ML24150A400

Comment (263) E-mail Regarding Monticello SLR Draft EIS

ML24150A400
Person / Time
Site:	Monticello
Issue date:	05/24/2024
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
89FR31225
Download: ML24150A400 (7)

Text

From:

JOHN LaFORGE <johnmichaellaforge@gmail.com>

Sent:

Friday, May 24, 2024 8:19 PM To:

MonticelloEnvironmental Resource

Subject:

[External_Sender] Public Comments -- NRC-2023-0031, Docket ID NRC-2023-0031 MonticelloEnvironmental@nrc.gov C/O Office of Nuclear Material Safety and Safeguards Docket No. 50-263 NRC-2023-0031 Docket ID NRC-2023-0031 Document Number: 2024 08746 Re. Draft Site-Specific Environmental Impact Statement for License Renewal, Supplement 26, Second Renewal, Regarding Subsequent License Renewal (SLRA) for Monticello Nuclear Generating Plant To the NRC Office of Nuclear Material Safety and Safeguards:

I urge you to deny the application by Northern States Power Minnesota, operating as Xcel Energy (NSPM/Xcel or applicant), for a second license renewal for the Monticello reactor.

I urge you to extend the public comment period on your Draft Site-Specific Environmental Impact Statement for License Renewal by at least 60 days.

The Monticello reactor endangers our communities and our drinking water. It threatens accidental radiation releases, like the recent 829,000-gallon leak of radioactive tritium-contaminated wastewater which, according to your Draft EIS, likely reached the Mississippi River. (NRC Draft EIS, p. 3-47, line 11:

Tritium detections in wells near the Mississippi riverbank [i.e., MW-29A, MW-33A, MW-37A, and MW-48A] in 2023 indicate tritium-impacted groundwater likely discharged to the river.) Yet your Draft EIS only obliquely notes that the Mississippi River is the source of drink water for Minneapolis, St. Paul and their surrounding suburbs.

The Nuclear Regulatory Commissions (NRCs) Draft EIS, under "Local and Regional Hydrology at page 3-28, line 4, says, The Minneapolis Water Works Reservoir also is supplied from the Mississippi River with its intake located approximately 37 mi (59.5 km) downstream of Monticello (Xcel 2023-TN9084).

This notice, while hardly given any weight in the Draft EIS, is the principle matter of fact regarding Monticellos radioactive contamination of ground water which feeds and interchanges with the Mississippi River. As the Draft EIS notes under 2022 Tritium Release to Groundwater on page 3-46, line 1: Under normal site hydraulic conditions, groundwater flow is toward the Mississippi river.

On March 18, 2023, soon after NSPM/Xcel publicly acknowledged the massive leak, the Associated Press (AP) interviewed NRC spokesperson Victoria Mitlyng, and reported: Mitlyng said there is no pathway for the tritium to get into drinking water. (Associated Press, Regulators: Nuclear plant leak didn't require public notice, March 18, 2023, https://apnews.com/article/xcel-energy-nuclear-leak-tritium-6e522afbb12ad26925c40d833853088d) This alarming error is contradicted by NSPM/Xcels own 2022 Annual Radioactive Effluent Release Report, May 10, 2023, which states that, There are several mechanisms that can result in doses to Members of the Public, including: Ingestion of radionuclides in food or water. (Xcel Energy, 2022 Annual Radioactive Effluent Release Report, May 10, 2023, p. 5, https://www.nrc.gov/docs/ML2313/ML23130A190.pdf. There are several mechanisms that can result in dose to Members of the Public, including: Ingestion of radionuclides in food or water; Inhalation of radionuclides in air; Immersion in a plume of noble gases; and Direct Radiation from the ground, the plant or from an elevated plume (See Figure 5 [Exposure Pathways to Man)

Public misinformation by the NRCs Mitlyng is flatly contradicted by the NRCs own Draft EIS, which states: Tritium detections in wells near the Mississippi riverbank (i.e., MW-29A, MW-33A, MW-37A, and MW-48A) in 2023 indicate tritium-impacted groundwater likely discharged to the river. (NRC Draft EIS,

Agency/Docket Numbers: Docket No. 50-263; NRC-2023-0031; Docket ID NRC-2023-0031; Document Number: 2024-08746; https://www.nrc.gov/docs/ML2410/ML24102A276.pdf, on page 3-47, lines 11 to 14, under 2022 Tritium Release to Groundwater.)

The leaked radioactive tritium is a direct threat to the Mississippi River because, according to the Minn.

Pollution Control Agency and the NRCs Draft EIS (above), the groundwater under Monticello moves toward the river. (Doug Wetzstein of the Minn. Pollution Control Agency interviewed on WCCO television in March 2023 said: The groundwater beneath the facility moves in the direction of the Mississippi River. https://www.youtube.com/watch?v=r5c6j7UZZA0&ab_channel=WCCO-CBSMinnesota)

Even the sheet pile steel wall constructed by the applicant between the Monticello reactor and the Mississippi River is not designed to prevent tritium from reaching the river but, as the Draft EIS says, at p.

3-45 line 7, is intended to merely help contain tritium-contaminated water to the Monticello site.

NSPM/Xcels sheet pile wall cannot and will not prevent discharges of tritium-impacted water to the Mississippi. As the Draft EIS says at page 3-47, line 21, As described above, Monticello has installed a sheet pile wall along the riverbank to minimize discharges of tritium-impacted water to the Mississippi River. [Emphasis added.]

NSPM/Xcel has repeatedly said there is no health risk to the public or plant workers because the affected groundwater contains very low levels of tritium. However, the Nuclear Regulatory Commission itself warns on its website, [T]he radiation protection community conservatively assumes that any amount of radiation may pose some risk for causing cancer and hereditary effect, and that the risk is higher for higher radiation exposures. A linear no-threshold dose-response relationship is used to describe the relationship between radiation dose and the occurrence of cancer. any increase in dose, no matter how small, results in an incremental increase in risk. (U.S. NRC, Radiation Exposure and Cancer, https://www.nrc.gov/about-nrc/radiation/health-effects/rad-exposure-cancer.html)

The fact that the NRC has concluded that tritium-impacted groundwater likely discharged to the river means that drinking water supplied to millions of people in the Mpls/St.Paul metro area, and millions of other people down stream from there, are likely being internally contaminated with NPSs leaked tritium.

Further, although the concentration of tritium in drinking water drawn from the Mississippi River may be diluted to a great degree does not eliminate the tritium which remains in the water for ten radioactive half-lives or about 123 years. Even trace amounts of tritium in ingested drinking water increase a persons risk of cancer, pregnancy problems, birth abnormalities and other illnesses. This is especially true for women, girls, infants, and fetuses, because tritium crosses the placenta.

The basis for maintaining NRCs precautionary warning that no dose of radiation exposure, no matter how small, increases the risk of causing cancer and hereditary effects is a large volume of peer-reviewed scientific evidence, including the following:

The National Academy of Sciences 7th book-length report on the biological effects of radiation, BEIR-VII, declares that any exposure, regardless of how small, can induce cancer. (Matthew Wald, With New Data, a Debate on Low-Level Radiation, New York Times, July 19, 2005) The 2005 NAS panel that produced BEIR-VII, could not ignore the current body of scientific studies that are now recognizing harmful and hitherto unpredicted effects at very low doses of radiation. (Cindy Folkers, U.S. Radiation Panel: No Radiation Dose Safe, Nuclear Monitor, No. 632, July 15, 2005.)

Further, a 2005 Russian cancer study published in Radiation Research, and reported in Science, was called the latest blow to the notion that there is a threshold of exposure to radiation below which there is no health threat. (Richard Stone, Epidemiology: Russian Cancer Study Adds to the Indictment of Low-Dose Radiation, Science, Vol. 310, Issue 5750, Nov. 11, 2005; reference to Radiation Research, Nov.

2005)

In 2015, a landmark international study published in The Lancet, provides strong evidence of positive associations between protracted low-dose radiation exposure and leukemia. (The Lancet, Ionising radiation and risk of death from leukaemia and lymphoma in radiation-monitored workers: an international cohort study, Vol. 2, No. 7, July 2015; http://www.thelancet.com/journals/lanhae/article/PIIS2352-3026(15)00094-0/abstract : In summary, this study provides strong evidence of an association between protracted low dose radiation exposure and leukaemia mortality.) As reported in Nature, The finding scuppers the popular idea that there might be a threshold dose below which radiation is harmless and provides scientists with some hard numbers to quantify the risks of everyday exposures. (Alison Abbott, Researchers pin down risks of low-dose radiation, Nature, June 30, 2015, http://www.nature.com/news/researchers-pin-down-risks-of-low-dose-radiation-1.17876)

In 1990, the International Commission on Radiological Protection recommended a dramatic cut in the maximum allowable radiation exposure for nuclear reactor workers, medical personnel, others exposed in their work, and the public. The ICRPs recommendation was that the annual limit be cut to 20 milliSieverts per year from 50. (Ian Fairle & Marvin Resnikoff, No dose too low, Bulletin of the Atomic Scientists, Nov/Dec. 1997, p. 50; Matthew Wald, International Panel Urges Cut In Allowable Radiation Dose, New York Times, June 23, 1990, p. A1.)

Between 1977 and 1990, scientists tripled their estimate of the damage inflicted by a given dose of radiation. (Ian Fairle & Marvin Resnikoff, No dose too low, Bulletin of the Atomic Scientists, Nov/Dec.

1997, p. 50; Matthew Wald, International Panel Urges Cut In Allowable Radiation Dose, New York Times, June 23, 1990, p. A1.) A 1992 study published in the American Journal of Industrial Medicine found that people exposed to small doses were four to eight times more likely to contract cancer than previously estimated. (Researcher discovers great radiation risk, AP, Milwaukee Journal, December 9, 1992.)

In 2012, a wide-ranging analysis of 46 peer-reviewed studies published in Biological Reviews found that even the very lowest background levels of radiation exposure are harmful to health and have statistically significant negative effects on DNA. (Anders Moller, Timothy Mousseau, The effects of natural variation in background radioactivity on humans, animals and other organisms, Biological Reviews, Vol. 88, Issue 1, pp. 226-254, Feb. 2013, http://onlinelibrary. wiley.com/doi/10.1111/j.1469-185X.

2012.00249.x/abstract, Vol. 88, Issue 1, pp. 226-254, Feb. 2013) Consequently, emissions of radioactive xenon, krypton, iodine-131, strontium, and tritium, etc. from operating nuclear reactors, like the huge 820,000-gallon leak of tritium-contaminated cooling water from Monticello, are believed by scientists, researchers, and other observers to be the cause of childhood leukemia, cancer, and other illnesses among people living nearby.

Scores of studies have found health effects, especially childhood leukemia, to be associated with living with chronic low-doses of radioactive emissions from nearby nuclear power plant operations. Age at exposure is important: Studies have found that, in most cases, the younger a person is at exposure, the higher the risk of cancer. (Anders Moller, Timothy Mousseau, The effects of natural variation in background radioactivity on humans, animals and other organisms, Biological Reviews, Vol. 88, Issue 1, pp. 226-254, February 2013, http://onlinelibrary.wiley.com/doi/10.1111/j.1469-185X.2012.00249.x/abstract, Vol. 88, Issue 1, pp. 226-254, Feb. 2013)

In 2004, the British governments Committee Examining Radiation Risks of Internal Emitters reported that low-level radiation from nuclear reactors may be up to ten times more hazardous when ingested or inhaled than previously estimated. Two committee members issued a minority report that said inhaled radioactive particles could lodge in the body of a fetus and do 100 times more damage than experts believe. (Jenny Booth, Nuclear plant radiation may be 10 times previous estimates, (London) Times Online, Oct. 20, 2004; Ian Sample and Owen Bowcott, The Guardian, Danger of nuclear plant discharges underrated, October 21, 2004)

In 1991, a federally mandated study published in the Journal of the American Medical Association found that low doses of radiation caused up to ten-times as much cancer as previously expected. This study tracked 8,318 employees of the Oak Ridge National Laboratory in Tennessee over 40 years, and found unexpectedly high rates of leukemia deaths, and an overall cancer death risk related to radiation dose that is 10 times higher than has been seen in atomic bomb blast survivors. (Janny Scott, Radiation risks may be more than believed, The Paducah Sun via Los Angeles Times, March 20, 1991; Dr. Steve Wing, Journal of the American Medical Association, March 20, 1991.)

In 2012, French researchers reported a clear correlation between elevated rates of acute leukemia in children and their nearness to operating reactors. The authors noted, The results suggest a possible excess risk of acute leukemia in the close vicinity of French NPPs [nuclear power plants] in 2002-2007.

(Claire Sermage-Faure, Dominique Laurier, Stéphanie Goujon-Bellec, Michel Chartier, Aurélie Guyot-Goubin, Jérémie Rudant, Denis Hémon, and Jacqueline Clave, Childhood leukemia around French nuclear power plants, the Geocap study, 2002-2007, International Journal of Cancer, February 28, 2012;

http://onlinelibrary.wiley.com/doi/10.1002/ijc.27425/abstract) This study by a team from three major scientific institutes demonstrated the doubling of childhood acute leukemia incidence in France. The increase in cancer was higher, up to 2.2 times the expected rate, among children under age five. This research the nationwide Geocap case-control study included the 2,753 cases of acute leukemia diagnosed in mainland France over 2002-2007 and 30,000 contemporaneous population controls. The childrens last addresses were geo-coded and located around Frances 19 nuclear power stations, which operate 54 reactors. Overall, the findings call for investigation for potential risk factors related to the vicinity of NPP, the studys authors said. This study did not establish a causal connection, but noted that the investigators could see no environmental factor that could produce the excess cancers other than living in the plume of radioactive gaseous emissions from operating reactors.

In 2007, the German Childhood Cancer Registry published the findings of the massive, long-term epidemiological case control study of childhood cancer and nuclear power plants, or the KiKK study.

(Kaatsch, Spix, Jung, Blettner, Childhood Leukemia in the Vicinity of Nuclear Power Plants in Germany, Deutsches rzteblatt International, 2008; 105(42): 725-32 http://www.aerzteblatt.de/pdf.asp?id=62000)

The results of this 25-year-long study were published in both the International Journal of Cancer and the European Journal of Cancer in 2008. As defined in the study, cancer cases were all the children under 5 years of age diagnosed with a malignant disease between 1980 and 2003 who lived in the study region at the time of diagnosis and whose cases were notified to the German Childhood Cancer Registry. The authoritative findings of this major study helped lead to the German parliaments decision to retire and phase out all of Germanys nuclear reactors, which was accomplished in 2023.

The authors noted: The question the recent study sets out to answer was whether children with cancer lived, on average, closer to an NPP than randomly selected healthy control children.... In the KiKK study, as in preceding studies, an increased risk of leukemia was observed for children under the age of 5 years who live within 5 km of an NPP. Overall, An association was found between the nearness of residence to nuclear power plants and the risk of leukemia (593 cases, 1766 controls). Within the 5-km zone, the OR [Odds Ratio] for the development of leukemia in children under 5 years of age was 2.19 compared to the rest of the region, and this elevation of the OR was statistically significant. (Kaatsch, Spix, Jung, Blettner, Childhood Leukemia in the Vicinity of Nuclear Power Plants in Germany, Deutsches rzteblatt International, 2008; 105(42): 725-32 http://www.aerzteblatt.de/pdf.asp?id=62000)

In addition to higher incidences of cancers, these long-term studies found even stronger associations with proximity to operating reactors than any previous studies. The authors concluded: Many factors may conceivably cause leukemia, possibly operating in combination, and these factors may be present to a greater extent in the vicinity of German nuclear power plants. (Kaatsch, Spix, Jung, Blettner, Childhood Leukemia in the Vicinity of Nuclear Power Plants in Germany, Deutsches rzteblatt International, 2008; 105(42): 725-32 http://www.aerzteblatt.de/pdf.asp?id=62000)

Similar leukemia spikes have been reported around U.S. reactors by researchers at the Medical University of South Carolina. One MUSC study analyzed previously published reports covering 136 reactor sites in the U.K., Canada, France, the U.S., Germany, Japan, and Spain. According to lead author Peter J. Baker, leukemia rates in children are elevated near nuclear facilities. (Peter J. Baker, Meta-analysis of standardized incidence and mortality rates of childhood leukemia in proximity to nuclear facilities, European Journal of Cancer Care, Vol. 16, Issue 4, July 2007, pp. 355-363, www.blackwell-synergy.com/doi/abs/10.1111/j.1365-2354.2007.00679.x) According to the study, the incidence of leukemia in children under age nine living close to reactors compared to rates elsewhere showed an increase of 14 percent to 21 percent, while death rates from the disease were raised by 5 percent to 24 percent, depending on proximity to the radiation emitters. The meta-analysis combined and statistically analyzed 17 research papers on childhood leukemia, and shows an increase near nuclear facilities.

Death rates for children up to age 9 were elevated between 5 percent and 24 percent depending on their proximity to the reactors. Leukemia incidence rates were increased by 14 percent to 21 percent in children up to age 9, and 7 percent to 10 percent for those up to age 25. While the study did not support a hypothesis to explain the excess, childhood exposure and parental exposure to radioactive emissions were named as possible causes of these cancers and premature deaths.

A two-year U.S. government study by the National Cancer Institute in 1990 found a marked increase in leukemia deaths among people living near Northern State Power Co.s, the applicants, Prairie Island nuclear power reactor also on the Mississippi River, in southeast Minnesota. The significantly high incidence of leukemia deaths appeared among Prairie Island area residents between the ages of 40 and 59, the report found. The leukemia risk rate for people aged 40 to 59 in Goodhue County, Minnesota and Pierce County, Wisconsin near the reactor, was 141-percent higher than in other counties. Before the reactor opened in 1973, the risk was 17 percent lower. Tom Bushee, speaking for NSP at the time, told the press the increased leukemia death rate was unrelated to the companys Prairie Island reactor, and that the company would look for an explanation. (Philip Brasher, Associated Press, Study finds no link between nuclear plants, cancer deaths: But leukemia deaths near Prairie Island plant high in older age group, St. Paul Pioneer Press, Sept. 20, 1990.)

According to the Archives of Environmental Health for January-February 2002, local infant mortality and childhood cancer rates dropped dramatically among nearby residents following the closure of eight U.S.

nuclear reactors. (Joseph J. Mangano, Jay M. Gould, Ernest J. Sternglass, Janette D. Sherman, Jerry Brown, William McDonnell, Infant Death and Childhood Cancer Reductions after Nuclear Plant Closing in the United States, Archives of Environmental Health, Vol. 57, No.1; Jan/Feb. 2002, p. 23.

http://www.insp.mx/biblio/alerta/al0302/08.pdf ) This research into infant death rates showed a 17.4 percent drop in infant mortality in the two years following the reactors closure in counties lying up to 40 miles downwind of the U.S. nuclear reactors. New York State Assemblyman Richard Brodsky said about this study, We finally have peer-reviewed accurate data attaching nuclear power reactors to death and injury in the host communities.

Infant mortality rates around five U.S. nuclear power reactors dropped almost immediately after the reactors were closed according to studies by the Radiation and Public Health Project, and published in the spring 2000 edition of Environmental Epidemiology and Toxicology. The study by Joseph Mangano, et al, found that from 1985 to 1996, average infant death rates dropped 6.4 percent every two years. But in areas surrounding five reactors shut down between 1987 and 1995 (Genoa, near LaCrosse, Wisc.,

closed in 1987; Rancho Seco, outside Sacramento, and Ft. St. Vrain in Colo., both closed in 1989; Trojan, by Portland Oregon, shut in 1992; Millstone in Conn., closed in 1995), infant death rates dropped an average of 18 percent in the first two years. Additional research at Maine Yankee and Big Rock Point in Michigan both shuttered in 1997 showed that infant death rates fell 33.4 percent and 54.1 percent, respectively. (Harvey Wasserman, No Nukes Equals Better Health, The Nation, Jan. 29, 2001, p7; and Danielle Knight, Infant mortality rates drop around five reactors after reactors closed, Mother Jones, May 4, 2000.)

As Dr. Arjun Makhijani, President of the Institute for Energy and Environmental Research, has reported:

From the beginning of the nuclear era until 1989, radiation doses from radioactive materials inhaled or ingested by workers were not calculated or included in worker dose records. Large numbers of workers have received information about their radiation exposures which systematically understates their actual exposures. Limits for allowable exposures have varied over the years, but have generally tended to decline as evolving knowledge about the cancer risks from radiation indicated that the dangers it posed were greater than previously thought. For instance, the limit for lung exposure until 1958 was 15 rem-per-year for workers and off-site populations. It was lowered for off-site populations to 1.5 rem-per-year in 1959. (Arjun Makhijani and Bernard Franke, Worker Radiation Dose Records Deeply Flawed, Science for Democratic Action, Nov. 1997.)

In 1989, a new estimate of the risk of cancer from low levels of radiation exposure was quadrupled. The National Research Councils BEIR-V report (its fifth study of the biological effects of ionizing radiation) declared that the risk is three-and-a-half to five times as high as those in the preceding BEIR studies.

(Philip Hilts, Higher Cancer Risk Found in Low-Level Radiation, New York Times, Dec. 20, 1989, p. A1.)

The new estimate indicated "a much greater danger" of mental retardation among babies exposed in the womb. And the new risk standard will increase the number of people expected to get cancer from radiation release accidents like the 1979 Three Mile Island partial meltdown, and the 1986 Chernobyl explosion. The National Research Council is the research arm of the National Academy of Sciences. Its

new risk model should have forced regulatory bodies like the NRC to reduce the maximum exposure allowed for workers in the nuclear industry and hospitals. The maximum amount of radiation that nuclear reactors are allowed to emit in gases and liquids should also have been reduced.

According to research reported in 1990 by Dr. Alice Stewart, people exposed to small allowable doses of radiation are four to eight times more likely to develop cancer than previous estimates suggested. Dr.

Stewart, whose 1976 government study found higher cancer rates among U.S. nuclear weapons workers, had her findings rejected and funds cut off. In 1990, Stewart reviewed her earlier statistics leading to the new conclusions. (New York Times, Dec. 8, 1992; Alice Stewart & George Kneale, American Journal of Industrial Medicine, March 1992.)

In 1992, a long-delayed radiation injury called delayed mutation effect was discovered by two groups of scientists that were working independently, Nature reported. (New York Times, Feb. 20, p. A12; & Nature, Feb. 20, 1992.) The findings may eventually lead to more stringent standards; and if the work is confirmed, estimates of the health risks of radiation may have to be revised upward. Eric Wright at the British Medical Research Council, Radiobiology Unit, Oxford, and John Little at the Harvard Univ. School of Public Health, both found that some cells that survive radioactive assault appear normal at first, but produce abnormalities several cell divisions later. This could have implications for the eventual rise of leukemias and other cancers long after exposure to radiation, Dr. Wright said.

In 1999, the U.S. government admitted that radiation exposures previously considered safe caused cancers among workers at nuclear weapons facilities. (New York Times, July 15, 1999, p. A1) This finding was repeated in January 2000, when the federal government ended decades of officially denying that worker exposures were causing ill health at nuclear weapons production facilities. The admission was part of the government's most comprehensive review ever of studies of worker health. Almost 600,000 people have worked in the nuclear weapons complex since 1945, the report said, and it named 22 categories of cancer presumed to have been caused by the chronic low-doses of radiation, most of them fatal. Some of the cancers listed were bone, bladder, prostate, kidney, salivary gland, lung, as well as leukemias and lymphomas. (New York Times, Jan. 29, 2000)

A 2003 article by Joseph Mangano in Archives of Environmental Health found elevated levels of childhood cancers in populations living within 30 miles of nuclear reactors between 1988 and 1997. For example, in Plymouth County, Mass. (near the Pilgrim reactor), there was found to be a 14.6 percent increase in the incidence of childhood cancers as compared to the rest of the country. And in Essex County, Mass. and Rockingham County, New Hampshire (near the Seabrook reactor), there was found to be a 24.8 percent increase in the number of childhood cancer mortalities.

Based on the foregoing information, I urge you to withdraw the Draft EIS and deny the SLRA.

JOHN M LaFORGE 740 Round Lake Road Luck, WI 54853 715-491-3813

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89FR31225 Comment Number:

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