ML073100308
| ML073100308 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/12/2007 |
| From: | Public Commenter Public Commenter |
| To: | Division of License Renewal |
| References | |
| 72FR45075 | |
| Download: ML073100308 (10) | |
Text
From: <K5487@aol.com>
To: <IndianPointEIS@nrc.gov>
Date: 10/12/2007 10:32:43 PM
Subject:
comment from Rockland County Conservation Association
Dear Mr. Pham:
Attached please find comments from the Rockland County Conservation Association, Inc. regarding the EIS for the proposed re licensing of Indian Point.
We feel that the lack of coordinated attention to the FAA Redesign Project that will bring increased air traffic to the airspace in close proximity to Indian Point needs critical attention that is lacking in the EIS.
Thank you for your anticipated attention to these comments and concerns.
Sincerely, Dorice Madronero, president Rockland County Conservation Assoc., Inc.
PO Box 213, Pomona, NY 10970
- See what's new at http://www.aol.com
Federal Register Notice: 72FR45075 Comment Number: 14 Mail Envelope Properties (47304C7A.HQGWDO01.OWGWPO04.200.200000A.1.19BC79.1)
Subject:
comment from Rockland County Conservation Association Creation Date: 10/12/2007 10:32:43 PM From: <K5487@aol.com>
Created By: K5487@aol.com Recipients
<IndianPointEIS@nrc.gov>
Post Office Route OWGWPO04.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 683 10/12/2007 10:32:43 PM TEXT.htm 1881 11/6/2007 11:14:02 AM Comment on Indian Point re 9-19-2007.doc 56320 11/6/2007 11:14:02 AM Mime.822 81654 11/6/2007 11:14:02 AM Options Priority: Standard Reply Requested: No Return Notification: None None Concealed
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Page 1 of 1
Dear Mr. Pham:
Attached please find comments from the Rockland County Conservation Association, Inc. regarding the EIS for the proposed re licensing of Indian Point.
We feel that the lack of coordinated attention to the FAA Redesign Project that will bring increased air traffic to the airspace in close proximity to Indian Point needs critical attention that is lacking in the EIS.
Thank you for your anticipated attention to these comments and concerns.
Sincerely, Dorice Madronero, president Rockland County Conservation Assoc., Inc.
PO Box 213, Pomona, NY 10970 See what's new at AOL.com and Make AOL Your Homepage.
file://C:\EMailCapture\IndianPointLRScoping\14\attch1.htm 11/6/2007
Rockland County Conservation Association, Inc.
PO BOX 213, Pomona, NY 10901 Founded 1930 September 19, 2007 Comment on Indian Point 2&3 re-licensing application proposal:
The Rockland County Conservation Association (RCCA) has opposed the Indian Point facility since Indian Point 1 was first proposed. Throughout the years of reviews and assurances of compliance and safety our confidence in the safety of the facility has been greatly challenged by radioactive leaks, personnel literally sleeping at the switch, and failed promises to meet deadlines of a fully functioning siren system. Now we are called upon again to believe that all is safe and well with a facility that is leaking strontium 90, tritium and has unplanned shutdowns.
As recent as September 11, 2007, the Journal News reported Feds Suspend Inspection at Indian Point 3 (http://www.thejournalnews.com/apps/pbcs.dll/article?AID=2007709110344).
BUCHANAN - The Nuclear Regulatory Commission has suspended an inspection at Indian Point 3 after federal experts found plant officials unprepared to answer questions about a series of unplanned shutdowns that led the agency to lower the reactor's safety rating in April.
"They just didn't have the documentation we needed," said NRC regional spokesman Neil Sheehan, noting that such suspensions are rare. "But also, the types of questions we are asking, they did not have answers for at this point."
Again, public confidence for the safety of this facility is marginalized. Further the article reports Kathy McMullin, an Indian Point spokeswoman, said the matter was "really much ado about nothing" and wouldn't have reached the level of public notification without the current regulatory climate surrounding the plant.
"In this particular environment, the NRC erred on the abundance-of-caution side, as we have done on issues that on their face might not seem all that significant," she said. "It's not necessarily routine that an inspection would be postponed, but it's not that unusual either."
So we are to understand that the NRC has made an error in judgment and that postponement of an inspection because the operator of a nuclear facility was unprepared to answer questions about the operation of its facility would not have been revealed if not for the regulatory climate
surrounding the plant. Does this infer out of sight out of mind is an acceptable position for a nuclear facility operator?
The residents in the Hudson Valley have just been advised of the FAAs decision to increase air traffic in the region. Rockland County residents were not advised of the proposed plan until until a few weeks before the end of the comment period. In fact, the County has filed a lawsuit on the merits of the environmental review process conducted by the FAA. Where there were few to no aircraft flying over the County we can now expect up to 600 flights per day increasing the noise level. On average every two to three minutes the noise of aircraft flying overhead will be heard.
Entergys Environmental review reports no foreseeable related Federal projects were identified. As the FAA Redesign Project is a Federal project, we ask what effect the background noise of increased air traffic might have on the efficacy of the emergency alert system. Specifically, was the system designed to be heard above the increased noise coming from the increased noise levels projected for Rockland County?
[2.13 Related Federal Project Activities During the preparation of this report, Entergy did not identify any known or reasonably foreseeable federal projects or other activities that could contribute to the cumulative environmental impacts of license renewal at the site. http://www.nrc.gov/reactors/operating/licensing/renewal/applications/indian-point/1-ipec-lra-appendix-e_1-2.pdf, pg 113 of 156)]
A proposal for a desalinization plant along the Hudson in a location not yet disclosed, though it is anticipated to be in Stony Point or Haverstraw, has been submitted for review by United Water of New York (UWNY). As the proposed facility is anticipated to be in use by UWNY within the proposed license period of Indian Point 2 & 3, we ask that this exposure be considered in Entergys environmental impact study. Further if it is deemed that it is not appropriate until approval for a desalination plant is granted, we ask the Indian Point facility be required to assess its potential impacts to the desalinization plant. Given the leakage of strontium 90 and tritium we do not believe that this is unreasonable. Further, it would be unreasonable for UWNY customers to have to pay related costs to remove, if possible, radionuclides emanating from Indian Point.
Thank you for your anticipated consideration to our comments.
Submitted by, Dorice Madronero, president
Feds suspend inspection at Indian Point 3 By GREG CLARY THE JOURNAL NEWS (Original Publication: September 11, 2007)
BUCHANAN - The Nuclear Regulatory Commission has suspended an inspection at Indian Point 3 after federal experts found plant officials unprepared to answer questions about a series of unplanned shutdowns that led the agency to lower the reactor's safety rating in April.
"They just didn't have the documentation we needed," said NRC regional spokesman Neil Sheehan, noting that such suspensions are rare. "But also, the types of questions we are asking, they did not have answers for at this point."
Entergy Nuclear Northeast, which owns and operates Indian Point, sent a letter Friday to the NRC requesting a delay, two days after the NRC pulled its special inspectors out of a review that normally takes weeks to complete.
The letter, obtained by The Journal News, didn't mention that the NRC had suspended the inspection on Wednesday, noting instead the arguments for a delay and the company's regret for "any inconvenience we may have caused the NRC Staff."
Kathy McMullin, an Indian Point spokeswoman, said the matter was "really much ado about nothing" and wouldn't have reached the level of public notification without the current regulatory climate surrounding the plant.
"In this particular environment, the NRC erred on the abundance-of-caution side, as we have done on issues that on their face might not seem all that significant," she said. "It's not necessarily routine that an inspection would be postponed, but it's not that unusual either."
Indian Point has applied to extend its operating licenses for its two working reactors to 2033 and 2035 respectively and has been wrestling with increased opposition from elected officials and the community because of radiation leaks and a system of warning sirens that has missed three deployment deadlines.
Sheehan said the agency required the supplemental inspection as part of its decision to lower Indian Point 3's safety rating to white, one level down from the top rating of green, because the unplanned shutdowns happened more frequently than regulations allow.
On April 6, an explosion and fire forced the company to unexpectedly shut down the atomic reactor for the second time in four days and the fourth time in less than a year.
Plant workers quickly controlled the fire, and NRC officials at the time said there was no radiation threat, but the agency announced the safety rating downgrade later that day.
One of the people notified Friday of the suspension was Rockland County Executive C. Scott Vanderhoef, who said this was just the latest in the company's seeming continual series of problems.
"The fact that they didn't know they weren't ready is more of a concern than simply a scheduling conflict," Vanderhoef said. "It raises the question of their competence in running the plant."
Westchester County officials were none too happy either.
"We're concerned about why they weren't ready when they said they would be," said David Novich, a spokesman for Emergency Services Commissioner Anthony Sutton.
http://www.thejournalnews.com/apps/pbcs.dll/article?AID=/20070916/NEWS02/709160352&templa te=printart Indian Point's siren vendor fired, sued in Pennsylvania By GREG CLARY THE JOURNAL NEWS (Original Publication: September 16, 2007)
BUCHANAN - Indian Point isn't the only nuclear plant having trouble installing a new emergency siren system.
A Pennsylvania power company has fired and is suing Acoustic Technology Inc., the Boston company that Indian Point's owner, Entergy Nuclear, hired to install its 155 new sirens. ATI so far has missed three federal deadlines.
The lawsuit filed by PPL Corp., the former Pennsylvania Power and Light, claims ATI failed to install a new alerting system for the PPL Susquehanna Nuclear Power Plant near Wilkes Barre.
"It was theirs to deliver and they didn't do that," PPL spokesman Lou Ramos said of ATI. "Hindsight is 100 percent, but we selected a vendor that from the get-go never had the capacity to deliver."
ATI officials declined to address specifics of the case, citing the litigation, which was filed Tuesday, but disputed PPL's contention that the system fell short.
The one clear difference between the two locations is that federal regulators told Indian Point its new system doesn't pass muster, while PPL didn't present its system to the Federal Emergency Management Agency for approval.
"We never got as far as the FEMA tests," Ramos said. "We wanted to make sure they met our testing requirements first."
Laura Burns, a vice president of ATI, said her company "went above and beyond what was required" at Susquehanna. She called PPL's demands "a little bit unreasonable."
Indian Point spokesman Jim Steets said Entergy has spoken to PPL since ATI was fired.
"We expect to continue to work with ATI," Steets said.
In what were both very technical installations, the details created most of the headaches for officials from the two power companies and their common vendor.
Both carried large-scale replacements of decades-old systems that would continue to be used until the new systems were approved.
PPL's 76 sirens totaled about half of Indian Point's, and that part of the installation in each case has been finished.
PPL's major obstacle, Ramos said, remains an inability to sound different configurations of sirens based on potential scenarios within its 10-mile emergency planning zone.
Indian Point's problems, according to an eight-page letter from FEMA that calls the system "inadequate," center on volume, sustainability of the sirens' sound and overall reliability.
One national siren expert pointed to the density of the Lower Hudson's population as a unique difficulty for ATI to overcome.
"You have some places there that are over 10,000 people per square mile," said John Fuoto, a siren consultant who has evaluated emergency notification systems for FEMA for about 13 years. "Most nuclear plants are pretty much located in outer boondocks. Indian Point is not a typical location. The more people around, the louder the outside noise is. You have to be louder in volume for high-population areas than in lower population areas."
Fuoto said the hilly topography of the area should present no more problems for a siren system than it has in similar locations in California, Pennsylvania and Tennessee.
"Topography, all it means is that you would need more sirens to cover a given amount of area to have the same loudness," Fuoto said. "Other nuclear plants have that same and similar type of topography, and they've managed to solve it. Topography may make it harder to do, but it does not make it impossible."
Fuoto said a key issue in putting in a new alert system is how close the actual delivered system comes to reaching the original design.
FEMA's eight-page analysis letter delivered Tuesday states that what has been delivered so far at Indian Point doesn't meet the design specifications that FEMA originally approved and that nuclear plant officials were "willing to have a system that does not meet its own emphatically stated design objectives, as long as FEMA will allow them to."
Entergy Nuclear's chief executive officer, Michael Kansler, released a statement late Friday saying the company would do all that was required to get the system in place and thanked local residents for their patience.
"We failed to meet a key communications goal - listening," Kansler said in the statement. "We did not listen to those voices - such as (FEMA) or county emergency planning personnel - when they said the system needs to be louder. We understand the trust you have placed in Entergy Nuclear to safely and securely operate Indian Point. We take this responsibility seriously, and demand nothing less of ourselves than your highest expectations for performance."
ATI's Burns said her company is confident that the issues at Indian Point can be resolved.
Alan Nelson, the director of emergency preparedness for the Nuclear Energy Institute, an industry trade association, said Entergy has been a victim of its own efforts to install a top-flight alert system.
"The Indian Point people, to give them credit, were willing to say, 'We're going to put in the world's best system, state of the art,' " Nelson said. "Often when you do that, it's a prototype."
He said about a third of the country's 104 nuclear plants have changed their alert systems, but most are not making changes the size of Indian Point's. He said power companies are watching projects like Entergy's closely as more and more look to replace outdated siren systems.
"Sirens are not the only way in which people can be notified," Nelson said, noting burgeoning technologies such as reverse telephone calling and other electronic options.
The Indian Point installation is making use of those technologies as well, to allow the company flexibility as alerting options move beyond the Cold War practice of blaring sirens.
"With any type of prototype, you're going to have your starts and stops and bumps and misses,"
Nelson said. "I think at the end you're going to have a system that is second to none."
http://www.thejournalnews.com/apps/pbcs.dll/article?AID=/20070913/NEWS02/709130367&templa te=printart FEMA: Indian Point's new sirens inadequate By GREG CLARY THE JOURNAL NEWS (Original Publication: September 13, 2007)
BUCHANAN - Indian Point's new $15 million emergency siren system won't receive federal approval until the nuclear plant can prove that the replacements are reliable and will sound at volumes loud and steady enough to meet federal standards.
In a strongly worded eight-page letter loaded with decibel standards and test result analysis, the Federal Emergency Management Agency yesterday said the warning system is inadequate.
"The three major areas identified ... must be successfully resolved before the new (system) can be placed into service," wrote Rebecca Thomson, FEMA's branch chief for radiological emergency planning.
Indian Point officials said they disagreed with key portions of the letter but would work as quickly as possible to meet federal requirements.
Thomson sent her letter to the New York State Emergency Management Office, Entergy Nuclear, which owns and operates Indian Point, and the Nuclear Regulatory Commission.
FEMA officials said the system does not meet basic agency standards.
The agency went so far as to note that Indian Point's documentation indicated to federal officials that the company "admits the sirens as installed and tested do not meet the design objectives ...
and rather than take corrective action, Entergy is willing to have a system that does not meet its own emphatically stated objectives, as long as FEMA will allow them to."
Entergy spokesman Jim Steets said the company will cooperate with the agency to resolve the issues and "assure that a state-of-the-art emergency alert system is in place and working successfully."
Steets declined to address the details of the letter.
"We must thoroughly review the highly technical portions of the letter on acoustics and audibility before commenting further on specifics," Steets said.
How Indian Point responds to FEMA will affect what sanctions might be imposed on the plant by the NRC, which relies on the U.S. Department of Homeland Security and FEMA to oversee emergency issues outside the walls of the nation's 104 working nuclear plants.
The NRC fined the company $130,000 for missing an April 15 deadline to have the sirens operational, after extending the original Jan. 30 deadline at Entergy's request.
Last month, a third deadline came and went without the system in place, though Entergy publicly announced it was ready to go two days before the Aug. 24 deadline.
FEMA officials at the time said they would take up to 45 days to review the paperwork the company delivered.
NRC spokesman Neil Sheehan said his agency has imposed no new deadline and will decide on further enforcement after evaluating Entergy's response to FEMA.
The region's elected officials yesterday continued to hammer the company for the delays.
"Entergy's failure to get the siren system up to FEMA standards is completely inexcusable," said Sen. Hillary Rodham Clinton, D-N.Y. "They have had more than two years to get this right, and we are still waiting."
Clinton said she would ask the Department of Homeland Security's inspector general to investigate the matter.
Rep. Nita Lowey, D-Harrison, said the repeated missed deadlines and lack of a replacement system should cost the company a "significant fine."
Until the new system is in place, the current system will continue to be used to notify residents within 10 miles of the plant that they should turn on their radios, TVs and computers to find out what to do to protect themselves.
In the event that no sirens can be heard in part or all of the four-county emergency planning zone, police and other official organizations would alert residents by loud speaker, traveling street by street in affected communities.
C.J. Miller, spokeswoman for Rockland County Executive C. Scott Vanderhoef, said despite some concerns that emergency evacuation could be difficult in such a densely populated area, a fail-safe siren system is crucial to improving residents' odds.
"We don't take the fatalistic view," she said. "A warning system needs to be in place so that people know they need to relocate or take protective action."