ML11356A515
| ML11356A515 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/22/2011 |
| From: | Stewart G Riverkeeper |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 21642, 50-247-LR, ASLBP 07-858-03-LR-BD01, 50-286-LR | |
| Download: ML11356A515 (8) | |
Text
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Entergy Nuclear Operations, Inc.
)
Docket Nos.
(Indian Point Nuclear Generating
)
50-247-LR Units 2 and 3)
)
and 50-286-LR
___________________________________________ )
PREFILED WRITTEN TESTIMONY OF GILLIAN STEWART REGARDING CONTENTION RK-EC-3/CW-EC-1 (SPENT FUEL POOL LEAKS)
On behalf of Riverkeeper, Inc. (Riverkeeper), Gillian Stewart submits the following testimony regarding Consolidated Contention RK-EC-3/CW-EC-1:
Q.
Please state your name and address.
1 A.
My name is Gillian Stewart and my business address is School of Earth and 2
Environmental Sciences, Queens College, CUNY, 65-30 Kissena Blvd., Flushing, NY 11367 3
4 Q.
What is your educational and professional background?
5 A.
My undergraduate degree is in Biology Magna Cum Laude from Harvard University in 6
1997. My doctoral degree is from the School of Marine and Atmospheric Sciences (formerly 7
Marine Sciences Research Center) at Stony Brook University in Coastal Oceanography (2005).
8 The title of my thesis was The Accumulation and Trophic Transfer of Polonium-210:
9 Biogeochemical Implications. My thesis advisors were Dr. Nicholas Fisher, a marine radio-10 ecologist, and Dr. Kirk Cochran, a marine radio-geochemist. I performed much of my doctoral 11 research at the IAEA Marine Laboratory in Monaco under the supervision of Dr. Scott Fowler, 12 an aquatic radio-chemist and radio-ecologist.
13 14 15 16 RIV000061 Submitted: December 22, 2011
Docket Nos. 50-247-LR & 50-286-LR Pre-filed Testimony of Dr. Gillian Stewart In support of RK-EC-3/CW-EC-1 2
Q.
Can you please discuss your experience as it relates to fate, transport, and 1
accumulation of radionuclides in aquatic systems.
2 A.
Although my thesis work and subsequent research has primarily focused on natural 3
(primordial, U-series) radionuclides, I have taken numerous courses in radiochemistry, radio-4 ecology, and marine pollution. I specifically study the grandmother/grand-daughter isotope pair 5
of lead-210 and polonium-210. These isotopes each exhibit unique behavior in aquatic systems 6
and act as model particle-reactive radiogenic isotopes. I have written over 18 papers on radio-7 isotope fractionation between the dissolved and particulate pool in aquatic systems, and have 8
authored a book title called Bioaccumulation of U/Th isotopes in marine organisms. In addition 9
to my work on isotopes, I have studied trace metal accumulation in multiple freshwater, 10 estuarine, and marine systems including metal uptake by invertebrates of the Hudson River from 11 resuspended sediments after simulated dredging.
12 13 I am a tenured professor of Environmental Science at Queens College and have taught graduate 14 courses in Environmental Biogeochemistry, Marine Ecology, and Isotope Chemistry in Long 15 Island Sound, along with multiple undergraduate courses in Earth and Environmental Science, 16 Water Resources, and Oceanography.
17 18 Q.
What is the purpose of your testimony?
19 A.
The purpose of my testimony is to provide support for, and my views on, Riverkeeper 20 and Clearwaters Consolidated Contention RK-EC-3/CW-EC-1. This contention was admitted 21 by the Atomic Safety & Licensing Board (ASLB) on July 31, 2008. Intervenors assert that 22 Entergy Nuclear Operations, Inc. (Entergy) and the U.S. Nuclear Regulatory Commission 23 (NRC) have failed to adequately address the environmental impacts of accidental radiological 24 leaks at Indian Point, including a failure to sufficiently consider how such radionuclides impact 25 the aquatic ecology of the Hudson River, and a failure to consider impacts related to a reasonably 26 foreseeable drinking water pathway in light of a proposed desalination facility to be located in 27 the direct vicinity of Indian Point.
28 29 30 31
Docket Nos. 50-247-LR & 50-286-LR Pre-filed Testimony of Dr. Gillian Stewart In support of RK-EC-3/CW-EC-1 3
Q.
What materials have your reviewed in preparation for your expert report and 1
testimony?
2 A.
I reviewed Riverkeeper and Clearwater Consolidated Contention, NRC Staffs FSEIS, 3
documentation related to United Water New Yorks proposed desalination project, several 4
documents identified as relevant to the contention by Entergy.
5 6
Q.
What conclusions have you reached about the impact of accidental radiological 7
leaks at Indian Point on the Hudson River?
8 A.
If there is present, past, or future leakage of radio-activity in the form of Sr-90, H-3, Cs-9 137 or other isotopes from Indian Point into the waterway of the Hudson River, even low 10 activities of these materials will form a potential threat to the health of the local ecosystem via 11 dissolved and particulate exposure. Current research indicates that there is a linear, no threshold 12 response curve between human exposure to radioactivity and solid cancers. Further, there is 13 evidence that multi-celled organisms exposed to low doses of radiation can develop mutations 14 which are transmissible to offspring, indicating that leaks which happened in the past may still 15 affect organisms that rely on the Hudson River for food or water today or in the future. The fact 16 that Sr-90 has been found in fish tissue from the Hudson River and more than half of river water 17 samples, indicates that strontium represents a potentially harmful contaminant, as it is a known 18 carcinogen which accumulates in skeletal material and can cause bone and blood cancers. The 19 dissolved phase of Sr-90 can travel long distances on the tidal river (both north and south of the 20 source) and will most likely not be removed by traditional decontamination methods such as 21 filtration, coagulation, and clarification. Cs-137 would be expected to behave similarly, but does 22 not accumulate in organisms, making it more likely to travel long distances in the dissolved 23 phase and be difficult to remove from the water column. Both Sr-90 and Cs-137 have half-lives 24 of approximately 30 years and so can be expected to remain in the system for over 150 years or 5 25 half-lives. A careful study of the temporal and spatial distribution of these isotopes should be 26 conducted before water from the Hudson River is considered safe for human consumption.
27 28 Q.
Please describe your understanding of radiological leaks and groundwater 29 contamination at Indian Point.
30 A. Based on my review of exhibits 33, 39, and 40 as well as the DEIS of the UWNY, it is my 31 understanding that at certain times groundwater from Indian Point is or has been highly 32
Docket Nos. 50-247-LR & 50-286-LR Pre-filed Testimony of Dr. Gillian Stewart In support of RK-EC-3/CW-EC-1 4
contaminated with radioactive isotopes from previous and possible ongoing leaks from fuel pools 1
and other sources, at levels exceeding state and federal drinking water standards. For the 2
radiological samples (Table 2.4 in Chapter 2 of DEIS), the samples were collected at various 3
locations throughout the Hudson River and not specifically at the outflow of the groundwater or 4
near Indian Point. Despite this fact, many samples were positive for radioactivity. Even though 5
average gross alpha and gross beta are below MCLs, some of the samples were higher than the 6
MCL. Specifically, the maximum alpha acticity was 20pCi/L when the MCL is 15 pCi/L and the 7
maximum beta activity detected was 62 pCi/L when the MCL was 50 pCi/L. This fact can also 8
explain why the averages are relatively high (3.5 and 10.8 pCi/L respectively), even though 9
samples below detection were averaged as zero in the calculation. These high ranges of 10 radioactivity detected are likely due to leaks or flows via groundwater effluent into the Hudson 11 River.
12 13 Further, although the levels are low, Sr-90 was detected in more than half of the Hudson River 14 water samples. Therefore, more sampling needs to be done (both a time-series to verify temporal 15 variability and a transect to the North, South, and West to verify spatial variability) in the area 16 directly adjacent to Indian Point and to the intake location of the Proposed Project in Haverstraw 17 Bay. As far as Uranium, the indication is that it was found in all samples at low levels.
18 19 It appears undisputed that contamination in the groundwater migrates to the Hudson River; 20 Entergy has chosen to employ Monitored Natural Attenuation. This is not a satisfactory approach 21 because the long half-lives of the radionuclides involved (approximately 30 years for the 22 isotopes of Sr and Cs) mean this contamination released into the Hudson River through the 23 groundwater will pose a threat to the water quality of the river throughout the entire period of 24 extended operations of the proposed project in Haverstraw Bay, and requires more study before 25 it can be allowed to decay without treatment. Generally, radio-chemists use a very optimistic 26 benchmark of 5 half-lives to determine the residence time of isotopes in a system. With this in 27 mind, the Cs-137 and Sr-90 will be in the vicinity of Indian Point (and tidal waters north and 28 south) for at least 150 years. Further, new or continuous leaks would add new radio-isotopes to 29 the water column and thus would not contribute to natural attenuation.
30 31
Docket Nos. 50-247-LR & 50-286-LR Pre-filed Testimony of Dr. Gillian Stewart In support of RK-EC-3/CW-EC-1 5
Q.
What is understood about the pathways for fate and transport of this 1
contamination?
2 A. The fate of radio-isotopes depends on the phase it is in: dissolved or particulate. Both Cs and 3
Sr are slightly particle reactive, generally on the order of 1000 times more concentrated on 4
particles than in the dissolved phase (IAEA TRS 190, 1976: Effects of ionizing radiation on 5
aquatic organisms and ecosystems). However, using the partition coefficients, Kds, this still 6
results in the majority of the isotope to be found in the dissolved phase. In most cases, the 7
particulate phase is more dense than water and settles to the bottom of the water column or gets 8
ingested by organisms. The dissolved phase, on the other hand, can travel for long distances just 9
as the water in the river is constantly being flushed by the flood and ebb of the tide. The 10 residence time of the radio-isotopes in various locations of the River would be determined by the 11 flushing time of the water in that region and not by the radiological decay of the isotopes.
12 13 Another relevant influence on radioisotope distributions in river-estuarine systems 14 is suspended-sediment concentration. The activity of isotopes would tend to be lower in 15 the presence of high suspended-sediment concentrations (Benoit and Rozan,1999). The 16 Hudson River is a highly turbid environment and thus there would be many opportunities 17 for the isotopes to sorb to particle surfaces and be removed from the dissolved phase.
18 However, in the Hudson there has been extensive dredging, most recently associated with 19 PCB clean-up. This has the potential to resuspend isotopes sorbed to sediments and re-20 introduce them into the water column and ecosystem.
21 22 Once Sr-90 gets into organisms, it replaces calcium in bone due to their similar chemical nature.
23 This prevents the effective removal of the isotope from the body and strontium can accumulate 24 over time with low level chronic exposure. Cesium, on the other hand, forms a chloride 25 compound in the body and is water-soluble, thus is effectively flushed from organisms through 26 urine or sweat. Thus, while Cs-137 will not accumulate through food chains via trophic transfer, 27 there is a high potential that Sr-90 will. Humans could thus be exposed to Sr-90 at low levels by 28 drinking river water contaminated with the isotope, or by the consumption of fish which have 29 accumulated Sr-90 throughout their lifetimes.
30 31
Docket Nos. 50-247-LR & 50-286-LR Pre-filed Testimony of Dr. Gillian Stewart In support of RK-EC-3/CW-EC-1 6
1 Q.
The Hudson River is a tidal estuary as far north as the Federal Dam in Troy and 2
south into New York Harbor. How far will the radioactive isotopes leaking from Indian 3
Point travel?
4 A.
Because Sr-90 and Cs-137 are primarily found in the dissolved phase, they will travel 5
with the river water as far as the local water travels. According to the hydrological surveys, the 6
groundwater enters the river at depth. This will affect the distance the water travels since the 7
salty water travels more slowly up the bottom of the river than the freshwater travels seaward 8
along the river surface. Either way, there is nothing stopping the isotopes from travelling with a 9
parcel of river water.
10 11 However, while they travel, the parcel of water is being diluted by other river water and so the 12 concentration will decrease over time due to dilution. The rate of dilution will be faster than the 13 rate of radioactive decay, so this will limit the activity of the isotopes as they travel, but not the 14 distance they can travel. The only thing that would limit the distance traveled is adsorption onto 15 particles or uptake into organisms.
16 17 Q.
The NRC Staff stated in its FSEIS concerning the proposed license renewal of 18 Indian Point that there is no drinking water exposure pathway to humans that is affected 19 by the contaminated groundwater conditions at the IP2 and IP3 site.1 How would you 20 respond to this statement?
21 A.
While that may currently be the case, it is my understanding that there is a proposed 22 project for a desalinization plant to be sited 5 miles downstream of Indian Point by United Water 23 New York, called Haverstraw Long-Term Water Supply Project. While the initial pilot project is 24 removing 144,000 gallons per day (at a rate of 100 gallons per minute to deliver approximately 25 100,000 gpd of potable water), the final completed plant would withdraw 10 million gallons of 26 water per day from the Hudson, which would yield 7.5 mgd of drinking water for Rockland 27 County residents.2 As I understand, this project is currently in permitting phase; it is reasonably 28 foreseeable that it will come to fruition. This will result in water from the Hudson River right 29 1 Indian Point FSEIS at 2-111.
2 Haverstraw Water Supply Project DEIS, Draft EIS, http://www.dec.ny.gov/docs/permits_ej_operations_pdf/uwnyfnlscope.pdf (Exhibit RIV000101); Pilot Study:
http://haverstrawwatersupplyproject.com/project-facts/pilot-study.html
Docket Nos. 50-247-LR & 50-286-LR Pre-filed Testimony of Dr. Gillian Stewart In support of RK-EC-3/CW-EC-1 7
near Indian Point being used for a drinking water source at some point during the proposed 1
extended operating terms.
2 3
Q.
Please summarize your opinions about the impact of accidental radiological leaks at 4
Indian Point on the Hudson River.
5 A.
In summary, I believe that Sr-90 and Cs-137 that are leaking into the Hudson River via 6
groundwater from the Indian Point Nuclear Facility pose a clear and imminent threat to both the 7
ecosystem of the Hudson River as well as potential contaminants for the desalinization plant 8
proposed by UWNY in Haverstraw Bay. Because of the long half-lives of these isotopes and 9
their ability to travel long distances in the dissolved phase, they will easily be able to travel the 10 five miles to the intake point for the drinking water project. Low levels of exposure to these 11 radionuclides via drinking water or contaminated seafood have the potential to cause cancer in 12 humans. More sampling needs to be done to determine the extent of radiological contamination 13 in both time and space. The Sr-90, H-3, and Cs-137 leaks will need to be stopped and some 14 decontamination efforts will need to be taken before the water in the Hudson near Indian Point is 15 consistently safe for human consumption.
16 17 Q.
Does this conclude your initial testimony regarding Consolidated Contention RK-18 EC-3/CW-EC-1?
19 A.
Yes.
20
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Entergy Nuclear Operations, Inc.
)
Docket Nos.
(Indian Point Nuclear Generating
)
50-247-LR Units 2 and 3)
)
and 50-286-LR
___________________________________________ )
DECLARATION OF GILLIAN STEWART I, Gillian Stewart, do hereby declare under penalty of perjury that my statements in the foregoing testimony and my statement of professional qualifications are true and correct to the best of my knowledge and belief.
Executed in Accord with 10 C.F.R. § 2.304(d)
Gillian Stewart School Of Earth and Environmental Sciences Queens College, CUNY 65-30 Kissena Blvd.
Flushing, NY 11367 December 22, 2011