ML20062G083
| ML20062G083 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/21/2020 |
| From: | - No Known Affiliation |
| To: | |
| SECY/RAS | |
| References | |
| 85FR03947, NRC-2020-0021 | |
| Download: ML20062G083 (9) | |
Text
Page 1 of 2 As of: 2/27/20 11:13 AM Received: February 21, 2020 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 1k4-9f5a-iq8m Comments Due: February 24, 2020 Submission Type: Web Docket: NRC-2020-0021 Indian Point Nuclear Generating Unit Nos. 1, 2, and 3; Transfer of Control of Licenses and Approval of Conforming License Amendments Comment On: NRC-2020-0021-0001 Indian Point Nuclear Generating Unit Nos. 1, 2, and 3; Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments Document: NRC-2020-0021-DRAFT-0040 Comment on FR Doc # 2020-00824 Submitter Information Name: Corinne Kelly Address:
6 Mancuso Drive Ossining, NY, 10562-2527 Email: corinneakelly@yahoo.com General Comment I live in Ossining NY within the 10-mile Emergency Evacuation Zone for Indian Point along with an estimated 300,000 other residents. About 17 plus million or more people live within a 50-mile radius of Indian Point (see attached evacuation map). I have lived here for more than 33 years and have experienced alarm each time the Indian Point sirens have sounded. You must believe that there would be no way to evacuate some 300,000 men, women and children from this area as witnessed by the traffic on local roads at rush hour. I was extremely relieved to hear that Indian Point would be shutting down. Then I attended "The 2019 Regional Nuclear Decommissioning Forum" (Oct 10, 2019-Montrose NY). There were speakers from around the country discussing the problems they had recently experienced or were currently experiencing during the decommissioning process. Subsequently I became exposed to research that others had done on the Indian Point site and learned that: 1) two high pressure gas transmission pipelines run under and adjacent to Indian Point (see attached pipeline map) 2) Indian Point 2 and Indian Point 3 reactors, due for decommissioning, contain 58.2% (IP2) and 57% (IP3) of high burn-up nuclear fuel according to DOE GC 859 data June 2013. "High burn-up nuclear fuel contains a higher percentage of Uranium 235 and high burn-up nuclear fuel temperatures make used fuel more vulnerable to damage from handling and transport." (from the article: Spent Nuclear Fuel at the Indian Point Nuclear Power Station by Robert Alvarez, Institute for Policy Studies, Oct 10, 2019) 3) there are contaminated water leaks from Indian Point's spent fuel pool that have migrated into the Hudson River which several river towns rely on for their drinking water (see attached article https://www.fdms.gov/fdms/getcontent?objectId=090000648439b5c9&format=xml&showorig=false 02/27/2020
Page 2 of 2 published in the Huffington Post 2/15/16 and 12/6/17). 4) decommissioning increases the risk of accidents since activity is significantly increased, raising accident potential above normal plant operations. (Section 4.3.9.2 of NUREG-0586 Supplement 1). It of grave concern to me that Entergy has proposed to transfer its operating and general licenses to Holtec Decommissioning International LLC (HDI), a subsidiary of Holtec International. Holtec's Comprehensive Decommissioning International, LLC (CDI) is a joint venture with SNC-Lavalin (SNC-L). HDI has identified CDI as the contractor of the Indian Point decommissioning. Both Holtec and its partner, SNC-Lavalin have been involved in cases of corruption, fraud and dishonesty and have received bribery convictions and debarments. Additionally HDI and CDI are limited liability corporations (LLC's). They can walk away from decommissioning without any financial responsibility to finish the job or to do the job properly. Holtec also manufactures its own storage canisters which are thin-walled and vulnerable to cracking. Holtec has also been reported as employing staff that are not skilled and experienced specialists to do the decommissioning work. Based on these concerns with Holtec, it is my hope that the NRC will not approve the Entergy licenses to transfer to Holtec, its partners and subsidiaries at the Indian Point site. However if the transfer is approved, I urgently request that the NRC make certain demands of Holtec, its partners and subsidiaries who will do the decommissioning at Indian Point and hold them accountable to : 1) retain and employ specialized, skilled and experienced workers for the entire decommissioning process at Indian Point 2) fund the costs for the complete decommissioning process at Indian Point, including funds for unexpected problems that may arise as well as cost overruns 3) use thick nuclear waste casks (at least 10 to 20 inches thick) due to the high burn-up fuel that needs to be stored at Indian Point as it is problematic that the DOE will be able to accept the nuclear fuel any time in the foreseeable future and it may have to remain on site indefinitely 4) provide for and train local first responders for any emergency that may arise during decommissioning 5) request that Algonquin's two high-pressure gas transmission pipelines that run under and are adjacent to Indian Point be turned off or diverted during decommissioning 6) conduct their business in an ethical, honest and transparent manner or be fined and barred from further decommissioning activities at Indian Point 7) accept the oversight of technical and scientific experts chosen by the surrounding communities to insure that the decommissioning of Indian Point is being carried out properly and safely. Whatever company is chosen to do the decommissioning must meet the highest standards. The health and safety of hundreds of thousands and potentially millions of lives depend on the outcome of Indian Point's safe decommissioning.
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Energy Matters Indian Point Contaminates the Hudson River With Uncontrollable Radioactive Flow Posted: 12 Feb 2016 07:51 PM PST By Roger Witherspoon For more than a decade, it has been impossible for operators of the Indian Point nuclear power plant to stop highly radioactive reactor and spent fuel pool coolant from leaking into the groundwater and migrating to the Hudson River.
And despite assurances from Entergy that this time will be different, there is no indication that the company has developed the ability to prevent the latest uncontrolled leaks from following the underground waterway into the Hudson. And because the river is a tidal estuary flowing as much as 20 miles above and below the nuclear site, radioactive contaminants may be sucked into the drinking water systems of several river towns.
While Entergy focuses attention on tritium, a radioactive form of water and the predominant contaminant leaking from the plants cooling system, the actual leak contains a basket of radioactive elements, including Strontium-90, Cesium-137, Cobalt-60, and Nickel-63 according to an assessment by the New York Department of State as part of its Coastal Zone Management Assessment. ( http://bit.ly/1Kf8iOY )
The Coastal Zone Assessment, released November, 2015, expressed concern about the periodic leaks into the Hudson River because it serves as a direct water source for Poughkeepsie, Wappingers Falls, Highland, Port Ewen, East Fishkill, Hyde Park, and the Village of Rhinebeck. It is also a backup water source for some 9 million residents of New
York City and Westchester County.
Tritium, explained David Lochbaum, nuclear safety expert at the Union of Concerned Scientists, is just the first item reported. It tends to be the leading edge of any spill since it is the lightest and most mobile of the radioactive contaminants. The other isotopes slow down as they go through the soil. That other stuff is on its way, however. Tritium just wins the race.
Indeed, ongoing monitoring by the NY State Department of Health (
http://on.ny.gov/1WhlQu7 ) has found detectable deposits of a broad variety of radioactive isotopes above and below the Indian Point discharge site into the fast-moving Hudson River tidal estuary that the Native Americans referred to as the river that runs both ways.
Indian Point schematics provided by the NRC show the site of the leak or leaks is roughly 69 feet above the Hudson River at the beginning of a groundwater flow that widens to about 80 feet as it rushes downward, pools above the bedrock and then flows inexorably into the Hudson River. ( http://bit.ly/1QaQ7WT ) Once the contaminants enter that groundwater flow there is no system at Indian Point to remove them. Entergy representatives declined to comment on planned and unplanned radioactive discharges into the environment.
The sequence of events leading to leaks of radioactive liquids from Indian Point 2 is the subject of an intense investigation by federal and state officials. The Nuclear Regulatory Commission dispatched a radiation specialist to Indian Point Thursday to work with the three, on-site, resident inspectors to determine how the leak occurred and whether or not it can be stopped. There are more than three miles of inaccessible piping under the 239-acre
site, and the inability of Entergy to properly assess possible corrosion within the pipes has been a key part of the ongoing challenge to the plants licenses by Attorney General Eric Schneiderman. And Gov. Andrew Cuomo has ordered the state Departments of Health, Environmental Conservation, and Public Service to coordinate investigations into maintenance issues at Indian Point.
In the past, the Coastal Zone Management report states, radioactive releases have been detected at the Indian Point facility from cracks in two different spent fuel pools. Leaks of radioactive liquids from the Indian Point 2 spent fuel pools have reached the Hudson River and have been detected in the groundwater beneath the Indian Point facility.
Entergy has sought to assure the public that there is no possible danger from the leaking liquids. In their initial announcement that high levels of tritium had been found in three monitoring wells near Indian Point 2, the company insisted that there was nothing to worry about.
While elevated tritium in the ground onsite is not in accordance with our standards, there is no health or safety consequence to the public, and releases are more than a thousand times below federal permissible limits, the company statement said. The tritium did not affect any source of drinking water onsite or offsite.
That blanket assertion of safety may not be true.
The leaks were first detected Friday in three monitoring wells (30, 31, and 32) between the spent fuel building, the reactor containment building, and the Reserve Water Storage Tank (RWST), a 350,000-gallon stainless steel structure that plays a critical role in the reactors operation. (http://bit.ly/1KJFA90 ).
The operating reactor core contains water with boron, which serves to moderate the fission reactions and help make them more controllable. Some of the water in that fission environment becomes radioactive tritium. In order to monitor fluctuations within the highly pressurized reactor, there is a steady stream of this coolant which is siphoned off for both analysis - to determine if there is an appropriate amount of boron in the mix - and to detect particles, which indicates cracks in some of the fuel rods.
The movement of the fluid is not always a closed loop, explained Lochbaum. There are occasional balance issues. When the reactor changes power levels the water heats up and expands or cools and contracts. The system is used to supply water or take water out.
Lochbaum said there is a wide array of pipes leading to the storage tank, and both tanks
and pipes have leaked in the past, which is why they have monitoring wells.
The tank is also used to supply coolant during refueling outages. The water in the tank fills the well holding the reactor, so the top can be removed under several feet of coolant and workers can safely access the fuel rods.
Initial reports from Entergy to the NRC and to Gov. Cuomos office were that the tritium readings were as high as 8 million picocuries per liter - far above the 20,000 picocuries per liter limit that the federal Environmental Protection Agency has set for drinking water.
A picocurie is a molecular level measurement that is just one trillionth of a Curie. But radiation and other contaminants in the environment are frequently measured in scales of one part per billion, because at that level there can be significant damage to a persons cell structure or DNA. The NRC and Entergy consider the periodic spills to be safe because the Hudson River is not considered drinking water and, therefore, EPA safe limits do not apply.
The fact that several river towns do use the Hudson as a primary water source is discounted because the radioactive flow is diluted by the rest of the water in the River.
But that ignores the fact that radioactive particles do not dissolve or lose their potency even if they are harder to encounter. The State Coastal Management review, to some degree, shares that view.
The possibility that people will come into contact with the radioactive material, even in small quantities, prompted Paul Gallay, director of the environmental group Riverkeeper, to call for closing the plants pending an investigation of the latest accident.
The NRC says there is no safe level of tritium contamination, said Gallay. When tritium is released in concentrations as high as 400 times the standard for drinking water, it is not out of the realm of possibility that people recreating in the Hudson River will come into contact with that material, or consume fish that ingested some of this material. There is certainly a risk to the environment.
Entergy has a State Pollutant Discharge Elimination System (SPDES) permit which entitles Indian Point to regularly pour radioactive contaminants into the groundwater, the Hudson River, and the air. In 2013 Indian Point released 1,300 Curies of radioactive material into the Hudson and the Buchanan air. That is trillions of times more radioactive material, released legally, than is being released accidentally now. DEC officials would not immediately release discharge figures for 2014 and 2015, or discuss possible impacts on the municipal water systems utilizing the Hudson River.
Susan Shapiro of the Indian Point Safe Energy Coalition, a civic group seeking to close the
plants, said the NRC should penalize Entergy for exceeding its operating license and state discharge permit with the accidental releases of additional radioactive material into the groundwater.
If you have a mom and pop gas station and they have an underground leak, Shapiro said, they would be immediately shut down until the leak is plugged. In New York State, all groundwater has to be potable and contamination is not permitted.
But Entergy is getting away with contaminating our groundwater just because they are under the auspices of a government agency that doesnt feel as strongly about our water.
For me, that is shocking.