ML062070051
| ML062070051 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/17/2006 |
| From: | Abrahams S Clean Water Action |
| To: | Austin Young Atomic Safety and Licensing Board Panel |
| Giitter R | |
| References | |
| 50-293-LR, ASLBP 06-848-02-LR, RAS 12010 | |
| Download: ML062070051 (7) | |
Text
From: "Stephanie Abrahams" <abrahams.s@hotmail.com>
To: <hearingdocket @ nrc.gov>, <amy@nrc.gov>
Date: Mon, Jul 17,2006 11 :16 AM
Subject:
P~lgrimLicense Renewal Statement DOCKETED Attached and copied into this email is a statement from MASSPIRG, Toxics USNRC Action Center, and Clean Water Action regarding the relicensing of the July 17, 2006 (11 :I6am)
Pilgrim Nuclear Power Plant.
OFFICE OF SECRETARY Office of the Secretary RULEMAKINGS AND Attn. Rulemaking and Adjudications Staff ADJUDICATIONS STAFF Mail Stop: 0 - 16C1 U S . Nuclear Regulatory Commission Washington, DC 20555-0001 Administrative Judge Ann Marshall Young Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001.
Statement on Behalf of Clean Water Action, MASSPIRG, Toxics Action Center To Judge Ann Marshall Young and the Rulemaking and Adjudications Staff, W e appreciate the opportunity to take part in the environmental review of the Pilgrim Nuclear plant during the re-licensing process. The public deserves a strong voice in the decision of whether to extend the life of such a controversial facility.
W e fully support the motions filed by the Attorney General of Massachusetts and Pilgrim Watch, who are petitioning the Nuclear Regulatory Commission for an adjudicatory hearing on Entergy's application for re-licensing the Pilgrim nuclear power plant. W e agree with the petitioners that Entergy's application fails to comply with the National Environmental Policy Act's requirement that Entergy take into account significant new information regarding environmental impact in its application.
There is a wide range of issues where significant new information should affect the application; these include the risk of spent fuel pool storage and radioactive fires; risks from terrorist attacks; impacts of radioactive releases; and the impacts of the once-through cooling system.
We urge the NRC to consider in-depth each of these significant environmental impacts, which we believe are grounds for denying the re-licensing of the plant.
Spent fuel: Over 1.2 million pounds of high-level radioactive waste is stored on site at the Pilgrim plant. It is estimated that this number will more than double if Pilgrim is allowed to operate for an additional twenty years. This waste poses a risk to the health of humans and ecosystems for centuries to come, but there are currently no clear disposal options outside of the state. Federal plans for storage are inadequate and new evidence suggests that plans for Yucca Mountain storage may not move forward. In recent months the Senate panel has cut requested funding for the program, and geologists have assessed the area and deemed it a complex geological
area. This new information regarding Yucca Mountain clearly portrays major impediments to the progress of the project. Even if present plans for establishing a Federal Waste Repository at Yucca Mountain move forward on schedule, that facility would reach maximum capacity long before a re-licensed Pilgrim stopped generating waste. Plant owners and the NRC need to have a clear and safe plan for storage of radioactive waste before the extension is granted. In addition, current storage of spent fuel at the Pilgrim plant is unsafe. Spent fuel is stored in cooling pools that are highly vulnerable to accidents or sabotage and are located outside the primary containment area. These pools are less secure than the nuclear reactor and the radioactivity of these pools far surpasses that of the reactor's core. The removal of water from these pools could easily cause an uncontrollable fire releasing a devastating level of radiation into the surrounding area. Recent analysis by Dr. Gordon Thompson and Dr. Jan Beyea estimate the costs and latent cancers following releases of Cesium-137 from Pilgrim's spent fuel pool:
10% release C-137 100% release C-137 Cost $105-$175billion $342-$488billion Latent Cancers 8,000 24,000 This new knowledge of costs and risks associated with spent fuel storage must be analyzed thoroughly before considering re-licensing the Pilgrim Nuclear Power Plant.
Terrorism: The nation's nuclear facilities' vulnerability to a planned terrorist attack can no longer be ignored. Since the September 1 1 th attacks, these concerns have come into greater focus. A recent study done by Large & Associates states that nuclear power plants are almost totally unprepared for a terrorist attack from the air. The study also noted that the probability of success of a deliberate attack is essentially 100%. (John H. Large, Large and Associates, "The Implications of September 1 1 th for the Nuclear Industry," Disarmament Forum, vol. 2,2003).This credible risk, which has not been thoroughly discussed, must be examined when discussing the re-licensing of the Pilgrim nuclear power plant.
Radioactive releases: The National Academy of Sciences BElR VII report from July 2005 stated that there is no safe dose of radiation. Pilgrim's daily radiation emissions have been linked to increased rates of leukemia and thyro~dcancers in towns around Plymouth (Morris, MS and Knorr, RS.
Southeastern Massachusetts Health Study. Final Reort. Boston, MA; Bureau of Environmental Health Assessment, Massachusetts Department of Public Health, 1990).In addition, new evidence indicates that on average, by 2030,nearly 1 in every 3 people in the Emergency Planning Zone will be 55 or over. (The Boston Metropolitan Area Planning Council Report on Population and Employment Projections 2010-2030, available at:
http://www.mapc.org/2006~projections.htmI).This age group, which is currently increasing, is more susceptible to the effects of radiation (Richardson, DB and Wing, S. Greater Sensitivity to Ionizing Radiation at Older Age: follow-up of workers at Oak Ridge National Laboratory through 1990.Int. Journal of Epidemiology, 1999,28:428-436.) It is necessary. when looking at the re-licensing of the Pilgrim Nuclear Power Plant, to look at both the increased knowledge of radiation effects, and these effects on an older population.
Once-through cooling system: The Pilgrim Plant's cooling system causes
significant damage to the environment of Cape Cod Bay. Pilgrim uses a once-through cooling system, taking in nearly one-half billion gallons of water a day, and sending it into the Bay at 25 or more degrees hotter. An additional 20 years of operation at Pilgrim using this cooling system could kill billions of aquatic plants and animals. This cooling system also violates Section 316(b) of the federal Clean Water Act, which requires the plant to use the best available technology to minimize environmental impact.
W e believe that the plant must be held to the highest standards under the Clean Water Act, and a closed-cycle cooling system should be installed as soon as possible and certainly before the license extension is granted.
Based on the seriousness of these environmental impacts, we ask the Commission to include issues of waste accumulation and storage, terrorism, radiation release and impacts of the Pilgrim cooling system in its environmental review.
Sincerely, Brian Thurber, Clean Water Action Frank Gorke, MASSPIRG Stephanie Abrahams, MASSPIRG Sylvia Broude, Toxics Action Center Is your PC infected? Get a FREE online computer virus scan from McAfeeB Security. http://clinic.mcafee.com/clinic/ibuy/campaign.asp?cid=3963
DOCKETED Office of the Secretary USNRC Attn. Rulemaking and Adjudications Staff Mail Stop: 0 - 1 6 C 1 July 17, 2006 (11:16am)
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 OFFICE OF SECRETARY RULEMAKINGS AND Administrative Judge Ann Marshall Young ADJUDICATIONS STAFF Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001.
S t a t e m e n t o n Behalf o f Clean W a t e r Action, MASSPIRG, Toxics Action C e n t e r To Judge Ann Marshall Young and the Rulemaking and Adjudications Staff, We appreciate the opportunity t o take part in the environmental review of the Pilgrim Nuclear plant during the re-licensing process. The public deserves a strong voice in the decision of whether t o extend the life o f such a controversial facility.
We fully support the motions filed by the Attorney General of Massachusetts and Pilgrim Watch, who are petitioning t h e Nuclear Regulatory Commission for an adjudicatory hearing on Entergy's application for re-licensing the Pilgrim nuclear power plant. We agree with the petitioners t h a t Entergy's application fails t o comply with the National Environmental Policy Act's requirement that Entergy take into account significant new information regarding environmental impact in its application.
There is a wide range of issues where significant new information should affect the application; these include the risk o f spent fuel pool storage and radioactive fires; risks from terrorist attacks; impacts o f radioactive releases; and the impacts o f the once-through cooling system.
We urge the NRC t o consider in-depth each of these significant environmental impacts, which we believe are grounds for denying the re-licensing of the plant.
Spent fuel: Over 1.2 million pounds of high-level radioactive waste is stored on site a t t h e Pilgrim plant. It is estimated that this number will more than double i f Pilgrim is allowed t o operate for an additional twenty years. This waste poses a risk t o the health o f humans and ecosystems for centuries t o come, but there are currently no clear disposal options outside of the state. Federal plans for storage are inadequate and new evidence suggests that plans for Yucca Mountain storage may not move forward. I n recent months t h e Senate panel has cut requested funding for the program, and geologists have assessed the area and deemed i t a complex geological area. This new information regarding Yucca Mountain clearly portrays major impediments t o t h e progress o f t h e project. Even if present plans for establishing a Federal Waste Repository a t Yucca Mountain move forward on schedule, that facility would reach maximum capacity long before a re-licensed Pilgrim stopped generating waste. Plant owners and the NRC need t o have a clear and safe plan for storage o f radioactive waste before the extension is granted. I n addition, current storage of spent fuel a t the Pilgrim plant is unsafe. Spent fuel is stored in cooling pools that are highly vulnerable t o accidents o r sabotage and are located outside the primary containment area. These pools are less secure than t h e nuclear reactor and the radioactivity o f these pools far surpasses t h a t of t h e reactor's core. The removal of water from these pools could easily cause an uncontrollable fire releasing a devastating level of radiation into the surrounding area. Recent analysis by Dr. Gordon Thompson and Dr. Jan Beyea estimate t h e costs and latent cancers following releases o f Cesium-137 from Pilgrim's spent fuel pool :
10%release C 137 100% relea\e C 137 Cost $105-8175 b ~ l l ~ o n $342-$488 b ~ l l ~ o n Latent Cancers 8.000 24.000 This new knowledge of costs and risks associated with spent fuel storage must be analyzed thoroughly before considering re-licensing the Pilgrim Nuclear Power Plant.
Terrorism: The nation's nuclear facilities' vulnerability t o a planned terrorist attack can no longer be ignored. Since t h e September llth attacks, these concerns have come into greater focus. A recent study done by Large &Associates states that nuclear power plants are almost totally unprepared for a terrorist attack from t h e air. The study also noted t h a t the probability of success of a deliberate attack is essentially 10O0/0. (John H. Large, Large and Associates, "The Implications of September llth for t h e Nuclear Industry," Disarmament Forum, vol. 2, 2003). This credible risk, which has not been thoroughly discussed, m u s t be examined when discussing t h e re-licensing of t h e Pilgrim nuclear power plant.
Radioactive releases: The National Academy of Sciences BEIR V I I report from July 2005 stated t h a t there is no safe dose of radiation. Pilgrim's daily radiation emissions have been linked t o increased rates of leukemia and thyroid cancers in towns around Plymouth (Morris, MS and Knorr, RS.
Southeastern Massachusetts Health Study. Final Reort. Boston, MA; Bureau of Environmental Health Assessment, Massachusetts Department of Public Health, 1990). I n addition, new evidence indicates t h a t o n average, b y 2030, nearly 1 in every 3 people in the Emergency Planning Zone will be 5 5 or over. (The Boston Metropolitan Area Planning Council Report on Population and Employment Projections 2010-2030, available a t : http://www.mapc.orq/2006 projections.html). This age group, which is currently increasing, is more susceptible t o t h e effects of radiation (Richardson, DB and Wing, S. Greater Sensitivity t o Ionizing Radiation a t Older Age: follow-up of workers a t Oak Ridge National Laboratory through 1990. I n t . Journal of Epidemiology, 1999, 28:428-436.) It is necessary, when looking a t t h e re-licensing of t h e Pilgrim Nuclear Power Plant, t o look a t both t h e increased knowledge of radiation effects, and these effects on an older population.
Once-through cooling system: The Pilgrim Plant's cooling system causes significant damage t o t h e environment of Cape Cod Bay. Pilgrim uses a once-through cooling system, taking in nearly one-half billion gallons of water a day, and sending i t into t h e Bay a t 25 or more degrees hotter. An additional 20 years of operation a t Pilgrim using this cooling system could kill billions of aquatic plants and animals. This cooling system also violates Section 316(b) of t h e federal Clean Water Act, which requires t h e plant t o use t h e best available technology t o minimize environmental impact. We believe t h a t the plant must be held t o t h e highest standards under t h e Clean Water Act, and a closed-cycle cooling system should be installed as soon as possible and certainly before t h e license extension is granted.
Based on t h e seriousness of these environmental impacts, we ask t h e Commission t o include issues of waste accumulation and storage, terrorism, radiation release and impacts of t h e Pilgrim cooling system in its environmental review.
Sincerely, Brian Thurber, Clean Water Action Frank Gorke, MASSPIRG Stephanie Abrahams, MASSPIRG Sylvia Broude, Toxics Action Center
CC: ifrank@masspirg.org>, ibthurber@cleanwater.org>, isylvia@toxicsaction.orgzMail Envelope Properties (44RBA9A6.ASC : 33 : 43613)
Subject:
P~lgrimLicense Renewal Statement Creation Date Mon, Jul 17, 3006 11: 15 ALM From: "Stephanie Abrahams" <ab~.:~h~l~ns.s@hot~nail.com>
Created By: abrahams.s@hotmail.com Recipients nl-c.gov OWGWP002.HQGWD001 HearingDocket (HearingDocket) n1.c.gov TWGWP004.HQGWDOOl AMY (Ann Young) toxicsaction.org sylvia CC masspirg.org frank CC Post Office Route OWGWP002.HQGWDOO 1 nrc.gov TWGWP004.HQGWD001 nrc.gov toxicsaction.org cleanwater.org masspirg.org Files Size Date & Time MESSAGE 7406 Monday, July 17,2006 11:15 AM NRC Pilgrim Stalcmcnt 7.17.06.doc 36864 Mime.822 60118 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None
Concealed
Subject:
No Security: St an c l a d Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This messase was not classified as .Junk Mail Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled Block List is not enabled