplement 22 H-22 July 2005

Appendix H for immediate occupational dose (3300 person-rem) and long-term occupational dose -

(20,000 person-rem over a 10-year cleanup period) wereiused.-;'The present value of these doses was calculated using the equations provided in the handbook in conjunction with a monetary equivalent of unit dose of $2,000 per person-rem, a real discount rate of 7 percent, and a time period of 20 years to represent the license renewal period.\ For the purposes'of initial screening, which assumes all severe accidents are eliminated, Dominion calculated an AOE of approximately $27,300 for the 20-year license renewal period.

Averted Onsite Costs (AOSC) -

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted power replacement costs. Repair and refurbishment costs are considered for-recoverable accidents only and not for severe accidents.' Dominion derived the values for AOSC based on information provided in Section 5.7.6 of the regulatory analysis handbook (NRC 1997b).

Dominion divided this cost element into two parts - the Onsite'Cleanup and Decontamination-Cost, also commonly referred to as averted cleanup and decontamination costs, and the replacement power cost. -

Averted cleanup and decontamination costs (ACC) were calculated using the following formula:

ACC= Annual CDF reduction - -'

x present value of cleanup costs per core damage event -'.

x present value conversion factor. - - '-.. ' -

The total cost of cleanup and decontamination subsequent to a severe accident'is estimated in the regulatory analysis handbook to be $1.5 billion (undiscounted). This value was converted to present costs over a 10-year cleanup period and integrated over the term of the proposed:

license extension.' For the purposes of initial screening, which assumes-all severe accidents are eliminated, Dominion calculated an ACC of approximately $831,700 for the 20-year license; renewal period. : , - ,

Long-term replacement power costs (RPC) were calculated using the following formula:

RPC = Annual CDF reduction - . - -- -

x present value of replacement power-for a single event -

x factor to account for remaining service years for which replacement power is required * . -

x reactor power scaling factor Dominion based its calculatio'ns on the value of 870 megawatts .electric (MW[e]).. Therefore, - ,

Dominion applied a power scaling factor of 870 MW(e)/910 MW(e) to determine the July 2005- H-23 i NUREG-1437, Supplement 22 -

Appendix H replacement power cost. For the purposes of initial screening, which assumes all severe accidents are eliminated, Dominion calculated the RPC to be approximately $540,300.

Using the above equations, Dominion estimated the total present dollar value equivalent associated with completely eliminating severe accidents at MPS2 to be about $1,920,000.

Dominion's Results The total benefit associated with each of the 44 SAMAs evaluated by Dominion is provided in Table H-3. These values were determined based on the above equations for the various averted costs together with the estimated annual reductions in CDF and population dose, and then increased by a multiplier of 1.3 to account for additional risk reduction in external events.

The values for total benefit reported in Table H-3 include this multiplier. As a result, one of the 44 SAMAs was considered to be cost beneficial:

SAMA 3: Enhance loss of RBCCW procedure to ensure cool down of RCS prior to seal LOCA. The resolution of this issue is expected to be either a new procedure or a procedure modification that will require actions to prevent/mitigate a seal LOCA upon loss of RBCCW.

As stated in the ER, Dominion is addressing SAMA 3 as part of a comprehensive industry initiative in response to Generic Safety Issue 23, "Reactor Coolant Pump Seal Failure.'

Additionally, the CEOG is addressing this issue in CEOG Task 1136, 'Model for Failure of RCP Seals Given Loss of Seal Cooling.' The SAMA is anticipated to be implemented before the period of extended operation, and is being addressed under the current license (Dominion 2004b).

In response to an RAI, Dominion assessed the applicability and feasibility of several SAMAs_

considered by another CE plant. As a result, Dominion eliminated all of the SAMAs questioned except one - adding a capability to flash the field on the EDG (using a portable generator) to enhance SBO event recovery. Dominion stated that this SAMA is not expected to be cost-beneficial because it would likely require a plant modification to install a disconnect to allow the connection of a portable (temporary) generator, as well as development of a new SAMG.

However, Dominion stated that if this SAMA can be accomplished via a SAMG without a hardware modification, the SAMA would be cost-beneficial and will be implemented prior to the period of extended operation (Dominion 2004b).

H.6.2 Review of Dominion's Cost-Benefit Evaluation The cost-benefit analysis performed by Dominion was based primarily on NUREG/BR-01 84 (NRC 1997b) and was conducted in a manner consistent with this guidance.

NUREG-1437, Supplement 22 H-24 July 2005

Appendix H In order to account for uncertainties in the cost estimates, Dominion applied a factor of two margin in assessing whether SAMAs were cost-beneficial, i.e.,; a'SAMA was considered to be cost-beneficial if the total benefit is within a factor of two of the estimated cost. The staff asked the applicant to consider the impact of uncertainty in the CDF (NRC 2004). In response, Dominion stated that CDF uncertainty calculations are not available in the current version of the Millstone PRA model. However, based on a review of recent SAMA analyses in support of license renewal, the 95" percentile CDF ranged from a factor of 2.0 to a factor of 6.4 greater than the mean CDF. Dominion stated that, in order to provide conservatism, it compared the costs to twice the calculated benefit.- Dominion further indicated that most of the benefit calculations were performed in a bounding fashion, i.e., the SAMA is completely effective, and that such estimates would be substantially less if a more realistic analysis were performed for each SAMA (Dominion 2004b).

The staff questioned the approach of increasing the benefit (based on internal events) by 30 percent to account for external events (NRC 2004). In response to the RAI,-Dominion stated that a multiplier of 1.3 was used because the external events analyses are not readily' quantifiable (Dominion 2004b). The use of a multiplier on the benefits obtained from the internal events PRA to incorporate the impact of external events makes the implicit assumption that the consequences from external events sequences are the same as the consequences

from internal events sequences. To demonstrate the robustness of the analysis, Dominion -

performed a sensitivity study that increased the assumed contribution from external events from 30 percent to 60 percent of the internal event benefits; The result was that the increased benefit exceeded the lower bound of the cost estimate range for only SAMA 3, which was already determined to be cost-beneficial. Therefore, Dominion concluded that the use of the 1.3 multiplier is acceptable. -

Dominion assessed the impact of other factors on the analysis results, such as the contribution of external event initiators that were not explicitly included in the MPS2 risk profile,-the use of a 3 percent discount rate as compared to the 7 percent discount rate used in the baseline calculations, as well as a 15-percent real discount rate (Dominion 2004a). These sensitivity' cases resulted in an increase in the benefit calculation of about 30 percent or less. These analyses did not change Dominion's conclusion that none of the candidate SAMAs would be cost-beneficial except as noted above. In addition, Dominion performed sensitivity analyses that addressed assumptions made in other parts of.the cost-benefit analysis, including meteorological data,-source term, and evacuation., Dominion also considered the sensitivity to the impact of current and future fuel management practices. These sensitivity cases are:

bounded by the 3-percent discount rate sensitivity study.

The staff notes that accounting for each of these factors would tend to increase the benefit as compared to the baseline case analysis. However, the calculated benefits used in the baseline analysis are generally over estimated and, therefore, conservative. -,The staff concludes that the July2OO5..;,. H NUREG-1437, Supplement 22

Appendix H use of the factor of two to account for uncertainties, coupled with the fact that the calculated benefits are generally conservative, provides a reasonable treatment of uncertainties and is adequate for the SAMA evaluation.

The staff questioned Dominion about lower cost alternatives to some of the SAMAs evaluated, including the use of a direct-drive diesel AFW pump (NRC 2004). In response, Dominion identified and evaluated several lower-cost alternatives to those considered in the ER. These alternatives included 1) installing a RBCCW header cross-tie, 2) using the hydrogen purge system as an unfiltered hardened containment vent, 3) using the existing systems to flood the reactor cavity, 4) providing reactor water storage tank makeup, and 5) using the diesel fire pump as a backup to the turbine-driven AFW pump. Dominion concluded that all of the alternatives considered are either covered by an existing procedure or SAMG, or could be instituted following evaluation and guidance by the Technical Support Center. With regard to the specific lower cost alternative involving a direct-drive diesel AFW pump, Dominion stated that the alternative would not be viable at MPS2 due to room and ventilation constraints as well as costs. Dominion further stated that MPS2 has a SAMG for using the diesel fire pump to provide water to the AFW system (Dominion 2004b).

The staff also questioned Dominion about several other candidate SAMAs that were found to be potentially cost-beneficial at another CE plant but not addressed by MPS2 analysis (NRC 2004). In response, Dominion provided an evaluation of the applicability and/or costs and benefits for these SAMAs at MPS2. Based on this assessment, all of the SAMAs were - -

dismissed except one involving adding a capability to flash the field on the emergency diesel generator to enhance SBO event recovery. Dominion stated that the ability to flash the field on the EDG (using a portable generator) to enhance SBO event recovery would likely require a plant modification to install a disconnect to allow the connection of a portable (temporary) generator, as well as a new SAMG. However, If a hardware modification is not required, then the SAMA would be cost-beneficial. Dominion committed to complete its evaluation of this SAMA and develop a SAMG prior to the period of extended operation if it found to be cost-beneficial (Dominion 2004b).

The staff concludes that, with the exception of the two potentially cost-beneficial SAMAs discussed above, the costs of the SAMAs would be higher than the associated benefits. This conclusion is supported by uncertainty assessment and sensitivity analysis and upheld despite a number of additional uncertainties and nonquantifiable factors in the calculations, summarized as follows:

A factor of two was used to account for uncertainties. Even if a higher factor were considered to reflect a larger uncertainty in CDF, e.g., a factor of five, only two additional SAMAs would be close to becoming cost-beneficial - SAMAs 150 and 175. However, these SAMAs involve hardware modifications that are not expected to be cost-beneficial under more realistic assumptions regarding risk reduction.

NUREG-1437, Supplement 22 H-26 July 2005

Appendix H

• -,Sensitivity calculations were performed with respect to the discount rate (3 percent anid

.15 percent) and various MACCS2 parameters, including meteorological data, evacuation I speed, evacuation delay time, and source terms. The results of these sensitivity studies showed that none of the risk benefits were increased by more than 30 percent. Since this is less than the margin between cost and benefit for the SAMAs considered, the uncertainties in these parameters would not alter the conclusions.

H.7 Conclusions Dominion compiled a list of 196 SAMA candidates using the SAMA'analyses'as submitted in support of licensing activities for other nuclear power plants, NRC and industry documents discussing potential plant improvements, plant-specific insights from the MPS2 PRA model. A qualitative screening removed SAMA candidates that (1) were not applicable at MPS2 due to design differences, (2) had already been implemented at MPS2, or (3) were related to RCP seal vulnerability. A total of 152 SAMAs were eliminated, leaving 44 for further evaluation:' '

For the remaining SAMA candidates, a more detailed design and cost estimate were developed as shown in Table H-3. The cost-benefit analyses showed that one of the SAMA candidates was cost-beneficial.' Upon completion of a 3-percent discount rate sensitivity study, as well as other sensitivity studies, no additional SAMA candidates were determined to be cost-beneficial.,

To account for uncertainties, Dominion compared the costs of the SAMA with twice the calculated benefit. As a result, no additional SAMAs were cost-beneficial.

The staff reviewed the Dominion analysis and concluded that the methods used and the implementation of those methods were sound. -The treatment of SAMA benefits and costs, the generally large negative net benefits, and the inherently small baseline risks support the general conclusion that the SAMA evaluations performed by Dominion are reasonable and sufficient for the license renewal submittal. The unavailability of an external event PRA model precluded a quantitative evaluation of SAMAs specifically aimed at reducing risk of external event initiators; however,-improvements that have been realized as'a result of the IPEEE process and the inclusion of a multiplier to account for external events would minimize the likelihood of there being cost-beneficial enhancements in this area.

Based on its review of the Dominion SAMA analysis, the staff concurs that none of the -

candidate SAMAs are cost-beneficial, except for SAMA 3 and possibly an additional SAMA involving adding a capability to flash the field on the EDG (using a portable generator) to enhance SBO event recovery. This is based on conservative treatment of costs and benefits.-

This conclusion is consistent with the low residual level of risk indicated in the MPS2 PRA and the fact that MPS2 has already implemented many of plant improvements identified from the IPE and IPEEE processes. Although the one SAMA candidate is cost-beneficial and a second SAMA may be cost-beneficial if it can be implemented via procedural enhancements, neither of';

July 2005 H NUREG-1437, Supplement 22

Appendix H these SAMAs relates to adequately managing the effects of aging during the period of extended operation. Therefore, they need not be implemented as part of the license renewal pursuant to 10 CFR Part 54.

H.8 References 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants."

Dominion Nuclear Connecticut, Inc. (Dominion). 2004a. Applicant's Environmental Report-Operating License Renewal Stage, Millstone Power Station, Units 2 and 3. Dominion Nuclear Connecticut, Inc., Richmond, Virginia. January 2004.

Dominion Nuclear Connecticut, Inc. (Dominion). 2004b. Letter from Leslie N. Hartz, Dominion, to United States Nuclear Regulatory Commission Document Control Desk.

Subject:

Dominion Nuclear Connecticut, Inc., Millstone Power Station, Units 2 and 3, Response to Request for Additional Information, License Renewal Applications. (August 13, 2004).

Dominion Nuclear Connecticut, Inc. (Dominion). 2004c. Email from Richard J. Gallagher, Dominion, to Richard Emch, NRC.

Subject:

Clarification of RAI Responses. (September 16, 2004).

Northeast Nuclear Energy Company (NNECO). 1993. Letter from S. E. Scace, NNECO, to U.S. Nuclear Regulatory Commission Document Control Desk.

Subject:

Millstone Nuclear Power Station, Unit 2, Response' to Generic Letter 88-20 Individual Plant Examination for Severe Accident Vulnerabilities Summary Report. (December 30, 1993).

Northeast Nuclear Energy Company (NNECO). 1995. Letter from D. B. Miller, NNECO, to U.S.

Nuclear Regulatory Commission Document Control Desk.

Subject:

Millstone Nuclear Power -

Station, Unit 2, Response to Generic Letter 88-20, Supplements 4 and 5 Individual Plant Examination for External Events Summary Report. (December 29, 1995).

U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, "Individual Plant Examination for Severe Accident Vulnerabilities." (November 23,1988).

U.S. Nuclear Regulatory Commission (NRC). 1990. NUREG-1 150, Severe Accident Risks: An Assessment for Five U.S. Nuclear Power Plants, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1991. NUREG-1407, ProceduralandSubmittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, Washington, D.C.

NUREG-1437, Supplement 22 H-28 July 2005

Appendix H U.S. Nuclear Regulatory Commission (NRC). 1996. Letter from Daniel G. McDonald, U.S.

NRC, to Ted C. Feigenbaum, Northeast Utilities Service Company.

Subject:

NRC Staff's Evaluation of the Individual Plant Examination (IPE) Submittal for Millstone Nuclear Power Station, Unit No. 2 (B1 4702), (TAC NO. M74433). (May 21, 1996).

U.S. Nuclear Regulatory Commission (NRC). 1997a. NUREG-1560, Individual Plant Examination Program: Perspectives on Reactor Safety and Plant Performance, Washington, D.C. rie.. - -

U.S. Nuclear Regulatory Commission (NRC). 1997b. NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997c. NUREG/CR-6525, SECPOP90: Sector Population, Land Fraction, and Economic Estimation Program, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2001. Letter from Jacob I. Zimmerman, U.S.

NRC, to R. G. Lizotte, Northeast Nuclear Energy Company.

Subject:

Millstone Nuclear Power Station, Unit No. 2- Individual Plant Examination of External Events (IPEEE) (TAC NO.

M83642). (January 12,2001).

U.S. Nuclear Regulatory Commission (NRC). 2004. Letter from Richard L. Emch, Jr., NRC, to David A. Christian, Dominion.

Subject:

Request for Additional Information (RAI) Regarding Severe Accident Mitigation Alternatives for the Millstone Power Station, Units 2 and 3 (TAC NOS. MC1 827 and MC1828). (June 22, 2004).

U.S. Department of Agriculture (USDA). 1998. 1997 Census of Agriculture, National Agriculture Statistics Service, 1998.

July 2005 H-29 NUREG-1 437, Supplement 22

Appendix I NRC Staff Evaluation of Severe Accident Mitigation Alternatives (SAMAs) for Millstone Power Station, Unit 3, in Support of the License Renewal Application Review

Appendix I NRC Staff Evaluation of Severe Accident Mitigation Alternatives (SAMAs) for Millstone Power-Station, Unit 3, in Support of the License Renewal Application Review 1.1 Introduction Dominion Nuclear Connecticut, Inc. (Dominion) submitted an'assessment of SAMAs for '

Millstone Power Station, Unit 3 (MPS3) as part of the Environmental Report (ER) (Dominion 2004a). This assessment was based on the most recent MPS3 Probabilistic Risk Assessment (PRA) available at that time, a plant-specific offsite consequence analysis performed using the' MELCOR Accident Consequence Code System 2 (MACCS2)'computer program, and insights frohm the MPS3 Individual Plant Examination (IPE) (NNECO'1990) and Individual Plant Examination of Extemal Events (IPEEE) (NNECO1991). In identifying and evaluating potential SAMAs, Dominion considered SAMA analyses performed for other operating plants, as well as, industry and NRC documents that discuss potential plant improvements, such as NUREG-1560' (NRC 1997a). Dominion identified 185 potential SAMA candidates. This list was reduced to 52 unique SAMA candidates by eliminating SAMAs that were not applicable to MPS3 due to design differences, had already been implemented, or were related to a reactor coolant pump (RCP) seal loss of coolant accident (LOCA)' Dominion assessed the costs and benefits associated with each of the remaining'SAMAs and concluded in the ER that none'of the candidate SAMAs evaluated would be cost-ben'eficial for MPS3.

v -;- - - , .. - >>*?'*

Based on a review of the SAMA assessment, the NRC issued a request for additional information (RAI) to Dominion by letter dated June 22, 2004 (NRC 2004). Key questions concerned the following areas: peer reviews of the PRA, 'dominant risk contributors'at MPS3 and the SAMAs that address'these'corntributors, the mapping "ofLevel 1 PRA results into the Level 2 analysis, the potential impact of external event initiators and uncertainties on the assessment results, detailed information on some specific candidate SAMAs, and consideration of additional SAMAs. Dominion submitted additiorinl infoirmation bVletter dated August 13,2004 (Dominion 2004b) including summaries of peer review comments and their impact on the SAMA analysis; importance measures and corresponding SAMA candidates; information regarding the Level 2 analysis; informatio'n related to the resolution of IPEEE outliers and the impact of external events in the risk anaiysis, an assessment of the' impact of uncertainties; and additional information 'regarding specific SAMAs. Dominioin's responses July 2005' 1-1 NUREG-1 437, Supplement 22

Appendix I addressed the staff's concerns. As a result, Dominion identified one SAMA that would be cost-beneficial if it can be accomplished via a severe accident management guideline, without a hardware modification.

An assessment of SAMAs for MPS3 is presented below.

1.2 Estimate of Risk for MPS3 Dominion's estimates of offsite risk at MPS3 are summarized in Section 1.2.1. The summary is followed by the staff's review of Dominion's risk estimates in Section 1.2.2.

1.2.1 Dominion's Risk Estimates Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA analysis: (1) the MPS3 Level 1 and 2 PRA model, which is an updated version of the IPE (NNECO 1990), and (2) a supplemental analysis of offsite consequences and economic impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The identification of candidate SAMAs was based on Revision 4 of the PRA model, dated October 1999; the quantification of SAMA benefits was based on an October 2002 update of the PRA (referred to as Revision 0, using a new naming convention) (Dominion 2004b). The scope of the MPS3 PRA does not include external events.

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is approximately 2.57 x 1 o5 per year. The CDF is based on the risk assessment for internally initiated events. Dominion did not include the contribution to risk from external events or internal flooding within the MPS3 risk estimates; however,- it did account for the potential risk reduction benefits associated with external events by increasing the estimated benefits for internal events by 60 percent. This is discussed further in Sections 1.4 and 1.6.2.

The breakdown of CDF by initiating event is provided in Table 1-1. As shown in this table, LOCAs, RCP seal LOCAs, transients including anticipated transients without scram (ATWS),

and loss of offsite power (LOOP) are dominant contributors to the CDF. Bypass events (i.e., steam generator tube rupture [SGTR] and interfacing systems LOCA [ISLOCA])]

contribute less than 5 percent to the total internal events CDF. The contribution to CDF from internal floods is estimated to be 8.6 x 10' per year (NNECO 1990).

The Level 2 PRA model is based on the Level 2 model used in the Millstone Unit 3 Probabilistic Safety Study (NNECO 1983) and the IPE (NNECO 1990). The result of this analysis is a set of formulae for transforming the MPS3 plant damage state (PDS) frequencies into containment NUREG-1437, Supplement 22 1-2 July2005 I

Appendix I release category frequencies. The source terms for each release category (also termed the source term category) were obtained from the results of MAAP 4 analyses of the dominant core damage sequences in the IPE. -:-

Table i-1. MPS3 Core Damage Frequency -.

- . Initiating Event or ,  : CDF ~  % Contribution to Accident Class (Per Year) CDF RCP Seal LOCA - - 5.66 x 1046 22.0 Transients -. _-4.04 x 1045 ' -- 15.7 - -

LOCAs 3.42 x 104 13.3 LOOP 2.77 x 104 10.8 ATWS 2.39 x 104 9.3 Steamline break inside containment 2.31 x 104 9.0 Station blackout (SI80) 1.78 x 104 6.9 Total loss of service water 1.28 x 104 5.0 4

SGTR 1.00x 10 3.9 Loss of one vital DC bus . _ 4.18 x 10-7 . . 1.6 Steamline break outside containment - 3.79 x.107_ _.... - 1.5 '

ISLOCA - 2.21x107 0.9 Instrument tube LOCA 5.04 x 10a8 . 0.2 Total CDF 2.57 x 10- 100 The offsite consequences and economic impact analyses use the MACCS2 code to determine the offsite risk impacts on the surrounding environment and public. Inputs for this analysis include plant-specific and site-specific input values for core radionuclide inventory, source term and release characteristics, site meteorological data, projected population distribution within a 80 kilometer (km) (50-mile [mi]) radius for the year 2040, emergency response evacuation modeling, and economic data.. The core radionuclide inventory is based on the generic pressurized water reactor (PWR) inventory provided in the MACCS2 manual, adjusted to represent the MPS3 power level of 3411 megawatts thermal (MW[t]). The magnitude of the onsite impacts (in terms of clean-up and decontamination costs and occupational dose) is based on information provided in NUREG/BR-0184 (NRC- 1997b).

In the ER, Dominion estimated the dose to the population within 80 km (50 mi) of the MPS3 site*

to be approximately 0.128 person-sieverts (person-Sv) (12.8 person-roentgen equivalent man l

[person-rem]) per year. The breakdown of the total population dose by containment release July 2005:. 1-3 -\ NUREG-1437, Supplement 22

Appendix I mode is summarized in Table 1-2. Late-containment failures dominate the population dose risk, at MPS3, followed by SGTR and ISLOCAs. Early failures and containment isolation failures are each indicated to be zero contributors to risk. As indicated in the response to an RAI, these release modes were deleted from the IPE model because of low contribution (i.e., <0.1 percent)

(Dominion 2004b).

Table 1-2. Breakdown of Population Dose by Containment Release Mode (Unit 3)

Population Dose Containment Release Mode (Person-rem(a) Per Year)  % Contribution Late failure 6.60 51.5 SGTR 2.77 21.6 ISLOCA 2.23 17.4 Intermediate failure 0.93 7.2 No containment failure 0.24 1.9 Basemat failure 0.05 0.4 Early failure 0 0 Containment isolation failure 0 0 Total Population Dose 12.8 100 (a) One person-rem = 0.01 person-Sv 1.2.2 Review of Dominion's Risk Estimates Dominions's determination of offsite risk at MPS3 is based on the following three major elements of analysis:

• the Level I and 2 risk models that form the bases for the 1990 IPE submittal (NNECO 1990) and the 1991 IPEEE submittal (NNECO 1991),

• the major modifications to the IPE models that have been incorporated in the MPS3 PRA, and

• the MACCS2 analyses performed to translate fission product source terms and release frequencies from the Level 2 PRA model into offsite consequence measures.

Each of these analyses was reviewed to determine the acceptability of Dominion's risk estimates for the SAMA analysis, as summarized below.

NUREG-1437, Supplement 22 1-4 July 2005

Appendix I The staff's review of the MPS3 IPE is described in an NRC report dated May 5,1992-(NRC 1992). Based on a review of the original IPE submittal, the staff concluded that IPE submittal met the intent of Generic Letter 88-20 (NRC 1988); that is, the IPE was of adequate" quality to be used to look for design or operational vulnerabilities. The staff did, however, identify a number of weaknesses in the IPE analysis. In response to an RAI, Dominion indicated that all of these weaknesses have been addressed in the PRA used for the'SAMA analysis (Dominion 2004b). -- -

, ,~~~~ . , , . .- . L_.......................................

A comparison of internal events risk profiles between the IPE and the PRA used in the SAMA analysis indicates a decrease of approximately 3x1 O"per year in the total CDF (from 5.52 x .10'5 per year to 2.57 x 1 05 per year).- -The change is a net result of modeling improvements and some minor plant design changes that have been implemented at MPS3 since the IPE was submitted. A summary listing of those changes that resulted in the greatest impact on the total CDF was provided in the ER and in response to an RAI (Dominion 2004a, 2004b), and include the following: -

• modified the SBO logic to consider the SBO diesel battery capacity limitation and hardware/procedural changes implemented to cope with the condition, "I

• incorporated the latest revision of the MPS3 plant-specific database,

• modified the SBO event tree to incorporate the results of core uncovery time based on the most probable RCP seal LOCA leakage rates,

• incorporated the accident sequence analysis for LOCAs, SBO, ATWS, and total loss of service water (SW), x. -

• removed initiating events associated with common cause failure (CCF) to run 3and 4 SW

.-pumps, based on industry guidance on identification of CCF-groupings. -

- . . *. .;  ;- i. . - ' . .1. I.; i .  ; - . , -  : - ...  : .

An additional change that has a significant impact on the CDF value is the truncation'value used in the PRA model. For the PRA version used for the SAMA analysis, Dominion used a truncation value of 1.0 x 10-1. Jn contrast, use of a truncation value of 2.0 x 1 '.9 (as used in previous versions of the PRA) would result in a CDF of about 2.04 x 1O 5per year rather than a value of 2.57 x 10-5 per year as used in the SAMA analysis:..:: -- . --

The IPE CDF value for MPS3 is comparable to the CDF.yalues reported in the IPEs for other Westinghouse PWR plants. Figure 11.6 of NUREG-1560 shows that the IPE-based total internal events CDF for four-loop Westinghouse plants ranges from 4 x 104 to 3 x 1 per year (NRC 1997a). It is recognized that other plants have reduced the values for CDF subsequent.-. -

July 2005 l-5 NUREG-1437, Supplement 22

Appendix I to the IPE submittals due to modeling and hardware changes. The current internal events CDF results for MPS3 remain comparable to the results for other plants of similar vintage and characteristics.

The staff considered the peer review performed for the MPS3 PRA, and the potential impact of the review findings on the SAMA evaluation. In response to an RAI, Dominion described the external peer review, which was the Westinghouse Owners Group Peer Review performed in September 1999 (Dominion 2004b). The review resulted in four Level A facts and observations (extremely important and necessary) and 41 Level B facts and observations (important and necessary but may be delayed until next update). Two of the Level A and 24 of the Level B recommendations are yet to be incorporated. The Level A recommendations not yet incorporated are in the areas of accident sequence analysis and human reliability analysis.

Both involve the completeness of the treatment of pre-initiator human errors. The Level B recommendations not yet incorporated affect essentially all PRA elements. Dominion has reviewed all of the unresolved facts and observations and concluded that they have negligible impact on the SAMA analysis (Dominion 2004b). The staff has also reviewed Dominion's assessment of the impacts of the outstanding peer review comments and has come to the same conclusion.

Given that (1) the MPS3 PRA has been peer reviewed and the potential impact of the peer review findings on the SAMA evaluation has been assessed, (2) Dominion satisfactorily addressed staff questions regarding the PRA (Dominion 2004b), and (3) the CDF falls within the range of contemporary CDFs for Westinghouse plants, the staff concludes that the Level 1 PRA model is of sufficient quality to support the SAMA evaluation.

The licensee included external events in the IPE submittal in August 1990 (NNECO 1990). The external events analysis in the IPE/IPEEE is taken from the uMillstone Unit 3 Probabilistic Safety Study" (NNECO 1983). This submittal and several updates were reviewed extensively by the NRC staff as documented in NUREG-1 152 (NRC 1985a) and by contractors'as documented in NUREG/CR-4142 (NRC 1985b) and NUREG/CR-4143 (NRC 1985c). While the IPEEE submittal did not identify any vulnerabilities to severe accident risk from external events, a number of minor improvements were identified. In a letter dated May 26, 1998, the staff concluded that the IPEEE submittal met the intent of Supplement 4 to Generic Letter 88-20, and that the licensee's IPEEE process is capable of identifying the most likely severe accidents and severe accident vulnerabilities (NRC 1998).

'The seismic PRA performed for MPS3 resulted in a seismic CDF of 9.1 x 1i0 per year. The dominant contributor to this was seismically induced SBO. In NUREG-1 152, the staff recommended that two alternatives be further evaluated (improve the anchorage' system for the emergency diesel generator lube oil coolers and add a manually-operated, AC independent containment spray system). In response to an RAI, Dominion indicated that the first of these NUREG-1437, Supplement 22 1-6 July 2005

Appendix I alternatives has been implemented at MPS3. Dominion provided additional information concerning the costs related to the other alternative. Dominion concluded that, because of adequate seismic margins and the complexity associated with increasing the seismic capacity of a structures and components, no cost-effective SAMAs could be identified (Dominion 2004b).

The staff agrees that it is unlikely that cost-effective SAMAs to further reduce seismic risk will exist. This is due to high cost of structural modifications compared to the benefits expected.

The fire PRA performed for MPS3 resulted in a fire CDF of 4.9 x 104-per year. The dominant contributors are fires in the charging and component cooling pump area, cable spreading area, and control room. The dominant fire areas and the associated CDF for those areas are:

Fire Area Description - O:CDF(ervear)

AB-1 Charging and component cooling pumps area,- -1.07 x 10-6 CB-8 .-Cable spreading area -; . 9.89 x 107 CB-9 Control room - . 7.28x10 7 A subsequent modification to the fire detection system in the cable spreading area has reduced the CDF in this area to 3.75 x 107 per year (Dominion 2004b). - - * :

- _ . 4_,fs;,r .5, -'4 In a RAI, the staff asked Dominion to explain, for each important fire area, what measures were taken to further reduce risk, and explain why these CDFs cannot be further reduced in a cost-effective manner (NRC 2004).. For each area, Dominion provided a discussion of the major fire contributors assumed in the analysis and the existing plant features to address fire events. Dominion identified several improvements that have been implemented to address fire-related issues. Dominion also discussed the potential for further cost-effective hardware changes to address the fire-related matters listed above, including improvements to detection, systems, enhancements to suppression capabilities, and changes that would improve cable separation and train separation (Dominion 2004b). Dominion concluded that no further modifications would be cost-effective for any of the fire areas. I

. , t. - . . . - 4 .if .

The staff notes that although additional SAMAs to reduce the fire risk contributors might be viable,-given the low level of risk from fires and the improvements that have already been implemented, it is unlikely that further modifications would both substantially reduce risk and remain cost-beneficial. I

>, ,- ,, - . '-, " . , ', .' -' -; -' - i_;-:';!f-- . . ' - . -

In the SAMA analysis, Dominion accounted for the additional risk contribution due to external events by increasing the benefit derived from the internal events model by 60 percent. This was determined by summing the following CDFcontributions: ; .- - -

I; .' '. .' ', ' t-, .  : , ' , _ , - '. . , -. 5 . ' ,' el t' ,. ;.'

.~~~~ ~ ~. .,* ~ .- . ..-. , , -*

July 2005 . 1-7. NUREG-1 437, Supplement 22

Appendix I

• Fire 4.9 x 104 per year

• Internal flooding 0.9 x 10.6 per year

• Seismic 9.1 x 10.8 per year The fire contribution is discussed above. The internal flooding CDF of 8.6 x 10i7 per year was obtained directly from the MPS3 IPE (NNECO 1990). This value is the result of a bounding, screening-type analysis. The total external events CDF from the above is 1.49 x 10-5 per year, or approximately 58 percent of the CDF due to internal events. This was rounded up to 60 percent for the SAMA analysis.

The MPS3 Level 2 PRA analysis is based on the IPE (NNECO 1990). The result of this analysis is a set of formulae for transforming the MPS3 plant damage state (PDS) frequencies into containment release category frequencies. This is described in Section 1.2.3 of the ER (Dominion 2004a), and further clarified in response to RAls (Dominion 2004b, 2004c). The formulae and the release category frequencies are provided in Tables 1.2-4 and 1.2-6 of the ER, respectively (Dominion 2004a). The release fractions for each release category were obtained from MAAP 4 analysis for the dominant sequences in the IPE and are provided in Table 1.1-2 of the ER (Dominion 2004a). In response to an RAI concerning the use of IPE dominant sequences to determine the release fractions used in the SAMA analysis, Dominion provided a discussion and a comparison of the PDSs and release categories for the IPE and SAMA analyses (Dominion 2004b). The staff reviewed Dominion's source term estimates for the major release categories and found the release fractions to be within the range of the release fractions for like plants. Dominion also provided results of several sensitivity studies relative to the source term and release characteristics including doubling the plume release height, doubling the duration of source term release time, and varying source term release fractions.

The results showed that these parameter variations had only a minor impact (less than 20 percent) on the estimated dollar benefits for the candidate SAMAs. The staff concludes that the process used for determining the release category frequencies and source terms is reasonable and appropriate for the purposes of the SAMA analysis.

During the staff's review of the Level 2 model, the staff identified an error in the formulae used to translate PDS frequencies into release category frequencies. Dominion confirmed the error and determined that it resulted in a slight overestimation of the benefits for candidate SAMAs, which is conservative for the cost-benefit analysis (Dominion 2004b).

As discussed previously, the fission product inventory used in the consequence analysis is based on a fission product inventory scaled from generic information. In response to an RAI concerning the impact of current and future fuel management practices, Dominion described a conservative bounding analysis of core fission product inventory considering a range of enrichments and bumups (Dominion 2004b). Using this inventory would result in a 28-percent increase in total benefit from eliminating all risk. Using realistic mid-life or average conditions NUREG-1437, Supplement 22 I-8 July 2005

Appendix I would result in a smaller increase in the maximum benefit. The'staff concludes that the scaling based on the plant-specific power level yields'suff iciently accurate and reasonable results for the dose assessment.

The staff reviewed the process used by Dominion to extend the containment performance' (Level 2) portion of the PRA'to' an assessment of offsite consequences (essentially a Level 3 PRA). 'This included con'sideratiorn of the mrajdr input assuriptions used in the offsite consequence analyses. The MACCS2 code was utilized to estiimate offsite consequences.

Plant-specific input to the-code includes the source terms for each release category and the MPS3 reactor core radionuclide inventory (both discussed above), site-specific meteorological data, projected population distribution within a 80 km (50 mile) radius for the year 2040, and' emergency evacuation' modeling.' This information is provided in Appendix G to the ER (Dominion, 2004a). .

Dominion used site-specific meteorological data processed from hourly measurements for the 2000 calendar year as input to the MACCS2 code. -The hourly data (wind direction, wind speed, and stability class) were collected from the onsite meteorological tower. Precipitation data were recorded at the Green Airport near Providence, Rhode Island, the closest weather station to-Millstone. Morning and afternoon mixing height values were obtained from the National Climatic Data Center. The applicant also considered the impact on SAMA benefits of using meteorological data for 1998 and 1999. .The results of .these sensitivity cases showed that the benefits increased by an average of about five percent. The staff considers the use of the 2000 data in the base case to be reasonable. - .- - - --

The population distribution the applicant used as input to the MACCS2 analysis was estimated

• for the year 2040, based primarily on SECPOP90 (NRC 1997c).; U.S. Census Bureau Year,:-;

2000 population data, projected to year 2040, was then used to update the SECPOP90 -

population data (Dominion 2004a). The staff questioned the difference between the use of SECPOP90 and SECPOP2000, and what the impact would be if the latter was used. In response, Dominion noted that the expected impact of using SECPOP2000 would be negligible since census data from 2000 was used to update the SECPOPp9 file. The staff considers the r methods and assumptions for estimating population reasonable and acceptable for purposes of the SAMA evaluation.

The emergency evacuation model was modeled as a single evacuation zone extending out 16 km (10 mi) from the plant. It was assumed that 100 percent of the population would move at N an average speed of approximately 1.49 meters per second with a .delayed start time of 7200 seconds from the offsite alarm reference time point (Dominion 2004a). Dominion performed sensitivity studies exploring the impact of the fraction of population that evacuates and the evacuation speed. The results demonstrated that the total dose and economic cost results are July 2005 ' 1_9 NUREG-1437, Supplement 22

Appendix I insensitive to these parameters (Dominion 2004a). The staff concludes that the evacuation assumptions and analysis are reasonable and acceptable for the purposes of the SAMA evaluation.

Much of the site-specific economic data were provided from SECPOP90 (NRC 1997c) by specifying the data for counties surrounding the plant to a distance of 50 miles. The SECPOP90 input file was updated to 2001 using cost of living and other data from the Bureau of the Census and the Department of Agriculture (Dominion 2004). The agricultural economic data were updated using available data from the 1997 Census of Agriculture (USDA 1998).

The staff concludes that the methodology used by Dominion to estimate the offsite, consequences for MPS3 provides an acceptable basis from which to proceed with an assessment of risk reduction potential for candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDF and offsite doses reported by Dominion.

1.3 Potential Plant Improvements The process for identifying potential plant improvements, an evaluation of that process, and the improvements evaluated in detail by Dominion are discussed in this section.

1.3.1 Process for Identifying Potential Plant Improvements Dominion's process for identifying potential plant improvements (SAMAs) consisted of the following elements:

• review of the most significant basic events from the MPS3 PRA Model, Rev. 4 (October 1999),

• review of items not already evaluated and/or implemented during the IPE and IPEEE,

• review of SAMA analyses submitted in support of original licensing and license renewal activities for other operating nuclear power plants, and

• review of other NRC and industry documentation discussing potential plant improvements.

Based on this process, an initial set of 185 candidate SAMAs was identified. In Phase 1 of the evaluation, Dominion performed a qualitative screening of the initial list of SAMAs and eliminated SAMAs from further consideration using the following criteria:

• the SAMA is not applicable at MPS3, NUREG-1 437, Supplement 22 1-10 July 2005

Appendix I

• the SAMA has already been implemented at MPS3, or the MPS3 design meets the intent of the SAMA, or -

. -the SAMA is related to a RCP seal vulnerability stemming from charging pump dependency on component cooling water (CCW). (MPS3 does not hIave this vulnerability because the:

charging pumps do not rely on CCW for RCP seal injection.)

Based on this screening, 133 SAMAs were eliminated leaving 52 for further evaluation. Of the SAMAs eliminated, 47 were eliminated because they were not applicable, 77 were eliminrated' because they already had been implemented, and 9 were eliminated because they were related to RCP seal vulnerability. -A cost estimate was prepared for'each'of the 52 remaining candidates to focus on those that had a possibility of having a net positive benefit.. To account' for the potential impact of external events, the estimated benefits based on internal 'events of each SAMA were multiplied by a factor of 1.6 for all SAMAs except those related to ISLOCA and SGTR-initiated events.

The 52 SAMAs were evaluated and subsequently eliminated, -as described in Sections 1.4 and' 1.6.1 below.' - - -

1.3.2 Review of Dominion's Process Dominion's efforts to identify potential SAMAs focused primarily on areas associated with internal initiating events. 'The initial list of SAMAs generally addressed the accident categories

that are dominant CDF contributors or issues that tend to hav-e 'a'large impact on a number of accident sequences at MPS3' -.

The preliminary review of Dominion's SAMA identification p'rocess raised some concerns regarding the completeness of the set of SAMAs identified and the inclusion of plant-specific risk contributors. The staff requested additional information regarding the top 30 cut sets and certain sequences (NRC 2004). In response to the RAI, D6miinion provided a listing of the top '

contributors to'risk, the associated plant damage state, and across-reference between the top contributors to risk from a later version of the PRA and the'SAMAs'that addressed those' risk contributors (Dominion 2004b).- l - - ' E , -

The staff noted that Dominion based the SAMA identification process on PRA Revision 4 (dated, October 1999) and the SAMA quantification on an October 2002'update of the PRA (referred to as Revision 0). The'staff questioned Dominion regarding the' impact on the'SAMA identification-process if the later version of the PRA was used to identify potential SAMAs (NRC 2004). In response, Dominion reassessed the SAMA identification process considering the later PRA revision. The basic events not included in the initial Unit 3 PRA importance list were identified.

Those events with a risk reduction worth greater than or equal to 1.005 from the more recent July 2005 : 1-1 1: - NUREG-1437, Supplement 22

Appendix I PRA model were specifically evaluated. These events were compared to the SAMA list to determine which events were already addressed by a SAMA. Dominion determined that all of the additional basic events map to previously identified SAMAs. As a result, no new SAMAs were created (Dominion 2004c). Based on these additional assessments, Dominion concluded that the set of 185 SAMAs evaluated in the ER addresses the-major contributors to CDF and offsite dose, and that the review of the top risk contributors does not reveal any new SAMAs.

The staff questioned Dominion regarding use of the second screening criterion (i.e., screening out a SAMA on the basis that it has already been implemented at MPS3) to eliminate SAMAs that were identified based on review of the PRA (NRC 2004). In response, Dominion provided qualitative or quantitative details on the plant-specific SAMAs that were screened using this criterion (SAMAs 159, 163, 165, 166, 167, 174, 181 and 185). None of these SAMAs were determined to be cost-beneficial based on this further evaluation.

The staff questioned Dominion about lower-cost alternatives to some of the SAMAs evaluated, including the use of portable battery chargers and a direct-drive diesel auxiliary feedwater (AFW) pump (NRC 2004). In response, Dominion identified several lower-cost alternatives, all of which are covered by an existing procedure or severe accident management guideline (SAMG), or could be instituted following evaluation and guidance by the Technical Support Center. This is discussed further in Section 1.6.2.

The staff notes that the set of SAMAs submitted is not all inclusive, since additional, possibly even less expensive, design alternatives can always be postulated. However, the staff concludes that the benefits of any additional modifications are unlikely to exceed the benefits of the modifications evaluated and that the alternative improvements would not likely cost less than the least-expensive alternatives evaluated, when the subsidiary costs associated with maintenance, procedures, and training are considered.

The staff concludes that Dominion used a systematic and comprehensive process for identifying potential plant improvements for MPS3, and that the set of potential plant improvements identified by Dominion is reasonably comprehensive and therefore acceptable.

This search included reviewing insights from the IPE and IPEEE and other plant-specific studies, reviewing plant improvements considered in previous SAMA analyses, and using the knowledge and experience of its PRA personnel. While explicit treatment of external events in the SAMA identification process was limited, it is recognized that the prior implementation of plant modifications for seismic and fire events and the absence of external event vulnerabilities reasonably justifies examining primarily the internal events risk results for this purpose.

NUREG-1 437, Supplement 22 1-12 July 2005

Appendix I 1.4 Risk Reduction Potential of Plant Improvements Dominion evaluated the risk-reduction potential of the 52 remaining SAMAs that were applicable to MPS3. A majority of the SAMA evaluations were performed in a bounding fashion in that the SAMA was assumed to completely eliminate the risk associated with the proposed enhancement. Such bounding calculations overestimate the benefit and are conservative.

Dominion estimated the potential benefits for each SAMA by generating a revised set of PDS frequencies. Using these revised frequencies, a revised Level 3 (dollars averted) calculation was performed. The benefit was calculated using the fault trees, event trees, and databases from Revision 0 of the MPS3 PRA. The assumptions made to evaluate the benefit were provided in response to an RAI (Dominion 2004b, 2004c). Table 1-3 lists the assumptions considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk reduction in terms of percent reduction in CDF and population dose, and the estimated total benefit (preserit value) of the averted risk (including the 1.6 multiplier to account for benefits in external events). The determination of the benefits for the various SAMAs is further-discussed in Section 1.6.

The staff has reviewed Dominion's bases for calculating the risk reduction for the various plant improvements and concludes that the rationale and assumptions for estimating risk reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what would actually be realized). Accordingly, the staff based its estimates of averted risk for the various SAMAs on Dominion's-risk reduction estimates. The estimated risk reduction for several of the SAMAs was negligible or zero.:- In these instances, the SAMA either affects sequences or phenomena that do not contribute to risk at MPS3, or represents an ineffective plant improvement. As such, a minimal impact on risk is not ufireasonable in those cases.

1.5 Cost Impacts of Candidate Plant Improvements Dominion personnel experienced in estimating the cost of performing work at a nuclear plant estimated the costs of implementing the 52 candidate SAMAs. For some of the SAMAs considered, the cost estimates were sufficiently greater than the benefits calculated that it was not necessary to perform a detailed cost estimate. Cost estimates typically included procedures, engineering analysis, training, and documentation, in addition to any hardware.

The staff reviewed the bases for the applicant's cost estimates (presented in Section 1.3 of Appendix G to the ER). For certain improvements, the staff also compared the cost estimates to estimates developed elsewhere for similar improvements, including estimates developed as part of other licensees' analyses of SAMAs for operating reactors and advanced light-water reactors. The cost estimates provided were in the form of ranges. For purposes of evaluating specific SAMAs, the staff selected the low end values from the range to represent the costs.

July2005 1-13 NUREG-1437, Supplement 22

z >

E-D C) Q.

,4 Table 1-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 3 Cl) c  % Risk Reduction D SAMA Assumptions Total Benefit (P) Cost ($)

C CDF Dose 9 - Provide additional SW pump that can Set failures of SW pumps and CCF of 8.5 9.6 164,800 10.000.000 M be connected to either SW header SW pumps to zero 10 - Create an independent RCP seal Eliminate the need for RCP cooling 22.8 22.3 419.800 10.000.000 cooling system with dedicated diesel from the fault tree 11 - Create an Independent RCP seal Same as SAMA #10 22.8 22.3 419,800 5,000,000 cooling system without dedicated diesel 20/21 - Develop a new procedure for Changed fault tree from failure of one 1.7 0.3 14,100 150,000 cross-tying either the CCW pumps or train to failure of one train of SW AND SW pumps (including analysis, failure of the opposite train or failure of validation, and training) operator action to align the opposite train (prob. 0.10) 34 - Install a containment vent large Set failure of reactor protection system 9.3 1.3 103,400 10,000,000 enough to remove ATWS decay heat electrical components (except reactor trip breakers), CCF of reactor trip breakers, CCF of 10 or more control rods to insert, and CCF of 35 or more control rods to insert to zero 35 - Install a filtered containment vent to Set CCF of recirculation air conditioning 5.8 6.4 110,800 12,000,000 remove decay heat units to operate, misalignment of manual valve 3RHS*V43, loss of the recirculation spray system, CCF of motor-operated valves (MOV) 3SWP MOV50A/B to close, and CCF of 3SWP*MOV71A/B to close to zero C-C 0

.11

- . . I

C_

Table 1-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 3 o  % Risk Reduction SAMA Assumptions Total Benefit (S) Cost (S)

CDF Dose 36-Install an unfiltered hardened Same as SAMA #35 5.8 6.4 110,800 10,000,000 containment vent 43 - Create a reactor cavity flooding Set release categories with <0.1 41.9 344,800 18,000,000 system Intermediate and late containment

........... failure and basemat failure to zero 44 - Creating other options for reactor Same as SAMA #43 <0.1 41.9 344,800 18,000,000 cavity flooding . . .

60-- Provide additional DC battery Lengthen time for restoration of offsite 2.2 2.6 42,800 600,000 capability power to become available to prolong DC battery life 61 - Use fuel cells instead of lead-acid Same as SAMA #60 2.2 2.6 42,800 3,000,000 batteries 63- Improved bus cross tie ability Changed fault tree from failure of one 27.8 17.9 429,600 2,000,000 en AC bus to failure of one AC bus AND

-;failure of the opposite AC bus or failure of operator action to align the opposite AC bus (prob. 0.01). .

64 - Alternate battery charging capability Same as SAMA #60 2.2 2.6 42,800 5,000,000 67 -Create AC power cross tie capability Create crdss-tle logic (prob. 0.02) with 8.6 10.4 170,800 4,000,000 across units; iJ the Millstone Power Station, Unit 2 (MPS2) emergency diesel generators C , '.-; -i *,' ' (EDGs) In the fault tree m 73-Installgasturbin'egenerftors Set failures of EDGs 'A and 'B and 29.9 24.2 500,100 8,000,000 l .- CCF of EDGs 'A and 'B' to zero CO to ) - . .. .

C . ......-

CCT (D

r' .. , ....

3o M ,, . - - -- -

~~~~~~'

^;,;;,:,;

,.,.1:,

z M Table 1-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 3 n m _(

GO

% Risk Reduction SAMA Assumptions Population Total Benefit (S) Cost (S) n CDF Dose V 75 - Create a river water backup for Same as SAMA #76 0.7 0.5 11,100 750,000 diesel cooling 76 - Use firewater as a backup for diesel Eliminate failures of SW supply to the 0.7 0.5 11,100 CD 750,000

. cooling EDGs from the fault tree 77 - Provide a connection to alternate Eliminate failures of LOOP from the 38.4 30.0 635,100 6,000,000 offsite power source (the nearest dam) fault tree 80 - Create an auto-loading of the SBO Set failure of the operator to correctly 2.4 2.9 47,400 7,000,000 diesel start and align the SBO diesel to zero 87 - Replace steam generators with new Eliminate the possibility of SGTR 3.5 21.6 144,800 175,000,000 design events from the fault tree 93 - Additional instrumentation and Set the iSLOCA containment release 0.8 17.4 83,600 9,000,000 inspection to prevent ISLOCA category frequency to zero sequences 94 - Increase frequency of valve leak Same as SAMA #93 0.8 17.4 83,600 2,000,000 testing 99 - Ensure all ISLOCA releases are Same as SAMA #93 0.8 17.4 83,600 4,000,000 scrubbed 100 - Add redundant and diverse limit Same as SAMA #93 0.8 17.4 83,600 18,000,000 switch to each containment isolation valve 112 - Proceduralize local manual Set all recoveries of offsite power to 2.2 2.6 42,800 100,000 operation of AFW when control power is zero lost C_

rQ 0

0 Ln

C-Table 1-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 3 o  % Risk Reduction

-- SAMA - - - Assumptions ' Total Benefit:(S) Cost(S)

Assumptions Population cs S

- -CDF Dose 113 - Provide portable generators to be Bounded by SAMA #112 1.9 2.3 38,400 5,000,000 hooked In to the turbine driven AFW train after battery depletion 120 - Create passive secondary side Eliminate failures of the AFW system 40.6 15.4 532,900 50,000,000 coolers from the fault tree 123 - Provide capability for diesel-driven, Eliminate failures of the emergency 19.7 22.9 396,000 7,500,000 low pressure vessel makeup core cooling system Injection from the

- fault tree 124/125 - Provide an additional high Set failures of HPSI pumps and CCF of 3.5 1 42,800 10,000,000 pressure injection (HPSI) pump with HPSI pumps to zero independent diesel 138 - Create automatic swapover to Set failure of operator to establish sump 1.7 0.3 19,800 2,000,000 recirculation on refueling water storage recirculation after a LOCA'to zero

., tank depletion '

156 - Install secondary side guard pipes Eliminate steam line break inside 13.4 22.5 335,700 10,000,000 up to the main steam isolation valves, ' containment from the fault tree (MSIVs)  :

160 - Install turbine-driven AFW pump Set failures of the turbine-driven AFW 42.0 33.5 712,200 12,000,000

! pumps to zero 161 - Install SBO diesel Set failures of the SBO diesel to zero 5.3 6.4 105,400 8,000,000 162 - Install charging system train Set failures'of charging pu-m'ps'an'd 7.2 3.6 103,300 20,000,000 CCF of charging pumps to zero Z 164 - Install safety Injection train Set failures of HPSI pumps and CCF of 3.5 1 42,800 20,000,000 I HPSI pumps to zero O 168 - Automate feed and bleed Set failures of operator to establish feed 28.8 21.5 480,800 1,000,000 and bleed cooling to zero C 169 - Improve boron Injection reliability Eliminate failures of emergency 0 0 0 2,000,000

- with new procedure and hardware boratlon from the fault tree 170- Add another air-operated valve Set failures of MOVs 3SWP*MOV5OAIB 7.1 8.9 143,800 2,000,000 >

CDc 3 (AOV) to Isolate SW and 3SWP*MOV7lAIB to close, CCF of ',

CD

( 3SWP*MOV5OANB to close, and CCF of . . . C 3SWPMOV71AB to close to zero - a

z C Table 1-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 3 -O m CD

% Risk Reduction r0.

x SAMA Assumptions Population Total Benefit (S)

C') Cost (

CDF Dose 171 - Install another containment Same as SAMA #172 1.7 1.5 28,800 10,000,000 recirculation system (RSS) parallel flow

-4 ED path 172 - Add a redundant train of RSS Set failures of RSS pumps and CCF of 1.7 1.5 28,800 20,000,000 2 RSS pumps to zero 173 - Add additional SW AOVs (air-lo- Same as SAMA #170 7.1 8.9 143,800 2,000,000 close/air-to-open) 175 - Add a redundant DC bus Set failures of vital 120 VDC buses 0.3 0.5 7,000 5,000,000 oD 301 A1 and 301 B1 to zero 176 - Add a redundant charging pump Set failures of the charging pumps and 7.2 3.6 103,300 10,000,000 CCF of the charging pumps to zero 177 - Add a redundant block valve for Eliminate failures of the PORVs to 3.4 2.5 55,100 2,000,000 the power-operated relief valve (PORV) reseat from the fault tree 178 - Add redundant MSIVs Eliminate failures of the MSIVs to close 0.8 0.2 10,000 5,000,000 from the fault tree 179 - Add a redundant SW pump Eliminate failure of the SW train 'A' and 2.1 1.7 34,700 1,000,000 ventilation train train 'B' pump cubicle ventilation from the fault tree 180 - Add a redundant valve in series to Eliminate failures of the steam dump 4 0.5 44,300 5,000,000 isolate the steam line dumps to valves to the condenser from the fault condenser tree 182 - Add redundant AC bus Changed fault tree from failure of one 27.8 17.9 429,600 15,000,000 AC bus to failure of one AC bus AND failure of the opposite AC bus or failure of operator to align the opposite AC bus (prob. 0.01)

I 183 - Add redundant AFW flow path Set CCF of the discharge and injection 0.9 0.3 11,200 15,000,000 AFW check valves to open to zero 184 - Add redundant demineralized Set failure of the DWST to zero 0.8 0.2 9,800 5,000,000 C- water storage tank (DWST)

C:

CA 01

Appendix I For some SAMAs, the costs appeared to be overestimated. Therefore, the staff asked the I applicant to justify the costs for those SAMAs that had significant benefits (NRC 2004). In response to the staff's request, Dominion provided a discussion of the components and activities that were considered in estimating the costs of those SAMAs for which the benefit was determined to be $50,000 or more. The discussion included a description of the modification, if any procedure changes and training would be required, and if any new instrumentation and maintenance would be required (Dominion 2004b). The staff reviewed the costs and subsequent explanations and found them to be reasonable and generally consistent with estimates provided in support of other plants' analyses. - -

The staff concludes that the cost estimates provided by Dominion are sufficient and appropriate for use in the SAMA evaluation. ,

1.6 Cost-Benefit Comparisonm-Dominion's cost-benefit analysis and the staff's review are described in the following sections.

1.6.1 Dominion Evaluation The methodology used by Dominion was based primarily on NRC's guidance for performing cost-benefit analysis, i.e., NUREG/BR-01 84, Regulatory Analysis TechnicalEvaluation Handbook (NRC 1997b). The guidance involves determining the net value for each SAMA according to the following formula: , -

Net Value = (APE + AOC +AOE + AOSC) - O-E where, .  ;

APE,= present value of averted public exposure ($) --

AOC = present value of averted offsite property damage costs ($)

AOE = present value of averted occupational exposure costs ($) ,

AOSC = present value of averted onsite costs ($) -

COE = cost of enhancement ($).  ;

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the benefit associated with the SAMA and it is not considered cost-beneficial. Dominion's -

derivation of each of the associated costs is summarized below. -

July 2005 1-19 NUREG-1437, Supplement 22

Appendix I Averted Public Exposure (APE) Costs The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (Aperson-rem/year) x monetary equivalent of unit dose ($2,000 per person-rem) x present value conversion factor (10.76 based on a 20-year period with a 7-percent discount rate).

As stated in NUREG/BR-01 84 (NRC 1997b), it is important to note that the monetary value of the public health risk after discounting does not represent the expected reduction in public health risk due to a single accident. Rather, it is the present value of a stream of potential losses extending over the remaining lifetime (in this case, the renewal period) of the facility.

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an accident could occur at any time over the renewal period, and the effect of discounting these potential future losses to present value. For the purposes of initial screening, Dominion calculated an APE of approximately $275,900 for the 20-year license renewal period, which assumes elimination of all severe accidents.

Averted Offsite Propertv Damaae Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction x offsite economic costs associated with a severe accident (on a per-event basis) x present value conversion factor.

For the purposes of initial screening, which assumes all severe accidents are eliminated, Dominion calculated an annual offsite economic risk of about $21,800 based on the Level 3 risk analysis. This results in a discounted value of approximately $234,700 for the 20-year license renewal period.

Averted Occupational Exposure (AOE) Costs The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction x occupational exposure per core damage event x monetary equivalent of unit dose x present value conversion factor.

NUREG-1437, Supplement 22 1-20 July 2005

Appendix I Dominion derived the values for averted occupational exposure from information provided in' Section 5.7.3 of the regulatory analysis handbook (NRC 1997b).; Best estimate values provided' for immediate occupational dose (3300 person-rem) and long-term occupational dose '-- - '

(20,000 person-rem over'a 10-year cleanup period) were tused.'" The present value of these doses was calculated using the equations provided in the handbook in conjunction with a monetary equivalent of unit dose of $2,000 per person-rem a real -discount rate of 7 percent, and a time periodof 20'years to represent the license renewal period.' For the purposes of initial screening, which assumes all severe accidents are eliminated, Dominion calculated an AOE of approximately $11,000 for the 20-year license renewal period.

Averted Onsite Costs (AOSC) - -

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted-power replacement costs. Repair and refurbishment costs are'considered for'recoverable accidents only and riot for severe accidents. Dominion derived the values for AOSC based on information provided in Section 5.7.6 of the regulatory analysis handbook (NRC 1997b).

Dominion divided this cost element into two parts -the Onsite Cleanup and Decontamination Cost, also commonly referred to as averted cleanup and decontamination costs, and the replacement power cost..

Averted cleanup and decontamination costs (ACC) were calculated using the following formula:

ACC = Annual CDFreduction -

x present value of cleanup costs per core damage event-x present value conversion factor. ..- -

The total cost of cleanup and decontamination subsequent'to a'severe accident is estimated in -

the regulatory analysis handbook to be $1.5 billion (undiscounted). This value was converted to present costs over-a 10-year cleanup period and integrated over the term of the proposed - -

4:

license extension. For the purposes of initial screening, which assumes all severe accidents are eliminated, Dominion calculated an ACC of approximately $334,400 for the 20-year license renewal period.

Long-term replacement power costs (RPC) were calculated using the following formula:

RPC = - Annual CDF reduction 4 ,

x present value of replacement power for a single event .A - -,;

-x factor to account for remaining service years for which replacement power is -

required - . --

x reactor power scaling factor July 2005 -- 1-21 NUREG-1437, Supplement 22

Appendix I Dominion based its calculations on the value of 1154 megawatts electric (MW[e]). Therefore, Dominion applied power scaling factor of 1154 MW(e)/910 MW(e) to determine the replacement power cost. For the purposes of initial screening, which assumes all severe accidents are eliminated, Dominion calculated the RPC to be approximately $288,600.

Using the above equations, Dominion estimated the total present dollar value equivalent unassociated with completely eliminating severe accidents at MPS3 to be about $1,145,000.

Dominion's Results The total benefit associated with each of the 52 SAMAs evaluated by Dominion is provided in Table 1-3. These values were determined based on the above equations for the various averted costs together with the estimated annual reductions in CDF and population dose, and then increased by a multiplier of 1.6 to account for additional risk reduction in external events. The values for total benefit reported in Table 1-3 include this multiplier. As a result, all SAMAs that were evaluated were eliminated because the cost was expected to exceed the estimated benefit.

In response to an RAI regarding the costs of SAMA 1 2 (proceduralize local manual operation of AFW when control power is lost), Dominion assessed the applicability/feasibility of a procedure for manual operation of the turbine-driven AFW (TDAFW) pump when control power is lost, similar to that in place at MPS2. Dominion stated that this SAMA would likely require a plant modification to provide the level indication that would be necessary during SBO, in addition to a new procedure. However, Dominion stated that if this SAMA can be accomplished via a SAMG, without a hardware modification, then the SAMA would be cost-beneficial and will-be implemented prior to the period of extended operation (Dominion 2004b).

1.6.2 Review of Dominion's Cost-Benefit Evaluation The cost-benefit analysis performed by Dominion was based primarily on NUREG/BR-01 84 (NRC 1997b) and was conducted in a manner consistent with this guidance.

i In order to account for uncertainties in the cost estimates, Dominion applied a factor of two margin in assessing whether SAMAs were cost-beneficial, i.e., a SAMA was considered to be cost-beneficial if the total benefit is within a factor of two of the estimated cost. The staff asked the applicant to consider the impact of uncertainty in the CDF (NRC 2004). In response, Dominion stated that CDF uncertainty calculations are not available in the current version of the Millstone PRA model. However, based on a review of recent SAMA analyses in support of license renewal, the 951 percentile CDF ranged from a factor of 2.0 to a factor of 6.4 greater than the mean CDF. Dominion stated that in order to provide conservatism, it compared the NUREG-1437, Supplement 22 1-22 July 2005

Appendix I cost to twice the calculated benefit. Dominion further indicated that most of the benefit -

calculations were performed in a bounding fashion, i.e., the SAMA is completely effective; and that such estimates would be substantially less if a more realistic analysis were performed for each SAMA (Dominion 2004b). - --

The staff questioned the approach of increasing the benefit (based on internal events) by 60 percent to account for external events (NRC 2004). In response to the RAI, Dominion stated that a multiplier of 1.6 was used because the external events'analyses are not readily. . - -.

quantifiable (Dominion 2004b). The use of a multiplier on the benefits obtained from the '

internal events PRA to incorporate the impact of external events makes the implicit assumption that the consequences from external events sequences are the same as the consequences'..

from internal events sequences. To demonstrate the robustness of the analysis,- Dominion performed a sensitivity study that increased the assumed contribution from external events from 60 percent to 120 percent of the internal event benefits. iThe result was that the increased benefit exceeded the lower bound of the cost estimate range for only 2 SAMAs (112 and 168).

Dominion stated that external events are dominated by LOOP and SBO (approximately 85 percent of the external events CDF comes from SBO). SAMA 168 (automate feed and bleed) would have no benefit for SBO sequences because feed and bleed cannot be achieved without power. Additionally, this SAMA could create additional means for a spurious power-operated relief valve opening or safety, injection (a negative benefit).- Therefore, Dominion concluded that the use of the 1.6 multiplier is acceptable. SAMA 112 is discussed further below. -

Dominion assessed the impact of other factors on the analysis results, such as the contribution' of external event initiators that were not explicitly included in the MPS2 risk profile, the use of a 3 percent discount rate as compared to the 7 percent discount rate used in the baseline calculations, as well as a-15-percent real discount rate (Dominion 2004a). -These sensitivity cases resulted in an increase in the benefit calculation of about 30 percent or less. These analyses did not change Dominion's conclusion that none of the candidate SAMAs would be cost-beneficial except as noted above. In addition, Dominion performed sensitivity analyses' that addressed assumptions made in other parts of the cost-benefit analysis, including meteorological data, source term, and evacuation. Dominion also considered the sensitivity to the impact of current and future fuel management practices. These sensitivity cases are generally bounded by the 3-percent discount rate sensitivity study.

The staff notes that accounting for each of these factors would tend to increase the benefit as compared to the baseline case analysis. -However, the calculated benefits used in the baseline .

analysis are generally overestimated and, therefore, conservative. The staff concludes that the use of the factor of two to account for uncertainties, coupled with the fact that the calculated benefits are generally conservative, provides a reasonable treatment of uncertainties and is adequate for the SAMA evaluation.

July 2005. 1 NUREG-1437, Supplement 22'-.

Appendix I The staff questioned Dominion about lower cost alternatives to some of the SAMAs evaluated, including the use of a direct-drive diesel AFW pump (NRC 2004). With regard to the specific lower-cost alternative involving a direct-drive diesel AFW pump, Dominion stated that the alternative would not be viable at MPS3 due to room and ventilation constraints as well as costs. Dominion further stated that MPS3 has a SAMG for using the diesel fire pump to provide water to the AFW system (Dominion 2004b).

Dominion also identified and evaluated several lower-cost alternatives to those considered in the ER. These included (1) installing an unfiltered hardened containment'vent, (2) using existing systems to flood the reactor cavity, (3) creating a new SAMG to direct manual control of AFW, and (4) using the fire water system to fill the steam generators. Dominion concluded that three of the alternatives are covered by an existing procedure or SAMG, or could be instituted following evaluation and guidance by the Technical Support Center. The alternative involving creation of a new SAMG to direct manual control of the AFW pump is not currently covered by an existing procedure, but is related to SAMA 112.

SAMA 112 involves physical modifications to provide steam generator level indication in an SBO scenario, as well as the development of an emergency operating procedure that would direct the manual control of the TDAFW pump (Dominion 2004b). This SAMA was estimated to have a benefit of about $43,000 and an implementation cost of about $100,000. As such, it would not be cost-beneficial. As an alternative to SAMA 112, Dominion considered the development of a SAMG without the hardware modification. This improvement could be effective in a more limited number of sequences in which auxiliary feedwater control power is' lost, but steam generator level indications are not. Development of a SAMG for manual control of the pump would involve engineering to determine the feasibility,,creation of the new SAMG, field verification of the' actual operation, and final SAMG production. Dominion estimated the cost of this alternative to be in the range of $50,000 to $60,000. The estimated benefit of this modification (after doubling to account for uncertainty) is greater than the expected cost; therefore, it is potentially cost-beneficial. As indicated in its RAI response, Dominion plans to complete its evaluation of this SAMA and, if it is cost-beneficial, will develop a SAMG addressing manual control of the turbine-driven AFW pump prior to the period of extended operation (Dominion 2004b).

The staff concludes that, with the exception of one potentially cost-beneficial SAMA discussed above, the costs of the SAMAs would be higher than the associated benefits. This conclusion is supported by uncertainty assessment and sensitivity analyses and upheld despite a number of additional uncertainties and non-quantifiable factors in the calculations, summarized as follows:

NUREG-1437, Supplement 22 1-24 July 2005

Appendix I

• A factor of two was used to account for uncertainties.' Even'if 'a higher factor were considered to reflect a larger uncertainty in CDF, e.g., a factor of five, only one additional SAMA would be close to becoming cost-beneficial -SAMAl 68. However, this SAMA is '

not expected to be cost-beneficial under more realistic assumptions regarding risk reduction and implementation costs. -

• Sensitivity calculations were performed with respect to the discount rate (3 percent and 15 percent) and various MACCS2 parameters,'including' meteorological data, evacuation' speed, evacuation delay tirrie, and source terms. The results of these sensitivity studies' showed that none of the risk benefits was increased by more than 40 percent. Since this is less than the margin between cost and benefit for the SAMAs considered, the uncertainties:

in these parameters would not alter the conclusions.

1.7 Conclusions --..

Dominion compiled a list of 185 SAMA candidates using the SAMA analyses as submitted in support of licensing activities for other nuclear power plants, NRC and industry' documents" discussing potential plant improvements, plant-specific insights from the MPS3 PRA model.' A qualitative screening removed SAMA candidates that (1) were not applicable at MPS3 due to design differences, (2) had already been implemented at MPS3,'or (3) were related to' RCP seal vulnerability. A total of 133 SAMAs were eliminated, leaving 52 for further evaluation.

For the remaining SAMA candidates, a more detailed design and cost estimate were developed as shown in Table G-3. The cost-benefit analyses showed that none of the SAMA candidates was potentially cost-beneficial. Upon completion of a 3-percent discount rate sensitivity study, as well as other sensitivity studies, no additional SAMA candidates were determined to be',

potentially cost-beneficial. To account for uncertainties, Dominion compared the cost of thev-SAMA with twice the calculated benefit. As a result, no additional SAMAs were cost-beneficial.

The staff reviewed the Dominion analysis and concluded that the methods used and the implementation of those methods was sound. The treatment of SAMA benefits and costs, the generally large negative'net benefits, and the inherently small baseline risks support the general conclusion that the SAMA evaluations performed by Dominion are reasonable and sufficient for the license renewal submittal. The unavailability of an external event PRA model' precluded a quantitative evaluation of SAMAs specifically aimed at reducing risk of external event initiators; however, improvements that have been realized as a result of the IPEEE process and the inclusion of a multiplier to account forexternal events would minimize 'the likelihood of identifying cost-beneficial enhancements in this area."'"

July 2005 1-25 NUREG-1437, Supplement 22

Appendix I Based on its review of the Dominion SAMA analysis, the staff concurs that none of the candidate SAMAs are cost-beneficial, except for SAMA 112- proceduralize local manual operation of AFW when control power is lost. This is based on conservative treatment of costs and benefits. This conclusion is consistent with the low residual level of risk indicated in the MPS3 PRA and the fact that MPS3 has already implemented many of plant improvements identified from the IPE and IPEEE processes. Although SAMA 112 may be cost-beneficial if it can be implemented via procedural enhancements, this SAMA does not relate to adequately managing the effects of aging during the period of extended operation. Therefore, it need not be implemented as part of the license renewal pursuant to 10 CFR Part 54.

1.8 References 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants.'

Dominion Nuclear Connecticut, Inc. (Dominion). 2004a. Applicant's Environmental Report-OperatingLicense Renewal Stage, Millstone Power Station, Units 2 and 3. Dominion Nuclear Connecticut, Inc., Richmond, Virginia. January 2004.

Dominion Nuclear Connecticut, Inc. (Dominion). 2004b. Letter from Leslie N. Hartz, Dominion, to United States Nuclear Regulatory Commission Document Control Desk.

Subject:

Dominion Nuclear Connecticut, Inc., Millstone Power Sation, Units 2 and 3, Response to Request for Additional Information, License Renewal Applications. (August 13, 2004).

Dominion Nuclear Connecticut, Inc. (Dominion). 2004c. Email from Richard J. Gallagher, Dominion, to Richard Emch, NRC.

Subject:

Clarification of RAI Responses. (September 16, 2004).

Northeast Nuclear Energy Company (NNECO). 1983. Millstone Unit 3 ProbabilisticSafety Study. August 1983.

Northeast Nuclear Energy Company (NNECO). 1990. Letter from E. J. Mroczka, NNECO, to U.S. Nuclear Regulatory Commission Document Control Desk.

Subject:

Millstone Nuclear Power Station Unit No. 3, Response to Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities, Summary Report Submittal. (August 31, 1990).

Northeast Nuclear Energy Company (NNECO). 1991. Letter from J. F. Opeka, NNECO, to U.S. Nuclear Regulatory Commission Document Control Desk.

Subject:

Millstone Nuclear Power Station, Unit Nos. 1, 2 and 3, Response to Generic Letter 88-20 Supplement 4, Revised NUREG-1437, Supplement 22 1-26 July 2005

Appendix I Response to Generic Letter 88-20 Supplement 1, Individual Plant Examinations (IPE) for Severe Accident Vulnerabilities (December 23, 1991).

U.S. Nuclear Regulatory Commission (NRC). 1985a. -NUREG-1 152, Millstone 3 Risk Evaluation Report, An Overall Review and Evaluation of the Millstone Unit 3 Probabilistic Safety Study, Washington, D.C. -

U.S. Nuclear Regulatory Commission (NRC). 1985b. 'NUREG/CR-4142, A Review of the Millstone Probabilistic Safety Study, Washington, D.C. -

U.S. Nuclear Regulatory Commission (NRC). 1985g. NUREG/CR-4143, Review and'-,

Evaluation of the Millstone Unit 3 Probabilistic Safety Study, Containment Faihfre Modes, Radiological Source-Terms and Offsite Consequences, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, "Individual Plant Examination for Severe Accident Vulnerabilities." November 23,1988.

U.S. Nuclear Regulatory Commission (NRC). 1990. NUREG-1150, Severe Accident Risks: An Assessment for Five U.S. Nuclear Power Plants, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1991. NUREG-1407, ProceduralandSubmittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1992. Letter from Vernon L. Rooney, U.S. NRC, to John F. Opeka, NNECO.

Subject:

Staff Evaluation of Millstone 3 Individual Plant Examination (IPE) - Internal Events, GL 88-20 (TAC NO. M74434). (May 5,1992).

U.S. Nuclear Regulatory Commission. 1996. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997a. NUREG-1560, Individual Plant Examination Program: Perspectives on Reactor Safety and Plant Performance, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997b. NUREG/BR-0184, RegulatoryAnalysis Technical Evaluation Handbook, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997c. NUREG/CR-6525, SECPOP90: Sector Population, Land Fraction, and Economic Estimation Program, Washington, D.C.

July 2005 1-27 NUREG-1437, Supplement 22

Appendix I U.S. Nuclear Regulatory Commission (NRC). 1998. Letter from James W. Andersen, NRC, to Martin L. Bowling, Jr., NNECO.

Subject:

Millstone Nuclear Power Station, Unit No. 3 -

Individual Plant Examination of External Events (TAC NO. M83643). (May 26,1998).

U.S. Nuclear Regulatory Commission (NRC). 2004. Letter from Richard L. Emch, Jr., NRC, to David A. Christian, Dominion.

Subject:

Request for Additional Information (RAI) Regarding Severe Accident Mitigation Alternatives for the Millstone Power Station, Units 2 and 3 (TAC NOS. MCi 827 and MCI 828). (June 22, 2004).

U.S. Department of Agriculture (USDA). 1998. 1997 Census of Agriculture, National Agriculture Statistics Service, 1998.

NUREG-1437, Supplement 22 1-28 July 2005 I

NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER (9-2004) (Assigned by NRC. Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, If any.)

BIBLIOGRAPHIC DATA SHEET (See hIstructions on the reverse) NUREG-1437, Supplement 22 2 TITLE AND SUBTITLE 3. DATE REPORT PUBUSHED Generic Environmental Impact Statement for Ucense Renewal of Nuclear Plants (GEIS) MONTH YEAR Supplement 22 Regarding Millstone Power Station, Units 2 and 3 July2005 Final Report 4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT Technical

7. PERIOD COVERED (Inldusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (ItNRC. pie Diviion. Office orRefon, U.S Near Regulatory Commisson, and maling address;Itcontractors providename and malkig address.)

Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (ItNRC,type Same as abowe;i otcoprvidoHRCD~ision, twfice orRegion, U.S. Nucteareftulatory Commisseon, and makig addres&)

Same as 8 above

10. SUPPLEMENTARY NOTES Docket Numbers 50-336, 50-423 I1. ABSTRACT 1200 worts or less)

This final supplemental environmental Impact statement (SEIS) has been prepared in response to an application submitted to the NRC by Dominion Nuclear Connecticut, Inc. (Dominion) to renew the operating license for Millstone Power Station, Units 2 and 3 (Millstone) for an additional 20 years under 10 CFR Part 54. The final SEIS includes the NRC staff's analysis that considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives to the proposed action, and mitigation measures available for reducing or avoiding adverse Impacts. It also includes the staffs recommendation regarding the proposed action.

The NRC staffs recommendation is that the Commission determine that the adverse environmental Impacts of license renewal for Millstone are not so great that preserving the option of license renewal for energy-planning decisionmakers would be unreasonable. This recommendation Is based on (1) the analysis and findings in the GEIS; (2) the Environmental Report submitted by Dominion; (3) consultation with Federal, State, and local agencies; (4) the staffs own independent review; and (5) the staff's consideration of public comments.

12. KEY WORDSIDESCRIPTORS (Lst words orphrases thatwiassistresearchers hItocatng the report.) 13. AVAILABILITY STATEMENT Millstone Power Station, Units 2 and 3 . unlimited Millstone - -. SECURITY CLASSIFICATION Final Supplement to the Generic Environmental Impact Statement - (This Page)

FSEIS . unclassified National Environmental Policy Act (Ths Report)

NEPA -  : - unclassified Ucense Renewal GEIS 15. NUMBER OF PAGES

16. PRICE NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER

Printed on recycled paper Federal Recycling Program

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, DC 20555-0001 OFFICIAL BUSINESS