ML070660326

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Comment (15) of Robert S. Knorr on the Draft Supplemental Environmental Impact Statement on the Pilgrim Nuclear Power Station Located in Plymouth Massachusetts (NUREG-1437, Supplement 29)
ML070660326
Person / Time
Site: Pilgrim
Issue date: 02/28/2007
From: Knorr R
State of MA, Dept of Public Health
To:
NRC/ADM/DAS/RDB
References
71FR75280 00015, NUREG-1437
Download: ML070660326 (3)


Text

1NRCREP - Response from "Comment on NRC Documents" .

From: Robert S. Knorr, Director <Robert.Knorr@state.ma.us>

To: <nrcrep@nrc.gov> :0 Date: Wed, Feb 28, 2007 4:18 PM -

M,

Subject:

Response from "Comment on NRC Documents" .Co Below is the result of your feedback form. It was submitted by Robert S. Knorr, Director (Robert.Knorr@state.ma.us) on Wednesday, February 28, 2007iat 16:18:26 cm rT-1 0-)

DocumentTitle: Draft Supplemental Environmental Impact Statement on the Pilgrim Nuclear Power Station located in Plymouth Massachusetts [NUREG-1437, Supplement 29 Draft SEIS Pilgrim Nuclear Power Station]

Comments: The purpose of this letter is to provide comments on the Draft Supplemental Environmental Impact Statement on the Pilgrim Nuclear Power Station located in Plymouth Massachusetts [NUREG-1437, Supplement 29 Draft SEIS Pilgrim Nuclear Power Station].

The comments provided specifically address section 4.7 ("Evaluation of New and Potentially Significant Information on Impacts of Operation during the Renewal Term), pages 4.65-4.66. This section discusses the Southeastern Massachusetts Health Study (SMHS) that was conducted by the Massachusetts Department of Public (MDPH).

On page 4.66, beginning on line 5 text reads "...with regard to the SMHS, NRC has considered the relevant information in these citations and concludes that the peer reviews and even the authors now agree that the SMHS does not demonstrate a causal relationship between the PNPS effluents and the potential effect of excess cancers in the areas around the site." The MDPH believes this statement is neither a correct summarization of the peer reviews nor the author's published or unpublished opinions.

The correct summarization of the second peer review panel would be that:

1. The findings cannot be readily dismissed on the basis of methodological errors or proven biases;
2. The association found between leukemia and proximity to the Pilgrim nuclear facility was unexpectedly strong and, this raised concern regarding the biologic plausibility of the study; and 3.However, because the study results could not be dismissed, further study may be warranted, including expanding case finding and including children.

The specific statement in the draft report found on page 4-66, lines 7-8, "the SMHS does not demonstrate a causal relationship between the PNPS effluents and the potential effect of excess cancers in the areas around the site", is specifically not correct for the following reasons. The MDPH report specifically states that it is not possible to reach definitive conclusions regarding cause and effect but that the results should be followed up to clarify their public health implications. This conclusion is consistent with that stated by the peer reviewers. While the findings of the study may not support a causal relationship, the NRC arguments in the Supplemental Impact Statement ignore the principal MDPH and peer review conclusions that the findings cannot be dismissed and that further attention to the possible risks associated with the power plant may be warranted.

We would be happy to answer any questions you may have, or provide additional clarification. Please feel free to contact us at 617-624-5757.

organization: Massachusetts Department of Public Health addressl: Center for Environmental Health , A,*- -5 6/-7/-=

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address2: 250 Washington Street, 7th Floor city: Boston state: MA zip: 02108 country: US phone: 617-624-5757

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Response from "Comment on NRC Documents" Creation Date Wed, Feb 28, 2007 4:18 PM From: Robert S. Knorr, Director <Robert.Knorr@ state.ma. us>

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