ML070600309

Attachments to Pilgrim Draft Environmental Impact Statement Afternoon Meeting Transcripts

ML070600309
Person / Time
Site:	Pilgrim
Issue date:	01/24/2007
From:	Ruddock R Associated Industries of Massachusetts
To:	Office of Nuclear Reactor Regulation
References
Download: ML070600309 (8)

Text

J4MJ- UU UU r-1 &I 1 1 1-1 1 M F I -e ý LPUU LUU ,*UU F:u U -!U', U LU/

MM I the employer's voice & resource 222 Berkeley Street - P.O. Box 763 Boston, MA 02117-0763 I 1 617-262-1180

• Fax: 617-536-6785 ASSOCIATED INDUSTRIES OF MASSACHUSETTS www.aimnet.org BRIDGEWATER BURLINGTON HOLYOKE MARLBOROUGH WASHINGTON, D.C.

Statement of Associated Industries of Massachusetts Before the Nuclear Regulatory Commission Concerning the Draft Environmental Impact Report for the Pilgrim Nuclear Plant License Renewal Application January-24, 2007 Good afternoon, my name is Robert Ruddock and I am the General Counsel for Associated Industries of Massachusetts (A.I.M.). A.LM. is the state's largest non-profit, nonpartisan association of Massachusetts employers. Our mission is to promote the well being of our more than 7000 members and their680,000 employees and the prosperity of the Commonwealth by improving the economic climate, proactively advocating fair and equitable public policy, and providing relevant,, reliable information and excellent services.

Let me begin by thanking the Commission;for the opportunity to present our views today on the important matter of the renewal of the licernse of the Pilgrim Nuclear power plan.

In this case we are presenting our views on -ite draft impact report. Even though this hearing is about the adequacy of that report, A.I.M. must put its comments in support of the draft report in a larger context. .

Massachusetts has among the highest electricity costs in the nation. These costs are of course added to our already high housing, health care, and other costs of living in the Commonwealth and the New England region. On the electricity side, the high costs reflect the decisions made over the years that have resultied in enormous reliance on costly and what appears to be increasingly, scace natural gas. Pilgrim is an important balance to this dependence on natural gas, increasing our reliability and moderating costs.

Pilgrim's contribution to society in supplying reliable power is only one positive part of its role in Massachusetts. We should be proud and very supportive of the plant's role in producing power without contributing. to;air pollution and particularly without carbon dioxide - a significant greenhouse gas. -Massachusetts was the first state in the nation to adopt mandatory power plant controls on C02 emissions in 2004. Recently our Governor agreed to join a regional initiative to do the same.thing. This will not come without costs, but its great to know that we can rely on economical electricity from the Pilgrim power plant that produces no carbon dioxide.

Fi L1r 1 I - I' UUU L: U E-"U Uo J4 U J-1 U U I L! 't I* i M t We know projections show we can expect electricitygrowth to increase annually at about 2% which is compounded year over year. This requires keeping all our existing fleet of power generation facilities and adding new plants. Pilgrim is essential to meet this demand.

There is no question that Pilgrim Nuclear. Po'w'erStation is a positive contributor to reliability, supply, and cost of electricity,, aý,yell as providing significant environmental benefits.

Turning to the draft impact statement, we urge the Commission to adopt the draft's recommendation that the adverse environmental impacts are not great and that renewal of the license should continue to be considered. Given the plant's positive electricity contribution to our state and region, its .enormously positive contribution to the world's climate, and its positive contribution to the local economy, coupled with the draft impact statements preliminary recommendation, we u*urge the Commission to re-license this power station.

If you have any questions about our views I would be happy to respond.

Respectfully submitted, General Counsel

'a

Jýrl UU UU UL:;Lllrl Mal-4rtv 1 1"1 1 ý8- 1 W M j~- ~UUU u uuu~1

ý.,LU L!U/U I p. 1 Rebecca Chin - Vice-Chair - Duxbury Nuclear Advisory Committee NRC's Draft SEIS is inadequate in that the NRC staff mistakenly concluded the Applicant's SAMA Analysis was "sound." The faulty SAMA analysis used by Entergy in the Environmental Report caused it to wrongly dismiss mitigation alternatives such as adding a filter to the Direct Torus Vent The purpose of a SAMA review is to ensure that any plant changes that have a potential for significantly improving severe accident safety performance are identified and addressed. One example of how a poorly performed SAMA analysis can lead to erroneous conclusions is the Pilgrim Environmental Report's look atiýthe costs and benefits of installing a direct torus vent filter at Pilgrim.

The Direct Torus Vent System (DTVS) is a method to relieve the high pressure which is generated during a severe accident. In 1986, it was determined that the Mark I containment, especially being smaller with lower design pressure, in spite of the supp're's'sio pool, has a 90% probability of that containment failing. The purpose of the containment is to provide a barrier between the lethal radiation inside the reactor and the public. In order to protect the Mark I contaimnpeii 1fom a total rupture it was determined necessary to vent high pressure buildup. As a result, the "Direct Torus Vent System" at all Mark I reactors, including Pilgrim, was installed.

Operated from the control room, the vent'is a reinforced pipe installed in the torus and designed to release radioactiv:e'lhigh pressure steam generated in a severe accident by allowing the %unfiltered.releasedirectly to the atmosphere through the 300 foot vent stack. Use of the: vent discharges steam and radioactive material directly to the atmosphere bypassing the standby gas treatment system (SBGTS) filters normally used to process releases via the containment ventilation pathwayý.. There is.no radiation monitor on the pipe and valves that comprise the DTV line.. Operators now have the option by direct action to expose the public andithe environment to unknown amounts of harmful radiation

'.I

Jan JU Ub UJ:b'/p JaniU ~ ~i~~p Martin F-ariesj bU8-bfU-eU~hb. P. 1 As a result of Pilgrim's design deficiency, the original idea for a passive containment system has been dangerously compromised and given over to human control with all its associated risks of error and technical failure.

There appears to be an internal ,contradiction in what we are being told.

"The NRC believes that the release from a severe core-melt accident would be reduced [by the suppression pol]l*by a factor of one hundred. This is considerably more optimistic than estimated in the NRC's first study on the subject. Also, the contention is. that the reduction by a filtration system would have zero benefit. Here the. contenders seem to be assuming that a factor of one hundred equals 100%,.,,IThadti (false. Even a release of 1 percent of the core's radioactive iodine and cesium would be a very severe event.

In its Environmental Report, Entergy anlyzes the benefits of installing a filter to the torus vent in the co6use of; eviewing possible severe accident mitigation alternatives. Their Report"states, this analysis case was used to evaluate the change in plant ris'f*romn installing a filtered containment vent to provide fission product scrubbmig..A bounding analysis was performed by reducing the successful torus veitiig'aiidett progression source terms by a factor of 2 to reflect the additional filtered capability. Reducing the releases from the vent path resulted in no benefit:" The, Report then states, "Basis for

Conclusion:

Successful torus venting,;accident progressions source terms are reduced by a factor of 2 to reflect, the additional filtered capability. The cost of implementing SAMA at Peachl Bottom was estimated to be $3 million.

Therefore this SAvIA is not .cost .effective for [Pilgrim]." Entergy has determined that in return for a.0cstof.$3 million there will be no benefit to public health and safety. ,

2

- ;2 'j

J451-. UU UU UZZ i ý.O 1 r rl M I- t. 1 1-1 1 45 F I = ZJ ýuuU ULOU LUU 11-Z How it is possible to find zero benefit from installing a filter that would reduce by a factor of two the radioactive -venting to the public in the case of a severe accident? Unfiltered venting hdasbeen judged unsafe by all regulatory agencies outside the United, Stites. In its analysis of several risk contributors to Core Damage Frequency, the disposition of those events frequently included "venting via DTV path to reduce containment pressure."

In other words, a filter in the torus vent could reduce the impact in many possible severe accidents. The only conclusion to draw from the outcome of the DTV filter SAMA analysis is that, Entergy has used the MACCS2 code to downplay the health and economic' 9Ogts of severe accidents and used the Probabilistic Safety Analysis (PSA) model to make the benefits of mitigation appear to be zero.

NRC staff reviewed Entergy's analysis and concluded that the methods used and implementation of those methods.Was sound. And "the costs of SAMAs evaluated would be higher than the associated benefits. 5.2.5. The NRC staff is wrong to accept Entergy's SAMA analysis in the application.

The SAMA analysis included in the Pilgrim Environmental Report is incomplete. Not only does thepro'babilistic miodeling for severe accidents artificially make consequences appear`insignificant, but the Applicant has used incomplete and incorrect input pa eters into the MACCS2 code.

The direct torus vent filter as an example of how this cost benefit equation might have been skewed in favor' ofnomitigation "While NEPA does not require agencies to select particular, options, it is intended to 'foster both informed decision-making and informed public participation, and thus to ensure the agency does not act upon: incomplete information, only to regret its decision after it is too late to correct'. It then said "if 'further analysis' is called for, that in itself is a valid andnmeanmngful remedy under NEPA." The Applicant has drastically under counted the costs of a severe accident, and this could have led it to erroneously reject mitigation alternatives. Further analysis is called for.

I .3

Jan UU UU UL :LJ1,-ti- 45 F 1 1 1I " UU LU L UI'U'U' EPA has acceptable standards for exposure, in the real world, there is no safe level of exposure to radiation.

In conclusion, the danger of NRC:iubber stamping Entergy's SAMA in the Draft SEIS - accepting the licensee s miinniization of consequences that make the cost of adding a filter to the Direct Torus Vent seem unnecessarily high/ not cost effective when it is obvious that the mitigation of installing the filter could indeed serve to protect public health and safety. I repeat, unfiltered venting has been judged unsafe by all regulatory agencies outside the United States. Wake up 4

J.E2 1-1 U U U U I L: 4 L, Lo p rl 45Ir t ;. rt- I M riI e Z:*I ~.,L j~a1 U U ULAU1oUUU :UYeU I- . 1 Rebecca Chin - Vice-Chair - Duxbury Nuclear Advisory Committee NRC's Draft SEIS concludes that the health impact is and will continue to be, small by mischaracterizing the Southeastern Massachusetts Health Study.

Draft SEIS states, "The authors of the SMIHS have stated that the study shows both a statistical association and a cause-and-effect relationship between leukemia incidence around PNPS and exposure to effluents from the plant. The final report, released to the public in October 1990, found a two to four fold increase of leukemia among residents of certain towns within a 20-mile radius from the plant (MDPH 1990)." The Draft goes on to cite peer reviews from a second re-review peer group that, "... did not support a causal relationship."

The peer re-review panel referred to mthe Draft SEIS was appointed at Boston Edison's request - the owner of Pilgrim at ihatitime. Contrary to accepted scientific practice, half of the re-review panel members were appointed by MDPII and the other half by Boston Edison - the company directly implicated by the SMHS findings.

In the "Executive Summary" of its repo~rt, The second peer review panel concluded that:

1. The findings cannot be readily disiiis'sed on the basis of methodological errors or proven biases.

2. The association found between leiikemia and proximity to the Pilgrim nuclear facility was unexpectedly strong and, this raised concern regarding the biologic plausibility of the study.

3. However, because the study, results could not be dismissed, further study may be warranted, including expanding case finding and including children.

SMHS noted that Boston Edison adimiihiedl -"higher-than average" releases in its early days due to poor fuel/damaged fuel rods and lack of a filtration system. The

, ;.' ,* *. . (* 1

jan .u uS u-t:u-tp riarTrin rarie OUU-OeU-eUf.

The re-review's panel's Executive Suninary admitted that "there have been other reports of observed cancer increases th~at'are inconsistent with predictions based on mathematical modeling and radiobiologytheory."

The 1990 SMHS finding was not based on "mathematical models" or "estimates" of radiation releases. Rather, it focused on what really happened to real people.

NRC's Impact Statement ignores the principal MDPH and peer review conclusions that the findings cannot be dism~issed and that further attention to the possible risks associated with the power plant may be warranted., including expanding case finding and inclu ing children.

0