ML073100311
| ML073100311 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/12/2007 |
| From: | Public Commenter Public Commenter |
| To: | Division of License Renewal |
| References | |
| 72FR45075 | |
| Download: ML073100311 (6) | |
Text
From: gary shaw <crotonshaw@optonline.net>
To: <IndianPointEIS@nrc.gov>
Date: 10/12/2007 8:59:15 PM
Subject:
Re: EIS comment re: Indian Point (A CORRECTION)
Dear Sir:
In re-reading this comment, I found a minor error. It is corrected below towards the end of the second paragraph.
Thank you for your consideration.
Gary Shaw
Original Message -----
From: gary shaw To: indianpointeis@nrc.gov Sent: Thursday, October 11, 2007 9:49 PM
Subject:
EIS comment re: Indian Point
Dear Mr. Pham:
First I would like to thank you for speaking with me at the last NRC public hearing at the Colonial Terrace in Cortlandt Manor. I would like to take you at your words (which I paraphrase) that you have no predisposition towards the continuing operation of Indian Point, and that you are simply following the "letter of the law" by making all judgments based on existing regulations. That is encouraging, but truly insufficient. The relicensing regulations were largely written with consideration of the industry's lobbying arm, the NEI, and consequently are woefully lacking in a common sense approach of weighing the benefits derived from a relatively large nuclear generating plant (about 2000 MW and its tangential financial benefits) versus the potential downside risk of having an aging nuclear plant located in the most densely populated area of the United States. That is, any radiological contamination in this region could result in major health crises and the financial ramifications would dwarf the impact of the 9/11 attack on the World Trade Center. I would remind you that the NAS has stated unequivocally that there is no safe level of exposure to ionizing radiation, and Regional Director Sam Collins has publicly stated his agreement with that assessment.
One might ask what part of on-site or off-site radiation emissions would not warrant consideration as an environmental impact? Would the storage of high
level nuclear wastes above ground in casks stacked on an open concrete platform not pose a potential environmental impact? Would continuing leakage of radioactive elements into groundwater not represent an environmental impact?
Would a potential terrorist attack on the control room, reactor vessels or spent fuel storage not represent a potential environmental impact? The Ninth Circuit of the Federal Courts has ruled that a terrorist attack must be considered in environmental impact decisions. Would the inaccessibility of large amounts of the conduit system to visual inspection not represent potential environmental impact, especially in light of radioactive steam being released last winter from piping that was supposedly in the "non-nuclear" circulation system? Would the dye testing done by Entergy that showed linkage of leaks from the IP2 spent fuel pool into the leaking plume of IP1 not constitute a potential environmental impact? Would the ongoing, and undefined current leakage not portend a degradation of the larger system so that an assumption of viability for an additional twenty years would be simply unwarranted optimism?
As I have said to you in-person, my impression is that NRC policy making simply looks at the statistically low probability of a major release incident and assumes that the probability is virtually zero. Consequently, no real consideration is given to the impact of the low probability event happening. But one must understand that these probabilities are based on nuclear plant operations that have not reached the critical ages that are currently upon us. To truly live up to your agency's responsibility to protect public health and safety, your agency must consider the impact of radiological contamination if the unexpected actually does happen. I am always reminded of former Governor George Pataki standing on a podium after the massive 2003 blackout and saying "the experts told me this could not happen again." There is no fail-safe for nuclear plants, especially when both aging equipment failure and human error are distinct and realistic possibilities.
Please use common sense instead of the cover of "following regulations" in your considerations of the advisability of keeping Indian Point running until 2033 and 2035 for the two operating reactors. In terms of financial considerations, decommissioning is a very labor intensive and long term job. Improvement of transmission infrastructure lessens the need for a downstate nuclear plant.
Uranium based nuclear fuel is not a renewable or sustainable energy source, and long term strategies should include a variety of renewable resources such as solar, wind, geothermal, hydroelectric, distributed generation, etc., as well as efficiency and conservation programs. Allowing the production of high level nuclear wastes to go into vulnerable storage facilities that are already leaking seems illogical.
One of every 12 - 13 Americans lives within 50-miles of Indian Point. The financial capital of the United States is 35 miles from Indian Point. A large part of the New York City water supply is within the peak injury zone around Indian Point.
I respectfully and formally request that the issues I have cited become part of the considerations of the NRC Relicensing process for Indian Point.
Sincerely, Gary Shaw 9 Van Cortlandt Place Croton on Hudson, NY 10520
Federal Register Notice: 72FR45075 Comment Number: 16 Mail Envelope Properties (47304C7B.HQGWDO01.OWGWPO04.200.200000A.1.19BC7E.1)
Subject:
Re: EIS comment re: Indian Point (A CORRECTION)
Creation Date: 10/12/2007 8:59:15 PM From: gary shaw <crotonshaw@optonline.net>
Created By: crotonshaw@optonline.net Recipients
<IndianPointEIS@nrc.gov>
Post Office Route OWGWPO04.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 5294 10/12/2007 8:59:15 PM TEXT.htm 10082 11/6/2007 11:14:03 AM Mime.822 18017 11/6/2007 11:14:03 AM Options Priority: Standard Reply Requested: No Return Notification: None None Concealed
Subject:
No Security: Standard
Page 1 of 2
Dear Sir:
In re-reading this comment, I found a minor error. It is corrected below towards the end of the second paragraph.
Thank you for your consideration.
Gary Shaw
Original Message -----
From: gary shaw To: indianpointeis@nrc.gov Sent: Thursday, October 11, 2007 9:49 PM
Subject:
EIS comment re: Indian Point
Dear Mr. Pham:
First I would like to thank you for speaking with me at the last NRC public hearing at the Colonial Terrace in Cortlandt Manor. I would like to take you at your words (which I paraphrase) that you have no predisposition towards the continuing operation of Indian Point, and that you are simply following the letter of the law by making all judgments based on existing regulations. That is encouraging, but truly insufficient. The relicensing regulations were largely written with consideration of the industrys lobbying arm, the NEI, and consequently are woefully lacking in a common sense approach of weighing the benefits derived from a relatively large nuclear generating plant (about 2000 MW and its tangential financial benefits) versus the potential downside risk of having an aging nuclear plant located in the most densely populated area of the United States. That is, any radiological contamination in this region could result in major health crises and the financial ramifications would dwarf the impact of the 9/11 attack on the World Trade Center. I would remind you that the NAS has stated unequivocally that there is no safe level of exposure to ionizing radiation, and Regional Director Sam Collins has publicly stated his agreement with that assessment.
One might ask what part of on-site or off-site radiation emissions would not warrant consideration as an environmental impact? Would the storage of high level nuclear wastes above ground in casks stacked on an open concrete platform not pose a potential environmental impact? Would continuing leakage of radioactive elements into groundwater not represent an environmental impact? Would a potential terrorist attack on the control room, reactor vessels or spent fuel storage not represent a potential environmental impact? The Ninth Circuit of the Federal Courts has ruled that a terrorist attack must be considered in environmental impact decisions. Would the inaccessibility of large amounts of the conduit system to visual inspection not represent potential environmental impact, especially in light of radioactive steam being released last winter from piping that was supposedly in the non-nuclear circulation system? Would the dye testing done by Entergy that showed linkage of leaks from the IP2 spent fuel pool into the leaking plume of IP1 not constitute a potential environmental impact? Would the ongoing, and undefined current leakage not portend a degradation of the larger system so that an assumption of viability for an additional twenty years would be simply unwarranted optimism?
As I have said to you in-person, my impression is that NRC policy making simply looks at the statistically low probability of a major release incident and assumes that the probability is virtually zero. Consequently, no real consideration is given to the impact of the low probability event happening. But one must understand that these probabilities are based on nuclear plant operations that have not reached the critical ages that are currently upon us. To truly live up to your agencys responsibility to protect public health and safety, your agency must consider the impact of radiological contamination if the unexpected actually does happen. I am always reminded of former Governor George Pataki standing on a podium after the massive file://C:\EMailCapture\IndianPointLRScoping\16\attch1.htm 11/6/2007
Page 2 of 2 2003 blackout and saying the experts told me this could not happen again." There is no fail-safe for nuclear plants, especially when both aging equipment failure and human error are distinct and realistic possibilities.
Please use common sense instead of the cover of following regulations in your considerations of the advisability of keeping Indian Point running until 2033 and 2035 for the two operating reactors. In terms of financial considerations, decommissioning is a very labor intensive and long term job. Improvement of transmission infrastructure lessens the need for a downstate nuclear plant. Uranium based nuclear fuel is not a renewable or sustainable energy source, and long term strategies should include a variety of renewable resources such as solar, wind, geothermal, hydroelectric, distributed generation, etc., as well as efficiency and conservation programs. Allowing the production of high level nuclear wastes to go into vulnerable storage facilities that are already leaking seems illogical.
One of every 12 - 13 Americans lives within 50-miles of Indian Point. The financial capital of the United States is 35 miles from Indian Point. A large part of the New York City water supply is within the peak injury zone around Indian Point.
I respectfully and formally request that the issues I have cited become part of the considerations of the NRC Relicensing process for Indian Point.
Sincerely, Gary Shaw 9 Van Cortlandt Place Croton on Hudson, NY 10520 file://C:\EMailCapture\IndianPointLRScoping\16\attch1.htm 11/6/2007