ML051330077

E-mail from Richard Emch to Nancy Burton Regarding Millstone Draft EIS - Correction

ML051330077
Person / Time
Site:	Millstone
Issue date:	02/23/2005
From:	Emch R NRC/NRR/DRIP/RLEP
To:	Burton N - No Known Affiliation
References
Download: ML051330077 (7)

Text

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Paae i1II Richard Emch - Re: Millstone Draft EIS - correction Page"-,

Richard Emch Re: Millstone Draft EIS correction

- - JI From: Richard Emch To: NancyBurtonEsq @aol.com Date: 2123/05 4:53PM

Subject:

Re: Millstone Draft EIS - correction Ms. Burton:

Attached are our corrected responses to your questions. The correction is in the response to Question 10 regarding review of chemical releases. The legal staff pointed out that the response was not in complete sentences and therefore not readable.

Rich Emch

>>> <NancVBurtonEsp~aol.corn> 02110/05 09:39AM >>

Dear Mr. Emnch:

Please see attached.

Nancy Burton CC: Andrew Kugler; Ann Hodgdon; Brooke Poole; Francis Cameron; Jennifer Davis; Pao-Tsirn Kuo; Samuel Hernandez-Quinones

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Re: Millstone Draft EIS - correction Creation Date: 2/23/05 4:53PM From: Richard Emch Created By: RLE@nrc.gov Recipients Action Date & Time aol.com Transferred 02/23/05 04:54PM NancyBurtonEsq (NancyBurtonEsq@aol.com) nrc.gov TNVGWPOO1.HQGWDOO1 Delivered 02/23/05 04:53PM SHQ CC (Samuel Hernandez-Quinones) Opened 02/24/05 06:46AM nrc.gov owf4_po.OWFN_DO Delivered 02/23/05 04:53PM AJK1 CC (Andrew Kugler) Opened 02/23/05 11:42PM JXD1O CC (Jennifer Davis) Opened 02/25/05 07:17AM PTK CC (Pao-Tsin Kuo) Opened 02/23/05 05:27PM nrc.gov owf5_po.OWFN_DO Delivered 02/23/05 04:53PM APH CC (Ann Hodgdon) Opened 02/23/05 04:53PM BDP CC (Brooke Poole) Opened 02/23/05 05:OOPM FXC CC (Francis Cameron) Opened 02/24/05 08:35AM Post Office Delivered Route aol.com TWGWPOOI.HQGWDO01 02/23/05 04:53PM nrc.gov owf4_po.OWFNDO 02/23/05 04:53PM nrc.gov owf5_po.OWFNDO 02/23/05 04:53PM nrc.gov Files Size Date & Time MESSAGE 1252 02/23/05 04:53PM Response to CCAM Questions.wpd 19738 02/23/05 04:50PM Options Auto Delete: No Expiration Date: None Notify Recipients: Yes Priority: Standard Reply Requested: No Return Notification: None

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No Security: Standard To Be Delivered: Immediate Status Tracking: Delivered & Opened

Richard Emch - Res ponseto CAM Questionswpd Page 1 Response to Questions by Ms. Nancy Burton, Connecticut Coalition Against Millstone Question 1: NRC documents, with titles, authors and dates, of all studies of health effects of exposure to radionuclides and chemicals present at Millstone upon persons who have worked at Millstone, either as employees or contractors or in any other capacity, since 1970.

Response: We have no such documents.

Question 2: NRC documents, with titles, authors and dates of all studies of health effects observed, catalogued or studied in any way in the population of individuals identified in section (1) above after they have left service at Millstone and until their deaths.

Response: We have no such documents.

Question 3: NRC documents, with titles, authors and dates of all studies of health effects of exposure to radionuclides and chemicals present at Millstone on persons who have worked at Millstone, either as employees or contractors or in any other capacity, since 1970, based on postmortem evaluation.

Response: We have no such documents.

Question 4: NRC documents, with titles, authors and dates of all studies of health effects of exposure to radionuclides and chemicals, present at Millstone as well as discharged from Millstone, upon members of the public.

Response: We have no such documents.

Question 5: Please provide citations to the statutes, regulations and other legal requirements which identify what information a nuclear licensee such as the Millstone Nuclear Power Station is required to provide to the NRC with regard to the following:

(a) Reporting data of worker exposure to radiation; (b) Reporting data of health effects of worker exposure to radiation and chemicals during their terms of employment or assignment; (c) Reporting data of health effects of worker exposure to radiation and chemicals, both among employees and contract workers, following their departure from the licensee; (d) Reporting data of cancer incidences among present and former workers; (e) Reporting data of cause of death among former workers.

Response: 10 CFR 20.2206 requires licensees to submit information annually about the results of individual dose monitoring. However, according to 10 CFR 20.2106, this information is protected from public disclosure because of its personal privacy nature. In addition, the Millstone Technical Specifications, which are part of the operating license, require an annual

Page I Richard Emch - Response to CCAM Questions.wpd Richard Emch Response to CCAM Questions.wpd Page 22g report to the NRC of total plant occupational radiation exposure. There is no NRC requirement to report data about the health of workers.

Question 6: Please identify by title and date all information provided to the NRC by the owners and operators of the Millstone Nuclear Power Station since 1970 responsive to item (5) above.

Response: The All reports to the NRC regarding occupational dose that are available to the public are in the PDR. NUREG-0713, Volume 25, " Occupational Radiation Exposure at Commercial Power Reactors and Other Facilities 2003," summarizes the occupational exposure for each power plant including Millstone. It also has historical data for many years.

Question 7: Please provide the titles of all records reviewed by you and your staff with regard to the draft EIS of the phenomenon of the incidences of brain tumors among workers in the former "site maintenance" department at Millstone c. 1994 as well as the incidence of cancer and other diseases among contract workers fulfilling the job requirements of the former 'site maintenance" department after the "site maintenance" department was eliminated c. 1994 Response: We have no such documents.

Question 8: Please provide the titles of all records reviewed by you and your staff with regard to the draft EIS of the phenomenon of the incidences of cancer and disease among persons who have worked as pipefitters at Millstone.

Response: We have no such documents.

Question 9: Please provide the titles and dates of all records reviewed by you and your staff with regard to the draft EIS of the phenomenon of the incidences of cancer and disease among non-workers within 5-mile, 10-mile and 50-mile radii of the Millstone Nuclear Power Station.

Response: The specific reports reviewed by the staff regarding the impact of radiation exposure to the public from Millstone are discussed in Section 4.7 of the Millstone DSEIS and listed in the references in Section 4.10 of the Millstone DSEIS . However, there are two errors. On line 23 on page 4-53, "(Connecticut Tumor Registry 2004)" should be "(CTDPH 2004)", and reference CTDPH 2004 on page 4-61 should be entitled, "Cancer Incidence in Connecticut Counties, 1995-1999," dated January 2004. These corrections will be made in the final version of NUREG-1437, Supplement 22. Also, the Millstone DSEIS references the GEIS (NUREG-1437), which addresses the impact of radiation exposure to the public generically in Sections 3.8 and 4.6 and Appendix E.

Question 10: Please provide the dates and titles of all documents reviewed by you and your staff regarding radiological and chemical effluents discharged by the Millstone Nuclear Power Station since 1970.

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Richard Emch- Response to CCAM Questions.wpd Page 3 Response: Section 2.1.4 of the Millstone DSEIS lists the documents that we reviewed regarding radiological effluent releases from Millstone. Section 2.2.3 indicates that we reviewed the National Pollutant Discharge Elimination System (NPDES) permit to evaluate chemical effluent releases. During the environmental site audit, we met with Ken Major, Margaret Welch, Charles Nezianya, and Lee Dunbar of the Connecticut Department of Environmental Protection to discuss Millstone's compliance with the NPDES. Lee Dunbar was the expert on chemical toxicity issues.

Question 11: Please provide a list of the chemicals used and discharged at Millstone since 1970, as reviewed by yourself and your staff, and please provide the analysis applied in the draft EIS of how the environment would be affected if the Millstone Nuclear Power Station were to convert from an open to a closed cooling system, particularly as to how such conversion would reduce or eliminate the need for use and discharge of toxic chemicals to the environment.

Response: The NPDES permit issued by the Connecticut Department of Environmental Protection was reviewed as indicated in Section 2.2.3 of the Millstone DSEIS. No additional list of chemicals released from Millstone was obtained. No analysis was done by the staff of possible reductions in chemical effluents that could be achieved by converting to a closed cooling system.

Question 12: At pages 4 4-56 of the draft EIS, the following statements appear:

"CTDEP [Connecticut Department of Environmental Protection] conducts its own radiological environmental monitoring program around Millstone.... CTDEP concluded that Millstone's radiological effluent and environmental monitoring data were accurate."

With regard to such statements, please identify the names of all CTDEP individuals who provided such statements to you and your staff, the date(s) such statements were made, whether such statements were in writing or verbal (if in writing please provide a copy), and the dates, times, methods of analysis and monitoring referred to and the results of such monitoring as provided to you and your staff.

Response: On April 24, 2004, Brian Colby of Los Alamos National Laboratory and I talked by telephone with Dr. Edward Wilds, Director of the Division of Radiation, and Michael Firsick, Supervising Radiation Control Physicist, of the Connecticut Department of Environmental Protection. I talked with Dr. Wilds at the public meetings on February 17, 2004 and January 11, 2005. I also talked with Mr. Firsick by telephone in the Fall of 2004 to confirm that nothing had changed since the April telephone call. I received no written statements from these individuals.

Question 13: Please identify and explain the methodology you and your staff applied in reconciling the CTDEP statements (see (12) above) with Northeast Nuclear Energy's Company's plea of guilty to committing environmental felonies during a period of time (c.1 990s) while CTDEP conducted onsite monitoring of Millstone effluent releases.

Richardq Emch - Response to CCAM Questions.wpd _ Page 4 Response: As we indicated in the Millstone DSEIS, we reviewed the last few years of effluent and environmental monitoring reports for Millstone. We concluded that the radiological data in these reports serve as a valid indicator of the radiological effluents that can be expected at Millstone during the renewal period.

Question 14: At page 4-56 of the draft EIS, the following statement appears:

"CTDEP also concluded that the reports cited above by CTDPH, CASE and the National Cancer Institute reports showed no evidence of a causal link between public exposure to Millstone's radiological effluents and cancer in Connecticut towns."

With regard to such statements, please identify the names of all CTDEP individuals who provided such statements to you and your staff, the date(s) such statements were made, and whether such statements were in writing or verbal (if in writing please provide a copy).

Further with regard to such statements, please state whether you and your staff requested such CTDEP personnel to review other documents asserting such a causal link as submitted to the NRC by the Connecticut Coalition Against Millstone, including affidavits of Dr. Ernest Sternglass, Joseph Mangano, Michael Steinberg and Cynthia Besade and, if not, please explain.

Response: The statements regarding conclusions by CTDEP were based on the communications with Dr. Wilds and Mr. Firsick discussed in the response to Question 12. They indicated that they had not reviewed the claims by Dr. Mangano and Dr. Sternglass; we did not ask them to review those claims.