ML071370430

ACE Requested Written Explanations and Answers for Questions and Concerns Raised at Nrc'S 4/18/07 Meeting at Limerick Nuclear Power Plant

ML071370430
Person / Time
Site:	Limerick
Issue date:	05/02/2007
From:	Cuthbert D Alliance For A Clean Environment
To:	Paul Krohn NRC Region 1
References
Download: ML071370430 (6)

Text

May 2,2007 To: NRC, Region I Paul Krohn, Chief of Branch 6 Reactor Projects 475 Allendale Road King of Prussia, PA 19406 From: The Alliance For A Clean Environment P.O. Box 3063 Stowe, PA 19464 f3 W 0 RE: ACE Is Requesting Written Explanations and Answers For Questions and Concerns Raised At NRC's 4/18/07 Meeting At Limerick Nuclear Power Plant At the meeting held by NRC at Limerick Nuclear Power Plant April 18,2007, I had many questions on behalf of ACE and many residents in the region that could not attend the meeting. I requested written responses and was told to put it in writing. In this document I identied those qum'tions and concerns and again request written responses.

1. NRC written statements to ACE are contradicted by oral statements made by NRC employees at meetings, about the serious issue of how long spent fuel at Limerick must stay in the fuel pool before removal to dry cask storage. Please explain in detail the confusion identified below and provide written confirmation by someone that can be held accountable at NRC, on the exact amount of time Limerick will be required to keep high-level radioactive waste rods in fuel pools before removal for above around dry cask storage. At every meeting, including July 13, 2006 in Limerick and the April 18, 2007 meeting at Limerick Nuclear Power Plant, NRC claimed spent fuel had to be cooled in fuel pools for at least 5 years. A. Yet, in a June 16,2006 NRC letter to ACE, NRC stated in writing, it was only requiring the waste to be cooled for 1 year. B. At the 7/13/06 meeting, NRC verbally claimed NRC made a mistake in their letter to ACE by stating 1 year of cooling. C. 7/25/06 - ACE received the e-mail below with a different, very confusing explanation.

The e-mail below from NRC's James Tmpp to ACE clarifies nothinq. From: Jaines Trapp Date: 7/25/2006 7:04:34 AM To: ace@acereport.org Cc: Diane Screnci; Marie Miller; Robert Prince

Subject:

Clarification - Public Meeting on July 13,2006 Donna I wanted to clarify a statement made during the meeting regarding cooling time for spent fuel prior to it being placed in a dry storage cask. J In our letter to you dated June 16,2006 we steted the time was at least 1 year. This statement was correct. Regulations (72.2) specify spent fuel must be cooled in the pool for at least one year before if is placed in dry storage, so our June 16th letter was correct. 1 ACE Question - Then why do NRC emdovees keeD tellina the Dublic the rods will be cooled for at least 5 vears before removal. J However, in practice, most spent fuel that is placed in dry storage must be aged for 5 years or more, as required by all NRC-approved Certificates of Compliance for dry cask storage systems, and NRC issued site-specific licenses.

ACE Question - Does Limerick have a Certificate of Comdiance for dry cask storaae svstems that sDecifies how lona rods must be cooled in ~ools before removal and how manv vears are reauired in that Certificate?

Does Limerick have an NRC issued site-swcific license and how manv vears are reauired in that Certificate?

J Purposely using the word most, because there are cask designs, including NUHOMS, that would allow certain low-irradiated fuel to be placed In a cask with only 3 or more years of cooling in the spent fuel pool. ACE Question - Is Limerick usinn the NUHOMS cask that allows rods to be removed from the fuel ~ools after onlv 3 vears? If so. will NRC allow Exelon to remove Limerick's rods after onlv 3 vears? I hope this clarifies the statement made in the letter. If I can be a any further assistance, please let me know. Jim Trapp - Region I, USNRC, Phone #610-337-5186.

2. A. B. 3. A. BACK-UP POWER FOR WARNING SIRENS How does NRC justify allowing Exelon to avoid providing back-up power in a black out for warning sirens in this heavily populated area around Limerick Nuclear Power Plant? 17 of 63 other nuclear plants have back-up power. Why not Limerick where there is such a vast population? Exelon made

$1.5 Billion in profits in 2006, (a 73% increase over 2005). Certainly cost can not be used as an excuse by Exelon when Does NRC really believe emergency workers would be able to warn potentially hundreds of thousands of people during a radiation event with bull horns and knocking at doors? How many emergency workers would that take? And how many of them would risk their lives to ride around for hours or days while being exposed to the radiation?

INADEQUATELY ADDRESSED POTENTIAL CASK DESIGN FLAWS - SPECIFICALLY CORROSION OF STEEL IN CASKS AND QUESTIONABLE CEMENT CORROSION OF STEEL HOLDING HIGH-LEVEL RADIOACTIVE WASTES ABOVE GROUND IN CASKS. Please respond in detail to the following:

At the meeting in Limerick 4/18/07 it did not inspire much confidence in NRC to see NRC employees who were either unaware of the following important facts or were pretending to be unaware: 1) NRC's own testing by a national laboratory proved steel will corrode. 2) NRC correspondence to ACE in November, 2006 admitted steel would corrode, but NRC dismissed concern stating the license for cask storage was for only 20 years. 3) There is no guarantee that Yucca Mountain will ever open or that the high-level radioactive wastes stored above ground in steel canisters will ever be transported off-site at Limerick or that corrosion won't happen sooner than 20 years potentially making it impossible to move the waste. 2 B. CORROSIVE AIR IN LIMERICK. At the 4-18-07 meeting ACE once again requested continuous air monitoring for corrosives, especially all corrosive chemicals on the list of corrosive chemicals from Limerick's MSDS sheets for chemicals added to Limerick's cooling tower waters. ACE repeatedly previously provided this corrosives list to NRC, but will again attach it to this document for NRC's convenience.

J Evidence suggests Exelon's Environmental Supervisor is attempting to dismiss our concerns with false arguments.

J It was suggested that air testing is already done. While true for radiation, this is not true for Limerick's corrosive chemicals and their corrosive by- products through synergy.

J ACE has a NUHOMS diagram clearly showing corrosive air at Limerick can corrode steel holding the high-level radioactive wastes above ground. This diagram shows the dry cask storage system requires passive air cooling by convection currents of air that pass into the dry cask system via vents at the bottom, rise up and flow past the inner metal canisters which hold high-level radioactive wastes inside.

J This diagram shows the need to know exactly what corrosives are discharged with Limerick's 35 million gallons of steam every day at Limerick, and what corrosive reactions occur through the synergistic, additive, impacts with other air pollution in the region.

Obviously, only through modeling with site-specifc data on combinations of corrosive chemicals in the air and the kind of steel being used, can anyone even begin to estimate the rate of corrosion NRC admits will occur. If NRC is going to refuse to do this corrosive air testing, we request that a specific NRC employee sign that declaration.

J Faultv cement is still in question.

NRC has never addressed the concerns raised to us by a nuclear engineer about faulty cement used to build NUHOMS casks. Has NRC investigated this claim? J We understand that corrosive air could also impact cement in casks and would like to know if NRC has even investigated this issue. J What kind of cement or concrete will be used for Limerick casks?

P ACE questions corrosive chemicals in the air, and what those corrosives might do to the metal and concrete that comprise the cask infrastructure.

Clearly, thCs Is very relevant and needs independent scientific site specific testing BEFORE CASKS ARE BUILT AWD LOADED1 4. ACE questions why NRC would allow Exelon to place casks holdlna high-level radioadve wastes under high-tension wires. An original ACE concern was Limerick employees regularly monitoring too near the deadly wastes. We were told there was no cause for concern. Exelon now states they decided to look at other options because, "to access the temperature readings, they (employees) have to be on top of casks" k Whv would Exelon plan to store deadhr hiah-level radioactive wastes near hiah voltane wires when the site is over 440 acres and whv would NRC allow that? 3

5. What happens to all the radioactive asses that are continually penemtd in hiah level radioactive wastes due to the radioactive decay of the toxic brew of radioactive isotopes present there? I) Where do those radioactive gases go? 2) If the inner canister is air tight, doesn't the generation of those gases threaten to breach seals due to the build up of pressure within the canisters?

6. LIMERICK AIRPORT ACE raised concerns about Limerick Airport being too close to the nuclear plant for several years and repeatedly suggested this airport should have been closed immediately after 9/4 1. 1) At a previous NRC meeting after 9/11 we were told not to worry because Exelon owned the airport.

At the meeting 4/18/07 we were told someone else is buying the airport. Exactly who is buying the airport and how carefully have their background and connections been checked?

2) At the 4/18/07 meeting I raised an issue presented to ACE by several residents who live near the nuclear plant and the airport. Apparently each September there is a huge event at the Limerick Airport which draws massive numbers of people in planes. Since this airport is so close to the nuclear plant, is it wise to allow such an event to continue? Are all attendees screened?

3) Residents also say they are concerned about helicopters coming in and out of the Limerick airport.

They ask - can missiles be shot from helicopters? Please tell us if it is possible to shoot a missile from a helicopter.

7. Questionable Security Procedures Wlth Exelon's Security Finn Whv would NRC Demit Wackenhut (in a clear conflict of interest) to be in charm of testina itself and its comDetitors in simulated "force-on-force" terrorists attacks? Questions for NRC J Wackenhut is the security firm used at Limerick by Exelon. We understand they are no longer used by Homeland Security.

Is this true? If Wackenhut is no longer working for Homeland Security, why does NRC allow this company to be in charge of guarding Limerick or doing any testing of security, especially their own? J There have been numerous security problems documented at multiple Wackenhut-guarded U.S. nuclear facilities. Did Wackenhut have problems with sleeping guards at other nuclear plants in addition to Limerick?

At Limerick Nuclear Plant a auard was caunht sleeDina on the iob this Julv. 2006 and there have been other serious problems with Wackenhut wards at Limerick accordina to Limerick J A high percentage of Wachenhut workers at nuclear plants are said to be working far too many hours. How many hours in a row does NRC allow security people to work at Limerick? How much downtime is required between shifts? J Was Wackenhut caught cheating on a drill at a weapons facility in Tennessee?

4 J Does NRC have the facts on Wackenhut whistleblowers?

It has been claimed there has been retaliation on Wackenhut whistleblowers instead of making an effort to investigate and correct problems reported.

J 200 Wackenhut employees were interviewed who are said to have complained of excessive forced overtime and low pay. Has NRC checked into forced overtime?

Is there high turnover as claimed? What is the rate of turnover compared to other security firms? J Have NRC employees read the report titled, "Homeland

/nsecuritV:

How the Wackenhut Corporation is ComDromisinu America's NUCle8r Securitv." www.EveonWackenhut.com.

If not, we suggest NRC read this report and take immediate action to require the safest security company to guard Limerick Nuclear Power Plant.

8. Explain in detail why NRC believes Limerick Nuclear Power Plant does not need to be protected against terrorist missiles and air strikes. J NRC seemed to suggest there is no cause for concern. Exactly how is Limerick Nuclear Power Plant prepared to defend itself against a terrorist missile or air plane strike on any of the targets on site at Limerick that could become weapons of mass destruction, including fuel pools, reactors, and above ground cask storage?

J How many terrorists is Limerick required to guard against?

9. Why does NRC continue to claim Limerick's high-level radioactive wastes will be transported to Yucca Mountain in 20 years and continue to only reauire standards to license the waste to be stored above ground at Limerick for 20 years? Manv scientists Anree - Yucca Mountain Is An Environmentallv Unsuitable Site And In Utter Disarrav.

Current Yucca Mountain status as of the 4/18/07 meeting: 0 J Funding has been cut. J DOE is laying off employees for the Yucca Mountain project J Powerful Senator Harry Reid continues to be opposed to the building to Yucca Mountain.

J The State of Nevada stays resolute against the project. J Official statements suggest Yucca isn't projected to open before 2020. 0 The Department of Energy has yet to even set a date on which it will submit its application for approval by the Nuclear Regulatory Commission.

The NRC may be a long way from granting that application, as evidenced by these statements from the Las Vegas ReviewJournal of January 23rd ,2007: 0 J Ed McGaffigan, veteran Nuclear Regulatory Commission recently said Yucca Mountain is d*!eDlV flawed and the Nevada nuclear waste site should be ScraDDed.

J "It may be time to stop digging, and it may be time to rethink," McGaffigan said in a critique of the Energy Department program as he prepares to retire from the five-member commission that regulates nuclear safety. 5 J "I think Yucca Mountain has been beset by bad law, bad regulatory policy, bad science policy, bad personnel policy, bad budget policy throughout its history,"

McGalfigan said. "Every time somebody has done something to try to speed things up, it has backfired.

J "Each year that passes, we are not going to get any closer to Yucca under the current circumstances," McGaffigan said.

Yucca Mountain Is A Financial Debacle. Proiected Costs: - - - DOE'S Droiected new cost estimate is exDected to be The State of Nevada has predicted the cost will top The RatePaver Nuclear Waste Fund will collect - > $40 to $70 Billion Would Be Paid By Taxpayers for what clearly should be the responsibility of the nuclear industry.

Taxpayers should not be expected to pay to store massive amounts of the nuclear industry's deadly wastes for hundreds of thousands of years. $70 Billion. $100 Billion. $30 Billion. IO. NRC RADIATION STANDARDS ARE NOT CONSERVATIVE NOR PROTECTIVE.

The National Academy of Sciences affirmed in July 2005, there is no safe dose of exposure to radiation, J Yet NRC failed to update its radiation standards to reduce risks. J July 2006, in Limerick, NRC stated they could wait hours or days after an accident to warn the public. NRC was recently petitioned to require more protective radiation standards at older nuclear power plants. J Current radiation standards, based on "Standard Man" (an average healthy adult man), clearly jeopardize more vulnerable populations.

J Increasing cancer rates in Montgomery County, especially in children, and especially in communities near Limerick Nuclear Power Plant suggest more protective radiation standards are imperative Will NRC respond to the petition with a decision to protect public health from radioactive emissions from nuclear power plants or continue to protect nuclear industry interests?

J I plan to respond to your questionnaire about NRC's April 18, 2007 meeting at a later date. Please send responses to: ACE P.O. Box 3063 Stowe, PA 19464 Thank You, A -- Donna Cuthbert ACE Vice President 6