ML100500771

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Supplement to Vermont Yankee 2.206 Petition from Michael Mulligan - Tritium Leak (G20100027)
ML100500771
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 02/18/2010
From: Mulligan M
- No Known Affiliation
To: James Kim
Office of Nuclear Reactor Regulation
Kim J, NRR/DORL, 415-4125
References
2.206, G20100027
Download: ML100500771 (5)


Text

From:

Michael Mulligan [steamshovel2002@yahoo.com]

Sent:

Thursday, February 18, 2010 2:15 PM To:

Kim, James

Subject:

Re: Request to yet again submit this same petition for 2.206 reconsideration.

Mr Kim, I wish I could figure out how to get this the copy off the internet site to give you...so all i got is a link.

http://vtdigger.org/files/2010/02/VY-employee-allegation.pdf Would you including this as possible evidence for the petition and the rehearing.

Based on the above, could we make the my new address to the petition board as soon as possible.

Thanks, Mike Mulligan Hinsdale, NH From: "Kim, James" <James.Kim@nrc.gov>

To: Michael Mulligan <steamshovel2002@yahoo.com>

Sent: Thu, February 18, 2010 10:12:48 AM

Subject:

RE: Request to yet again submit this same petition for 2.206 reconsideration.

Mr. Mulligan, We would like to consider this as a supplement to your original petition dated January 12, 2010.

As indicated in my previous e-mail, the PRB met on Thursday, February 4, 2010, and made an initial recommendation to reject your petition for review under 2.206. In accordance with MD 8.11, we are offering you another opportunity to address the PRB to provide any relevant additional information to support your petition. Please let me know if you wish to address the PRB, and when would be good for you.

James Kim Vermont Yankee Project Manager, DORL U.S. Nuclear Regulatory Commission

From: Michael Mulligan [1]

Sent: Friday, February 12, 2010 4:08 PM To: Kim, James

Subject:

Request to yet again submit this same petition for 2.206 reconsideration.

Mr Kim, I actually think the NRC petition review board is actively misconstruing the events surrounding the tritium accident at Vermont Yankee...towards the interest of the nuclear industry. The Vermont Yankee tritium event is fundamentally different than any other tritium event at a nuclear power plant in the USA, and the NRC knows it. It is one of the highest radiation contamination rates anywhere in the country.

By Energy executives providing knowingly falsifying and incorrect testimony to the state of Vermont about the placement of radioactive pipes on the grounds of Vermont Yankee within the proceeding year

...it turned the tritium leak into a cold blooded intentional and unlicensed radioactive discharge onto the environs surrounding VY. If VY executives would have given the correct and accurate testimony to Vermont...there are over 40 radioactive processing pipes out on the grounds...those pipes would have been tested and found to be defective. It is reasonable to expect the pipe defects would have been corrected and the licensing of the plant would have been assured. The piping defects would have been identified and corrected, and there would be no illegal or secret uncontrolled discharge into the environment.

Again, this is unlike any nuclear power plant tritium discharge anywhere in the USA. The falsification of testimony and potential state indictment of a senior Entergy executive over the radioactive piping issue......the implication that 12 senior engineers and other executives facilitated this false testimony...the public apology of the executive and his removal from his position...the knowingly intentional negligence of not giving accurate testimony under oath translates into knowingly and cold bloodily discharging significant amount of radioactivity secretly; without NRC permits and approvals.

It was not inadvertent.

This was a startling gross negligent, uncontrolled and reckless discharge of radioactivity into the environs around the nuclear power plant. The perjured and false testimony facilitated the illegal discharge and has severely damaged the relicensing of this plant.

The false and perjured testimony was facilitated by many professional people...this turns VY sharply away from a inadvertent radioactive leak act, a not predictable act like the rest of the other plants (Oyster Creek is pretty close to the same situation as VY0. This turns Vermont Yankee tritium leak into a purposeful and secret cold blooded

discharge of radioactivity into the environs. The implications are by giving false testimony, that energy would gain many 100s of millions of dollars by gaining the re-licensing of the plant. The idea if discovered after relicensing the tritium leak consequence would be insignificant. If the true testimony was told pre relicensing, Entergy would incur the 10s of million of dollars of cost to the repair and replacement of the pipes. It would threaten the future existence of the plant. There is always the consideration if Entergy knew the true conditions of the pipes within the last year...the power purchase bid would have been higher to the state of Vermont...thereby Entergy would have closed the plant on their own as not profitable or practical in this environment. The employees of Vermont Yankee might have calculated if the true conditions of the radioactive pipes out in the VY grounds were known, this would have doomed the relicensing of the plant as being to expensive to fix. There is big incentives to give false testimony...big bucks...to lie here.

The risk to the community isnt about the health consequences with ingesting tritium to any one off site. It is about the high risk potential of health consequences to the surrounding community if the employees and executives of Vermont Yankee and Entergy cant be trusted to tell the truth to the community...to the federal, state agencies and other governmental bodies. Dare I admit the VY employees might not tell the truth to Entergy itself.

There is the question itself, if the state of Vermont had a different/higher quality and safety standard than the NRC did? Did the NRC cover-up the idea that the NRC has lower radioactivity discharge standards than the state...hide the piping problems from the state's knowledge.

Thanks, Mike Mulligan Hinsdale, NH From: "Kim, James" <James.Kim@nrc.gov>

To: Michael Mulligan <steamshovel2002@yahoo.com>

Sent: Fri, February 12, 2010 1:27:15 PM

Subject:

Initial Recommendation of your Vermont Yankee Petition Mr. Mulligan, The PRB met on Thursday, February 4, 2010, to discuss the petition to make an initial recommendation and the PRB made an initial recommendation to reject the petition for review under 2.206.

In accordance with MD 8.11, the PRB has decided to reject the petition. The basis for rejecting the petition is shown below:

This petition is rejected because the issue has already been the subject of NRC staff review, and resolution has been achieved. This issue has been extensively reviewed by NRC staff and the results of review are documented in the Lessons Learned Task Force (LLTF) Report (ML062650312).

Previously, Mr. David Lockbaum on behalf of the Union of Concerned Scientists submitted a 2.206 petition (G20060099) concerning the nuclear reactors releasing water potentially contaminated with radioactive materials. The Director's Decision (ML062370205) stated that even though there have been a number of events where significant quantities of radioactive liquids were released to the ground in an unmonitored, unplanned manner, none of the events resulted in public radiation dose limits being exceeded because of the negligible health effects of the isotopes at the quantities and concentrations released. Nonetheless the NRC chartered a Lessons Learned Task Force (LLTF) on March 10, 2006, and published a report containing 26 recommendations. And NEI initiated an industry initiative to improve management of inadvertent liquid radiological releases that includes the participation by licensees for all commercial nuclear power reactors.

Vermont Yankee implemented the nuclear industry's Ground Water Protection Voluntary Initiative that resulted in a discovery of small amount of Tritium in one of the monitoring wells on January 6, 2010. The nuclear industry's ground water initiative covers site hydrology and geology, identification of possible leaking plat structures and methods to monitor their condition, procedures for on-site groundwater monitoring and remediation decision processes, and communication requirements to notify the NRC, State, and local officials of any on-site leaks.

Thanks Jim Kim PRB Manager