ML051330141
| ML051330141 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/24/2005 |
| From: | Burton N Connecticut Coalition Against Millstone |
| To: | Emch R NRC/NRR/DRIP/RLEP |
| References | |
| Download: ML051330141 (7) | |
Text
Page 1If
- Richard Emch - Millstone Draft
- EIS Comments Draft EIS Comments Page 1 1 From: <NancyBurtonEsq @aol.com>
To: <rle nrc.gov>
Date: Thu, Feb 24, 2005 8:21 AM
Subject:
Millstone Draft EIS Comments
Dear Mr. Emch:
The Connecticut Coalition Against Millstone requests that you provide clarification of some of your responses to its February 10, 2005 request for additional information.
Please see attached.
Sincerely, Nancy Burton Connecticut Coalition Against Millstone CC: <ajkl @nrc.gov>
c:\temp\GW)00001 .TMP Page Page 11 "II c:\temp\GWIOOOO1 .TMP Mail Envelope Properties (421DD4D1.786: 8: 14214)
Subject:
Millstone Draft EIS Comments Creation Date: Thu. Feb 24, 2005 8:21 AM From: <NancyB urtonEsq @aol.com>
Created By: NancyBurtonEsq@aol.com Recipients nrc.gov OWGWPO02.HQGWDOO 1 RLE (Richard Emch) nrc.gov owf4.po.0WFNDO AJKI CC (Andrew Kugler)
Post Office Route OWGWPOO2.HQGWDOO I nrc.gov owf4_po.OWFNDO nrc.gov Files Size Date & Time MESSAGE 286 Thursday, February 24, 2005 8:21 AM TEXT.htm 819 MillstoneEISEmchNBEmail22405.doc 35840 Mime.822 51766 Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed
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Page 1 I Richard Emch MillstorieEISEmchNBEmail224O5.doc Emch - MillstoneEISEmchNBEmail22405.doc
- Page 1 1.l 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.
Please identify "We."
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.
Please identify "We."
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.
Please identify "We."
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.
Please identify "We."
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:
(1) Reporting data of worker exposure to radiation; (2) Reporting data of health effects of worker exposure to radiation and chemicals during their terms of employment or assignment; (3) Reporting data of health effects of worker exposure to radiation and chemicals, both among employees and contract workers, following their departure from the licensee;
Page
- Richard Emch - MillstoneEISEmchNBEmail22405.doc Richard Emch MiIlstoneEISEmchNBEmaiI224O5.doc Page 24 (4) Reporting data of cancer incidences among present and former workers; (5) 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 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.
Please identify "We."
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.
Please identify "We."
I Richard Emch - MillstoneEISEmchNBEmail22405.doc Richard Emch MillstoneEISEmchNBEmail224O5.doc Page 3I Fiage;3-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.
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.
Please state with specificity what information was provided to you by Messrs. Major, Nezianya and Dunbar and Ms. Welch regarding compliance with the NPDES.
Did you review Emergency Authorizations?
Did you review litigation seeking declaratory and injunctive relief on grounds the NPDES permit and the Emergency Authorizations were invalid?
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.
Richard EmIch - MillstoneEISEmchNBEmai[22405.doc Page 4 11 Emc_ - Mill _stonezlS mcB mail_ _O.do Richa_ .rd6 Pag 41X 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.
Please state with specificity why "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.
Please state with specificity what you mean by the statement "nothing had changed since the April telephone call."
Your response completely evades the question. Please provide a full, fair and forthright response.
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.1990s) while CTDEP conducted onsite monitoring of Millstone effluent releases.
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.
Richard Emch - MillstoneEISEmchNBEmail22405.doc Page5 Please identify the period of time encompassed by "the last few years" and why that period of time was selected rather than the entire operating life of the facility.
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.
Please state whether Dr. Wilds or Mr. Firsick stated whether they had reviewed affidavits of Michael Steinberg and Cynthia Besade.
Please state whether you provided these documents to Dr. Wilds or Mr.
Firsick.
Please state why you did not ask them to review the claims of Dr.
Sternglass or Mr. Mangano.