Appendix A

* , -- - > !, . - I, , #P ho9 6--

. - // 1/0-

. I

II

II

Chief,-Rules and Directive Branch

Office of Administrative Scrvices

MailstopT-6D59

US Nuclear Regulatory Commission

Washington, DC 20555

IJanuary 11, 2005 -.

Re: Millstone Nuclear Plant e should be closed. :- *-- - - --

Dear Regulatory Commission Officer, -- - -

MPS-26-1 I write to you today on behalf of my family and close friends who all live

near the Millstone Nuclear Plant. It has come to our attention that although

the plant has already outlived its Intended life span, it is slated for relicensing for another 20 years. We strongly oppose this decision and regard

it as shortsighted and foolhardy.

Nuclear power plants, risky even under the best conditions,I should by no

means be patched together to overextend their designed use. We simply

roll the dice of fate every day we let this continue.

MPS-26-2 This is doubly alarming now tchat wec fate likely threats of terrorism on our

oMn soil. Millstone is essentially a Weapon of Mass Destruction waiting to

be detonated!

We wvish, as our founding fathers did, to be free from remote tyranny. We

wvill not let a remote tyrant (Bin Laden or the US NRC) risk our lives,

health, environment and livelihoods.

We look fornvard to your reply and assurance that Millstone vill notbe relicensed. Until then, I am

SincerelyYours,

Lindsay Suter, AIA

Rogers Mill -':'*-,

16 Mill Road

Noith Branford, ET..0641 :;. *.

(203)4.84-5059 :. ;.

Ife99 e,3 -D, - - -

July 2005- A-221 . Spee2 NUREG-1437, Supplement 22
Appendix A

I NRCREP - Response from Comment on NRC Documents' . . .. _ _ . _ . .P.e. I

. v - _ _

From: Michael Hess .crnchaeLd_hessOdom.com>

To: <nrcrep~nrc.gov>

Date: Tue. Jan 25.2005 7:37 AM

Sublect: Response from *Comment on NRC Documents

8elow is the result of your feedback form. It was submitted by

Michael Hess (michael_d_hessOdom.com) on Tuesday. January 25.2005 at 07:37:42

J%9/081al

6fz /0:,7

DocumentTltbe: Generic Environmental Impact Statement for Ucense Renewal of Nuclear Plants.

Supplement 22. Regardcng Millstone Power Station. Units 2 and 3

MPS-27-1 Comments: QUESTION: Can the report be modirfed to make clear that entrainment d 20% of the lrvae

production does not result hi 20% reduction of adult fish because the larvae entrained Is outside of the

river and this larvae may have lIttle or no Impact on the total population of adult Niantic River Winter

Flounder?

BACKGROUND: Section 4.1.1 seems to assume that the percentage of NMantic River Winter Flounder

larvae that result hi adult fish Is tho same. regardless ol whether the larvae Is allowed to reach try stage hi

the river or whether the larmae bs released to Niantic Bay and Long Island Sound. It would seem that

larvae released to the bay and sound would experience a more hostile environment, even without

Millstone. Therefore, larvae that have left the river would have significantly less Impact on the adult

population than larvae that remains I the river. Skie Milkstone can only entrain larvae that has left the

river, the effect of entrahment would seem to be greatly exaggerated by simple comparsons as a

percentage of larvae production, as discussed on page 4-15 of the report

organIzation: Representing Self

addressl: 828 Old Black Point Road

address2:

clty. Niantic

state: CT

zir: 06357

county: USA

phone: (860) 444-4202

. .. ... . . . . . . _ . _

,t:1,- .5 -:. ,4 ,) " -41 Z

Ca, (,4z&--) 5a5#/ C -16c?,fe

/7ir &Z AL -a3 / 3

NUREG-1437, Supplement 22 A-222 July 2005
Appendix A

Chief, Rules and Directives Branch ;/

Division of Administrative Services .

Office of Administration .. Iew 1-Af oJ 

Mailstop T-6D 59

US Nuclear Regulatory Commission

Washington., DC 20555-0001 , >-

February 10, 2005

Commissioners: . - -^

MPS-28-1 TheGreenParty of New Haven opposes extension of

operating licenses for Millstone's 2 and 3 nuclear power

reactors in Waterford, Connecticut, owned by Dominion

Nuclear Connecticut, Inc. for the following reasons:.-

MPS-28-2 1. After a hearing in Waterford on Jan.ll, a fire broke

out Jan.14 highlighting the vulnerabilitycof these aging

plants.

MPS-28-3 2. The draft Environmental Impact Statement (EIS) being

prepared by the Nuclear Regulatory Commission (NRC) with

respect to the license renewal does not address some

highly-related issues such as the Evacuation Plan.

The current evacuation zone does not include the effect of

a major release and its effect on Connecticut and its

cities such as New Haven, only about 40 miles from the

plant, nor does it consider the proximity of Long Island

only a few miles away across the Sound where evacuation

has been shown to be impossible.

MPS-28-4 3. Terrorism and sabotage are not included in the draft

EIS even though these plants can be prime targets with

their highly-radioactive spent fuel stored in unprotected

pools or, as approved, in dry cask storage on the reactor

site.

MPS-28-5 4. Environmental Justice issues were incorrectly discarded

by not considering that the low-level radioactive wastes

are shipped routinely to places such as Barnwell, S.

Carolina, an area that has a predominately poor and

African-American population.

MPS-28-6 5. There is a need for an independent epidemiological

9 -Z)/3

July 2005 A-223 NUREG-1437, Supplement 22
Appendix A

MPS-28-6 study of areas around the plant beyond Waterford and

including New Lonaon County and parts of Long Island where

cancer clusters have been identified. Radioactive and

chemical contaminants are routinely released from the

plants into air and water.

MPS-28-7 Dominion has a poor envirormental record having been fined

for having hidden violations of the Clean Air Act at

another of its facilities.

MPS-28-8 Speaking for the New Haven Chapter of the Green Party, we

feel the draft EIS, as proposed, is flawed, and thus a new

process should be initiated with hearings that include all

stakeholders and their concerns.

Sincerely,

Charlie Pillsbury

247 St. Ronan Street

New Haven CT 06511

Allan Brison

115 Everit Street

New Haven CT 06511

I

NUREG-1 437, Supplement 22. A-224 July 2005;-
Appendix A

.. rage I

-- - S - - . } - ~ - . - - _ -

From: 'Dave Sirrpson <cdavid.sirnpsonlpostate.ct.us>

To: acmillstoneElSOnrc.gov>

Dato: Wed. Jan 5, 2005 3:11 PMh

SubJect: Millstone GEIS comments : -

Richard.

MPS-29-1 1 reviewed the sections ol the GElS pertaining to entrainment and thought you folks did a very nice job.

especially summarizing the available informaUon and the debates/points of disagreement on models and

analysis.

MPS-29-2 I have only a few minor comments on pages 2-25 and 2-26 reference li made to the Gull of Maine stock -

sure you meant southern New England.

MPS-29-3 pg 2-26 One 8 'The stock Is at low biomass level and Is considered to be OVER exploited (NOM 1998).

MPS-29-4 pg 2-25 Commercial havrest Is generally accomplished with trawl and salness. rd scratch selnes for our

area. Virtually all landings are by trawt.

Thanks for sending us a copy of the report.

Dave

David Simpson Supervising Fisheries Biologist

State of Connecticut

Department of Environmental Protection

Marine Fisheries DMvis1on

PO Box 719

Old Lyme, Cr06371

phone: (860)434-6043

fax: (860)434-6150 email: david.simpson"po.state.ct.us

-~-4i '2:0

July 2005' A-225 NUREG-1437,Supplem6nt 22
Appendix A

rawI

From:

To:

Date:

Subject:

<Urfcomm @aol.comr

<M1llstoneElS~nrc.gov>

Thu. Jan 6. 2005 3:07 PM

EIS for Milstone Power Stations UnIts 2 & 3 ,q, 0,I

To Whom It May Concern:

MPS-30-t I want to go on record as Opposing the renewal for licensing for Units 2 and

3.

MPS-30-2 I have grave concerns about the safety of this power plant. In the event of

a terrorist attack. the Impact to the trI state area would be devastating. I

would hate to have something occur as it relates to terrorism and this Power

MPS-30-3 Plants. to find that my concerns are correct. In addition to my concerns. It appears the NRC down plays the impact of EMF on the people and the

environment

MPS-30-4 There are alternative ways to generate electricity and Connecticut should be

looking for those ways. In these uncertain times decisions can't always be

about profits & shareholders. It must be more about safety and alternative

ways to generate clean and efficient energy.

There are 69 Issues for which the GEIS reached generic conclusions. but if we can be objective about these 69 Issues. they would be frightening.

I oppose the renewal of this licensing for Units 2 & 3.

Sincerely.

Marie Domenici

330 Oldfletd Court

Mattiluck. NY 11952

631 2987103

-5 6$XA.407

-/ -,- 6,rz= e b 04 -an I a

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NUREG-1437, Supplement 22 A-226 July 2005.
Appendix A

- .ra

. .... . . . 4.

da/O -C-/O S- . . I

-. From: *Baran. Marie 'Marie.9aranOfb.gov>

To: . . ~IIstoneElS~nrc.gov>*- .. -

Date: Fri. Jan 7.2005 2:38 PM .

MPS-31-1 Until Long Island has and evaluation plan we should not have nuclear:-.-

power plants operating within 100 miles of us. As I have learned. Ws

not it there wit be an accident I's lust when will it be. 911 should

have taught us all that we are so vulnerable.

Marie Baran

Z'.43 7/9/-o 

0D

-,i ... . . -

* ^ r_ , i . -

* ' I ' 'I C - z d " - ' ''

, a t c

,-s:D e I )-(' 3' -_ . * i , 7 -/ , 

July 2005 . A-227 NUREG-1437, Supplement 22
Appendix A

.1. -1

r-aue

From:

To:

Date:

Subject:

Assemblywoman Pal Acampora <acampopQ assembly.slatemny.us>

<MillstoneEIShnrc.gov>

Mon. Jan 10.2005 11:24 AMA

Millstone License Renewal

January 10. 2005

Mr. Richard Emch, Jr.

Division of Regubatroy Improvement Programs Office of Nuclear Reactor Regulation United States Nuclear Regutatory Commission

Washington DC 20555

I write concerning the United States Nuclear Regulatory Commissionrs

consideration for the Millstone Power Stations, Units 2 and 3 License

Renewal forthe next twentyyears. Unfortunately. I will be unable to

attend the during the Tuesday. January 11th public discussion forunm held in

Waterford, Connecticut. The New Yortk State Legislature Is In session on

that date and therefore, I will be in Albany.

MPS-32-1 I wish to share with you my serious concerns that Millstone's operation

poses a serious risk to the residents of the North Fork of Long Island.

Without an emergency plan In place that expands the current 10 mile radius

to a 50 mile radius including the North and South Forks, there should be no

consideration of renewing Millstone's contract. In the event of an accident

or terrorist attack, Long island Is currently extremely vulnerable. We must

ensure that safety of the residents of Eastern Long Island. Therefore, I

strongly oppose renewing the contract ol The Millstone Power Station.

Thank you for your consideration of this extremely Important matter. I

would also like to be informed In the future regarding public meetings and

discussions concerning the Millstone Power Station.

Sincerely.

Patricia L Acarnpora

MEMBER OF ASSEMBLY

CC: <dirrcomm OaoLcom>

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NUREG-1437, Supplement 22 A-228 July 2005
Appendix A

- nple"", a s uIv UIvlH:.>1U.Mu r-uWV1 olua"I

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Pane I

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From:

To:

Date:

Subject:

Wayne Burgess <wayneburgessasnet.nebt

NRC <MistoneEtSonrc.gov> _

TueJan1l,200510:4S9AM :- r &k/j ' 

Renewal of the Millstone Power Station '-

1.: ." -P' SY F :

January 11, 2005

To: MillstoneEISOnrc.gov

From: Wayne J. Burgess-President

Southeastern Connecticut Central Labor Council. AFL-CIO

V'7"' /40-' ;/

Re: Renewal of the Millstone Power Station operating license

MPS-33-1 The Southeastern Connecticut Central Labor Council. AFL-CIO has voted to support the renewal of the

operating license for Millstone Power Station.

Many of our members anc delegates have lived and worked In Southeastern Connecticut since Millstone

Power Station started unit one.The Power Station has had some problems over the years. However. we

believe the current management. DomInIon Nuclear. Inc has demonstrated responsible behavior, has

been a good member of the community and has worked to provide good jobs for citizens In Southeastern

Connecticut.

Therelore we support the license renewal of units two and three at Millstono power station.

$S=5/ .15' .t:

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July 2005

~-r

- C 4 .37, Supp et 2 - .I *-- U

A-229 .; NUREG-1437, Supplement 22
Appendix A

nitsioneu-io * renewafi r~age I

*; - 4.2/62 urI -

From:

To:

Date:

SubJect.

'8arbara Doyle 'badoyleocorncastnot>

<MillstoneElS Onrc.gov>

Tue, Jan 11, 2005 11:14 AM

renewal

MPS-34-1 Hello NRC stafl. I would like to not see a renewal of Units 2 & 3 at

the Millstone Power Plant site in CT.

MPS-34-2 Although I think that dry cask storage of radioactive waste at the plant is preferable to keeping the waste In a 'wetr pooL, the fact Is that

this Is not a long term solution to the problem of disposing of the

waste. We do not have a long term plan for dealing with the radioactive

byproducts of nuclear power plants, so I would prefer that we not renew

any nuclear power plant facility license.

Please keep In mind that any solution so lar proposed to dealing with

radioactive waste Is expensive and should be considered part of the

operating expense of any nuclear power plant. It is not a separate and

unrelated cost to the running of such a facility and should not be

presented to the public as so. I do not wish for my taxpaying dollars

In any way to continue to support the license of new or renewal of any

nuclear power facility.

Thank you. Barbara Doyle.

I/,• -

,-e,-js9 2 '-'--o 3

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=- 437.iSuppleme 2-2 t 3

NUREG-1437, Supplement 22 A-230 July 2005

I
Appendix A

um5stuulma - Millestone ructear rower mant Page 1

. I , ,, , , .- . . I , , ._

From: 'Arlene <typewel1OsbcglobaIlnet>

To: <MillstoneEIStnrc.gov> -

Date: Fri. Jan 14.2005 11:40 AM

Subject: Millestone Nucleir Power Plant

MPS-35-1 lam a former Long Island resident and I strongly oppose the relicensig ol the Miltestone Nuclear Power

MPS-35-2 Plant. Units 2 and 3 to the year 2045. However, should the license be renewed. I believe It Is Imperative

that the NCR expand the scope of its evacuation plant to a 50-mile radius to include an of Long Island. I

Implore you to consider this for the benefit and safety of the Long Island residents. '

Arlene FarInacct -

4812 W. 140th Street

Hawthorne. CA 90250 /*

Cg,5q B//15/

$75/ -W---

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July 2005 A-231- NUREG-i437, Supplement 22
Appendix A

*untsioneca - ino sumec Iane I -

J.. - A>4p -irFrom:

To:

Date:

Subject.

cCaseathome@aoi.com>

.cMllstoneElS~nrc.gov>

Fri. Jan 14.2005 3:43 PM

(no subject)

MPS-36-1 tam wnting to voice my strong objection to the Millstone rcense renewat

without making a plan for the evacuation of Long Istands north shore-within

the 10 mile radius of Millstone This is unacceptable. My e-mail. In case you wish to respond Is caseathome Oaol. corn.

0E

NUREG-1437, Supplement 22

-Ze:5~o - 6L9A -'O3

C 15 / - ro C& (<g I-ec

A-232 July 2005

I
Appendix A

wtIuecio- Mfi-tUtit ruwut riat - tU Mnesv tII Ll EuwaU - Liilist nelulwdla '-

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.. ;

4

fratim I I

MM _U_*

.. . ~ ~ ..

/.PC .

Frorn: RANDAZZO crafel @optonline.net>

To: <cMillstoneEIStnrc.gov> -

Date: Fri Jan 14,2005 4:28 PM

Subject: Millstone Power Plant 1 t0 MOies Oi1 U Sound - License Renewal

MPS-37-1 I arn a Long Island resident and I strongly oppose the reficensing of the Millestone Nuclear Power Plant,

MPS-37-2 Units 2 and 3 to the year 2045. However. should the license be renewed. I believe It Is Imperative that the

NCFi expand the scope or Hs evacuation plant to a 50-mile radius to Include alt of Long Island. I implore

you lo consider this for the benern and safety of the Long Island residents.

Janice Circo-Randazzo

213 Pine Road

Coram, NY 11727

-- G~ 7e 3

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July 2005 A-233 NUREG-1437, Supplement 22
Appendix A

-lY~~SA ,-raeu ,I

; ., .

From:

To:

Date:

VicBarb cvicbarb9@optonline net>

Marie Domenicl drrcomm e aol.com>. <MfillstoneEtS @nrc.gov>

Mon. Jan 17. 2005 4:27 PM

Sir:

MPS-38-1 I would like to protest your scheduling a vital public meeting on

operations at the Millstone nuclear plant without adequately notifying

the residents who would be effected If an accident should happen. I

read the New York Times every day. No notice was published. It looks

MPS-38-2 like you didn't want anyone to know there was a meeting. ItIs my

understanding that the Nuclear Commission In the State of Connecticut

have no plants for notification of residents who reside In a ten to

filty mile radius In the event o0 a nuclear matluncUon. A planfor evacuation of this area Is vital. Without a plan for viable evacuation,

the plant should be shut down.

Barbara & Victor DiPaola

vicbarb9Ooplonline.net

E~xitv; /

19,bAf

.0, =- /6- A. 6"e,

NUREG-1437, Supplement 22 A-234 July 2005
Appendix A

1Il13IUttIr10 - mirtswbU Nticl teaUlti t , -' rage 1,

J. . . ,

. . I ~ .

-: -/

,,e . JOr

From: <BeaconHA~aol.com>

To: <malstoneElS@nrc.gov>

Date: Mon. Jan 17,2005 5:05 PM

Subject: Millstone Nuclear Projects

MPS-39-1 I urge you to not allow the Millstone nuclear faclilties to operate for 8l

the safety, toxic waste. public health and national security reasons cited by

so rnany for so long end documented over the years by members ol the scientific

community who have no economic or other pecunlary Interests I the MIstoneo

proJects. E111 Garrett, 520 Savoy Street. Bridgeport, CT

- CC: - - <NancyBurtonEsqO aol.com>. .cupthesunocshore com>

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July 2005 A-235 NUREG-1437, Supplement 22
Appendix A

ILttttttritIa - MIUttLM INUUMtf MUtM=ts rn-age 1.

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ts86'

From:

To:

Date:

Subject:

<BeaconHA O aoLcom>

mrnklstoneEIS~nrcmgov>

Mon. Jan 17.2005 5:05 PM

Millstone Nuclear Projects

MPS-39-1 1 urge yu to not anow the MlWlstono nuclear faclfities to operate for all

the satety. toxic waste, public health and national security reasons cited by

so many for so long and documented over the years by members of the sclentific

community who have no economic or other pecuntary Interests In the Millstone

projects. Bil Garrett, 520 Savoy Street. Bridgeport. CT

CC: <NancyBIurtonEsq~aoI.cOm>. .upthesun~cshore.com>

C)

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NUREG-1437, Supplement 22 A-236 July 2005

I
Appendix A

*IICf~*D- ,OWn.,. fl Iw*I "-l*I rayt e I

4DO /e/,e

From:

To:

Date:

Subject:

Maureen and Valerie <rmaureenandvalerieOyahoo.com>

cMillstoneElSOnrc.gov> - --

Mon. Jan 31.2005 10:58AM - - - -

renewing of Millstone ric. -

MPS-40-1- We want to voice our concern about the renewal of the Millstone Power Plant license. We are strongly

opposed to this, and hope that you will consider closing the plant.

MPS-40-2 We are veryconcerned that there Is no apparant notification system In place .- we site the recent fire, and

site evacuation In Jan. 2005. There are no policies In places to notify neighboring states, this Is a huge

concern of ours. As residents of New Jersey. we would want to be fully advised, and alerted to when

public meetings are being held to dliscuss/debate the renewal of the license.-

Again, I urge you to refuse the renewal of the Millstone opereating Units 2&3

Sincerely. .

\'ValeieOB~riody'*'1 .'' a/jMaureen Swearingen

9 Delsey Road 67/v Z Y&/

Kendall Park, NJ 08824

732.398.9454

Please rie up to your mission statement: 0

"NRC's primary mission Is to protect pubrlic health and safety and the environment Irom the effects of

radiation from nuclear reactors, materials, and waste facllities.7

Do you Yahoo!?

Yahool Search presents -Jib Jab's 'Second Term'

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July 2005 A-.237 NUREG-1437, Supplement 22
Appendix A

. ........ 0, . ..tro I

,. o2S) -: 

From:

To:

Date:

Subject:

cTMJM19680aot.com>

.cMillstoneEISlnrc.gov>

Tue. Feb 1. 2005 11:00 AM

(no subject)

MPS-41-1 I have read the available Information sent to me about Millstone. I am deeply distressed that you would even consider extending the opening of this

facility. It seems that it would be common sense with all the other data in the

world about this type of situation, that you would have no reason to keep

this open or to extend the opening of IL

Please think about the future of our children and grand children and do the

right thing.

In God We Trust

Josephine

/.7 ;~,02,~ b -0/3

<I 5 t-3~~4 'eL~Ct_ we7)

NUREG-1437, Supplement 22 A-238 July 2005
Appendix A

0~g .

From:

To:

Date:

Subject:

John magnesi .rnagneslj2O03Qyahoo.cornm

amilostoneeisO nrc.gov>

Wed, Feb 9,2005 7.30 AM

License Renewal at Millstone ' :

I . I . -1.

. I

Dear Sir.

MPS-42-1 I wish to register my opinion that license renewal for Millstone nuclear power plant be delayed. Al the

parties who have concerns about this renewal have not been fully heard. These parties Include Long

Island communtlies, citizen groups and anti-nuclear activists. The health effects of this power plant may

not have been fully considered. As a consequence. I urge you to delay renewal of the license.

- Sincerely.

John Magnesl '-:

7 Partridge Run

-Wallingford, CT 06492

. , .

Cy~/"/? e%?'

Do You Yahool?

Tired of spam? Yahool Mal has the best sparn protection around

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July 2005 . A-239 , NUREG-1437, Supplement 22
Appendix A

irstisonet~m, * caoress Lorecion regaroing WstI~one ana rag*

From:

To:

Date:

Subject:

.c-lrrcommn~aol.ccm>

4MiiUlflsbnElS~nrc.gov>

Wed, Feb 23.2005 4:41 AM

Address Correction regarding Mifltione and-

^x!;,i.A

FT/9/S

Hello Mr. Emrch.

I have submitted my written comments regarding the re licensing of the

Millstone several many weeks ago and yesterday. I received communication from your office regarding sutlject: 'Response to Joshua Y. Horton, Southold Supervisor. Regarding Millstone

Power Station. UnIts 2 and 3 License Renewal Review' and found the NRC has an

Incomrct address for me. The purpose of this email to ask that you correct my

address to read as follows:,

Mario Domenici

330 Okftfeid Court

Mattituckc, NY II1952

MPS-43-1 In the future, when posting 'public meefirgs I recommend the NBC place your notlflcatlon* in no less than 3 newspapers: 1. NY Times

2. Newsday

3. Suffolk Thies

The Eastharripton Independent Is a free newspaper that Is distributed in local

supermarkets andIs not necessay a wellread newspaper. So.in fairness

to the residents of Long Island It would be prudent on your boWa to place

your public notifications In the 3 newspapers stated above. It you require contact Info on these newspapers. I wilt be happy-to provide that information.

Additionally, on January 12.I sent art email to Mr. Zalcman providing himt

with all the elected officials contact Information, from the Town Supervisor

all theway up toGovernor Palakito ensure thatfuture ,ourcalom were - made as appropriate. If you would lke acopy of that emailplease contatme.

Lastly. I ask that I be added as a contact name for future meetings that

will be conducted as It relates to Millstone.

Thanking you In advarnce for your attention to this matter.

Marie Domencll

631 298 0211

NUREG-1 437, Supplement 22A-4Juy20

,e -,ez b 5 r- 19.> " -Z')' 3

- /Y. ,, - r, 'A' Cez 4- )

A-240 July 2005

I
Appendix A

NRc FORM 655 . R t 7. -e U.S. NUCLEAR REGULATORY COULOSSION

NRC PUBLIC MEETING FEEDBACKI [11

Moeting Meeting Public Meeting to discuss the Draft Supplemental Environmental Impact

Date: 01/11/2005 -- Tlt: Statement for License Renewal at Millstone Power StaUitKT1its 2 and 3

In order to better serve the public, we need to hear from the meeting participants. Please take a few minutes to fll out

this feedback form and return It to NRC.

1. How did you hear about this meeting? Z

o NRC Web Page

Q RadZoTV

o NRC Martng List

9 Other___

.8Newspaper

2. . Were you able to fnd supporting information prior to - . -c

the me6etng?

No Somewhat

IPlease explain t2w

3. . Did the meeting achieve Its stated purpose? * ::0' 

0 -

Z/.

4. - Has this meeting helped you with your understanding - -0 -07

of the topic?

5. Were the meeting starting time, duration, and location 2 - reasonably convenient?

0 0 '

6. - Were you given sufficient opportunIty to ask questions - .- .-' - 0 . or express your views?

7. -Are ou satisned Overa wtth Me NRC staff who *.-- -- ' 3 - MpatETSDatUd I the E meeting? t y

COMUIENTS OFI SUGGESTIONS: "Thank you for an5vw

0 O

wing these questionr.

MP5-44

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A-241 ' NUREG-1437, Supplement 22
Appendix A

NRC FORU 955 ,,3 hoft,

Meeting

Date: 01/11/2005

4ib A.::g '0 U.S. NUCLEAR REGULATORY COUUISSION

NRC PUBLIC MEETING FEEDBACK

Meeting Public Meeling to dscuss the Draft Supplemental Environmental Impact Title: Statement for-Ucense Renewal at Millstone Power Station. Units 2 and 3

I1

In order to better serve the public. we need to hear from the meeting particpants. Please take a few minutes to fill out

this feedback form and return It to NRC.

1. How did you hear about this meetinh?

O NRC Web Page

o RadbtV

o NRC Mailing Ust

E Other

No Somewha :

yeas tPleaso exotstn below)

0 0 l'

i

I

2. Were you able to find supporting Information prior to

the meeting?

3. Did the meeting achieve its stated purpose?

4. Has his meeting helped you with your understanding

of the topic?

5. Were the meeting starting time, duration and location

reasonably convenient?

6. Were you given sufficient opportunity to ask questions or express your views?

7. Are you satisfied overall with the NRC staff who

pautlcated in the meeting?

COMMENTS OR SUGGESTIONS:

l Ml""

o 53--7 0

El

r- a0 E

o £" o

0 C-- 0

Thank you for answering these questions.

MPS-45-1

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Continue Comments on the reverse. > 7

OPT7ONAL

Name L /t! - j. Poro h4s Organlzation R etr X,4 "'Jsm"

TelephoneNo.. 5 -,19/- EMaE M vkh hereayofavAoMnlayo

Ad "memba'1of as NRC sk a, cooa da'oa

Please fold on the dotted fines with Business Reply side out. tape the bottom, and mall back to the NRC.

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cz-4-c- & .4, k Z. z-')

NUREG-1 437, Supplement 22 A-242 July 2005.
Appendix A

.. _

CONNEJCTICIUT COALITION AGAINST MITlSTONE

P.O. Box Niantic CT 06357 -.

- -www.srothballmillstone.or -

ANTI-MILLSTONE COALITION

REPORTS MOUNTING EVIDENCE OF

MILLSTONE LINK TO HIGH CANCER RATE

IN NEW LONDON COUNTY

.,FOR IMMEDIATE RELEASE - - -

JANUARY 11, 2005

Contact: Joseph J. Mangano Tel. 610-666-2985:-

Nancy Burton Tel. 203-938-3952

Michael Steinberg Tel. 860-739-7002

WATERFORD - Evidence is mounting of a scientific correlation

between routine radiation emissions from the Millstone Nuclear

Power Station and high cancer incidence in the surrounding area, the

Connecticut Coalition Against Millstone reported today.

MPS-46-1 Laboratory analysis of baby teeth donated by children with cancer

in the areas near the Millstone and Indian Point Nuclear Power Plants

found levels of radioactive strontium-90 more than twice as high as

found in teeth collected from other parts of the state, according to

Joseph J. Mangano, National Coordinator of the Radiation and Public

Health Project. -

OThe average level of strontium-90 concentration close to the

nuclear power plants was 6.16 picocuries per grai of calcium,

compared with 2.70 picocuries in other parts of the state,' Mangano

said.- -

5vz e f o o ICat -s =,Ip, -I. 4 - )

July 2005 A-243 NUREG-1437, Supplement 22
Appendix A

MPS-46-1 'For children suffering from cancer, the average level of strontium90 concentration was 7.03 picocuries per gram calcium,- Mangano

said.

Strontium-90 is a radionuclide routinely emitted by the Millstone

Nuclear Power Plant into the air and water,* said Mangano, who as

national coordinator of the Radiation and Public Health Project

(RPHP) has participated in analysis of baby teeth collected from

around the country. RPHP has published 21 articles in peer-reviewed

medical journals (including 4 on the tooth study), and five books,

since 1994.

'Strontium-90 mimics calcium and when it is taken into the body of

an exposed person it collects in the teeth and bones,' Mangano said.

MPS-46-1 OThe presence of strontium-90 elevated levels near the nuclear

power plants cannot be accounted for other than from their routine

releases of strontium-90,* Mangano said.

MPS-46-2 Mangano stated that cancer rates in the New London area, which

used to be below the state average, have risen steadily during the

period the Millstone nuclear reactors have been In operation,

beginning in 1970.

'in the 1950s and 1960s, cancer incidence in New London

County, where Millstone Is located, was 8 per cent below the state

rate," Mangano said. -After Millstone began operations in 1970. the

state rate rose steadily until it reached a level of 6 per cent above the

state rate in the late 1990s.'

*New London County's current cancer rate is the highest of all

counties in the state," Mangano said.

Mangano acknowledged that the Information about strontium-90

levels in baby teeth in Connecticut is based on a sampling of 37

teeth, and therefore the information is still of a preliminary nature. The

tooth-testing program is continuing to analyse baby teeth.

2

NUREG-1437, Supplement 22 A-244 July 2005
Appendix A

MPS46-3 In its most recent report of radiological emissions to the environment,

based on samplings taken in the year 2002, Dominion reported the

presence of strontium-9D in the milk of goats living two miles

downwind of Millstone.

'Despite Information to the contrary in its own reports, the owners

and operators of Millstone have denied that strontium-90 found in

goat milk near and downwind from Millstone has been coming from

their nuclear, reactors," said Michael Steinberg,.author of wMillstone

and Me," a book analyzing Millstone's radiological releases.

Stronbium-90 is only one of hundreds of radioactive waste

products Millstone releases into the air and water during routine

operations.

MPS46-4 Millstone has the third-highest'record of airborne radiation

releases to the environment of all nuclear power plants operating in

the United States according to Its own reports," said Mangano.

The official Tumor Registry maintained by the state of Connecticut

shows the region around Millstone has the highest incidence of

cancers known to be triggered by certain of the radionuclides

routinely released by Millstone, according to Mangaho.

MPS-46-5 According to the Coalition, Millstone radiological releases of tritium

- radioactive hydrogen - to the environment are increasing to all-time

highs. -

The Connecticut Coalition Against Millstone comments were

prepared for delivery to the U.S. Nuclear Regulatory Commission at a

proceeding today to consider the draft Environmental Impact

Statement (EIS) NRC staff prepared to assessenvironmental

consequences of extending the Millstone operating license an

additional twenty years.

MPS46-6 In its draft EIS, the NRC concluded that the agency need not

consider issues of human health as it relates to radiological

emissions from nuclear power plants undergoing relicensing because

3

July2OO5' A-245 NUREG-1437, Supplement 22
Appendix A

MPS46-6 an NRC guidance document released in 1996 discounted health

effects from nuclear power plant radiological releases.

"Millstone is poisoning our air and water and killing our children in

the year 2005,' said Nancy Burton, a founder of the Coalition, OWe do

not need its deadly megawatts. The community can no longer tolerate

the Millstone menace.-

The Coalition cited high cancer levels, environmental degradation and the threat of terrorism as causes for Millstone shutdown.

'Dominion sold itself to the people of Connecticut as a

conscientious environmental steward when it bought Millstone for $1.3 billion In 2001, Burton said.

MPS46-7 Yet, according to research by Public Citizen, a public-interest organization based in Washington, D.C., Dominion's record has

proved otherwise.

According to Public Citizen, in April 2003, a Dominion subsidiary agreed to pay $1.2 billion in a settlement with the U.S. Department of

Justice when it violated the Clean Air Act by increasing power- generating capacity of a huge coal-fired power plant in West Virginia without obtaining mandatory permits.

A year later, according to Public Citizen, Dominion paid a $500,000 civil penalty and had to offer a $4.5 million refund to its

customers after the U.S. Federal Energy Regulatory Commission

(FERC) caught the company violating federal regulations.

'When an outlaw company operates a killing machine that targets innocent families In our community, it Is time to demand that its

operations be terminated,' Burton said.

The Connecticut Coalition Against Millstone is an organization of

statewide safe-energy groups, Millstone whistleblowers and families.

4

NUREG-1437, Supplement 22 A-246 July 2005
Appendix A

it

*MWIaO N. wly Coolest. 1*

4- illuene ragv 9alick

Rowe Ferwy RoA

MaCldowJ. cm OC63SS ' ' '

. ,.1 I - . . : _..

-AAIII0uuuAuI

February 25, 2005 GAgrA 71'- 7

Chief. Rules Review and Directives Branch 4~;p% United States Nuclear Regulatory Commis!

Mail Stop T6-D59 -

Washington, DC 20555-0001 . . S , .

;ion Serial No.: 04-745

LPJG - R0

Docket Nos.: 50-336

! 50-423

- LUcense Nos.: * DPR-85

NPF-49

1\1

DOMINION NUCLEAR CONNECTICUT. INC. (DNC1

MILLSTONE POWER STATION UNITS 2 AND 3 :

LICENSE RENEWAL APPLICATIONS --

COMMENTS ON DRAFT SUPPLEMENT 22

TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT

On December i 2004, the Nuclear Regulatory Commission (NRC) issued Draft

Supplement 22 to the Generic Environmental Impact Statement (GEIS) regarding the

license renewal applications (LRAs) for Millstone Power Station Units 2 and 3.

Comments on the draft were solicited.

DNC has reviewed the draft and presents the following observations. Draft Supplement

22 fairly represents the environmental conditions associated with plant operation.

Furthermore, we concur with the overall conclusions concerning the Impacts associated

with the station's operation, and offer the attached comments and clarifications

concerning the content of the draft.

Should you have any questions regarding this letter, please contact Mr. William D.

Corbin. Director. Nuclear Engineering Department. Dominion Resources Services, Inc.,

at (804) 273-2365. ---

Very truly yours,- ; . - -

E. S. Grecheck - 4 - -

Vice President - Nuclear Support Services

. I J"'I r: : :--:  _1 ,. I . ., -- - --- ,

I

I- " I - ; _. .

Vas-.... '- ' : ','i!'. - . . z

Attachment: Comments on Draft Supplement 22 to th GElS for License Renewal

Commitments made in this letter None.

5- 5 / Oq e //-c 1 0 -,-

GusZ.<_ = .6 ctD e1, dec) & 

July 2005 - A-247 NUREG-1 437, Supplement 22
Appendix A

Serial No. 04745

Docket Nos.: 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Page 2 of 4

cc: U.S. Nuclear Regulatory

Commission

Region I

475 Allendale Road

King of Prussia. PA 19406-1415

Mr. V. Nerses

Senior Project Manager

U.S. Nuclear Regulatory

Commission

One White Flint North

11555 Rockville Pike

Mail Stop 8C2

Rockville, MD 20852-2738

Mr. S. M. Schneider

NRC Senior Resident Inspector

Millstone Power Station

Honorable Wayne L Fraser

First Selectman

P.O. Box 519

Niantic. CT 06357-0519

Mr. Stephen Page

Central VT PSC

77 Grove Street

Rutland, VT 06701

Honorable Elizabeth Ritter

CT House of Representatives

24 Old Mil Road

Quaker Hill, CT 06375

Mr. Denny Galloway

Supervising Radiation Control

Physicist

State of Connecticut - DEP

Division of Radiation

79 Elm Street

Hartford. CT 06106-5127

Honorable Christopher Dodd

US Senate

100 Great Meadow Road

Wethersfield, CT 06109

Ms. Catherine Marx

Governor's Eastern Office

P.O. Box 1007

171 Salem Turnpike

Norwich, CT 06360-1007

Mr. William Melnert

MMWEC -

P.O. Box 426

Ludlow. MA 01058-0426

Honorable Andrea Stillman

CT State Senate

5 Coolidge Court

Waterford, CT 06385

Honorable Ed Jutila

CT House of Representatdves

23 Brainard Road

Niantlc. CT 08357

Honorable Robert Simmons

US Congress

2 Courthouse Square

Norwich, CT 06360

Mr. Thomas Wagner

Town of Waterford

Town Planner

15 Rope Ferry Road

Waterford, CT 06385

Dr. Edward L Wilds

Director, Division of Radiation

State of Connecticut - DEP

79 Elm Street

Hartford. CT 06106-5127

NUREG-1437, Supplement 22 A-248 July 2005
Appendix A

Chairman Donald Downes

DPUC

10 Franklin Square

New Britain, CT 06051

Honorable Dennis L Popp

Chairman - Council of

Governments

Municipal Building

295 Meridian Street

Groton, CT 06340

Chief Murray J. Pendleton

Director of Emergency

Management

41 Avery Lane

Waterford, CT 06385-2806

Honorable Richard Blumenthal

Attorney General

55 Elm Street

Hartford, CT 06106-1774

Mr. John Markowlcz

Co-Chairman - NEAC

9 Susan Terrace

Waterford, CT 06385

Mr. Evan Woolacott

Co-Chairman - NEAC

128 Terry's Plain Road

Simsbury, CT 06070

Honorable M. Jodi Rell

Governor

State Capitol

Hartford, CT 06106

Mr. Mark Powers

4 Round Rock Road

Niantic, CT 06357

Mr. Jay Levin

23 Worthington Road

New London. CT 06320

Serial No. 04-745

Docket Nos.: 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Page 3 of 4

Mr. Jim Butler

Executive Director - Council of

Governments

8 Connecticut Avenue

'Norwich. CT 06360

Mr. Bill Palomba

Executive Director, DPUC

10 Franklin Square

New Britain, CT 06051

Honorable Ernest Hewett

State House of Representatives

29 Colman Street

New London. CT 06320

Honorable Terry Backer

CT House of Representatives

Legislative Office Building

Room 2102

Hartford, CT 06106

Honorable Kevin DelGobbo

CT House of Representatives

83 Meadow Street

Naugautuck, CT 06770

Honorable Thomas Hertihy

CT Senate

12 Riverwalk

Slmsbury, CT 06089

Honorable Cathy Cook

CT Senate, 18 District

43 Pequot Avenue

Mystic, CT 06355

Mr. Edweard Mann

Office of Senator Dodd

Putnam Park

100 Great Meadow Road

Wethersfield, CT 06109

July 2005 A-249' NUREG-1437, Supplement 22
Appendix A

Serial No. 04-745

Docket Nos.: 50-3361423

Comments on Draft Supplement 22 to the Generic Environmental Impact Statement

Page 4or4

Chairperson Pam Katz

CT Siting Council

10 Franklin Square New Britain, CT 06051

Mr. Ken Decko

CBIA

350 Churcn Street

Hartford, CT 06103

Hono-able Paul Eccard

Fiist Selectrman

Town of Waterford

15 Rope Feny Road

VWaterford, CT 06385

Mir. Richard Brown

City Manager New Lcndon City Hall

181 State Street

New London, CT 06320

Honorable Jane G. Glover

Mayor, New London

New London City Hall

181 State Street

New London, CT 06320

NUREG-1437, Supplement 22 A-250 July 2005
Appendix A

SN: 04-745

Docket Nos.: 50-336/423

- -- Subject: Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

COMMONWEALTH OF VIRGINIA )

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and

Commonwealth aforesaid, today by Eugene S. Grecheck. who is Vice President -

Nuclear Support Services, of Doninion Nuclear Connecticut. Inc. He has affirmed

before me that he Is duly authorized to execute and file the foregoing document in

behalf of that Company, and that the statements In the document are true to the best

of his knowledge and belief.

Acknowledged before me this j day o . 2005.

My Commission Expires: gool-

//2ts' / •zio,,

Notary Public

(SEAL)

July 2005 A-251 NUREG-1437, Supplement 22
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment/ Page 1 of 27

Attachment

Millstone Power Station Units 2 and 3

License Renewal Applications

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

for Ucense Renewal

Dominion Nuclear Connecticut

NUREG-1437, Supplement 22 A-252 July 2005
Appendix A

Serial No. 04-745

Docket Nos. 50-336/423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 2 of 27

MPS-47-1 Section 2.1.1 External Appearance and Setting

Page 2-2. Line 18

Draft GEIS Supplement 22 Statement

All development at Millstone Is situated south of this mostly below-grade rail ine.

Dominion Comment - - - -

After the word Millstone.' Insert 'except the training facility." such that the sentence reads:

'All development at iAUstone, except the training facility, Is situated south of this mostly

below-grade ran ine.'

MPS-47-2 Section 2.1.3 Coollna and Auxiliary Water Systems -

Page 2-7. Line 9

Draft GEIS Supplement 22 Statement

...cuts excavated from the bedrock at the eastem end of the quariy into Long Island Sound.

Dominion Comment

'eastem should be changed to 6southemn. such that the line reads:

...cuts excavated from the bedrock at the southern end -of the quany Into Long Island

Sound.

MPS-47-3 Section 2-1.3 Cooling and Auxiliary Water Systems .

Page 2-7. Unes 29-32

Draft GEIS Supplement 22 Statement

Service water Is withdrawn and diverted from the 'system bbfore the water enters the

condensers. This water Is used In a variety of applications, Including component cooling

(e.g., pump bearings and spent fuel pool water) and fire protection. A maximum of 2.3 m3 /s

(36f000 gpm) of senrlce water Is withdrawn.

July 2005 A-253 NUREG-1437, Supplement 22
Appendix A

Serial No. 04-745

Docket Nos. 50-336/423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 3 of 27

MPS-47-3 Dominion Comment

The configuration of the service water system Is somewhat different than that stated, and the

stated pump capacity Is that only for the three pumps at Unit 2. During normal operation, two

pumps at each unit are operating, for a total of 3.4 m3ls (54.000 gpm). Also, service water Is

used as backup for several other systems, but not for fire protection. This paragraph should

be changed to read:

*Service water Is also withdrawn Inside the Intake structures. This water Is used In a variety of applications, Including component cooling (e.g.. pump bearings and spent fuel pool water) and as an emergency backup supply for some systems. During normal operation. approxImately 3.4 m3/s (54.000 gpm) of service water Is withdrawn for both units.'

MPS-47-4 Section 2.1.4 Radioactive Waste Management Systems and Effluent Control Systems

Page 2-8. Ines 27-29

Draft GEIS Supplement 22 Statement

Millstono is in the process of obtaining a permit to construt a dry fuel storage area for

additional spent fuel assemblies.

Dominion Comment

Millstone has obtained the permit described above. It Is suggested that 'is In the process of

obtaining a permit to construct be changed to 'has constructed' so the sentence reads:

Millstone has constructed a dry fuel storage area for additional spent fuel assemblies.'

MPS-47-5 Section 2.1.4.3 Solid Waste Processinq

Page 2-12. line 3

Draft GELS Supplement 22 Statement

...volume was 24.3 m3 (858 ft)...

NUREG-1437, Supplement 22 A-254 July 2005

I
Appendix A

-. - - . I.:, .;

I . . . . I ,~.

. . . . w . '

MPS-47-5 Dominion Comment

Serial No. 04-745

Docket Nos. 50-336/423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 4 of 27

Change to:

,...volume was 243 m3 (8580 ft?)...

MPS-47-6 Section 2.1.5 Nonradloactive Waste Systoms g. I . 2-12. . .. U s 1 ' 1

Page 2-12, Uines 11-12

Draft GEiS Supplement 22 Statement

DomInIon has petitioned the CTDEP to be classified as a small-quantity generator because of

a reduction In the amount of waste generated at Millstone.

Dominion Comment

Although Millstone generates hazardous waste at the rate of a smatquantity generator, the

decision was made not to pursue dassificatlon as a small-quantity generator, In order to

maintain flexibility In storage and shipping. It is suggested that this sentence be deleted.

MPS-47-7 Section 2.1.5 Nonradloactive Waste Systems

Page 2-12. Unes 17-19

a Draft GEIS Supplement 22 Statement

Common types of hazardous waste generated at Millstone are lead acid sludges and

batteries, solvent rags, and sawdust contandnated with chemicals regulated under RCRA.

Dominion Comment

Lead acid batteries and sawdust contaminated with chemicals are classified as Connecticutregulated wastes. ihis sentence should be changed to the following:

*Common types o0 hazardous waste generated at Millstone are aerosol cans, paint-related

waste mateiials.iand solvent rags.

y2005 Jul2. A-255 NUREG-1437. SuDpleme . . Jul ant 22'
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 5 of 27

MPS-47-8 Section 2.1.6 Plant Operation and Maintenance

Page 2-12. line 37

Draft GEIS Supplement 22 Statement

Dominion assumes that an additional 60 employees will be needed...

Dominion Comment

Sentence should be changed to:

'Dominion assumes that no more than 5 additional employees will be needed...'

MPS-47-9 Section 2.1.7 Power Transmission System

Page 2-15, Line 2

Draft GElS Supplement 22 Statement

All personnel applying herbicides are required to process a valid applicator's license.

Dominion Comment

It is suggested that the word 'process be changed to 'possess: so that the sentence reads:

'All personnel applying herbicides are required to possess a valid applicators license.'

MPS-47-10 Section 2.2.2 Water Use

Page 2-17. Line 2

Draft GEIS Supplement 22 Statement

Additional minor amounts of ocean water are used for fire protection and other systems.

NUREG-1437, Supplement 22 A-256 July2005

I
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment / Page 6 of 27

MPS-47-10 Dominion Comment

Although ocean water can be used as backup for some systems. it Is not used In the fire -

protection system: The sentence should be modified as follows:

*Additlonal minor amounts of ocean water may be used as emergency backup for other

systems.

MPS-47-11 Section 2.2.2 Waler Use

Page 2-17, Unes 6-7

Draft GEIS Supplement 22 Statement

Dye tracer and modeling studies estinate that 20 percent of the Niantic River discharge goes

through the plant.

Dominion Comment

These studies determined flow characteristics during three-unit operation. It is estimated that

current two-unit operation results in approximately 15 percent of the Niantic River discharge

going through the plant The sentence should be changed to:

Dye tracer studies estimated that 20 percent of the Niantic River discharge went through the

plants during three-unit operation. It Is estimated that current two-unit operation results In

approximately 15 percent of Niantic River discharge going through the plants.'

MPS-47-12 Section 2.2.3 Water Quality

Page 2-17. Line 36

Draft GEIS Supplement 22 Statement

The NPDES pem2r, which Is renewed every five years, expired In 1997.

Dominion Comment

Change 'expired in 1997- to 'was set to expire In 1997 but remains In effect because a timely

renewal application was filed with the CTDEP so sentence reads:

July 2005 A-257 NUREG-1437, Supplement 22
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 7 of 27

MPS-47-12 'The NPDES permit, which Is renewed every five years. was set to expire In 1997 but

remains In effect because a timely renewal application was filed with the CTDEP.'

MPS47-13 Section 2.2.3 Water Quality

Page 2-18, Lines 7-8

Draft GEIS Supplement 22 Statement

Recent monitoring results show that the discharge quality occasionally exceeds pennit limits

Dominion Comment

It is suggested that the sentence be changed by adding 'There have been occasional

Instances when' before 'monitoring results,' substituting 'have been above' for 'show that

the discharge quarity occasionally exceeds' and adding 'These Instances have been property

reported In Millstone's monthly discharge monitoring reports to the CTDEP so the sentence

reads:

'There have been occasional Instances when monitoring results have been above permit limts (e.g.. total suspended solids). These Instances have been property reported In

Millstone's monthly discharge monitoring reports to the CTDEP.

MPS47-14 Section 2.2.3 Water Quality

Page 2-18. Line 24

Draft GEIS Supplement 22 Statement

... nay be present for no more than two hours In any one day.

Dominion Comment

After 'two hours.' Insert 'per unit,' so the sentence reads:

.. may be present for no more than two hours per unit in any one day.'

NUREG-1437, Supplement 22 A-258 July 2005
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 8 of 27

MPS.47-15 Section 2.2A Air Quality

Page 2-20, Unes 20-22

Draft GEiS Supplernont 22 Statement

Air emissions from these sources are subject to Connecticut General Statutes section 22a174-33 of the Regulations of Connecticut State Agencies (Connecticut Legislature 2003).

Dominion Comment

In addition to section 22a-174-33 (which regulates TIle V air permits), air emissions from site

sources are subject to other regulations. it Is suggested that this sentence read:

'Air emissions from these sources are subject to Connecticut General Statutes, various

sections of the Regulations of Connecticut State Agencies, Title 22a-174. 'Abatement of Air

Pollution, and various federal regulations. - - -

MPS-47-16 Section 2.2.5 Aquatic Resources

Page 2-20. Unes 28-29

- -Draft GEIS Supplement 22 Statement . _ '

Millstone Is located at Millstone Point, a small peninsula of land situated on the west shore of

Long Island Sound near Waterford, Connecticut.

Dominion Comment -; -

Change 'wesr to north, and change 'near to in,' so the sentence reads:

:Mllstone is located at Millstone Point. a small peninsula of land situated on the north shore

of Long Island Sound In Waterford, Connecticut'*

MPS-47-17 Section 2.2.5 Aquatic Resources

Page 2-20, Unes 38-39, and Page 2-21, Une 4.

July 2005 A-259 NUREG-1 437, Supplement 22
Appendix A

Serial No. 04.745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 9 of 27

MPS-47-17 Draft GEIS Supplement 22 Statement

...about 20 percent of the water discharged from the station from the Niantic River could be

passed through the Millstone cooling water system under three-unit operation...

Dominion Comment

Delete 'from the station, and add 'and about 15 percent under two-unit operation' to the end

of the sentence, so the sentence reads:

...about 20 percent of the water discharged from the Niantle River could be passed through

the Millstone cooling water system under three-unit operation, and about 15 percent under

two-unit operation...'

MPS-47-18 Section 22.5.1 General Water Body Characteristics

Page 2-22. Unes 12-15

Draft GEIS Supplement 22 Statement

Millstone Point lies on the western shore of Long Island Sound, near the mouth of the sound.

This area of Long Island Sound experiences a safinity of approximately 23 paels per thousand. Salinity Is Influenced by the presence of three major divers. the Thames, the

Housatonic. and the Connecticut. T7ese ries flow Into the Sound in the vicinity of the site.

Dominion Comment

It Is suggested that wyestem shore' be changed to 'eastem end,' that '23' be changed to

'26-30. and that 'These' be changed to -The Thames and Connecticut,* so the sentence

reads:

MiAfstone Point lies on the eastern end of Long Island Sound, near the mouth of the sound.

This area of Long Island Sound experiences a salinity of approximately 26-30 parts per

thousand. Salinity Is influenced by the presence of three major rivers: the Thames. the

Housatonic, and the Connecticut The Thames and Connecticut rivers flow Into the Sound In

the vkity of the site.'

NUREG-1437, Supplement 22 A-260 July 2005

I
Appendix A

Serial No. 04-745

Docket Nos. 50-336/423

Comments on Draft Supplement 22 to the

: .Generic Environmental Impact Statement

- ; Attachment I Page 10 of 27

MPS-47-19 Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish

Species

Page 2-24. Une41 -

Draft GEIS Supplement 22 Statement

...and the northem Atlantic cost of the U.S.

Dominion Comment -

Change cost to coastMPS-47-20 Section 2.2.5.5 Ponulation Trends Associated with -Impirtant Fish and Shellfish

Species

Page 2-25. Une 28

Draft GEiS Supplement 22 Statement - . -

IndMdual females can produce up to 500,000 eggs.

Dominion Comment ' - - -

It Is suggested that the sentence be changed to read:

'Individual females can produce up to 2,500.000 eggs, but 500,000 eggs Is an approximate

-- -awraged

MPS-47-21 Section 2.2.5.5 Population Trends Assoclated with Important Fish and Shellfish

Species

Page 2-25. Une 36 and Page 2-26, Flgure 2-6. * -

; *. Draft GEIS Supplement 22 Statement --

.. reporting years (Fgture 2-6) (NOAA 1998; MacLeod 2003; National Marine -Fisheries

Service...

July 2005 A-261 NUREG-1437, Supplement 22
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 11 of 27

MPS47-21 Dominion Comment

It Is suggested that Gottschall et al. 2003 be added to the reference list for Figure 2-6 on line 36, and In the figure Itself. Gotschall et al. Is the citation for the CTDEP Long Island

Sound Trawl Survey.

MPS47-22 Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish

Soecies

Page 2-26. Unes 4-8

Draft GEIS Supplement 22 Statement

According to NOA, 'The continuing low levels of landings, catch per unit effort Indices and

survey Indices suggest that winter flounder abundance in the Gulf of Maine has been reduced

substantially. Future Improvemnents In the condition of the stock wiff depend on decreases In

exploitation in both the recreational and commercial fisheries, and on improved recruitment.

The stock Is at a low biomass level and Is considered to be exploited) (NOAA 1998).

Dominion Comment

It Is suggested that the following Information regarding the Southern New England stock be

added to this paragraph, or as an additional paragraph:

YWith regard to current winter flounder stock abundance, NEFSC (2003) stated that the Southern New England/Mid-Atlantic winter flounder stock complex has been overfished and overfishing Is continuing to occur. The current assessment provided a much more pessimistic evaluation of stock status than the previous assessment made In 1998.

Recruitment to the winter flounder stock has been below average since 1989. and indications

are that the 2001 year-class Is the smallest In 22 years.'

The reference for this statement Is:

NEFSC (Northeast Fisheries Science Center). 2003. B1. Southern New England/Mid- Atlantic (SNE/MA) winter flounder. Pages 139-220 in Report of the 36ah northeast regional stock assessment workshop (SAW): stock assessment review committee (SARC) consensus

summary of assessments. NOANNational Marine Fisheries Service, Woods Hole, MA.

Accessed via:

httrn/Avww.nefsc-noaa.aovlnefscloublicationslcrdlcrdO3O6

NUREG-1 437, Supplement 22 A-262 July 2005
Appendix A

Serial No. 04-745

Docket Nos. 50-336/423

Comments on Draft Supplement 22 to the

- - Generic Environmental Impact Statement

- - ;Attachment I Page 12 of 27

MPS47-23 Section 2.2.5.5 Population Trends Associated with Important Fish and Shellfish

Species

Page 2-28, Unes 15-16

Draft GEIS Supplement 22 Statement

... wth comrnrdat harvests over the past seven years for tho Atlantis seaboard fm ang~ng 

approximatlay 259 to over 300 MT (286 to 331 tons)...

Dominion Comment

Change Atlantis to Ailantfc Also. all of the numbers In this sentence should be followed

by 'x 10'.:

MPS47-24 Section 2.2.5.5 Ponulation Trends Associated with Important Fish and Shellfish

Page 2-28, Line 25

Draft GEIS Supplement 22 Statoment

The stverslde (Menidia menid;a. family Athernidae) Is a small...

Dominion Comment

Two different species of silverside are found In the area. It Is suggested that the sentence be

changed to:

'The silversides (Menidia menldiaiMenidia beryllina, family Atherinidae) are small.."

MPS47-25 Section 2.2.5.5 Ponulation Trends Associated with Important Fish and -Shellfish

Species

Page 2-28. Une 32

July 2005 A-263 .- NUREG-1 437, Supplement 22 *
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment / Page 13 of 27

MPS-47-25 Draft GEIS Supplement 22 Statement

Regional abundance data are not available.

Dominion Comment

Dominion notes that Gotschall et al (2003) observed sImilar fluctuations. without trend

throughout Long Island Sound.

MPS-47-26 Section 2.2.5.6 Other Important Aquatic Resources

Page 2-31. Une 8

Draft GEIS Supplement 22 Statement

... bamaclos~ tMe algae Fucus spp., the red alga Chondrus spp., and...

Dominion Comment

It Is suggested that this sentence include Ascophyllunt nodosurm, and that It read:

'...bamnades, the brown algae Fucus spp. and Aso~phyllum nodosum. the red alga Chondrus

cdfspus. and...

MPS-47-27 Section 2.2.5.6 Other Imp~ortant Aquatic Resources

Page 2-31. Una 22

Draft GMlS Supplement 22 Statement

... and the bivalve mollusc Nuculana annulate...

Dominion Comment

Change'Nuculana to'Nucula.'

NUREG-1 437, Supplement 22 A-264 July 2005

I
t

tI

I

f Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment Page 14 of 27

MPS-47-28 Section 2.2.5.7 Threatened or Endangered Aguatic Species

Page 2-33. Une 9

Draft GEIS Supplement 22 Statement

Adult-sized (10 cm (6 or niore n.D sturgeon are occasIonally seen...

Dominion Comment

Dominion believes that the Intent was to characterize adult-sized sturgeon as 6 feet long,

rather than 6 Inches.

MPS-47-29 Section 2.2.6.1 Site Terrestrial Resources > - -

- Page 2-36. line 10 ; I 

Draft GEIS Supplement 22 Statement

... 173 fledglings have been produced overthis period. -

Dominion Comment - -.

As of the present time, the number of fledglings produced at Millstone stands at 186.

MPS-47-30 Section 2.26.1 Site Terrestrial Resources

Page 2-36. line 14

Draft GEIS Supplement 22 Statement

There are 18 specIes listed by FWS or the state of Connecticut as being known to occur on

the site. -'

July 2005 . A-265 - NUREG-1437, Supplement 22
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment / Page 15 of 27

MPS-47-30 Dominion Comment

Dominion belleves this sentence refers to the 18 species listed in Table 2-3. Some of those

species have been observed on the site or along the transmission lines, and some have not

been observed. but may occur. It is suggested that the sentence be changed to:

There are 18 species listed by FWS or the State of Connecticut that have either been

observed on the site or have the potential to occur In the area or along transmission lines.*

MPS-47-31 Section 2.2.6.1 Site Terrestrial Resources

Table 2-3

Draft GEIS Supplement 22 Statement

This table lists terrestrial species known to occur or that potentially occur at Millstone or along

the transmission lines.

Dominion Comment

Dominion notes the following:

* As of June 2004. the Cooper's hawk Is no longer listed by the State of Connecticut.

* The piping plover Is listed as 'threatened' by the State of Connecticut.

* Dominion Is unable to find any citation by the State of Connecticut that lists the New

England cottontail as either threatened or endangered. * The seabeach sandwort Is listed by the State of Connecticut as a special concern'

species.

MPS-47-32 SectIon 2.2.8.1 Housing

Page 2-44, One 1

Draft GEIS Supplement 22 Statement

...while another 200 live in Niantic and East Ume.

NUREG-1437, Supplement 22 A-266 July2005

I
Appendix A

. , .

. .

. ...

... . . - . . - .-

: - - .: . . ., --. .. ;- -

.. . . . .. . .

MPSX7-32 Dominion Comment

Serial No. 04-745

Docket Nos. 50-336/423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 16 of 27

Change 'Llme to OLyrne.'

MPS-47-33 Section 2.2.8.2 Public Services

Page 2-47, ines 10-12 'L ,,~

Draft GEIS Supplement 22 Statement . - - ;

A new water supply line was constructed In 2000 to supply Mlstone, and this line replaced

the use of two shallow low-)4eld wells that had been used to Inigate ball fields and supply

concession stands on the Millstone site licensed to Waterford. . . .- , ' ' ,, ' * '

Dominion Comment , . _ . ,

It Is suggested that this paragraph be replaced with the following clarification:

'A new water supply line was constructed In 2000 to supply a concession stand at the ball

fields licensed by Millstone to Waterford. The stand had been suppiled by a shallow low-yield

well, which continues to be used to Irrigate the ball Selds on a seasonal basis.'

MPS-47-34 Section 2.2.8.5 Demography

Page 2-55, LIne 30

Draft GEIS Supplement 22 Statement

Source: Dominion 20004a

Dominion Comment ,

Delete a zero in the date of the citation. '.

MPS-47-35 Section 2-2.8.5 tDemoqraphv

Page 2-56. Line 35

July 2005 A-267' NUREG-1437, Supplement 22
Appendix A

. _

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 17 of 27

MPS-47-35 Draft GEIS Supplement 22 Statement

...after September 11. 2000...

Dominion Comment

Change '2000 to '2001.-

MPS-47-36 Section 2.2.9.1 Cultural Backqround

Page 2-60, Une 25

Draft GEIS Supplement 22 Statement

...Park overlooking the Thames River about 8kan (5 mt) northwest of Millstone.

Dominion Comment

Change 'northwes' to'northeast.'

MPS-47-37 Section 2.2.9.1 Cultural Backaround

Page 2-63, Une 16

Draft GEIS Supplement 22 Statement

Actual power generation began In 1975.

Dominion Comment

Unit 1. which Is not the subject of this report, began generating power In 1970. It Is

suggested that 'at Unit 2' be Inserted so sentence reads as follows:

'Actual power generation at Unit 2 began In 1975.'

NUREG-1437, Supplement 22 A-268 July 2005
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment / Page 18 of 27

MPS-47-38 Section 2.3 References

Dominion Comment

It Is suggested that the following new references be added to this list. as discussed In

comments above:

iGottschali, K.F., D.J. Pacileo, and D.R. Molnar. 2003. Job 2: Marine finfish survey. Part l:

Long Island Sound trawl survey and Part II: estuarine seine survey.' Pages 41-149 In: A

study of marine recreational fisheries In Connecticutt CT Dept of Envir. Prot., Bureau of

Natural Resources. Fisheries Divislon.'

and

'NEFSC (Northeast Fisheries Science Center). 2003. B1. Southern New England/MidAtlantic (SNE/MA) winter flounder. Pages 139-220 in Report of the 36k northeast regional

* *stock assessment workshop (SAW): stock assessment review committee (SARC) consensus

-summary of assessments. NOAA/National Marine Fisheries Service, Woods Hole, MA.

* Accessed via:' .

httDpl/www.nefsc.noaa.oov/nefsclDublications/crd/crdO3O6

* MPS-47-39 Section 4.1 Coollna System

Page 4-7. lines 38-39

Draft GEIS Supplement 22 Statement

The barierprevents fish from entering the quany. Since Instaftedon of the fish barriers, the

- licensee has not observed any fish ktis related to the station discharge. -

Dominion Comment

As discussed In section 4.1.3, page 4-28. lines 26-27, temperatures within the quarry

occasionally exceed lethal temperature thresholds for some species. Some periodic, smallerscale fish kills have occurred due to themnal stiess for fish that entered the quariy as

eggs/larvae, as juveniles, or during barrier maintenance activities. None of these

occurrences have been of a magnitude that resulted In an Impact to source populations, and

they have been confined to the quany. The sentences should be modified as follows:

July 2005 A-269 ; NUREG-1437, Supplement 22
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 19 of 27

MPS-47-39 The barrier Is designed to prevent fish from swimming into the quarry. Since installation of

the fish barriers, the licensee has not observed any gas bubble disease-related fish kills

related to the station discharge.'

MPS-47-40 Section 4.1.1 Entrainment of Fish and Shellfish In Early Life Stages

Page 4-10. lines 17-19

Draft GEIS Supplement 22 Statement

Licensees are required to demonstrate compliance with the Phase it performance standards

at he time ofrenewal of their NPDES permit

Dominion Comment

.are' should be changed to 'will be, and 'at the time of renewal of their NPDES permit

should be changed to 'in accordance with the provisions of the new rule' so the sentence

reads as follows:

'Licensees will be required to demonstrate compliance with the Phase II performance

standards In accordance with the provisions of the new rule.'

MPS-47-41 Section 41.1 Entralnment of Fish and Shellfish In Early Life Staces

Page 4-10. UnLes 19-21

Draft GEIS Supplement 22 Statement

Licensees may be required as part of the NPDES renewal to alter the Intake structure,

redesign the coofing system. modify station operation, or take other mitigative measures as a

result of this regulation.

Dominion Commont

Delete Me words 'as part of the NPDES renewar so the sentence reads as follows:

'Ucensees may be required to alter the intake structure, redesign the cooling system. modify

station operation or take other mitigative measures as a result of this regulation.'

NUREG-1437, Supplement 22 A-270 July2005

I
-Appendix-A

Serial No. 04-745

Docket Nos. 50L-336/423

Comments on Draft Supplement 2-2 to the

Generic Environmental Impact Statement

Attachment I Page 20 of 27

MPS-47-42 Section 4.1.1 Entrainment of Fish and Shellfish In Early Life Stages

Page 4-13,.Table 4-4

Dominion Comment

-The 2003 Annual Report (Dominion 2004b) contained minor changes to the data In this table.

--- Also. the data columns are eac x0.Iisuggested that the table be replaced with the

following:

r.

i I.

.1 , . .

- I . 7 . . .

.. i, 7 .

July 2005 A-271 NUREG-1 437, Supplement 22
Appendix A

Serial No. 04-745

Docket Nos. 50-336/423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 21 of 27

MPS-47-42 Table 4-4

Estimated Numbe of Anchovtes. Wnter Flounder. American Sand Lance, Grubby, and Atanic

Menhaden Larvae Entrained Each Year from 1976 Through 2003 at Millston. and the Volume of

Codino Water on Which the Entralnment Estimates Were Based (From Dominion r2004bfl)

Anchovies Winter Flounder American Sand Grubby Atfantic Menhaden

Lance

Year No. Volume No. Volume No. Volume NO. Volume No. Vohune

entrained (i- entrained {m') eftatne (mi)b entrained (min)' entrained (mn)'

(XIOI (10h (XtO' E10 (X10) r1061- (XI (X 100 (XI ) 10I

1976 381 738 121 629 - - - - 3 798

1977 418 821 29 444 01 954 30 489 2 773

1978 1t5 912 80 390 178 709 It I S4 3 621

1979 805 788 44 343 110 919 20 546 <t 716

1980 67? 633 168 562 I1I 960 32 699 2 643

1981 1.452 860 45 373 74 620 42 408 2 711

1982 451 635 184 838 27 932 48 648 14 743

1983 623 691 211 541 30 902 54 828 19 564

1984 169 801 84 508 18 835 38 524 4 557

1965 693 697 8o 469 a 712 35 527 u 521

19t8 1.096 1.208 123 1.064 4 1.5T7 53 44 5 1.217

1987 119 1.332 165 t.193 30 1.712 51 1.144 2 893

1988 388 1.790 184 1.173 74 1291 112 1.132 6 791

1989 51S 1.445 167 889 42 1.511 67 857 208 1.420

1990 981 1.483 133 1.174 39 1,607 47 098 33 t.367

1991 4S5 899 116 750 7 1.278 31 760 56 802

1992 157 1.091 492 1.076 19 1.302 76 1.293 51 1220

1993 214 1.221 42 t87 46 1.801 51 1.15? 21 1.126

1994 507 1.033 173 920 58 899 58 43 68 8s8

1995 171 696 214 1.006 90 1.532 5r 996 88 997

1998 24 138 51 472 18 7 41 46? 23 92

1997 17 145 6s 173 3 212 28 154 5 135

1998 64 40 84 358 11 440 22 300 33 615

1999 157 1.119 148 748 14 880 49 820 124 .377

2000 75 875 333 1,003 8s 1.459 47 754 468 1.571

2001 26 1.031 377 963 13 1.008 178 721 143 908

2002 28 881 119 8810 6 760 33 875 1A54 1.088

2003 - 434 1.096 19 725 153 890 -

(a) Includes data from December of the previous calendar year.

(b) Volume was determined from the condenser and service cooling water flow at Millstone during

the season of occurrence for each taxon.

NUREG-1 437, Supplement 22 A-272 July2005

I
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 22 of 27

MPS47-43 Section 4.1,1 Entrainment of Fish and Shellfish In Early Life Staaies

Page 4-14, Table 4-5

Dominion Comment

The 2003 Annual Report (Dominion 2004b) contained minor changes to the data In this table.

It Is suggested that the table be replaced wth the followingK'

Table 4-5. Estimated Number of Cunner, Tautog, and Anchovy Eggs Entrained Each Year

from 1979 through 2002 at Millstone and the Volume of Cooling Water on Which

the Entrainment Estimates Were Based (Frorn Dominion r2004bl).

Cunner Tautog Anchovies

Year No. Volume No. Volume No. Volume

Enrained (m) entrained (m Entrained {m)a

(XIo) (X1o) (X10') (XIO) (X1O) (x10)

1979 1.055 . 423 445 - 680 323 -383

1980

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

1,640

1.535

2074

.1 888

2,089

2,809

2.855

4,082

4.294

4.306

3.634

4.116

2.648

5.379

6.099

5.524

871

569

577

1i963

4,800

4.339

3.340

677

620

755

- .462

532

737

1,795

1,713

1.800

1.436

r 1.689,

1.223

1.509

1.492

1.381

1.198

256

185

718

1.222

1254

1.416

1,188

962

1.353

1.248

1.019

1,S02

1.717

3.747

3.575

2.693

3.001

2,100-

1.513

1.341

2.048

1.989

2.481

312

105

494

1.173

2.149

3.015

2.040

773

620

719

-627

SS9~

774

1.795

1.713

1,510

1,641 - -

1.214

1.492

1.381

-1.198 -

256

134

709

1t222

1.369

1.416

1.188

87

285

210

-411

.883

26

523

31

1S

5

27

105

18

228

1TS

, 29

4

'Cl

- 47

I

'1

*ct

359

583

801

377.

453

* - 441

772

740

-905

632

.724

538

648

626

867

- -737

114

92

376

339

:- 849

635

750

(a) Volume was determined from the condenser cooling-water flow at Millstone duning the season

of occunence for each taxon. r -,,..-.

July 2005 ! A-273 - NUREG-1437, Supplement 22
Appendix A

.

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 23 of 27

MPS-47-44 Section 4.1.1 Entrainment of Fish and Shellfish In Early Life Stages

Page 4-16, Line 1

Draft GEIS Supplement 22 Statement

.. nonentralned, late stage larvae from reaching reproductive maturity.

Dominion Comment

It Is suggested that 'and subsequent juveniles' be Inserted after larvae, so the sentence

reads:

-... nonentrained, late stage larvae and subsequent Juveniles from reaching reproductive maturity.'

MPS-47-45 SectIon 4.1.1 EntraInment of Fish and Shellfish In Early Life Stages

Page 4-18, line 17

Draft GEIS Supplement 22 Statement

...coolng water entrained through the cooling system, the number of eggs entrained...

Dominion Comment

It Is suggested that 'eggs' be changed to larvae.'

MPS-47-46 Section 4.1.2 Implngement of Fish and Shellfish

Page 4-22, lines 8-10

Draft GEIS Supplement 22 Statement

Liensees are required to demonstrate compliance with the Phase II perfomance standards

at the time of renewal of theirNPDES permit

NUREG-1437, Supplement 22 A-274 July 2005
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 24 of 27

MPS-47-46 Dominion Comment

'are should be changed to will be,. and 'at the time of renewal of their NPDES permit'

should be changed to 'in accordance with the provisions of the new rule so the sentence

reads as follows:

*ULcensees will be required to demonstrate compflance with the Phase It performance

standards In accordance with the provisions of the new rule.'

MPS-47-47 Section 4.1.2 Impingement of Fish and Shellfish '

Page 4-22. lines 10-12

Draft GEIS Supplement 22 Statement

Lkensees may be required as part of the NPDES renewal to after the Intake stfrcture.

redesign the coohing system, modify station operation, or take other mitigative measures as a

result of this regulation.

Dominion Comment

Delete the words 'as part of the NPDES renewar so the sentence reads as follows:

*Lcensees may be required to alter the Intake structure, redesign the cooling system, modify

station operation or make other mitigative measures as a result of this regulation.

MPS-474B Sectlon 4.12.1 Implngament Monitoring

Page 4-24, Table4-6 4: -'

Dominion Comment

Dominion believes that the correct reference for this table is Jacobson et al (1998). See the

comment below for SectIon 4.10 for the complete reference. --

Also, on line 18, the species name for the rock crab Is irwratus.

I .

July 2005 - A-275 NUREG-1437, Supplement 22
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment J Page 25 of 27

MPS-47-49 Section 4.1.3 Heat Shock

Page 4-29, Lines 9-15

Dominion Comment

Dominion offers the following minor edits:

Une 9, change 'concorta'to 'contoda.'

Line 10. change 'gragi7e' to 'ragile,' and change 'Saragassum gilipendula to 'Sargassum

filipendula.-

Une 13, change abundance' to 'nodal growth.'

LUne 15. change 'abundance to 'growth.

MPS-47-50 Section 4.4.2 Public Services: Public Utility Impacts During Operations

Page 4-40. Lines 17-18

Draft GEIS Supplement 22 Statement

Millstone's 2000 to 2001 potable water usage avenged 1.257 X 10e L per day (3.320 X 10'

gpd).

Dominion Comment

Change 3.320 X 108 gpd to '3320 X 105 gpd.'

MPS-47-51 Section 4.6.2 Terrestrial Species

Page 4-52. Unes 33-34

Draft GEIS Supplement 22 Statement

Both the bald eagle (Haliaeetus leucocephalus) and the piping plover (Charadnus melodus)

are known to occasionally use the Millstone site.

NUREG-1437, Supplement 22 A-276 July 2005
Appendix A

- . - . t

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment I Page 26 of 27

MPS-47-51 Dominion Comment

To Dominion's knowledge, the piping plover has not been observed on the Millstone site.

Dominion believes the Intent may have been to name the roseate term. which has been

observed on the site. It is suggested that the sentence be changed to:

-Both the bald eagle (Hailaeetus leucocephalus) and the roseate tern (Stema dougallil) are

known to occasionally use the Millstone site.'

MPS-47-52 Section 4.10 References

Page 4-62

Dominion Comment -

Add the following reference, as discussed above:

'Jacobson, P.M., E. Lorda, D.J. Danhia, J.D. Miller. CA Tomichek, and RA Sher. 1998.

Studies of cooling water Intake effects at two large coastal nudear power stations In New

England. In Proceedings of a workshop on Clean Water Act Section 316(b) Technical Issues

held at the Coolfont Conference Center, Berkeley Springs. WV, September 22-23, 1998.

Electric Power Research Institute, Palo Alto, CA EPRI Technical Report.'

MPS-47-53 Section 8.1 No-Action Alternative

IPage 84, Unes 26-27 I .. - .. .. $ ..

Draft GEIS Supplement 22 Statement

When the plant stops operating, there will be a reduction I use of groundwater.

Dominion Comment

The station Itself does not use groundwater. The only use of groundwater Is that used by the

town of Waterford for seasonal Irrigation of the ball fields. Therefore, closure of the plants

would not necessarily result In a reduction In the use of groundwater.

July 2005 A-277' NUREG-1437, Supplement 22
Appendix A

Serial No. 04-745

Docket Nos. 50-3361423

Comments on Draft Supplement 22 to the

Generic Environmental Impact Statement

Attachment / Page 27 of 27

MPS-47-54 Section 8.2.5.10 Utillty-Sponsored Conservation

Page 8-50. LUne 18

Draft GEIS Supplement 22 Statement

Dominion participates in State-wide residential, commerilal, and industrfal pregrams to

reduce...

Dominion Comment

Dominion Is not the local distributor of electricity. It Is suggested that 'Dominion participates

In be replaced with 'Connecdcut has so the sentence reads:

'Connecticut has State-wide residential, commercial, and industrial programs to reduce...'

MPS-47-55 Atnondix H

Page H-1. Unes 17-18

Draft GElS Supplement 22 Statement

...or were related to a reactor coolant pump (RCP) seat loss of coolant accident (LOCA).

Dominion Comment

loss of coolant accident (LOCAr should be replaced with 'dependency on charging pumps'

so the sentence reads:

...or were related to a reactor coolant pump (RCP) seal dependency on charging pumps.'

NUREG-1437, Supplement 22 A-278 July 2005

I
Appendix A

.. - , lep -

. ~ ~ ~ .o 5 / o - -

_

Jean M. Thorsen -

4 Bay View Avenue -

Old Saybrook, CT06475.

69 744~7

Chief, Rules and Directives Branch

Division of Administrative Services

Office of Administration

Mailstop T-6D 59

U. S. Nuclear Regulatory Commission

Washington, D. C. 20555-0001

February 20, 2005

Re: License Renewal Millstone 2 & 3

Dear Sir.

I attended the hearing on January 11, 2005 in Waterford, CT concerning the license

renewal for Millstone. It appeared to me that your experts did an excellent job for

their client, the Department ofEnergy.

MPS-48-1 In their comparisons of alternative methods of electricity production, I could not find

a chart showing total dollar costs for production by the various alternative means.

When considering environmental costs, I feel that nuclear waste and the production

of depleted uranium are the most undesirable. The cost of electricity keeps rising

for Connecticut residents. As a citizen of this state I would prefer to pay more if the

MPS-48-2 power came from more environmentally friendly method of generation. Iberefor, I

hope you will not renew this license.

Sincerely,

M. Thorsen

5 ,,°/cvy L

.5- ,Ir e-.v e-,, m R- -I 3 Go= ta..Ac CAte.45

July 2005 A-279 -. NUREG-1437, Supplement 22
Appendix A

| 1 Doris Doi Menr~da- doa-ReotN Report Number b NUREG-1437. Supplement .. 22

Frorm: saintrobert csaintrobertncomcastnetb

To: <opaOnragovv

Date: 2/28/05 9:01 PM

SubjecL Report Number NUREG-1437. Supplement 22

Please see the attached comrments.

Robert Fromer

Page II

/aI ). AAw-ff-

'311A/4AO

,I, >-- 7,1137

G 7 Suppeme /2t2

NUREG-1437, Supplement 22

6" ... CS

A-280 July 2005

I
Appendix A

P.O. Box 71

Windsor, Cr 06095

February 28,2005

Chief -

Rule Review and Directives Branch

US. Nuclear Regulatory Commission

MailstopT-66D59

Washington, DC 20555 1

-Re: Draft Report For Comment on Generic Environmental Impact Statement for

-License Renewal of Nuclear Plants, Regarding Millstone Power Station, Units

2 and 3, NUREG-1437, Volumes land 2, Supplement 22

Dear Chief Rule Review and Directives Branch: K

-Itihe problem at hand, which is that centrally generated eectricity is a vulnerable genie.

In order to be used it must travel on an ugly, complex and inefficient labyrinth of wires and

substations Even from a security view (national or otherwise) such a fragile system is suicide."

Gordes, Hartford Courant Letter to the Editor, February 1978.

Dominion his not provided a comparative analysis and assessment o life cycle energy.

consumption to determine that re-licensing of Millstone is the preferred option. Nor, has

Dominion considered cumulative alternatives (ife., energy sources) to meet the current and

future energy demands.

A. INTRODUCFION

The United States Nuclear Regulatory Commission ('NRC') considered the

environmental impacts of renewing nuclear power plant operating licenses ("OsW) for a 20-year

period in its Generic Environmental Impact Statementfor License Renedal of Nuclear Plants (GELS),

NUREG-1437, Volumes I and 2, and codified the results In 10 Code of Federal Regulations

(CFR) Part 51. In the GEIS (and Its Addendum 1), the staff identifies 92 environmental issues

and reaches generic conclusions related to environmental impacts for 69 of these issues that

* - apply to all plants or to plants with specific design or site characteristics. Additional plantspecific review is required for the remaining 23 issues. These plant-specific reviews are to be

included in a supplement to the GEIS.' [GEIS, p. iii.)

Tlhis draft supplemental environmental impact statement (SEIS) has been prepared in

response to an application submitted to the NRC by the Domninion Nuclear Connecticut

(Dominion) to renew the OLs for Millstone Power Station, Units 2 and 3 (Millstone) for an

additional 20 years under 10 CFR Part 54. This draft SEIS includes the NRC staff's analysis that

considers and weighs the environmental impacts of the proposed action, the environmental

impacts of alternatives to the proposed action, and mitigation measures available for reducing

or avoiding adverse impacts. It also includes the staff's preliminary recommendation regarding

the proposed action.' Id. -

July 2005 - A-281 NUREG-1 437, Supplement 22
Appendix A

Robert Fromer

Feb. 28,2005

B. BACKGROUND

'By letter dated January 20,2004, the Dominion Nuclear Connecticut, Inc. (Dominion)

submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the

operating licenses (OLs) for Millstone Power Station, Units 2 and 3 for an additional 20-year

period. If the OLs are renewed, State regulatory agencies and Dominion will ultimately decide

whether the plant will continue to operate based on factors such as the need for power or other

matters within the State's jurisdiction or the purview of the owners. If the OLs are not renewed,

then the plants must be shut down at or before the expiration dates of the current OLs, which

are July 10 2015 for Unit 2 and November 2025 for Unit 3. The NRC has implemented Section

102 of the National Environmental Policy Act (NEPA) (42 United States Code [USCI 4321) In

10 CFR Part SL In 10 CFR 5120(b)(2), the Commission requires preparation of art

environmental impact statement (EIS) or a supplement to an EIS for renewal of a reactor OL In

addition, 10 CFR 51.95(c) states that the EIS prepared at the OL renewal stage will be a

supplement to the Generic Environmental Impad Statement for License Renewal of Nuclear Plants

(GEIS), NUREG-1437, Volumes I and 2." (Emphasis added.) [Executive Summary, p. xv.)

"Upon acceptance of the Dominion application, the NRC began the envirounental

review process described in 10 CFR Part 51 by publishing a notice of intent to prepare an EIS

and conduct scoping. The NRC staff visited the Millstone site in May 2004 and held public

scoping meetings on May 18, 2004, in Waterford, Connecticut. In the preparation of this draft

supplemental environmental impact statement (SEIS) for Millstone, the staff reviewed the

Dominion Environmental Report (ER) and compared it to the GEIS, consulted with other

agencies, conducted an independent review of the issues following the guidance set forth in

NUREG-1555, Supplement 1, the Standard Review Plans for Environmental Reviews for Nuckear

Power Plants, Supplement 1: Operating License Renewal, and considered the public comments

received during the scoping process. .... Id.

-"his draft SEIS includes the NRC staff's preliminary analysis, which considers and

weighs the environmental effects of the proposed action, the environmental impacts of

alternatives to the proposed action, and mitigation measures for reducing or avoiding adverse

effects. It also includes the staff's preliminary recommendation regarding the proposed action.

Id, xv-xvi

-NRC regulations [10 CFR 51.95(c)(2)] contain the following statement regarding the

content of SEISs prepared at the license renewal stage.

The supplemental environmental impact statement for license renewal is not required to

include discussion of need for power or the economic costs and economic benefits of the

proposed action or of alternatives to the proposed action except insofar as such benefits

and costs are either essential for a determination regarding the inclusion of an

alternative in the range of alternatives considered or relevant to mitigation. In addition,

the supplemental environmental impact statement prepared at the license renewal stage

need not discuss other issues not related to the environmental effects of the proposed

action and the alternatives, or any aspect of the storage of spent fuel for the facility

within the scope of the generic determination in § 51.23(a) ["Temporary storage of spent

2

NUREG-1 437, Supplement 22 A-282 July 2005
Appendix A

Robert Fromer

Feb.28, 2005

fuel after cessation of reactor operation-generic determination of no significant

environmental inpacti and in accordance with § 5123(b).'

Id., xvi.

-If the Millstone operating licenses are not renewed and the units cease operation on

or before the expiration of their current operating licenses, the adverse impacts of likely

alternatives will not be smaller than those associated with continued operation of Millstone.

The impacts may, in fact, be greater in some areas.' (Emphasis added.) Id., xix. * . . - ~ . ... ,.,.....

- he 'preliminary recommendation 'of -the NRC staff Is that the Commission

determine that the adverse environmental impacts of license renewal for Millstone are not so

great that preserving the option of license renewal for energy planning decislonmakers

would be unreasonable. This recommendation is based on (1) the analysis and findings in

the GElS; (2) the ER submitted by Dominion; (3) consultation with other Federal, State, and

local agencIes; (4) the staff's own independent review; and (5) the staff's consideration of

public commetS receivedi during the scoping process." (Emphasis idded.) Id.

123 The Proposed Federal Action'

The proposed Federal action is renewal of the OLs for Millstone. The Millstone site is

located in Waterford, Connecticut on' the coast between the Niantc and Thames Rivers,

appwoximately64 km (40 nil) east of New Haven, 64 km (40 ml) southeast of Hartford and 32

km (20 mi) west of Rhode Wland. Unit 2 is a Corn oningineenng-designed pressurizedwater reactorwith a design power level 2700 megawatts tonal (MW~tD and a net-power

output of 870 megawatts electric (MWIe]). Unit 3 is a Westinghouse-designed pressurizedwater reactor with a design power level of 3411 MW(t) and a net power output of 1154 MW(e).

Plant cooling is provided by'a once-through cooling-water system that is withdrawn from

Niantic Bay and dissipates heat by discharge into Long Island Sound. Units 2 and 3 produce

electricity to rteet about 50 percent of the electrical use of Connecticut. The current OL for Unit

2 expires on July.31, 2015, and for Unit 3 on November 25,2025. .By letter dated January 20,

2004, Dominion submitted an application to the NRC (Dominion 2004b) to renew these OLs for

an additional 20 years of operation (i.e., until July 31, 2035, for Unit 2 and November 25, 2045,

for Unit 3)." [GEIS, p. 1-8.1

_nA The Purpose and Need for the Proposed Action:

Although a licensee must have a renewed license to operate a reactor beyond the term of

the existing Ok the possession of that license is just one of a number of conditions that must be

met for the licensee to continue plant operation during the term of the renewed license. Once

an OL is renewed, State regulatory agencies and the owners of the plant will ultimately decide

whether the plant will continue to operate based on factors such as the need for power or other

matters within the State's jurisdiction or the purview of the owners. Thus, for license renewal

reviews, the NRC has adopted the following definition of purpose and need (GEIS Section 1.3):

- ;. 1 ', Cl£| - * .- . , -, ;

.3

July 2005' A-.283 -" NUREG-1437, Supplement 22
Appendix A

Robert Fromer

Feb. 28,2005

The purpose and need for the proposed action (renewal of an operating license) is to

provide an option that allows for power generation capability beyond the term of a

current nuclear power plant operating license to meet future system generating needs,

as such needs may be determined by State, utility, and where authorized, Federal (other

than NRC) decisionmakers.-

[GEIS, p. 1I-&

This definition of purpose and need reflects the Commission's recognition that, unless

there are findings in the safety review required by the Atomic Energy Act of 1954 or findings in

the NEPA environmental analysis that would lead the NRC to reject a license renewal

application, the NRC does not have a role in the energy-planning decisions of State regulators

and utility officials as to whether a particular nuclear power plant should continue to operate.

From the perspective of the licensee and the State regulatory authority, the purpose of renewing an OL is to maintain the availability of the nuclear plant to meet system energy requirements

beyond the current term of the plant's license. (Emphasis added.) [GELS, pp. 1-8 to 1-9.]

-LS Compliance and Consultations

Dominion is required to hold certain Federal, State, and local environmental permits, as

veU as meet relevant Federal and State statutory requirements. In its Environmental Review,

DdTmilon provided a list of the authorizations from Federal, State, and local authorities for

current operations, as weU as environmental approvals and consultations associated with

Millstone license renewal. Authorizations and consultations relevant to the proposed OL

renewal action are included in Appendix E- [GEIS, p. 1-9.1

The staff has reviewed the list and consulted with the appropriate Federal, State, and

local agencies to identify any compliance or permit issues or significant environmental issues of concern to the reviewing agencies. These agencies did not identify any new and significant

environmental issues The ER states that Dominion is in compliance' with applicable

environmental standards and requirements for Millstone. The staff has not identified any

environmental issues that are both new and significant." Id.

S.2.5 Other Alternatives

Other generation technologies considered by NRC are discussed in the following

paragraphs.' [GEIS, p. .

8.21Wind Power

Wind power, by itself. is not suitable for large base-load electrical generation. As

discussed in Section 83.1 of the GEIS, wind has a high degree of interinittency, and average

annual capacity factors for wind plants are relatively low (less than 30 percent). Wind power, in

4

NUREG-1437, Supplement 22 A-284 July 20051.
Appendix A

Robert Fromer

Feb.28, 2005

conjunction with energy storage mechanisms, might serve as a means of providing base-load

power. However, current energy storage technologies are too expensive for wind power to

serve as a large base-load generator' [GEIS, p. .1

SThe State of Connecticut is in a wind power Cass 2 region (average wind speeds at 10-

m 130-ftD elevation of 5.6 to 6A m/s [18 to 21 ft/sJ): On the coast, Connecticut Is in a wind

power Class 3 region (average wind speeds at 10-m (30-ft) elevation of 6.4 to 7.0 rn/s [21 to 23

ft/sD) (DOE 2004a). -In wind power Class 2 areas wind turbines are economically marginal for

development, but in lass 3 areas may be suitable with future technology (DOE 2004a)." Id.

'There are active wind power facilities in the region, and others are proposed. As of

January 16 2003, there were approximately 48 MW of grid-connected wind power facilities in

New York State, with an additional 410 MW of additional capacity in various stages of planning

(American Wind Energy Association 2003). In addition, the US. Army Corps of Engineers

(USACE) is preparing an environmental impact statement for a proposed wind farm to generate

420 MW(e) using 170 turbines off the coast of Massachusetts (USACE 2004)!' Id.

"Access to many of the best land-based wind power sites near the coast likely would

require extensive road building, as well as clearing (for towers and blades) and leveling (for the

tower bases and associated facilities) in steep terrain. Also, many of the best quality wind sites

are on ridges and hilltops that could have greater archaeological sensitivity than surrounding

areas. For these reasons, development of large-scale, land-based wind-power facilities are not

-only likely to be costly, but could also have MODERATE to LARGE impacts on aesthetics,

archaeological resources, land use, and terstrial ecology." Ed..

The offshore wind speeds are higher than those onshore and could thus support

greater energy production than onshore facilities. Ten offshore wind power projects are

currently operating in Europe, but none have been developed in the United States The

European plants together provide approximately 250 MW(e),whdch is significantly less than the

-- : electrical output of Millstone (British Wind Energy Association 2003). For the preceding

reasons, the staff concludes that locating a wind-energy facility an or near the Millstone site, or

offshore as a replacement for Millstone generating capacity, is not only lIkely to be costly, but

- could also have MODERATE to LARGE impacts on aesthetics, aquatic ecology, and shipping

lanes." Id.

-825.2SolarlPower

Solar technologies use the sun's energy and light to provide heat and cooling light, hot

water, and electricity for homes, businesses, and industry. In the GEIS, the staff noted that by

its nature, solar power is intermittent. Therefore, solar power by itself Is not suitable for baseload capacity and is not a feasible alternative to license renewal of Millstone. The average

capacity factor of photovoltaic cells is about 25 percent, and the capacity factor for solar thermal

systems is about 25 percent to 40 percent (NRC 1996). Solar power, in conjunction with energy

storage mechanisms, might serve as a means of providing base-load power. However, current

energy storage technologies are too expensive to permit solar power to serve as a large baseload generator. Therefore, solar power technologies (photovoltaic and thermal) cannot

"5

July 2005 A-285 - NUREG-1437, Supplement 22
Appendix A

Robert Fromer

Feb. 28.2005

currently compete with conventional fossil-fueled technologies in grid-connected applications,

due to high costs per kilowatt of capacity. (NRC 1996)." [GEIS, p..1

WThere are substantial impacts to natural resources (wildlife habitat, land-use, and

aesthetic impacts) from construction of solar-generating facilities. As stated in the GEIS, land

requirements are high - 14,000 ha (35,000 ac) per 1000 MW(e) for photovoltaic and

approximately 5700 ha (14,000 ac) per 1000 MW(e) for solar thermal systems. Neither type of

solar electric system would fit at the Millstone site, and both would have large environmental

impacts at an alternate site. Yd.

'The Millstone site receives approximately 3 to 35 kWh of solar radiation per square

meter per day (Dominion 2004), compared to 6 to 8 kWh of solar radiation per square meter per

day in areas of the western United States, such as Califoinia, which are most promising for solar

technologies (DOE/EIA 2000). Because of the natural resource impacts (land arid ecological),

the area's relatively low rate of solar radlation, and high cost, solar power is not deemed a

feasible base-load alternative to renewal of the Millstone 01s. Some solar power may substitute

for electric power in rooftop and building applications. Implementation of nonrooftop solar

generation on a scale large enough to replace Millstone would likely result in LARGE

environmental impacts." Id.

8.253Hydropower

Connecticut has an, estimated 43.5 MW(e) of undeveloped hydroelectric resources (Idaho

National Environmental and Engineering Laboratory 1995). This amount is far less than would

be needed to replace the 2024 MW(e) capacity of Millstone. In Section 83A of the GEIS, the staff

points out that hydropower's percentage of U-11 generating capacity is expected to decline

because hydroelectric facilities have become difficult to site as a result of public concern about

flooding, destruction of natural habitat, and alteration of natural river couhes' [GEIS, p. .1

-In the GEMS, the staff estimated that land requirements for hydroelectric power are

approximately 4.0 x 105 ha (1.0 x 106 ac) per 100 MW(e). Replacement of Millstone generating

capacity would require flooding more than, this amount of land. Due to the relatively low

amount of undeveloped hydropower resource in Connecticut, and the large land-use and

related environmental and ecological resource impacts associated with siting hydroelectric

facilities large enough to replace Millstone, the staff concludes that, on its own, local

hydropower is not a feasible alternative to Millstone O<s renewal Siting hydroelectric facilities

large enough to replace Millstone would result in LARGE environmental impacts." Id.

&82.54GeothermaI Energy

Geothernal energy has an average capacity factor of 90 percent and can be used for

base-load power where available. However, geothermal technology is not widely used as baseload electrical generation due to the limited geographical availability of the resource and

immature status of the technology (NRC 1996). As illustrated by Figure &4 in the GEIS,

geothermal plants are most likely to be sited in the western continental United States, Alaska,

and Hawaii where hydrothermal reservoirs are prevalent. There is no feasible eastern location

6

NUREG-1437, Supplement 22 A-286 July 2005
Appendix A

Robert Fromer

Feb. 28,2005

for geothermal capacity to serve as an alternative to Millstone. The staff concludes that

geothermal energy is not a feasible alternative to renewal of the Millstone OLs." GElS, p. .1

"8.2.5Wood Waste

The use of wood waste to generate electricity is largey limited to those states with

significant wood resources, such as California,' Maine, - Georgia, Minnesota, Oregon,

Washington, and Michigan; Electric power is generated in these states by the pulp, paper, and

paperboard industries, which bum wood and wood 'waste for electrical power generation,

benefitting from the use of waste materials that could otherwise represent a disposal problernm

[GEIS, p..1

'A wood-burning facility can provide base-load power and operate with an average

annual capacity factor of around 70 to 80 percent and with 20 to 25 percent efficiency (NRC

1996). The fuels required are variable and site-specific. A significant barrier to the use of wood

waste to generate electricity is the high delivered-fuel cost and high construction cost per MW

of generating capacity. The larger wood-waste power plants are only 40 to 50 MW(e) in size.

Estimates in the GElS suggest that the overall level of construction impact per MW of installed

capacity should be approximately the same as that for a coal-fired plant, although facilities

'using wood waste for fuel would be built at smaller scales. Like coal-fired plants, wood-waste

plants require large areas for fuel storage and waste disposal and involve the same type of

combustion equipment.' Id.

"Due to uncertainties associated with obtaining sufficient wood and wood waste to fuel

a base-load generating facility, ecological impacts of large-scale timber cutting (e.g., soil erosion

and loss of wildlife habitat), and low efficiency, the staff has determined that wood waste is not

a feasible alternative to renewing the Millstone OLs." Id.

"825.6Municipal Solid Waste

Municipal waste combustors Incinerate the waste and use the resultant heat to generate

steam, hot water, or electricity. The combustion process can reduce the volume of waste by up

to 90 percent and the weight of the waste by up to 75 percent (EPA 2001). -Municipal waste

combustors use three basic types of technologies: mass bum, modular, and refuse-derived fuel

(DOE/EIA 2001). Mass burning technologies are most commonly used in the United States.

This group of technologies processes raw municipal solid waste "as is," with little 'or no sizing,

shredding, or separation before combustion." [GElS, p..I -

"Growth in'the municipal waste combustion industry slowed dramatically during the

1990s after rapid growth during the 198Is. The slower growth was due to three primary factors:

(1) the Tax Reform Act of 1986, which made capital-intensive projects such as municipal waste

combustion facilities more expensive relative to less capital-intensive waste disposal

alternatives such as landfills; (2) the 1994 Supreme Court decision (C&A Carbone, Inc. v. Town of

Clarkstoun), which struck down "local fow control ordiiaces that required waste to be

delivered to specific municipal waste combustion facilities rather thin the potentially lower-cost

(lower fee) landfills; and (3) increasingly stringent environmental regilations that increased the

7

July 2005 A-287 NUREG-1 437, Supplement 22
Appendix A

Robert Fromer

Feb. 28,2005

capital cost necessary to construct and maintain municipal waste combustion facilities

(DOE/EIA 2001)." Id.

'The decision to burn municipal waste to generate energy is usually driven by the need

for an alternative to landfills rather than by energy considerations. The use of landfills as a

waste disposal option is likely to increase in the near term: however, it is unlikely that many

landfills will begin converting waste to energy because of unfavorable economics, particularly

with electricity prices declining in real terms ELA prcqects that between 1999 and 2020, the

average price of electricity in real 1999 dollars will decline by an average of 05 percent per year as a result of competition among electricity suppliers (DOE/EIA 2001)." Id.

'Municipal solid waste combustors generate an ash residue that is buried in landfills.

The ash residue is composed of bottom ash and fly ash. Botton ash refers to that portion of the

unburned waste that falls to the bottom of the grate or furnace. Fly ash represents the small

particles that rie from the funace during the combustion process. Fly ash is generally

removed from flue-gases using fabric filters and/or scrubbers (DOE/EIA 2001)." Id.

'Currently there are approximately 102 waste-to-energy plants operating in the United

States These plants generate approximately 2800 MW(e), or an average of approximately 28

MW(e) per plant (Integrated Waste Services Association 2001), much less than needed to replace

the 2024 MW(e) of Millstone. Id.

"The initial capital costs for municipal solid-waste plants are greater than for

comparable steam-turbine technology at wood-waste facilities. This is due to the need for

specialized waste-separation and -handling equipment for municipal solid waste (NRC 1996).

Furthenmore, estimates in the GEMS suggest that the overall level of construction impact from a

waste-fired plant should be approximately the same as that for a coal-fired plant. Additionally,

waste-fired plants have the same or greater operational impacts (including impacts on the

aquatic environment, air, and waste disposal). Some of these impacts would be moderate, but

still larger than the environmental impacts of license renewal of Millstone. Therefore,

municipal solid waste would not be a feasible alternative to renewal of the Millstone Ols,

particularly at the scale required.' Id.

M2.5.70ther Biomwass-Derived Fuels

In addition to wood and municipal solid-waste fuels, there are several other concepts for

fueling electric generators, including burning crops, converting crops to a liquid fuel such as

ethanol, and gasifying crops (including wood waste). In the GEIS, the staff points out that none

of these technologies has progressed to the point of being competitive on a large scale or of

being reliable enough to replace a base-load plant such as Millstone. For these reasons, such

fuels do not offer a feasible alternative to renewal of the Millstone OUs.- GEIS, p. .1

"8.75.8Fuel Cells

Fuel cells work without combustion and its environmental side effects. Power is

produced electrochemically by passing a hydrogen-rich fuel over an anode and air over a

cathode and separating the two by an electrolyte. The only by-products are heat, water, and

8

NUREG-1437, Supplement 22 A-288 July 2005
Appendix A

Robert Frorner

Feb.28, 2005

carbon dioxide. Hydrogen fuel can come from a variety of hydrocarbon resources by subjecting

them to steam winder pressure. Natural gas is typically used as the source of hydrogen." Id.

Phosphoric acid fuel cells are generally considered first-generation technologies. These

fuel cells are commercially available at a cost of approximately $4500 per kW of installed

capacity (DOE 2004b). Higher-temperature, second-generation fuel cells achieve higher fuel-toelectricity and thermal efficiencies. The higher temperatures contribute to improved efficiencies

and give the second-generation fuel cells the capability to generate steam for cogeneration and

combined-cycle operations!' Id.

'DOE has a new initiative to reduce costs to as low as $400 per kW by the end of the

decade (DOE 2004b). For comparison, the installed capacity cost for a natural gas-fired,

combined-cycle plant is about $456 per kW (DOE/EIA 2004a). As market acceptance and

manufacturing capacity increase, natural gas-fueled fuel cell plants in the 50- to 100-MW range

are projected to become available. At the present time, however, fuel cells are not economically

or technologicaUy competitive with other alternatives for base-load electricity generation. Fuel

cells are, consequently, not a feasible alternative to renewal of the Millstone OLs."

C. Council on Enivironmrental Quality Regulations, 40 Code of Federal

Regulations

Sec. 1502.16. .Environmental consequences -

* 'This section forms the scientific and analytic basis for the comparisons under Sec.

: : 150I2.14. It shall consolidate the discussions of those elements required by sections 102(2)(C)(i),

(Ii), (iv), and (v) of NEPA which are within the scope of the statement and as much of section

102(2)(C)(ii) as is necessary to support the comparisons. The discussion will include the

environmental impacts of the alternatives including the proposed action, any adverse

environmental effects which cannot be avoided should the proposal be implemented, the

relationship between short-term uses of mans environment and the maintenance and

enhancement of long-term productivity, and any irreversible or irretrievable commitments of

resources which would be involved in the proposal should it be implemented. This section

should not duplicate discussions in Sec. 1502.14. It shall include discusions of:

(a) Direct effects and their significance (Sec. 1508.8). -

(b) Indirect effects and theirsignificance (Sec.08)

(c) Possible conflicts between the proposed action and the objectives of Federal,

regional, State, and local (and in the case of a reservation, Indian tribe) land use plans,

policies and controls for the area concerned. (See Sec. 15062(d).) -

(d) The environmental effects of alternatives including the proposed action. The

comparisons underSec. 1502.14 will bebased on this discussion.

(e) -Energy requirements and conservation potential of various alternatives and

mitigation measures. (Emphasis added.) -

9

July 2005 ' A-289 NUREG-1437, Supplement 22
Appendix A

Robert Fromer

Feb. 28,2005

(f) Natural or depletable resource requirements and conservation potential of various alternatives and mitigation measures.

(g) Urban quality, historic and cultural resources, and the design of the built environment, including the reuse and conservation potential of various alternatives and

mitigation measures.

(h) Means to mitigate adverse environmental impacts (if not fully covered under Sec. 1502.14(f)).

Sec. 15088 Effects.

"Effects includei

(a) Directeffects, which are caused by the action and occur at the same time and place.

(b) Indirect effects, which are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable. Indirect effects may include growth Inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate, and related effects on air and water and other natural systems, including ecosystems.

Effects and impacts as used in these regulations are synonymous. Effects includes ecological (such as the effects on natural resources and on the components, structures, and functioning of affected ecosystems), aesthetic historic, cultural, economic, social, or health, whether direct, indirect, or cumulative. Effects may also include those resulting from actions which may have both beneficial and detrimental effects, even if on balance the agency believes that the effect will be beneficial

D. COMMENTS

MPS-49-1 Dominion has not provided a comparative analysis and assessment of life cycle energy consumption to determine that re-licensing of Millstone is the preferred option. Nor, has Dominion considered cumulative alternatives (iLe., energy sources) to meet the current and future energy demands.

1. Energy Considerations

a. Embodied Energy

Most people are familiar with the concept of improving the energy efficiency of buildings by reducing the operating energy they use and increasing thermal resistance to heat loss. It's a common claim that energy-efficiency measures can reduce the operating energy of an individual building by 60% or more. Comparatively, little attention has been focused, however, on recognizing or reducing the embodied energy of structures Embodied energy, or embedded energy,' is an assessment that' includes the energy required for extracting raw materials from nature, plus the energy used in primary and secondary manufacturing or construction/demolition activities to provide a finished product or resulL There is embodied

10

NUREG-1 437, Supplement 22 A-290 July 2005
Appendix A

_ _

Robert Fromer

Feb. 28, 2005

energy in every processed product, from a drinking cup to a car. In embodied energy terms,

buildings represent a huge, relatively long-duration energy investment. Embodied energy can

be defined as the quantity of energy required by all of the activities associated with some

- production :or construction process including the acquisition of primary material.

transportation, manufacturing and handling over its useful life plus the energy for demolition,

recycling and/or reuse. -

* Take a day brick, for example. This includes the energy to extract the day, transport it

to the brickworks, mould the brick, fire it in the kiln, transport it to the building site and put the

brick into place. It also includes all the indirect energy required, i.e. all the energy required to

manufacture the equipment and materials needed to manufacture a brick, e.g. trucks, kilns,

- mining equipment, etc. All have a proportion of their energy invested in that brick.

Embodied energy is highly dependent on factors such as geographical location,

- technology employed in the manufacturing/construction process, the degree of automation,

mechanization and local methods of mnanufacture, etc.' The vague is by no neas absolute and is

different from on location to another.

Every building Is a complex combination of many processed materials, each of which

contributes to the building's total embodied energy. The energy required to extract and process

the raw material for an individual component, as wel the energy used to transport the finished

product to the job siteamind install it, all become part of the ernbodied ericgy cost of the

completed structure. Furthermore, energy involved in maintaining an individual building

component, And fnally renv it and recycling or otherwise disposing'of it at the end of its

useful life, can all be part of the embodied energy equation for a particular building material.

depending on how the embodied energy is quantified.

As the operating energy required for buildings declines, the embodied energy they

represent becomes a more significant percentage of the total energy buildings use over their life.

In coming years, more efforts will probably be directed toward measuring and reducing the

amount of embodied energy in buildings.

Where buildings no longer serve a particular use, waste indudes the material debris and

the demolition energy for disposal (ie., in-state or out-of-state).

b. ':Need for Energy Conservation

Dr. Charles Hall, a Systems EcologistPl has previously testified as follows:

[I] Dr. Hafl received his Doctorate of Philosophy at the University of North Carolina at Chapel

Hill in the field of energy and natural resource relationships to economics, which is his primary

-,scholarly and intelectual academic focus, studied under Dr.H.T. Odurn, who is the most noted

scholar in the field. Dr. Hall has published more than 160 papers and five books on energy,

natural resources and its relationship to economics in prestigious journals. Dr. Hall is a full

professor at the State University of New York College of Environmental Science and Forestry

and has been a professor previously at the University of Montana (2 years), Cornell University

:11

July 2005,.. A-291 . NUREG-1437, Supplement 22 -
Appendix A

Robert Fromer

Feb. 28,2005

1. Each dollar of cost requires the consumption of energy for meaning to that

dollar. For the nation as a whole, the cost is roughly 5,000 kilocalories (Le., 1 kilocalorie

-1,000 calories) consumed per dollar spent roughly half a liter of oil or its equivalent as

some other fueL Certain activities, such as construction, tend to be more energy

intensive per unit dollar spent. Very careful assessments of these energy costs were

made in the 1970s and are still useful when corrected for inflation. Spending large

amounts of money requires spending large quantities of energy for that money to have

meaning;

2. An important consideration In our society is the energy expenditures of various

social alternatives.... Energy consumption is the direct cause effectuating pollution;

impairment or destruction of the air, water or other natural resources;

3. Any time energy is used there are environmental impacts and consequences

ranging from impacts at extraction sites (e.g oil facilities in Southern Louisiana, Alaska

and Venezuela and coal mines in Wyoming or Pennsylvania), processing, fabrication

and transportation and at sites of consumption (ie. where cement or steel or bulldozers

are made and also on site). These impacts include edg. terrain disruption sulfur dioxide

emissions and so forth;

4. These impacts include essentially irrevocable changes to the atmosphere with

possible severe climatic Impacts. There is roughly one kilogram of carbon dioxide

released per dollar of economic activity in the US. . Thus each unit of economic activity

generates very long term disruption to our atmosphere;

5. The principal source of our energy use is fossil fuel, by definition non-renewable.

Our domestic petroleum and gas supplies are quite finite. For example, US. production

of oil peaked in 1970 (as predicted by Hubbert in 1955). It has been declining steadily

since then despite huge drilling investments, so that we now produce roughly half of

what we did in the 70's. We make up the difference from imported oil, which now

represents approximately 60 percent of our supply. It is not clear when the total world

oil production will peak, but it might be as soon as about this. year (predicted by

Hubbert in 1968) or 2007 (predicted by Campbell in 1998). It is hard to find a prediction

made by any competent researcher that pushes the peak beyond about 2030 assuming

continued economic growth, and most suggest sooner. Natural gas supplies are harder

to predict but might not be too different form oil. Amongst the world authorities on

these estimates are my forner students Cutler Cleveland and Robert Kaufmann,

Director and Associate Professor of the Boston University Center for Energy and the

Environment.

6. It is important to understand that there are many scientific, environmental,

economic and political reasons for minimizing energy usage and waste, over foreseeable

time.

(13 years) and Research Associate at the Ecosystems Center Woods Hole and Brookhaven

National Laboratories.

12

NUREG-1437, Supplement 22 A-292 July 2005
Appendix A

Robert Fromer

Feb. 28, 2005

7 Historical resource planning has prinarily concerned corrective considerations

- -~ and. :--

8. Comparative energy assessments for the expected life of alternatives (a/k/a lifecycle energy assessment) provide the best scientific basis for'selecting the preferred

' option to demolition for conservation of energy'and natural resources.

- c. Life Cyde'EnergyAnalysis and Assesments.'

This tool provides accurate energy analysis of projects (e.g.

residential/conmnercial/industrial facilities) resulting in detailed reports designed to reduce

energy consumption, greenhouse gas emissions and meet statutory energy requirements by

comparative assessments of alternatives directed towards'selection of the preferred option.

(1) Assessment of the phases of a p'oduct's lifecycle

Every product, service or facility has impacts on the environment. Those impacts don't

just effect operations but also all activities from cradle to graved

Raw materials: The materials that are used to manufacture the product are either extracted

*frorn he Earth by mining drilling and similar processes, or they are recycled from previous

:,, ,- :'products ,' . - ............... n

ManufacturinglFabrlcation/Assemblyr In order to fabricate the product, a factory consumes

energy and materials. Some of the materials, especially process chemicals, do not end up in the

* - product, but rather are discarded and therefore have environmental Impacts that are not easily

known by the consumer.

Packaging, storage and transportation: The packaging used to transport and sell the product

consumes energy and materials in its manufacture. Transportation of the product from the

factory to store shelves, and then to the purchaser's home, also costs energy. Even storage of the

product in a warehouse has impacts associated with construction and use of the warehouse. -. , - -. ... - , , ,.. ':

Use: Some products have large environmental "mpacts while they are under use by the

consumer. For intance,[automobiles output large quantities of air pollutants and greenhouse

gases as they are used, and homes consume large quantities of energy when they are heated

and cooled. .-

Disposal: Most discarded products becomte municipal solid waste, meaning they are either

buried in a landfill or incinerated. Some products are partially or fully recycled, a process that

itself requires certain amounts of heat, transportation and chemicals.

: (2) Environmental (Energy) Impacts VTraditionally, environmental impacts of a given activity or project are catalogued across

a spectrum of environmental realms, for instance, air quality;jwater quality and land use.

'13

July 2005: - A-293

y 25 . .

N U REG -1437, Supplem ent 22'
Appendix A

Robert Fromer

Feb.,28.2005

However, of far greater significance are the environmental impacts of each phase of a project's

lifecycle by measuring the total energy consumed during that phase.

By adding together the energy consumed in each projects phase, one can calculate an

energy content for the product: the total amount of energy consumed during the project's entire

lifetime. The projected energy consumed then becomes the "analytical embodied energy' of the

project, and is a rough but effective measure of that project's total environmental impact.

Example of Life Cycle Anilysis

The automobile instrument panel (IP) is a complex component that is fabricated of

numerous parts and must fulfill a variety of requirements. As the engineering manager for one

of the major automotive companies, your responsibility is to design and manufacture

instrument panels for one of your company's most popular vehicles. For the current version of

this vehicle, the structural parts of the [P are built primarily of steeL However, for the 1999

model, you and your staff are evaluating a design that is lighter and replaced much of the steel

with magnesium.

Issue

Thus far, the new design appears to meet all of your company's safety, aesthetic, cost

and other criteria. However, a recent technical report indicated that the material production

energy of magnesium is much greater than that of any other materials used in current IPs.

Since one of your company's objectives is to lower the life cycle energy of the instrument panel,

you must now assess if the new design will achieve this objective. Does the new design lower

the life cycle energy of the instrument panel? Please show your calculations and state

assumptions.

Data

Mateia, Production Data

Material Material Production Current Design (kg) New Design (kg)

Energy (MW/kg)

Steel 40 10 4

Magnesium 285 0 3

Polyurethane Foam 72 3 3

PVC 65 2 2

Other Plastic 93 10 8

I TOTAL 25 20

Manufadurin-' Phase Data

* Approximately 500 MJ/!P are required to produce either the current or new design

Use Phase Dadd

* Average car last 180,000 m

14

NUREG-1 437, Supplement 22 A-294 July 2005
Appendix A

Robert Fromer

Feb. 28,2005

* For this model of car, 1.0 MJ of energy are consumed to move one kg of weight for a

distance of 1,000 km, ie. the efficiency factor is 1.0 MJ/(kg*1000 km).

End of L Pha.se Data

* For either design, a total of 10 MJ/IP are consumed during the shredding and other end of

life processes.

KeyAssumption:

The mass of each material in the product Is equal to the mass of each material required

for manufacturing. This assumes no scrap is generated.

Life Cycle Analysis

Material roduction

FmaafW Esd + EnwpV. + Ep o + Ervc + Ee - '

Ee,,,, w 10Bkg*40O /kg+Okg'285J/kg+3kg72MJ/kg+2kg*65MJkg+ 10kg893

M 400 MI +0 MJ +216 IJ + 130 MJ + 930 MJ

E,,,,,, = 2676 Nq

;E.. =4kg'40MW/kg+3kg'285W/kg+3kg72 J/kg +2kg65MW/kg+8kg*93

. ,./kg

*160MJ+855lMv+216?M+130 +744KMJ

*. E 2105 NJ

Manufacturing Phase Data

E.% = 500 MJ for both the current and new designs

Use Phase Data

E~w = 1.0 M)/(kg ' 1000 km) * 180,000 km. Wu.

E... G 1.0 MJ/(kg ' 1000 kim) -1 80,000 km * 25 kg

= 4500 M

E. = 1.0 MJ/(kg * 1000 km) ' 180,000 km * 20 kg

= 3600 MJ

End of Life Phase Data

Few 10 MJ for both the current and new designs

Total Li* Cycle Enery

Eeom E.tw+ ELig Eus + Ed

E = 1676 M + 500 MJ + 4500 M + 10 M

= 6686 MJ

E.. =2105Ml+500MJ+3600M1+1OMJ

=6210 MJ

1S

July 2005 A-295 - NUREG-1437, Supplement 22
Appendix A

Robert Fromer

Feb.28,2005

Therefore, we can see that the new design does lower the life cycle energy of the

instrument panel.

E CONCLUSIONS

Dominion has not provided a comparative analysis and assessment of life cycle energy

consumption to determine that relicensing of Millstone is the preferred option. Nor, has

Dominion considered cumulative alternatives (ie., energy sources) to meet the current and

future energy demands.

Cordially,

Robert Fromer

M.S.EE., P.1E. P.C.. R.E.P.

16

NUREG-1437, Supplement 22 A-296 July 2005
Appendix A

Robert Fromer

Feb.28, 2005

REFERENCES

40 CFR Part 1502.16. Code of Federal Regulations, -Environmental Impact Statement", Council

on Environmental Quality - Regulations for Implementing NEPA

Life Cycle Assessment Reviews:

Electric vs. Gasoline Automobiles. Seikei University, 2001

Liestyle Impact Ratings. Union of Concerned Scientists, 1999

Manufacture vs. Use of Automobiles. Carnegie Melon University, 1998

Reusable vs. Disposable Cups. University of Victoria, 1994

Product Packaging. Tellus Institute, 1992

CUoth vs. Disposable Diapers. Franklin Associates, Ltd., 1992

Paper vs. Plastic Bags. Franklin Associates, Ltd., 1990

Life Cycle Energy, Costs, and Strategies for Improving a Residential House. Journal of

Industrial Ecology, Vol. 4, Issue 2 - Spring 2000

17

July 2005' A-297 NUREG-1437, Supplement 22
Appendix A

Appendix A, Part 3. Written Comments on the Draft EIS

NUREG-1437, Supplement 22 A-298 July 2005
Appendix A

dt.tO41 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

- REGION i

I CONGRESS STREET. SUTE 1100

BOSTON.MASSACHUSETTS 02114-2023

- * * - tZ>> ?M/ Ft-37 GOFF= DOFSTHEex

March 2, 2005 -

Chief, Rules Review and Directives Branch (li-) U.S. NuclearRegulatory Commission - : - -

Mail Stop T6-D59

Washington, DC 20555-0001

Re: Draft Supplemental Environmental Impact Statement (DSEIS) for Lcense Renewal of

Nuclear Plants at the Millstone Power Station, Units 2 and 3, NUREG-1437, Supplement 22

(EPA ERP #NRC-B06005-CI) * -

Dear Sir/Madam:

In accordance with our responsibilities under thcNational Environmental Policy Act (NEPA) and

Section 309 of the Clean AirAct we have reviewed the Nuclear Regulatory Commission's

(NRC's) Draft Supplemental Environmental Irnpact Statement (DSEIS) for relicensing of Units 2

and 3 of the Millstone Nuclear Power Station in Waterford, Connecticut.

As described in the DSEIS, Dominion Nuclear Connecticut, Inc. (Dominion) as submitted an

application to NRC forrenewal ofthe operating licenses for an additional 20 years. The current

operating licenses expire in 2015 for Unit 2 and 2025 for Unit 3. The DSEIS was prepared to

provide site specific information to supplement NRC's 1996 Generic EIS forLicense Renewal of

Nuclear Plants. It contains the NRC staff's preliminaryrecommendation that adverse

environmental effects of license renewal at Millstone arc not so great that preserving the option of

license renewal would be unreasonable.

Our comments on the DSEIS, which are contained in the attachment to this letter, highlight areas

ovhere we believe additional information is needed to more fully describe the impacts of the

Millstone facility. Specifically, these comments address the environmental impacts of operation.

including entrainment and impingement of fish and shellfish, impacts from heat shock, and

cumulative impacts. We encourage the NRC to address these issues prior to the close orthe

NEPA process. We also recognize that the intake and discharge of water at Units 2 and 3 are

regulated under the Clean Water Act's National Pollutant Discharge Elimination System

(NPDES) permit, administered in Connecticut by the Connecticut Department of Environmental

Protection (CTDEP). As discussed in the DSEIS, Dominion has submitted an application to the

CTDEP for rnewval of the NPDES permit. The comments in this letter are based solcly on our

review of the information in theNRC's DSEIS from the standpoint ofwhat is required byNEPA

and are not intended to address the requirements of the Clean Water ActNPDES permit.

s-r gA * 8 44

617.918.1010

Intemnet Akiss (URI4 * hvp**'WWAp&g-Vmg5onI

AcyRedndctB~cbb. *P Ed wIh V~gIabb, on Ba.. * ~Acrchd Pep. ratnfw. Ad% Pema

Ad7-a,_{

July 2005: A-299. NUREG-1 437, Supplement 22
Appendix A

-2-

For the reasons discussed above (and in the attachment which follows), EPA has rated this DSEIS

"EC-2 Environmental Concems-Insufficient Infomnation" in accordance with EPA's national

rating system, a description of which is attached to this letter. We look forward to reviewing

responses to the issues highlighted in this letter and technical attachment in the Final

Supplemental Environental Impact Statement (FSEIS). My staffis available to provide

additional input, as necessary, to help the NRC respond to the issues discussed in this letter.

Please feel free to contact me or Timothy Timnmermann of the Office of Environmental Review at

6171918-102S if you wish to discuss these comments further.

Sincerely, c

Robert WV. Varney

Regional Administrator

i

i

i

I

i

I

I

I

Attachment

cc: I

Gina McCarthy, Commissioner, Connecticut Department of Environmental Protection

i

I I

I

I

I

I

I

i

i

i

i

i I

I

I i

i I

I

t

I

NUREG-1437, Supplement 22 A-300 July 2005
Appendix A

Summary of Rating Definitions and Follow-up Action

Frirronrigntrl lmnact ofthe Aetion - - - -

LO-Lack or Objections' ' - -

The EPA review has not identified any potential enviroiirnental irmpacts requiring substantive changes to the proposaL

The teview nayhave disclosed opportunities for application of mitigation measures that could be accomplished with

no more than minor changes to the proposal.

EC-Environmental Concerns

The EPA review has identified environmental impacts tbat should be avoided In order to fully protect the

environmentL Corrective measures msy require changes to the preferred alternative or application of iitigation

measures that cani reduce the environmental impact. EPA would like to workc with the lead agency to reduce these

impacts.

EO-Environmental Objections

The EPA review has identified significant environmental In-pacts that must be avoided in order to provide adequate

protection for the environrient. Corrective tuasures miy require substantial changes to the preferred alternative or

consideration of some other project alternative (including the no action alternative or a new alternative). EPA intends

to work with the lead agency to reduce these impaets.

EU-Environm 'ntally Unsatisfactory t e of s mh

The EPA reviewhas identified adverseenvironnental irpactsthatarofsuffcintrmtruthattheyare

nusatisfaetory from thestandpoint of publiechealth or welfare orenvironrental quality. EPA intends toworkwith the

led agency to reduce these impacts. Ifthe potentiallyuntisfactory inpacts are not corrected at the final EiS stage,

this proposal will be recommended for referral to the CEQ.

Adeouaev of the Imnact Statement -- ;

Category I-Adequiate

EPA believes the draft EIS adequately sets forth the environmental impact(s) ofthe preferred alternative and those of

the alternatives reasonably available to the project or action. No further analysis or data collection Is necessary. but

the reviewer rmay suggest the addition oeclarifying language or information. -- -

Category2-lnsulleient Infortation ' , ,' . .

The draft EIS does not contain sufficient infornmtion for EPA to fully assess envronental impacts that should be

avoided in order to fully protect the environment, or the EPA ver has Identified wresonably available

alternatives that are vithin the spectrumofalternatives analyzed in the dft EtS which could reduce the

environmental impacts of the action. The identified additional information, data, analyses, ordiscussion should be

included in the final EIS.

Category3-1nadequate

EPA does not believe that the draft EIS adequately issesses potentially significant enviroomenal impacts orthe

action, or the EPA reviewer has ientified new. reasonably available alteinatives that are outside of the spectrum of

alternatives analyzed in the draft EIS whichshould be analyzed in order to reduce the potentially significant

environmental Impacts. EPA believesthat the identified additional Information, data, analyses, or discussions are of

such a magnitude that they should have full public review at a draft stage. EPA does not believe that the draft EIS is

adequate for the purposes of the NEPA and/or Section 309 reviewv and thus should be formally revised and made

available for public comment In a supplemental or revised draft EIS. On the basis of the potential significant impacts

Involved, this proposal could be a candidate for refeiral to the CEQ.

ADC-1

July 2005' A-301 OF NUREG-1 437, Supplement 22
Appendix A

Additional Detailed Comments

Draft Supplemental Environmental Impact Statement (DSEIS) for

License Renewal of Nuclear Plants at the Millstone Power Station, Units 2 and 3,

NUREG4I437, Supplement 22.

Comments on Chapter 2 - Description of Nuclear Power Plant and Site, and Plant

Interaction with the Environment

MPS-50-t Pg. 2-1. The DSEIS identifies the years when construction began for each of Millstone's three

units, but does not mention when the units came on line for commercial production of electricity.

These dates, as well as dates when each unit was offline for extended periods, would be helpful in

reviewing fish impingement and entrainment data, and should be included in the FSEIS.

MPS-50-2 Pg. 2-7. Intake velocity is estimated to be about 0.2 meters per second in front of the Unit 2

structure. The DSEIS does not state at what distance from the intake screen the velocity was

measured. Intake velocity should be presented in feet per second and should be estimated as

through-scrccn velocity, not in front of the screen, which estimates approach velocity.

Additionally, no intake velocity data are provided for Unit 3. This information is important for

assessing the potential of the intake structure to impinge organisms, and should be provided in the

FSEIS.

MPS:50-3 Pg. 2-7. The DSEIS identifies some features of the intake structure (eg., traveling screens, fish

return trough), but additional information is needed to assess the adequacy of the system for

returning fish and other organisms in good condition, as well as the potential to re-impinge

organisms that have been discharged from the fish return troughs. We recommend that the FSEIS

include information on the water pressure(s) of the spray wash system used to remove fish and

debris from the traveling screens, the frequency at which the traveling screens are rotated, a

- spatial-view diagram that includes the location of the intake structures and fish return troughs of

each unit, and any other information pertaining to system design or operation that may affect the

impingement oforganisms and the likely condition of those that are impinged.

Comments on Chapter 4 - EnvIronmental Impacts of Operation

Among the various potential impacts to the environment associated with the operation of a power

plant that utilizes once-through cooling water technology, the NRC identifies three issues that

wanant a site-specific rcvieev at Millstone, identified in the DSEIS as Category 2 issues. These

are 1) entrainment of fish and shellfish, 2) impingement of fish and shellfish, and 3) "heat shock".

The following comments identify information that we believe should be provided in the FSEIS.

ADC-2

NUREG-1437, Supplement 22 A-302 July 2005
Appendix A

-Entrainment

MPS-50-4 - In Section 4.1.1 entitled "Entrainment of fish and shellfish inEarlyLifestages 'we could not find

data or discussion about shellfish resources. While shcllfish larvae miy represent a small fraction:

- ': of the total composition'iof all larvae entrained, *e recommend that the FSEIS include a

discussion about species such as lobster, which has suffered significant declines throughout Long

Island Sound. Larval lobster are entrained at other coastal plants, and it is likcly that there is some

loss occurring atMillstone associated with the daily withdrawal of up to 2.1 billion gallons of

water. We recomniend that the FSEIS address the entrainment of larval lobster, blue crab, and

othershellfish ofcommercialandrecreationalinterest.

MPS-50-5 Pg.4-12. Table 4-3 (Percent Composition ofFlish Larvae and Eggs) is unclear on what the

significance of the dates is for each columniand why dates for larvae differ from those for eggs.

in addition, it is unclear why a 26-year average ofpercent composition data for larvae is compared

to data from one year (2002.3). We believe it would be more useful to provide a graph that

depicts how percent composition has changed annually over the past 27 years. We recommend

that the graph include, at minimum, bay anchovy, winter flounder, Atlantic menhaden, American

sandlance, grubby, tautog,'and cunner. -

MPS-50-6 Pg. 4-13. Table 44 presents larvae entrainmeni data for select'species of fish. As presented, this

table is not clear as to how many larvae are entrained on an annual basis. While knowing larval

concentration (i.e, the number of larvae per volume of water sampled) is important in

understanding the seasonal variations in larval abundance for each species, it does not in itself

provide a clear sense of the annual loss of larvae from the plant's operation. We recommend that

this table be replaced or accompanied by a table in the FSEIS that lists the estimated total larvae

for each species entrained annually froml 976- 2003. While the entrainment numbers may reflect

differences in operating schedules from year to year and such considerations should be noted

where they exist, ofgreatest interest is the number of larvae for'each species being removed from

th6 system. We recommend that that number beprovided in the FSEIS.

Pg. 4-14.- Table 4-5 presents similar data to Table 4-4, but for eggs of three fish species.

However, Table 4-5 presents what appears to be the total numbers of eggs entrained annually and

a volume that corresponds with the volume withdrawn during the period when these eggs were

likely tobe entrained. This maybe what the DSEIS was intended to illustrate in Table 4-4 (the

number listed multiplied by I million), but it was not noted on the headers of each column.

MPS-50-7 While an understanding of how many eggs and larvae are entrained annually is important, the

significance of those numbers varies from species to species based on a number of variables

including species fecundity, age to maturity, estimated annual mortality, recruitment, and status of

- the local population. -Another consideration that we recommend be addressed is whether a species

is an important forage'source to local predatory species, and what the loss of their eggs and larvae

- represent in terms of foregone productivity to the local ecosystem. -These analyses were likelyperformed byMillstone, and we recommend that the FSEIS provide additional information on

what the loss of eggs and larvae represent in terms of adult equivalenits, and the amount of

ADC-3

Jul 2005 -:. A-303- NUREG-1437, Supplement 22 -
Appendix A

MPS-50-7 production foregone for forage species. Additionally, for species that are exhibiting depressed

MPS-50-8 local stocks, such as winter flounder and cunner, we recommend that information on spawning

stock biomass forgone also be provided. The loss of one adult wintei flounder could represcnt the

cumulative loss of future egg production for 14 years, or more.

MPS-50-9 Pg. 4-21. The DSEIS concludes that impacts to the Niantic Rivcrwinter flounderpopulation from

entrainment is "moderate," though it suggests fishing mortality plays i much more significant

role. Other stressors, including rising water temperatures, arm also cited as possible contributing

factors. According to the DSEIS (pg.l-4), "moderate" is defined as "Environmental effects are

sufficient to alter noticeably, but not to destabilize, important attributes of the resource" From

our review of the DSEIS, there seems to be general agreement that the Niantic River winter

flounder stock has been destabilized, that multiple stressors are contributing to this condition, and

that the entrainment of larvae at Millstone (eg., 492 milli6n in 1992) is one of the contributing

stressors.

The DSEIS concludes that the NRC has no role in mitigating for entrainment impacts since such

impacts are regulated under the Clean Water Act. We agree that these impacts are regulated under

CTDEP's NPDES permit. However, we believe that under NEPA, the FSEIS needs to fully

evaluate and disclose the potential enviromnmental impacts from this operation, and identify

possible operational and technology alternatives that could effectively mitigate for the loss of

aquatic resources. The DSEIS correctly identifies the unique vulnerabilities associated with the

winter flounder's habitat of returning to natal systems to spawn, suggesting that localized impacts

could dramatically influence local population dynam ics. However,, the DSEIS includes only a

very limited discussion on mitigation alternatives, and suggests that any reduction in entrainment

losses would lessen the impact of the plant on the Niantic Rivcr vinterflounderpopulation. This

assessment does not fully document the plant's impact on the decline of local winter flounder

stocks.

MPS-50-10 Pg 4-20. The DSEIS concludes that there is no clear evidence of entrainment impact on species

other than winter flounder. While other species may not exhibit the same site fidelity for

spawning that winter flounder exhibit, data presented in the DSEIS indicate there is a potential

cause for concern that additional losses associated with entrainment to already depressed fish

stocks, such as bay anchovy and cunner, could impede stock recovery, at least locally. We believe

that entrainment impacts to fish populations ihat arc regionally depressed should receive closer

scrutiny in the FSEIS.

MPS-50-1 1 The DSEIS notes that populations of sandlancc, bay anchovy, and cunner have been depressed for

decades. Anchovy populations reached a 27-year low in 2002. On pg. 4-27, the DSEIS states that

anchovy declines appear to be reflecting a regional decline in the stock, but on pg. 2-28 it states

that population data for anchovy are not available for Long Island Sound or the Mid-Atlantic

region,.and thcrcfiore "...it is not possible to assess whether decreasing abundance of this species

near Millstone is a reflection of regional populations". For the FSEIS, we recommend that

Millstone's potential impacts to anchovy populations be reassessed and clarified.

ADC-4

NUREG-1437, Supplement 22 A-304 July 2005
Appendix A

Lmpingenent - .. - .

MPS-50-12. Pg. 4-24. Table 4-6 provides impingement data for Units I and 2. Apparently, no data was

collected forUnit 3 based on survival studies that indicated high survival rates for demersal

species during cool and cold water periods. Pelagic species, Including long-finned squid, bay

anchovy, and Atlantic silversides, had poorrates of survival year-round. While these studies may

provide some sense of the fish return system's effectiveness for demersal species in cool or cold

water conditions, it also clearly demonstrates that some'species such as bay anchovy and

menhaden are not likely to survive impingemen. In addition, it does not indicate what the

survival rate is during the warm water months of summer and early fall when the nevest year

class of some species such as vinter flounder are likely to be present in the vicinity of the intakes,

and vulnerable to impingement. Wc recommend that Information on survival rates ofdemcrsal

species during warmer periods be included in the FSEIS. -

MPS-50-13 The DSEIS states (pg. 4-23) that the highest annual irnpingement of winter flounder for Unit 2

and 3 combined was 2,446 fish, in 1986. However, Table 4-6 indicates that the largest annual

impingement ofwinter flounder was estimated to be 23,5S4. The table does not mentionwhether

the numberreflects impingement rates forUnit 3. The FSEIS should clarify the estimate oftotal

annual impingement for winter flounder and other species listed in Table 4-6 that reflects

impingement numbers forall units together. '

MPS-50-14 The DSEIS states (pg.'4-27) that the measures in place at Millstone Units 2 and 3 provide

mitigation for impacts related td impingement, and no new measures are warranted.- This

conclusion is a departure from NRC's approach taken'for entrainment which is io defer the issue

of mitigation to the CTDEP. It is unclear why the DSEIS advises that no further mitigation is

warranted for impingement, but for entrainment impacts which the NRC believe are moderate, the

question of need for, and altemative ways to accomplish, mitigation is largely deferred. As noted

abovc, we believe that underNEPA, a discussion ofappropriate mitigation alternatives should be

in the FSEIS. In addition, we recommend that the FSEIS not view entrainment and impingement

as mutually exclusive impacts, but instead assess the combined effects ofrentrainment,.

impingement, and the thermal plume on species such as winter flounder and anchovy that are

vulnerable to two or all of these stressors.

it Shock

MPS-50-15 Pg 4-27. This section ofrthe DSEIS provides a limited discussion of some potential

environmental impacts associated with the discharge ofrheated effluent. The use of the term 'heat

shock" implies a fairly limited scope of review for a pollutant (i.e. heat) that can affect aquatic

organisms and their habitats in many ways. We recommend that the FSEIS's discussion be

expanded to address heat's less conspicuous ability to: 1) preclude the use of affected areas by

temperature-sensitive species; 2) attract and expose organisms to areas of clcvated temperature

during spawning periods; and 3) expose eggs and larvae to water temperatures well above levels

that are typical under ambient conditions. . - i

AD t.

ADC5 -

July 2005 A-305' NUREG-1 437, Supplement 22
Appendix A

MPS-50-15 Whilo thermal plumes tend to remain near the surface during most of the year, they have been

known to become negativelybuoyant during the colderwvinterperiods. Ifthis is the case at

Millstone, or if the thermal plume affccts the entire water column in shallow areas of Niantic Bay,

we recommend that the FSEIS address how the pluine might affect adult winter flounder entering

Niantic Bay in the winter months en route to spawning grounds in the Niantic River. The 8,000

foot thermal mixing zone, in which temperatures are permitted to exceed ambient levels by4°F,

appears to covermost ofNiantic Bay. We recommend that theFSEIS provide a spatial-view

graphic depicting maximum temperatures of the thermal plume under various tidal conditions and

seasons, and a more comprehensive analysis of the potential sub-lethal effects caused by the

thermal plume.

The DSEIS contains a preliminary conclusion that potential impacts to fish and shellfish due to

heat shock are small, and that no new mitigation measures are wwaranted (pg. 4.29). As stated

above, EPA believes that the FSEIS should provide a broader review to ensure that all of the

possible thermal effects associated with Millstone's daily discharge of up to 2.1 billion gallons of

heated waler are adequately assessed. We recommend that the FSEIS re-evaluate Millstone's

thermal impacts, at least for winter flounder, before reaching a final conclusion on this issue.

Cumulative Tmracts

MPS-50-1 6 The DSEIS (pg. 4-57) identifies fishing mortality, entrainment from Millstone water withdrawvals,

environmental changes associated with regional increases in water temperature, and predator-prey

interactions as the primary stressors contributing to continuing lowv winter flounder population

levels7in the Niantid River area. EPA agrees that there are multiple stressors affecting winter

flounder, but eve believe that other impacts from Millstone besides entrainment may be helping to

: impede stock recovery, if not contributing to the population decline.'

Impacts from impingement on winter flounder and other depressed stocks have an additive effect

to entrainment losses, and we recommend that they be discussed in the assessment of cumulative

impacts. In addition, while the thermal plume from Millstone may not be causing acute mortality

to winter flounder and other species, non-lethal effects may have a significant effect to the Niantic

Bay area. According to the DSEIS, water temperatures in Long Island Soiind (US) have

increased over a 25-year period by 2.80F11.8°F (dailylannual mean). Temperatures in Millstone's

mixing zone are permitted to be up to 4.0OF higher than ambient. The DSEIS states that elevated

water temperatures in LIS may be a major contributing factor to the Sounder's decline, but the

report does not address possible effects elevated temperature from Millstone's thermal plume has

on Niaritic Bay, most ofwhich is contained within the designated thermal mixing zone. If there is

infornation supporting a conclusion that thermal effects are not having any adverse impacts on

winter flounder behavior, spawning success, habitat use, young-or-year survival, changei in

trophic dynamics or forage opportunities, we recommend that it be included in the FSEIS.

We recommend that the FSEIS provide maps with depictions orthe thermal plume on multiple

stages of the tide. These maps should include known aquatic resources, such as shellfish beds,

fish spawning and nursayhabitats and fish migration routes.

ADC-6

NUREG-1437, Supplement 22 A-306 July 2005
Appendix A

F__  , 6 -

CONNECTICUT COALITION AGAINST MILLSTONE

* . i . , . www.mothballmillstone.orag ; - v

- March 2,2005 -;, -, I, ' ./oY

Chief

Rules and Directives Branch

Division of Administrative Services , , -

Office of Administration .

Mailstop T-6D59 , ,

U.S. Nuclear Regulatory Commission

Washington DC 20555-0001

Re: Millstone Nuclear Power StationlDraft Environmental Impact

Statement - -: -

Dear Sirs: -

The Connecticut Coalition Against Millstone submits herewith

preliminary comments concerning the draft Environmental Impact

Statement (EIS) which the NRC staff has prepared in support of

relicensing of Millstone nuclear reactors Units 2 and 3 to extend their

terms to the years 2035 and 2045 respectively.-These comments will

be supplemented with a separate filing with attachments. -

MPS-51-1 The Coalition strongly opposes Millstone relicensing.

The data-available to the U.S. Nuclear Regulatory Commission in

its'environmental review establishes a clear link between Millstone's

radiological and chemical discharges to the environment and major

health effects in the surrounding community.

The data reviewed by the NRC is alarming.' '

MPS-51-2 The data strongly suggests - and indeed does so almost to a

certainty- 'that Dominion Nuclear Connecticut, inc. is operating and,-

will continue to operate the Millstone Nuclear Power Station in

violation of NRC regulations requiring limiting doses to the public of

15 millirems per year to any organ. "4 Z-.

I

Jl - 0 N - 437, S-,upplmen 2

July 2005 A-307 NUREG-1437, Supplem'ent 22 '
Appendix A

Put another way, the data strongly suggests that Dominion's

Millstone daily operations exceed the permissible dose of radiation to

the public and will continue to do so during the proposed relicensing

period.

Based on Dominion's own reporting of radiation sampling in the

environment, the Coalition believes the available data reviewed by

the NRC for the years 2001, 2002 and 2003 prove that routine

operations of Millstone are in violation of federal health standards and

are illegal.

MRC-51-3 By its own admission, the NRC confined Its review of Millstone

radiological releases, for Environmental Impact Statement purposes,

to the years 2001,2002 and 2003. ('Radioactive Waste Management

Systems and Effluent Control Systems 2.1.4,* DEIS at 2-9) (No

explanation is provided in the DEIS as to why the years 1970-2000

and the year 2004 - with the most current data - were excluded from

review.)

MRC-51-4 The Annual Radiological Environmental Operating Report

submitted by Dominion Nuclear Connecticut, Inc. to the NRC for the

year 2001 - one of the few reports the NRC specifically identified that

it had reviewed in its EIS procedure - contains the following

information:

On September 19, 2001, a concentration of strontium-90 of

55.5 picoCuries per liter (pCiAl) was measured in a sample of

goat milk taken from a location 5.5 miles north-northeast of the

Millstone Nuclear Power Station. The uncertainty factor

reported was plus or minus 5.3 pCi/L

A concentration of 55.5 picoCuries per liter is an extremely large

concentration, close to twice the highest concentration measured in

Connecticut pooled milk at the height of nuclear weapons testing in

1963 of 23 pCi/L," according to a report dated March 1, 2005 by Dr.

Ernest J. Stemglass, Professor Emeritus of Radiological Physics at

the University of Pittsburgh School of Medicine and an acknowledged

pioneer in the field of the effects of low-level ionizing radiation on

living cells. The report appears annexed hereto as Exhibit A.

NUREG-1437, Supplement 22 A-308 July 2005
Appendix A

MPS-51-4 Moreover, according to Dr. Stemglass, since the measured value

is ten times as large as the measurement uncertainty, this isan -

extremely significant result, with an astronomically small chance'that

it is a statistical fluctuation.

Put into perspective, an individual drinking two eight-ounce

glasses of the strontium-90-contaminated goat milk on a daily basis

would receive a maximum permissible dose of radiation -'under NRC

guidelines - within 30 days.

This assumes no other radiological contamination of the milk.

However, strontium-90 never appears alone in the environment.

When the radiological effects-of identified concentrations of

radionuclides also reported in the same goat milk samrple - cesium134, cesium-137, iodine-131, badrium-140andothers - are

considered, the effect is even more damaging and far less milk would

need to be consumned over fewer days before the 'maximum

permissible racdiati6n'does established by federal law would be

exceeded, according to Dr. Sternglass.

'The dose to bone or the bone marrow when other fission

products are present is some 5 to'6 times greater than from

strontium-90 alone, and the Dominion reports for goat milk show

significant concentrations of other fission products,'such as cesium137, in significant concentrations," Dr. Sternglass states in his report,

Exhibit A. -' . -

'Using the NRC NUREG 1.109 dose factor'of 0.0172 mrem/pCiAl

[millirem] from Table A-5, a mere 2.4 pCiA daily intake results in the

maximum permissible dose to any organ of 15 mrem per year set by

NRC guidelines; 23 times the amount mIeasu'red in a single liter,'

according to the Sterrgglass report.

Attached to Dr. Stemglass' report ar'easurements, reported to

the' NRC 'byDominion, of strontium-90 in goat milk sampledat

locations within-5 miles of Millstone during the years 2001, 2002 and

2003. . - . . u t y , 20 and

S - - < rt- 3. - a ,:i.! < - -

July 2005 A-309 NUREG-1437, Supplement 22
Appendix A

MPS-51-4 The reported samples of measurements show concentrations of

13 to 14 pCi/A on other days during the three-year period. According

to Dr. Stemglass, these are also significantly high readings since

strontium-90, concentrating in milk due to atmospheric nuclear

weapons testing which ended in 1980, has declined to less than 1

pCi/I in areas far removed from any nuclear reactors.-

Since the samples are collected by Dominion only twice a month,

it is unknown whether actual concentrations on other days exceeded

the levels reported.

In 1997, Millstone's previous owner, Northeast Utilities, persuaded

the NRC to permit it to discontinue sampling for strontium-90 in its air

filter monitoring program. As the 1997 Annual Radiological

Environmental Operating report states:

Section 4.5 Air Particulate Strontium (Table 5)

Table 5 in past years was used to report the measurement of

Sr-89 and Sr-90 in quarterly composited air particulate filters.

These measurements are not required by the Radiological

Effluent Monitoring Manual (REMM) and have been

discontinued. Previous data has shown the lack of detectable

station activity in this media. This fact, and the fact that milk

samples are a much more sensitive indicator of fission product

existence in the environment, prompted the decision for

discontinuation. In the event of widespread plant related

contamination or special events such as the Chemobyl incident,

these measurements may be made.

MPS-51-5 Strontium-90 is among the most deadly byproducts of nuclear

fission. Once ingested, its highly-energetic electrons damage and

cause mutations in nearby cells. Exposure to low levels of strontium90 and other bone-seeking radioactive chemicals routinely released

by nuclear power plants does not merely increase the risk of bone

cancer or leukemia, but it weakens the immune defenses provided by

the white cells of the blood that originate in the bone marrow. See

Declaration of Ernest J. Stemglass (August 8, 2004) submitted to the

NRC in In the Matter of Dominion Nuclear Connecticut. Inc., Docket

No. 50-336-LR, 50-423-LR, ASLBP No. 04-824-01-LR, annexed

hereto as Exhibit B.

NUREG-1 437, Supplement 22 A-31 0 July 2005
Appendix A

MPS-5;1-5 'As recently shown in the 2003 report by the European Committee

on radiation Risk, numerous epidemiological a'nd laboratory studies'

have shown that the risk of cancer and other diseases produced by

local internal doses to critical organs from fission products that are

inhaled or ingested have been underestimated by extrapolation from

high external doses by factors of hundreds to thousand of times,'

according to the Stemglass report, Exhibit Ai

"This explains why it now appears that releases from nuclear

plants, often acting synergistically with other environmental

pollutants, are'a major neglected reason for the recent rise of illness -

and deaths both among newboms'and the elderly observed in the

U.S. in the last two decades, as also discussed in the ECRR report,".-

according to Dr. Sternglass. Id.

For these reasons, it ismy professional opinion that the Millstone'

Nuclear Plant should not be relicensed,' Dr. Stemglass stated. In his

report, Exhibit A.- , . ,- ,

The Coalition has previously submitted, in these and the related

Atomic Safety and Ucensing Board proceedings, documentation from

Joseph Mangano and Michael Steinberg which links the Millstone

radiological effluent releases - including strontium-90 - to significant

negative health consequences in the community. These documents

are incorporated by reference herein.

CONNECTICUT COALITION

'AGAINST MILLSTONE

Nan urtonease address correspondence to: v

incyBurton..

PIl

Ne

147 Cross Highway

Redding Ridge CT 06876

Tel. 203-938-3952

I

July 2005

5

A-311 NUREG-1437, Supplement 22
Appendix A

ietmovu dunt to: Nancy Burton

Date: 031 IJOS

From: En est J. Stemglass. Ph. D.

Subject:) fillstone Relicersing

I have rec ntly had the opportunity to examine the levels of radioactivity-in goat milk

samples r poned by Dominium Nuclear Connecticut, hc In thei Anrida Radiological

Eniron=r ntal Operating Reparts and found that highly significant concentations of

cardinogei ic fission products were measured, Indicating that the Millstone nucleir plant

continues o represent a major health hazard to the people of the area.

Thus, in enclosed copy of Table 8 of the Report for the year 200 1,3a concentration of

55.5 picoC nes per liter (PCltL) of milk of Strontium-90 was reported for Location 22

for the saz4 le measured on September 19,2001. with an uncertainty of plus or minus 5.3

PCIIL. Thi is an extremely large concentration close to twice the highest concentration

measured connecticut pooled milk at the height of nuclear weapons testing in 1963 of

23 PCIL, can be seen from the enclosed Figure 6-1 prepared by the Dominion

Company rthe period 1961 to 1993. Moreover, since the measuredzvaluc is ten times as

large as the measurement uncertainty, this is an extremely significant result, With an

astronomic Miy small chance that it is a statistical fluctuation.

To put this nto perspective, wing the NRC NUREG 1.109 dosc factor of 0.01 72

mrem/PCI oin Table A.5. a mere 2.4 PC1 daily Intake rcsults in the nIaxint:

permissibl dose to any organ of I Snrrcm per year set by NRC guidelines. 23 times the

amount mc sured in a single liter.

Moreover, ince strontium-90 has a physical half-life of 2S years, it must have been

present for number of days that month. In fact, only 16 days at the measured

concentrat ri of 55 PCV/L are sufficient to reach the permissible dose.

As the enellscd saples of mcasurcents show, concentrations of 13 to 14 PCI/L -ere

found on o cr days, again significantly higher than the measurement uncertainty of 1-2

PCI/L. .I'

Moreover, s discussed Irxthe United Nations UNSCEAR reporutbcedose tobonc or tle !!

bone MLario when other fission products at thon

fnrm Sr-90 done. and the Dominion Report for rilk show significant cODeentratiOns

other fissios products. such as Cesiurn-13 7 , again significant concentrations.

chsicentrations of Sr-90 and other isotopes measured clearly exclude the

possibility 1 they are due to past nuclear bomb-tests. No other sources of Sr`90.exdst

other than tefission of Uranum, so the measured values repreent releases from

Millstone.

NUREG-1437, Supplement 22 A-312 July2005

I
'Appendix A

PAGE 02

21:e9 4126e16251

.~ :.

Asmea

nrninerou~

other d

tbat are r

-.. extral d

-1.- . appears

.- environnu

: - dchs bot

,i.- as also dis

For thcse - not be relh

y shown ii the 2003 report by the Eurupani Committee on Radiation Risk,

epidemiological and lhboratory studies hav shown that the riskl of cancer and

ises preduced by local internal dosts to critical organS From fBssion products

iWled or ingested, have been underesUtmated by exspoaton from high

,ses by factd orhundreds to thousands of times. Ths explains i*hv it now

it releases from nuclear plants, often acting ynergitically w;ith odher

nrta pollutants, are a major neglected reason for the recent rise of illness aid

amnong newborns and the elderly obserud in the U.S in the last two decades,

:ussed In the ECRR repor.-

=as s, I t is vy professional opinion that the Millstone 1clear Plant should

cnse&* ,

enmglass;Ph. D.

tmeritus of Radiological Physics

f Pittsburgh School of Medicine

ss: .- : :.

uare #2

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PAIS213 - -.

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Ernest J. S

Professor

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. : . . .- -

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. . r . I - I . . tJuly 2005 A-313, NUREG-1 437, Supplement 22 -
Appendix A

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00 MIU ows Fm&Ni&niai U a =In m i ui M4 INoWAS 

a uZs 3 z o OM Ce= Mm m n wx 0U nt ryqt .

__ - - - --- - -- - - --_ .......................... _ .._ _ __ _ __.___ __ ______ ____ __ _ _.__ __
C

N) 0

0

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.:

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Q se %=NW 1 WRO ;kI __ :_ __ Z aWc

Strontium-90 in Milk :.

, . 8

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CA

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Iz.. M

IC

:G)

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X
Appendix A

h4;1W- 6"6

UNrITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

BEFORE THE ATOMIC SAFETY AND LICENSING BOA

In the Matter of

DOMINION NUCLEAR CONNECTICUT, INC.: Docket No

50-423-LR

D

SO- 3 36 -LR,

I4824-01-LR

(Millstone Nuclear Power Station, Ualts 2 and 3) : ASLBP No.(

DECLARATION OF ERNEST I. STERNGLASE

1, Ernes J. Stemilass. dobereby decdre as followx

1. 1 am above the age of ighten (18)years and I believe in the obigationao

2.1 reside a 4601 FiMh Avenue in Pitbburg Pnnisyrvaduk, 15213.

an oath.

3. 1 submit this declarion in suppoat of CGnndcut Coalition Agaist nebtervenfion

the above rcfrenced matter.

4. 1 2m PrOfesor Enaaitns of Rdiological hysics at the University of Pi

Medcine and bave written and published extensively in the a of low- level rad

helth. and about the advere effst of radioactive etmsi& from the Mlskm

Station in particular.

S. I Am the 2unt of the book oSecr Fallout Low-Lerd Radtadoo fio Wim Mfile olandw published by McGrawnHill in 1981, of the review artidce "Enviro=

Human Health" published by the Univesity of Califoria P mss 1972. and the

Morlity Changes Around NuclearFacilities in Connecticut" published in Rdj Human Health ftmeedings of I CogMsuicaj Seminar Febny 10.197M8, by Pblicy Institilte in Wanb~ngton L)C. The fiacts and statements comtined in these

incorporated by refermco herein as efrnces 1. 2 and3 respectively.

6. 1 have published a ser. of papers co *8ects of low-kevcl enriroenta

Iuman health and develop produced by nucew weapow kst and reactorel

school of

don amd h ann

iear Power

toThree.

tIJ Radiation and

de ICac

Standards ad

En vironmental

icatlons AM

radiation on

sses for thiqlads

IE 9V~d TGZ9T.99ZTV 62:T' G20Zi1W0/E

NUREG-1437, Supplement 22 A-31 8 July 2005
Appendix A

I

'I forty years. and have testified on this subject at bearings held by the U.S. cboq

Acadcmy Cf Sciens. State Legisgatuas and U.S. Government Rcgtduatory AV

this subject. . , .

7. It is my pr opinion that the rAdioactive relee fron the Milda

Station since its startup in 1970 have caused and will continue to cause excess a

bixihweight, le"kemia and cancer as well as increased rates dboh chronic and

the towns armuid llstone as well as in New d bmty and. Comtecticut

8. Accordingo theNRCppubliu Rndioaxive Matials Rdeaed Frm

.Ya- Ins (NUREG ICR -2907), by 197f Millstone bad relcased a total oi32 Curi

,Iodine and ParticuLates into the air which include the hihl carcinqec Strwt

13 1. together with 6.7 million COuries of Total Fission and Activation gses sx

K-yptoa. and tih higst liquid rdeasca orMxoeds Fsiou ndActivation Podu

- plant in the Utnited States, namely 581 Curies or 581 trillion plcoCuries. the uni

:nlddinking wwa.

9. In a Iinge year. 1975. Mhllstom rdeased a record high of 9.99 COmics ofl

Pamiculatas into he air, more thm wice as high as the 4 Curies released shortly

- 1971. together with 29.7 n2illicm Cuxics oirTota Fission ad.Activation Gsses,

liquid Mfixed hssion and Activadon Products into Lng sland Sound also are V nudlearnt

ress. the Natioml

ncies as an expert on

Nudear Power

{ant mortality. low

Infetious diseases in

s a whole.

4ude Power

of rdioactive

0 md dine

as Xenco and

aof nynuclear

of concern in mrilk

*and

*sartupin

I C99uCries r

rdfor al U.S.

repot (3 X

London S miles a,

at s a

while it

the pattetn d

in dt milk

terto only 3 pCiil.

Nuclear Plant.

ping out any

that continued

10. Betweien tartu cfMillstone in 1970 and 197S, asz6wrn in the 197816

cancer mortality rose 89% in Waterford where the reacir is locai, 44% In Nle

noist, ethe 27% in New Haven 30 zmiles to the west. 12% for he Stare of Cq

wbole. 8% in nearby Rhode Island, 7% in Massachtusetts and 1% in New Haim

actually declined by 6% in the most distant New England tt fllo

Strontiurnn90 in 66 mile shown in the samc rtpoii ' ' t mn w n

11. As shown ini Txlc 9 of reference (3). while theS cost enttatt .~~ .. . . I ,,t,

declined for tbe U.S. xs &a Whole between 1970 and 1975 from 8 picoCuties per

it roae from 9.8Ln 1970 to a hi Or 15.8 in 1973 and 14.8 in 1974 Dear the NMill

remaining at10.7by1975.ThisisfarincxcessoftheU.S.averageof3pCMlr

signi-cant confrlltionoto the local milk bom bomb test fa tby France aiW Ch

uintil 1980.SO..i.' ... r .

i

I

- 39d .,. - - - _ .,-- P:Iz. 5OO:/131E0

July 2005 A-319 NUREG-1 437, Supplement 22
Appendix A

I

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12. As shown it Table 10 ozfrfnce (3) the calculated yealy radiation dw

due to the excess Strontium-90 within 10-15 miles of the plant In excess of e

U.S. rose from 33 Mireme per year in de first full year of operation to 204 mr

naiy thee timcs the nrmal bakground levelof 70 mrmyr in Coneclicut13. These doses due to Stroniumw90 alone may be compared with the 1.5 mr

permitted under current NRC reuladonsto the 2 mem produced to bone m~mi

X-ray ofm chil and the 80 turezumyr to a devdoping fetus fotaid to produce a

of childhood leukemis in the studies of Dr. Alice Stewait cted ir Reerence7 d

exposure in the mothcr's womb to X-rays in the fust three n of pregnanc

14. These considertions, later suppotted by the mo c studies of Sum

baby fteeh togetw with effecu an cancer m addcc and infanl molality as

submitted in the prsent case and referred to here as reference (4) plide ovem

the existence o01 a relationship betwcen the aboonmily high levels of Str

and the pattern of cancer changes at various distances from the Millsoone planL

15. The extence ol' directcs rcatioshipbeween Sir n-90 e

reactos and an increased risk of cancer is very strongly supportedby the fdin

Mwngwo (4) thwt baby teeth of children dignosed with cancer have doe

concentration of Strntium-90 than childkk bom the same year and in the

has led to a lawsuit havig been fMid in odida against the :rida Power and

family of a child with a very high Strontium-90 ooh concentration selCing

which a fed Ijudge ruled to be of suflicictt merit to go to tial in 2005, despi

defendant to hate it dimissed (5).

16. As panted ota in reference (3), this cncelusion is slp

types of cacer that se most straogly in the Connecticut a r Mi

exactly those that have been found to be most sensitive ito adiat in ir

intcniational standrd setting organizations nazsely those that inceased the mt

respirutory ancers (37%). breast ca (12%), and pancreatic cancer (32%).

17. Likewise. furdhrr support for a causal relationship of nuclear plint rees

effects is Lpriddd by the rct cited by Mwcuso et a.(S) cited in reference (1)

showed a much greater rise in women than in me, nmmely 17% for white "

t to bone of a child

,early dosn for the

r/yr by 1974,

= to myoara

in a typical chest

ububs of the rate

rfertee (3) for

um 90 measured in

by Maganw

gevidence for

aum-90 in the milk

from riucder

described by

blc the

area. This fInding

Eght compmny by the

peasation. a suit

P efrts of the

YThe fact tat the

Nuclear Plant are

tes by national and

Iby 1975, such as

a and adverse health

it canc deaths

aand only I1% for

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NUREG-1437, Supplement 22 A-320 July 2005
Appendix A

I ..- ... . .I

'. I

white m This r diffTce between males and females was foumd by M

investigators for atmic workers at the Hanford Nuclear Plant exposed to low

int-. nt exposes to aidical ors due to inhaled and ingested radioactive den

. -leased by Millstone over a period of years, together with protced extenmi l

gamma rays produced by fission products accumulated on the gund. nther th

ray exposures used in diagnostic p.-ocedures. . --

I 1A renwed rin in infant morality in the six towns neaest Millsloe took

; .decline by 18% when thaem units had been shut down for ost of 1996-97 as

of the 2004 repoctby M gano (4), with smlr decline oc 3.1% in 1998-99

I folowed by a rise of 8.8% in 2000-01. This is very strong evidence Induating

s-mallerreca Orm the two remaining PWR type of reactos confinue t adr

of the newborno tat ther can be no safe opeaion of any exiing typ of n

j d ndi on whomtbefuture ofournationdepends.-*-

* 19. Temuch gretersik to buman heah from rdodve ases ad particl

ingcst md contrte in certain critical orans such as the bone marrw or'

glands such as the pituitary gland targeted by the highly radioactive daughter Pr

- 90, the element Yttziun-90 t& has differest cdamical proeies and leaves the

j in soaf tisueL his sts in vesj high locil doss to boththe bone rw an

producing glands ovr long periods of time that greatly exceed the w -body 4 I

cancer and other advc deects an health hundreds to thousands ol times reat

expected by a linear extrapolation to low doss of the risk (run shat exte.al

received by the survivors ofl iroshima and Nagisaki orindivlduals exposed to

j - do not co _ in SpOTic lorgadnp . as dscaibed in the ECRR Seport (6).

20. ftisimpornt bnde thatexposue tolowlevels ofrSt tum-90ando

^. - ctivechtnlsrideays eaedby atdesptnts Ihesnble Caliu d

'increae the HAs of bone cance or leukemia. but they weakein the irntman defe

- white cells of he blood that orginatc in the bone maiW. As a result the ntc of c

au over the body normally held in check by white cells is inad, and the derf

infectious diseases such as influen pneumonia and AIDS sie lowered. in.. X

infant matility due to all causes combined as discusse in refercses (IX2X3) m

'' *.I' ''-^;--wT_,, r*.*. .

21. Unfomnatdiyforthe protection otbuman bea the opeao of nucla ]

NMillstone are no lon required to measure Strantium-90 in to milk, the sail, t

oand his co

dosei of both

mu n minblr to those

:$poss from F tovery shortXafteraslap

dscaibed in Tablc 9

relative to 1994-95.

even the much

yaffect the health

plant for the

s t6nt are inhled or

hormcn prodiing

duct of Strontium.

te to concentSate

the critical hormone

ose and result in

than had been

Postres such as

aedictil Xnrays that

c bone seeking

do not merely

es provided by the

ancer de, elonpent

ts against

zg both total and

id (6).

plants such as

water and other

._ ._, _ . ,5;b:Tz -o 90VI/ED

July 2005 A-321 NUREG-1437, Supplement 22
Appendix A

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II

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II

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f

I

I

GE MI,

enronmental sampes, nr does the government caure boao

1982. and milk concentrtons of this critical dement each mouth in a series of

nation since 1990. Thus. preschdy dhe operators of nuclear y dt

emitting elements such as CesiuI- 137 tat can be more easily and cheply meas

90 that emits only short range electrons that cannot penetrateth gecmer

rays. and which rquir more costly laboratory procedures for eac le.

22. As rec'evty bhoughl out in the ECCR report (6), the reao the i

exposures due to inhaled or ingesttd radioactive chemica is is 100 to 1000

sa dose due to shart expoas is that for dhe low d given over a long pes

free-radicals of oxygen dominate over direct damage to the DNA and cel memb

a doeresponse curve that se extemely rapidly for very mai dses and

doses, thsn causing the ero made by a linear extrapolation to zero doe used to

cxisting safety standards for pemitted releases from nuclearpants

23. Thus, the ECRR report states in paragraph 10 of its execadre summatyi

cancer epidemic is a conseqence ofexpour to global amospeic weap; sf*'

1959-63 and that more recent releases or radiolsotopes to the enviro

operation of the uaudear fuel.cyde will result In signifkant Increas:

other types or III health Emphasis added).

24. Thus, in the conduding paragraph of the executive sunruy. it sMs thatl

committees belief that nuclear power is a cosdy way of pdudcing emtcr when

defiitb ar: included in the overall asessment' and tat dte envirl a ceru 

radioactive discharges must be asscssd in rehuion to the total envroii n, int

indirect eifects on an living sysinza.(6).

hiselerment after

tes across the

measne gamma ray

5rred than Strontium.

used for gamma

C low protracted

Iimegrener %an the

rodthe damage by

uica. Thisleadsto

nlatten out at high

Caabliush the

that the present

[lout il the period

imentt from the

z In cancer and

tis 'he

i-man health

peinerms of

ding both direct and

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2.5. Although the mot serious airborne rAdioactive releAses so far have ocoir from the

operation of Unit I which was a Boiling WaterReactor (BWR) peraneny da in 1996, Eca

described in referenes (1) and (2) have found similar incrase in infant l. low birthwtiht

and cancer awmd Presstuied Wae Reactors (PWR) such as Sb 2pingport n2f ittsburgh and

Indian Ptint neatr New York City. Therefore. it is to be expected that a twenty yer renewal of the

operting liUc for leLtn Units 1 ald 2 would further ICae the adverse effects an human

health and their associated cost in health cam, as well as the damage to wil :ife, irds and fish taut

have been rising ala gly in recnt years.

TSt89Mtt Sd 63:TZ SOOZ/T3/Eo

NUREG-1 437, Supplement 22 A-322 July 2005
Appendix A

. I . " I

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II

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II

- 1. .i.

1. ,I I

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I 26. This fuiher increase of damagc to hmn health and the envirvmnet isu

shortilived ndiosive elements such as Iodine-131. but also due to the longhai

radioactive chemicals routinely deasedby nuclearplants such as the 28 years il

of StrUumt90 to decreae by half. Ibus. itis vey likely that coctinued oPCvu

Nuclear Hant will uiheRnas the rates of cancer,. low tirtbweigh. Infant ia

diseases such as yptrdism. diabetes, and other diseses rlaed to

system damage a these eements accumulatc in the underground wid table fic

their waler, maing it impoasible to safely protect the public. .

27. The unexpectedly gra Hi to the life and future heAlh of the newboan c

doses of radiation to cniical organ has just been further supported by a study c

prematurc births leading to underweight infants as repwtd in the Apil 28. 2

I

I

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0

1

I

I

I

I

Journal of the American Medical Association (7). 1his study revealed that thev o

scaured rME1ion to the thyroid in the neck ofthe modher puced by just am

during the riust te moxths of pregnancy, approximately 40 tillirym each, Sir

the risk of prmatuebirth and low birth weigL Tbis in turn is knon t Incres

well as prodcing a ge danger of mental and pbyscal problems for infants'

resdt of rccn advats in neonatal cart, but at huge emotionil cost to the fam

cam costs to society * -

et only due to the

-life of marty of the

takes forthe actirity

on of the Millstone

xEtality and chronic

and bormonal

n which wells draw

e to very $en

the inciAdence of

4 isse of the

y mall doe due to

Dr two detal X-rays

ificanty increased

meinfant ortaliy as

rho survive as a

an rimi health,

cts on humz health

lntium-90 and other

poe 2 md 3 reators

~ts forsafety. and

" the proposed

edr

j ,informatonx

I

i . i

-

28. In the lightofcn kwledge of the unnidpatedseus adersx effI

- ereeya m doses of prolonged enviromental radiation exposures to Strd

fissiot puts as descibed above, it is may professional opin f itt the M sa

I would need to end anl radiation releases in order to meet public heslith raqierel

thad tirmforel should not be granted ficense renewals to continue operadons

I twenty year rnewal periodwithout demonstrating that this objective can be achie

I bereby declre the foegoing to be true and accuate to the best of ry knowl

and belief underpenlty of pajury..

Dated Aupst 8, 2004

I~~ ISZ918szl 60:1z ScOOZ/io0c

July2OO5 A-323 NUREG-1437, Supplement 22
Appendix A

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LIST OF REFERENCES

1) Ernest J. S t& Secret FAllout Low-Level Raiton from EHlrshim

Island (McGraw - HEi. New Yost, 1981) Available on the wdsisc wwwm&,

2) Ernest J. Ster;ass, Enviromntal Radiation and Human HeaiW, pp.1

of the Sixth Berkdley Sympomizm on3 . aical Suaitics and Probability: EJ

Health', Edited by 1t L Lecamn, J. leynan El. Scott Univensity of Califomia

Lw Angeles 1972.

3) Ernest J. S tern2&% "Caner Motality Canges Amtd Nucdear Fkihit

pp. 174-212, nRadato Sbandads ndHn HeAt Proceedings of a Coagr

Fenuzy 10.197ppliashd byt EnionmmeniPolicyWitA, Wmntoa

ktolue~lwe

lion-org

15-216. Procedings

rects of Polh on

Pres Berkeley and

m inCoinmcticui.

smnal S .minwr"

DC.

4). Joep . MNzgmno.,Riks of cancer And Other Diseame Froui The Oi tion Of 'Me

XMIstone Nudewr Plant,' August 5, 2004, Radiation and Public HeaIIII Pro,-ct,.New Yodr, NY.

5). Einesns vs. ,PP Casn Number 03-140040-CIV-COHNILYNCHC

6) Philip P. Hud eta]. wAnteptma Dental Radlogrupdy and Low I

Journal of tit Ameican Medical Assoiation. Volume 291, .o.16. April 28. 2

7) .'Heallh Effcts o 1onizing Radisdon Exposur at Low Dose forRadiai

Purpose: Recomndadons of the European Committee on %distion Rik, E

with Rosalie Bated. Inge Schmitz - Yerhake, .Molly Scou Cato and Alexci Y;

for the ECRR by Green Audit Press, Castle Cottage. Aberystwyth. SY 23iDZ,1

(2003) Webeitb wrw. curdcoutorg 2003.

jith Wtight'.

)04. pp. l987-1993.

a Protction

Sitedby Cvis Busby

blokdv, Published

Jaited FKingdom.

Z E 3Sd TSZT83 ZTL' 60:1Z sOO iioico

NUREG-1437, Supplement 22 A-324 July 2005
Appendix A

COUNTY OF SUFFOLK 3/ /

-OFFICE OF THE COUNTY.EXECUTIVE - (^'4 0'A

St.-- Levy, f'i

CO. .YExEcunvE-

; : ccvin S.t Law . - tkd;r^

CmtyExcc Cc.hizcp ccuw '*rc; or nmcaut Arain

February23,2005 -

: Chie, Rules Review and Directives Branch

U.S. Nuclear Regulatory Commission - - '-- -

'-- -Mail Stop T-6 D59- - - -. _

-Washington; D.C. 20555-0001 '

Re: Millstone Power Station, Units 2 and 3,'NUREG-1437, Supplement 22 ~~~~~~~~~~* - * ,-* ..- , ,*,,* .. * ,; ............. - . .. e. -,t * ....... . .

Dear Chief: - - . .-. .- . . . -

A-draft-.upplemental impact stateme'nt (SElS)'ias been's6bniitted to the' Nuelear Regulatory

Commission (NRC) by Dominion-Nuciear ConnecliEUt lIncorporated concerning the application

..- to renew the operating IicenselforMillsl6oi'-Pover Statioii, Units 2 and 3 for an additronal 20

MPS-52-1 years- -,he County of Suffolk finds the do nidntvrliry'irrow in scope, aid lacking de'ail with

regard to.the issues of concern to the 1.4 milli6&i residerits of our county. *it appears thhi public - notifications to areas in'Suffolk-County-within the!'f'a'd T50 mtile erersencylanning zones

- - were neglected; that there is no need to rush 1d6* tirigc'liecnse Jreienwal for he plants decadcs

prior to their license expiration; and, that radiological emergency evacuation plans for Suffolk

Cdunityvere not addresseda.. 6 1 ,. ^ -- . - ( * :! -: i

! ' .' was dismaycdi'tfat a public hearing was noi held in Suffolk County concerning the renewal

' application and that the Commission failed to contact local municipalities and environmental

groups on easter Long Island (Supplement 22, Appendix D,- Organizations Contacted). An

- analysis'of major points -of vev 'conerning signlficinti'probeies' ind obfeeiions rsised by

. federal, state or local agencies is required by 10 CFR 51.71 in a draft environmental impact

'- statement.. In accordance .with NRC policy regarding public involvement in reactor license

renewal and as Suffolk County residents may be adversely affected by the renewal, ve request

that a public hearing be held in Suffolk County where the NRC and Dominion can respond to

*h.se ss e. .. . . .. . .

MPS-52-2 Suffolk County views the-applicattons to rcnew Millstone's.opcrting licenscs as preinatueICat

this time. 'The current operating licenses do n6t e6pize' forpeniodi Of 10rand 20 yeirs, 'until Jiiiy

201 5.for Unit 2 and November 2025 for Unit 3: 'Wilh the advance'of scicnce in 'ihe -next two.

decades, itis iikely that alternative cleaner e'nerg s'ources anidlor conservaiion wvil inegait the'

need for license renewvil foroutmoded and liazrdoiis hbclear jeherating plants:' it is clearl selfserving for the Commission-to conclude'1that 'FiVron'me- al impacts for futfre'gencrating and -

*-: ' conservation altematives-uould be greater than tlioc opfeating Millstone'(Supplementf22, pages

xix and 8-51). :te NRC Fact Sheet on Reactor Lfcense'Reneial states that the license renewal

onoDtsoti I 1ANSLRt6OAllWAY *fAbOIw10 * IIMWUAUGA V.Ifl-8 * (I)I

/'/{ "' @- ' ";- *-::; "'-l' -,' '- -. g5t '~-0

<g-<)AP- @i zFs,<

July 2005 A-325 NUREG-1437, Supplement 22
Appendix A

2

MPS-52-2 procedure is expected to tate no more than 30 months. Why then is there a push to renew

operating licenses decades before it is necessary to perform such a review?

Suffolk County is an important stakeholder in the application to renew the operating licenses

because the plants are located within 10 miles NNE of the tip of Orient Point and seven miles

WNW of Fishers Island in Suffolk County. Fishers Island and a portion of the Plum Island

Animal Disease Laboratory, now operated by the Department of Homeland Security, are located

MPS-52-3 within the Millstone Power Station's primary 10 mile Emergency Planning Zone (EPZ). In the

event of an emergency, Fishers Island's residents are to be evacuated to either New London or

Stonington Harbor and be bused north to Windham, CT. *That is the fate of researchers and

operations at Plum Island in the event ofa severe accident at Millstone?

A 50-mile Ingestion Planning Zone is identified in the State or Connecticut's Radiological

Emergency Plan in the event that a nuclear plant release is carried beyond 10 miles. This EPZ

encompasses virtually all of Suffolk County east of the William Floyd Parkway in Brookhaven - -T ownship. -Alftugh-ngestion sugcM.an-asssmentnofdv ndfdrinklrM7Nvacr,-a-rccasc=--

carried southward to Suffolk County is likely require additional public protective actions, up to

and including evacuation. This had been deemed infeasible during the public discourse

concerning the Shoreham nuclear plant due to the lack of adequate transportation infrastructure.

Since that era, no new major east-wAest transportation facilities have been constructed, hand there

has been a significant increase in the population of eastern Suffolk County. Evacuation of

eastern Suffolk County remains an infeasible scenario, a fact we consider to be a major factor

impeding renewal of Millstone's operating licenses.

MPS-524 NRC regulations limit commercial power reactor licenses to 40 years, but also permit such

licenses to be renewed where appropriate. In the case of Millstone, however, renewal for 20

years is not an appropriate public policy decision. Ihe NRC recognizes that some structures and

components or nuclear plants may have been engineered on the basis of an expected 40-year

service life. Suffolk County is not reassured by the assumption made by the NRC in NUREG1437, VoLI, section 53.1.

"In assessing the impact on the environmentfrom postulated accidents during the license

renewral period, the assumption has been made that the license renewial process it-l1

ensure. that aging effects on the plant are controlled and that the probability of any

radioactive releaserfrom accidents vill not increasc over the license reneiralperiod."

__~ . This does not appear to be a credible position in light of Dominion'sstatement.(Supplement-22,,.__

page xvifi) that it dn'otideniJ5;`any major plant refurbishment activities or mod~tycations as

necessary to support the continued operation of Milstonefor the license renewal periods The

county has difficulty reconciling the two positions that, l) the NRC will "control" the effects of

an aging plant forty years into the future, and yet 2) Dominion foresees no major maintenance

activity as necessary for safe operation through the year 2045.

Other significant issues that are not adequately addressed in the SEIS include:

MPS-52-5 * The cumulative impact of routine operations to aquatic resources, although recognized as

significant for winter flounder (Supplement 22, page 4-56), are not adequately addressed or

mitigated by the SEIS.

MPS-52-6 * In the event of a severe accident at Millstone the probability of wcighted consequences of a

release to groundwater is stated to be small (Supplement 22, page 5-4). However, there is a

potential for radioactive fallout directly onto the surface water bodies that serve as the

I4DLNISLVM Dflt: * 100VErMANS1nIORAt1J1GHWAY2 * P.AOOX4100 * tAVpAUOLPMY.118S4)00 * . jI3S12.6=

NUREG-1437, Supplement 22 A-326 July 2005
Appendix A

3

MPS-52-6 Fishers Island water supply. Radiological monitoring and the provision of an alternative

public water supply for these Suffolk County residents are not addressed in the document.

Dominion estimates that the dose to the population within 50 miles of the Millstone site from

severe accidents to be between 12.8 and 17.4 person-rem. What is the expected dose to

county residents living on Fishers Island and the North Fork that are in considerably closer - proximity and what health risks are posed by this exposure?

Thank you for the opportunity to comment on this proposal and we look forvard to hearing your

response at a forum held in Suffolk County. -

Sin cy

teve vy

Sti* ' folkCounity iXeCUlVC c - .-

Cc: Diane Screnci, Public Affairs Officei, United Statcs Nuclear Regulatory

Commission, 475 Allendale Road, King of Prussia. Penutsylvanial9406-1415

Kevin Law, ChiefDeputy County Executive and General Counsel

Paul Sabatinol1, ChiefDeputy CountyExecutive - -

Christine Malafi, County Attorney

Lynne Bizzarro, Deputy County Attomrey -

Michael Deering, Director of Environmental Affairs

Brian Harper, M.D. Commissioner, Department of Health

Vito Minci, Director, Division of Environmental Quality

. .

SL.EDE O5N BJL~Dc.' * .SOOVETtRARS~t£J1OUJLNfICIIA3. s O.OOWX4IOO *UIAUIPAUGLU.Y.I?1*~9 * (s2I)it-~

July 2005 A-327 NUREG-1437, Supplement 22
Appendix A

* Richard Emich - Deny Millstones Relicensing

: . s1 31/043Azd,-

Page 1-

From: Helga Waller chgloptonane net>

To: <reOnrc.gov>

Date: 2/25/05 8:19PM

SubjecLe Deny Millstone's Reticensing

MPS-53-1 I urge you to deny Millstone's Relicensing

MPS-53-2 1. There are no emergency plans in place for Long Island In the event or

an incident or accident at the facility.

The DEIS Ignores the safety threats to Long Island residents and the

environmental Impacts of the aging reactors.

MPS-53-3 2. Minstone has been operating with an expired Clean Water Act discharge

permit since 1997. The Clean Water Act mandates permit holders to obtain

five-year permits so that every live years they will have to demonstrate

that they have Implemented best available technology to reduce or eliminate

polution I they want their permits ronewed. Milstone has been able to

got away with operating with non-updaled technology an extra ive years.

MPS-53-4 3. Millstone is responsible for the depletion of native lish species

through the operations of Its Intake structures. All these assaults on the

environment would end If (a) Millstone were shut down or (b) If Millstone

converted to closed cooling system. This important Issue certainly affects

Long Island because of the dispersion of toxic and radioactive waste

byproducts by tidal and wave action.

I urge you to deny Millstone's Relicensing I

H. Gelsier Walter

Long Island Resident

hgeoptonrlne.net

1 0 2,4'/A1

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NUREG-1437, Supplement 22 A-328 July 2005
Appendix A

Richard Emch - Deny license extension to Millstone.

Se. -

From: Margie Brock <margieb:

To: <rleOnrc.gov>

Date: 2125/05 8:58PM

Subject: Deny license extension I

MPS-54-1 Please deny the icense extension to MfilsI

. - _

: 

_ .

Page I

3@optonline.neb

to Millstone.

tone. -

V .5 _ -- .,.

July 2005 - -

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A-329, NUREG-1437, Supplement 22
Appendix A . I

; I

i i

I !

i,

i.

0!_l-4 _, - r rnh _ I .- ,IKhotl . V. . I

.... _

From:

To:

Date:

Subject

<SMEP2OaoLcom>

<r1e0 nrc.gov>

2Q26/05 9:38AM

(no sublect)

To Whom It May Concern.

MPS-55-1 Nuclearenergyhas its attnbutes but plants should be located In sensible areas where evacuation In case ol emergency Is possible.

MPS-55-2 Please use your common sense and protect both the public and the fragile LI

MPS-55-3 Sound environment before you bcense Millstone to continue for another twenty

years.

Sylvia Palenyk

Southold. LI

/ ;'/"/D

6G/.i( /737

CC: <nlec 0 oplonlinenetv

t-,- = 4 "/- - e- 11 c, A-- 4 -,=)

NUREG-1437, Supplement 22 A-330 July 2005
Appendix A

Richard Emch - rolicensing of Millstone

.. . .- .

From: .cCaseathome~aol.com>

To: <flrtinrc.qOV.

Date: V27 33-8PM t/5 

SubJect: relicensing of Minstone

MPS-56-1 Gentlemen: It is very upsetting to leam that you are considering

relicensing the Millstone plant with all the negative considerations that has:

MPS-56-2 1. Millstone has been operating an expired clean water act permit 1or a full

5 years beyond the alloted lime. - . - - i - -

MPS-56-3 2. The Millstone operation depletes the natve lish population due to

Ineffective Intake methods

MPS-56-4 3. There is no plan In existance for a sale evacuation from Long Island In

spite of the fact that It is 11 miles away. Shoreham was shut down for just .

that reason. -F, . . -

MPS-56-1 How can you be thinking of this? Millstone must be shut down. Dent tool

with our Rvest - - .

Yours truly

Constance K Case -

Pige11

6~ 7Fe,59Y$57

July 2005A

,6r-,,O.q aS =,09 PC-3

f -.. c - . . e) -,- . -;

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A-331 , NUREG-1437, Supplement 22
Appendix A

Richard Emch- Minstone Relicensing Pane

s _A* o

From: <JudgekkOaol.com>

To: <WeQnrcgov>

Date: 2/26105 11:34AM

Subject: Millstone Reticensing

Mr. Emch.

MPS-57-1 As a property owner on Long Island Sound at Northville Beach. lam opposed

to the relicensing of the Millstone Nuclear Plant. My reasons are as totlow

MPS-57-2 1.The Millstone Dralt Environmental Impact Statement Is completely silent

on Impacts to Long Island. There are absolutely no evacuation plans In place

for Long Island.

MPS-57-3 2. Millstone has been operating with an expired Clean Water Act discharge

permit since 1997. The Clean Water Act mandates permIt holders to obtain

five-year permits so that every live years they will have to demonstrate that they have Implemented best available technology to reduce or eliminate pollution

If theywant their pernits renewed. Millstone has been able to get awaywith

operating with non-updaled technology an extra five years.

MPS-57-4 3. Millstone Is responsible for the depletion of native fish species through

the operations of Ks Intake structures. All these assaults on the

environment would end if (a) Millstone were shut down or (b) It Millstone converted to

closed cooling system. This important Issue certainlyaffects Long Island

because of the dispersion of toxic and radioactive waste byproducts by tidal

and wave action.

Kathleen McGraw

/ -s /cx

6 IrVeV,56

,5.r- j/ I - , ,. ye

--/I- 109bA4 -0/3

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NUREG-1437, Supplement 22 A-332 July 2005-
Appendix A

Richard Emeh - I Oppose the Nuke Plant Relicensing at Millstone CT Page 1 i

From: Justin Porter <Justembase~yahoo.com>

To: rle0nrc gov> . : -

Date: 2128/05 10.09AM

Sublect: I Oppose the Nuke Plant Rolicensing at Millstone CT -

Hi Dick.

MPS-58-1 I oppose renewing the license on the Milibrook Nuke. I feel It - *- - - -'S/7

threatens the safety and security of Eastern Long Islanders. I am a US

Citizen that votes.

Justin Porter

848 Roanoke Ave

Riverhead NY 11901

- NFEC <nfec0optonrinoneta wrote:

> Tell the NRC to Deny Millstone's Relfcensing! Deadrmo March 2.

a 2005!

> The operators of the Millstone Nuclear Reactors are seeking to renew

a> their

MPS-58-2 > license. If renewed, these reactors will be up and runnirig fori

i >another2D

i> years. yet there are no emergency plans In place for eastern Long

> Island In > the event of an incdent or accident at the facility. - -.

a> The Nuclear Regulatory Commission Is accepting comments on the Draft

a> Environmental Impact Statement (DEIS) for relicensing. The DEIS

a> Ignores

a> the safety threats to Long Island residents and the environmental

.> Impacts

a> of the aging reactors.

> Reasons to oppose:

MPS-58-2a 1. The Millstone DEIS I completely silent on Impacts to Long

>. Island. Shoreham did not come on inhe becuse we couldn't put an

a> evacuation plan hI place.

MPS-58-3 > 2. Millstone has been operating with an expired Clean Water Act > discharge permit since 1997. The Clean Water Act mandates permit

> holders to a obtain five-year permits so that every live years they will have to - '_

a> demonstrate that they have Implemented best available technology to

a> reduce

a> or efiminale pollution If they want their permits renewed. Millstone

a> has

a> been able lo get away with operating with non-updated technology an

a> extra

a,. five years.

MPS-58-4 > 3. Milstone is responsible for the depletion of natve fish

a> species

!> through the operations of Its Intake structures. All these assaults

> on the

a> environment would end If (a) Millstone were shut down or (b) If

a Millstone

£/ 3_J,1 (ew.A14, -4 s /b/ RL. e -- S

July 2005 A -333 - NUREG-1437, Supplement 22
Appendix A

Richard Eminh - I Oppose the Nuke Plant Relicensing at Millstone CT Page 2.|

MPS-58-4 > converted to closed cooling system. This Important issue certainly

> affects

> Long Island because of the dispersion of toxic and radioactive waste

> byproducts by tidal and wave action.

> Tell the NRC to deny license extension to Millstone.

>Emal your comments to rlefnrc.gov or send your comments to:

>Richard L

> Emch, Environmental Project Manager. U.S. Nuclear Regulatory

> Commission.

> Washington DC 20555-0001.

> The deadline is March 2.20051

> powered by ebasettm) v1.03. maito:inloOebase.org.

> http:/?ww.ebase.org

>-.

> North Fork Environmental Council

> P.O. Box 799

> Mattituck. New York 11952

, 631-298-8880

> Fax: 631-298-4649

> E-mail: niec~optonlinenet

> wwwnteci.org

Do You Yahool?

Tired of spamn? Yahoof Mail has the best sparn protection around

httpJ/mail.yahoo.com

CC: NFEC <ntec~optonline.net>

NUREG-1437, Supplement 22 A-334 July 2005
Appendix A

Richard Emch - Millstone .. 4 -. _ ...... .m ,

.'r .. .. I

Page i

'??) Z- - -

From:

To:

Date:

SubJect:.

.cABenners 0 aoLcom>

I ao0 nrc.gov>

2t28/D5 10:45AM

Millstone

MPS-59-1 Deny license extension lo Millstone

.,.,,' 1 , -.- , 6?g ,7/a

.~~ I ( S). 

The operators of the Millstone Nuclear Reactors are seeking to renew their

MPS-59-2 license. If renewed these reactors will boe up and running horanother2O

years. yet there aro no emergency plans In place for eastern Long Island In the

event of an incident or accident at the facility. - * *

The Nuclear Regulatory Commission Is accepting comments on the Draft

Environmental Impact Statement (DEIS) for relicensIng. The DEIS Ignores the safety threats to Long Island residents and the environmental Impacts of the aging

reactors.

Reasons to oppose:

MPS-59-2 t. The M1lstone DEIS Is completely silent on impacts to Long Ilsand.

Shorehamn did not come on line because we couldn't put an evacuation plan In

place.

MPS-59-3 2. Millstone has been operating wfit an expired lean Water Act discharge permit since 1997. The Clean Water Act mandates permit holders to obtain

live-year permits so that every five years they wll have to demonstrate that they have implemented best available technologyto reduce or eliminate pollution i

they want their permits renewed. Millstone has booen able to get away with

operathng with non4updated technology an extra five years. MPS-59-4 3. Millstone Is responsible for the depletion of native fish species

through the operations of Its Intake structures. Anl these assaults on the

ehvironment would end If (a) Millstone were shut down or (b) if Millstone converted to

closed cooling system. This Important Issue certainly aflects Long Island

because of the dispersion of toxic and radioactive waste byproducts by tidal and

wave action.

Deny license extension to Millstone.

Andrew Banners

South Jamesport NY

.. I , . ; ...

5oK' >/4.- - -:.

7d-e @Z3

,e-A b5 , - I. -es

.; - . ...

July 2005 A-335 NUREG-1437, Supplement 22 -
Appendix A

;Richard Emch - Please deny Milistone's License

From: Jenny Bloom <onnybloomOoptonline.net'

To: <rlo~nrcrgov>

Date: 2128105 5:22PM

Subject: Please deny Millstone's License

Richard L Emch. Environmental Prolect Managor. U.S. Nuclear Regulatory

Commission, Washington DC 20555-0001.

Mr. Emch.

MPS-60-1 Please deny Millstone's operating license.

MPS-60-2 As a resident of the North Fork of Long Island It Is unacceptable to me that

Millstone be allowed to operale without a workable evacualion plan In place

for my township.

MPS-60-3 The threat posed my Millstone's operation to Long Island's environment and

MPS-60-4 quarity of life are larger than the benefits to CT's energy costs.

Sincerely.

Jenny Bloom

11600 Main Rd

East Marion. NY 11939

(631) 477-3617

Page 1 4

4aZ3 2VC_/

5ez:;/ /6 el.A, 4

7;Ta Z i, -013

NUREG-1437, Supplement 22 A-336 July 2005
Appendix A

Richard Emch - Millstone

- ;, .

Paan 1 .1

-

.3/0/,45=7

From: cSweelSen aolcomr>

To: crte~nrc.gov>

Date: 2/28105 5.08PM

Subject: Millstone - -

Dear Richard L Ech.

MPS_61-1 Does Millstone have an updated Clean Water Act discharge permit? I

understand their's expired In 1997. II this Is true, why has It been allowed to'.

operate without one???

MPS-61-2 And it a closed coding system existed, would that not have a postive irpact

upon the environment? Why Isnt one being Installed?

How can we face the guilt of destiroying our envirment for our luture

generations because we are too cheap to do the right thing?

MPS-61-3 CLOSE MILLSTONE PLEASE.

Thank you.

Judi

9fA' 4 L3 7

I , I *. . .-

r eqA4 -zD /3

July 2005

,,9c S 5 -e 3

A-337 NUREG-1437, Supplement 22 -
Appendix A

Richard Enmch - Milstone Nuclear plant in CT Page 1

h 6 Aler

MPS-62-1

MPS-62-2

MPS-62-3

From: MBS <corango050optonlIne.net>

To: <rle~nrcgov>

Date: 2/28/5 2:28PM

Subject: Millstone Nuclear plant In CT

Greetings.

I am a resident of Connecticut and I am writing to you to strongly urge you to deny the renewal of the ricense for this plant There are significant health concerns associated with this plant that merit Immediate

Investigation. Also, the State of Connecticut has enacted legislation that

mandates a move to Clean. Renewable energy (referred to as Class I

renewable). ThI plant does not meet this criteria. The denial of this

extension would go a long way to Improving the health and environment of Ct as well as exephing the move to Clean Energy. I am sure that you have received many requests similar to this one: please look at the facts and make the right decision. What decision would you make

if you Eyed next door to this plant? Reject this application for the sake

of the residents, specifically the children of CT and of planet Earth.

Respectfully submitted.

Michael Schwartz

Orange. CT

'It Is amazing what you can accomplish If you do not care who gets the

credrit.

-Harry S. Truman.

.6 I

CC: .dnfoOmothballmilstone.orrg>

NUREG-1437, Supplement 22

,e-gUJP5- .19 X _3

Cab Igr- rcEC

A-338 July 2005

I
Appendix A

= s

Richard Emch - Millstone Nuclear Plant

I -, : i

-

Paoe 1 l

lb 13

0//10- 1,7

.

From:.

To:

Date:

Subject:

A- . Mar

crle.nrc.gov>

2/28105 11:27AM

Millstone Nuclear Plant

MPS-63-1 My husband and I rave in Greenport NY and are seriously opposed to the

relicensing of Millstone. It Is and has been what lisname portends, a

milstone around the neck of alt who ive on the eastern end of Long Istand.

.MPS-63-2 There is no way we can be safelyevacuated. should there be a problem, the

communications of warnings between the states seem to be nearly non-existent

MPS-63-3 and this plant Is functioning with an expired clean Water discharge permit

MPS-63-4 for over 4 years time. Long Island Sound Is dying and the NRC and EPA seem

to care very little for the welifare of the people who consume the fish and

shellfish that have managed to survive this long. Our rates of cancer have

drastically increased in recent years and someone needs to address the fact

that Millstone can be a serious contributor to the food chain poison we

*consume and breath. .

Please do riot retceinse this plant until it is able to pass all CURRENT

: permit requirements such as the Clean water discharge permit and the health

issues and evacuation route of Eastem Long Island are satisfiably

addressed.

We rive and work here.oour lives are no less Important than those of the

citizens of ConnectictA who receive their power from this plant. Make it

safe or close It down. -

. /,qL/q 1041

.1 dv,,r--4

(F).

Amy Martin

5th St - ;

Greenponr,

New York

6 7 / .. p..., - : , b .. .- -: .

.~~ - -,-- . . - . .- .. -.9 4 ~ ! . . , .\ . .- ) 

;, ..3 .9 .U E - 1 4 3 7 ., ... p p le m e -n t 2 2- .

July 2005
Appendix A

Robert Fromer sent his comments to NRC's Office of Public Affairs by email message on February 28,2005. His comments are located

in comment document #24 (MPS-49) starting on page A-280. He also sent those same comments to NRCs Rules Review and

Directives Branch (the address given in the draft SEIS). by letter dated 2/2812005. Mr. Fromer's letter was received on Mardh 10. 2005.

His letter was designated as comment document #39 before it was realized that the letter was a duplicate of his email message (#24).

Only the first page of his letter is reproduced here. All of his comments are reproduced. starting on pA -2

l, idXox

P.O. Box 71

VIndsor, CT 06095

February28,2003 //7

Rule Review and Directives Branch

US. Nuclear Regulatory Commission (ii Mailstop T-6D59

Washington, DC 20555-0001

Re: Draft Report For Comment on Generic Environmental Impact Statement for

Lcense Renewal of Nuclear Plants, Regarding Millstone rower Station, Units

2 and 3, NUREG-1437, Volumes 1 and 2. Supplement 22

Dear Chief Rule Review and Directives Branch

*ttlhe problem at hand, which is that centrally generated electricity is a vulnerable

genie. In order to be used It must travel on an ugly, complex and Inefficient labyrinth of wires

and substations Even from a security view (national or otherwise) such a fragile system is

sulcide. Gordes, Hartford Courant, Letter to the Editor, February 1978.

Dominion has not provided a comparative analysis and assessment of life cycle energy

consumption to determine that re-licensing of Millstone is the preferred option. Nor, has

Dominion considered cumulative alternatives (Ie, energy sources) to meet the current and

future energy demands

A. INTRODUCTION

The United States Nuclear Regulatory Commission (-NRC-) considered the

environmental Impacts of renewing nuclear power plant operating licenses (01s') for a 20-

year period in its Generic Environmental Impact Statement for License Rnewm l of Nuclear Plants

(GElS), NUREG-1437, Volumes 1 and 2, and codified the results In 10 Code of Federal

Regulations (CFR) Part 51. In the GEIS (and its Addendum 1), the staff Identifies 92

environmental issues and reaches generic condusions related to environmental impacts for 69

of these issues that apply to all plants or to plants with specific design or site characteristics.

Additional plant-specific review Is required for the renmaining 23 Issues. These plant-specific

reviews are to be included In a supplement to the GEIS." [GEIS, p. HiQ

This draft supplemental environmental impact statement (SEiS") has been prepared

in response to an application submitted to the NRC by the Dominion Nuclear Connecticut

(Dominion) to renew the Ofs for Millstone Power Station, Units 2 and 3 (Millstone) for an

additional 20 years under 10 CFR Part 54. This draft SEIS includes the NRC staff's analysis that

considers and weighs the environmental Impacts of the proposed action, the environmental

impacts of alternatives to the proposed action, and mitigation measures available for reducing

or avoiding adverse impacts. It also includes the staff's preliminary recommendation regarding

the proposed action.' Id.

B. BACKGROUND

upe et 2 A-340 July 200

NUREG-1437, Supplement 22 A-340 July 2005

I
Appendix A

Riichaid Ermch" Millstone License

. . . . .:

Page 1

- - -- 3 -

* / 10A;

MPS-64-1

MPS-64-2

MPS-64-3

From: ' :Jpr=261761 Caolcorm>

To: .rle~nrc.gov>

Date: 312/05 9:47AM

Subject: Millstone LUcense

Do NOT reissue license to Milislone reactor in Connecticut. There Is no

evacualion plan for eastern Long Island. and its clean water permit Is expired.

Millstone Is a serious danger.

John Rooney

PO Boi 1622

(425 Maple Lane)

SoutholdNY 11971:

6 7pe. f4 -

.1 77- >

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July 2005

A.4 - C ~ Ct) . -

A-341 NUREG-1 437, Supplement 22
Appendix A

MillstoneEIS -_oppose nuclear revival Page 1 r

From:

To:

Date:

Subject:

amanda meisel camandameiselyahoo.com>

<mifstoneeis nrc.gov>

Fr. Feb 25, 2005 1:19 PM

oppose nuclear revival

To Whom it may concern. MPS-65-1 I am writing to oppose the license renewal for the millstone nuclear reactors In Waterford. I am a MPS-65-2 physiclan and am truly concerned about the health Impact of the radioactive particles on the residents and

MPS-65-3 workers int our area. I would appreciate your consideration of a new hearing to include all stakeholders.

MPS-654 including nearby Long Island Communities, as the effects are far-reaching. The nuclear site also makes

MPS-65-5 us a target for terrorist activity, whIch Is certainly a concern In today's world. It has also come to my

attention that nuclear waste is shipped to Bamswell. South Carolina and has a negative health impact on

the poor community. This information about the destination and Impact of nuclear waste from Waterford

should be included In the NRC's environmental Impact agenda. Please reconsider the decision to extend

the operating licences for the Millstone 2&b reactors. Even a small percentage of cancer Increase Is too

much, if it can be prevented.

Thank you. Amanda M. Levitt, ND

Do you Yahool?

Yahool Mai l Helps protect you from nasty viruses. 495'4 onxgR/-,<

ST$,,'

b 4 -01 --ab 5 - - A~-1 -0

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NUREG-1437, Supplement 22 A-342 July 2005
Appendix A

MillstoneEIS - Millstone Paco I I

From:

To:

Date:

Subject:

*Baran. Marie- cMarie.Iaran~ffb.gov>

.cMiltstoneElS~nrc.gov>

Fri. Feb 25,2005 11:40 AM

Millstone

MPS-66-1 I wish to voice my opposition to the Millstone Nuclear power plant

MPS-66-2 1. The Millstone draft Environmental Impact Statement Is completely

silent on Impacts to Long Island. This gross omission by tho NRC Is

reason to deny re licensing on this basis alone. Meaning If and when

there Is a nuclear event (and there was one on January 14. 2005). they

do not have to notify Long Island who is Just 10 miles south of the

Millstone along the Long istand Sound. Shoroham did not come on lne

because we couldn't put an evacuation plan in place. Millstone Is our

Shoreham!l

MPS-66-3 2. Millstone has been operating with an expired Clean Water Act

discharge permit since 1997. The Clean Water Act mandates permit holders

to obtain five-year permits so that every five years they will have to

demonstrate that they have Implemented best available technology to

reduce or eliminate pollution It they want their permits renewed.

Millstone has been able to get away with operating with non-updated

technology an extra five years.

The Connecticut Coalition Against Millstone believes this Is a flagrant

violation of fedoral law. (In Connecticut. the Department of

Environmental Protection Is delegated by the federal EPA to Implement

the Clean Water Act and hence is the permitting agency. DEP has

routinely Issued 'emergency authorizations' of indefinite duration which

violate the permit conditions and which allow for increased pollution by

toxic chemicals. This Is a scandall Meaning the NRC and Millstone are

above the law and play by their own rules.

MPS-66-4 3. Millstone is responsible for driving the native fisheries stock

to near-extinction through the operations of Its Intake structures. AU

these assaults on the environment would end If (a) Millstone were shut

down or (b) It Millstone converted to closed cooling system. This

Important Issue certainly affects Long Island because of the dispersion

of toxic and radioactive waste byproducts by tidal and wave action.

Marie Baran

X ,-ee 5,

-77S d. /Ci4 

3- b At' <3

.53f/OD/.-

e),

'-r x)e At zc CiZ.z3

July 2005: A-343 NUREG-1 437, Supplement 22'
Appendix A

.MillstoneEIS - Millstone _ Page 2!

2567 7th Avenue

East Meadow NY 11554

CC: <tim.bishoprmaIDhouse.gov>, <jennhifr.gunnOrmaP.house.gov>.

<JonschneiderQmaR.house.gov>. <hilliary.cflntone mafl.house.gov>

NUREG-1437, Supplement 22 A-344 July 2005-
Appendix A

I MillstorleEIS -Minstone Pa22 IJ

I , , -, .: -13 -- .; Ae -,e I . -- -- - .

From: -cCayLea300aobcom>

To: .cMillstoneEISOnrc.gov' . -

Date: Fri. Feb 25,2005 11:27 AM

Subject: Miltstone

MPS-67-1 Sirs: I want to go on record as beig agamst the re licensing of

MPS-67-2 Millstone. They do not have an emergencey evacuation plan for where I Ave on Long

Island. . ArthurTaiman,

Mattituck. N.Y.

6- #/-13/7

-

. .

,

. .

. .

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July 2005 A-345 NUREG-1 437, Supplement 22
Appendix A

Richard Emch - Millstone Power Plant relicensing Page 1

c3/o/c7/OG

From: Kathleen Faraone <kathylaraone~yahoo.com>

To: crleOnrc.govn>

Date: 312t05 10:59AM

Subjcct: Millstone Power Plant reoicensing

Kathleen Cunningham Faraone 7'/3 59 7

44 Cosdrew Lane

East Hampton. New York 11937

t - 631-324-3581

1-631-324.7439

e-kathyfaraone~yahoo.com

Mr. Richard L Emch

Environmental Project Manager U.S. Nuclear Regulatory Commission

Washington. DC 20555-0001

2 March 2005

Dear Mr. Emch.

I understand the operators or the Millstone Nuclear

Reactors across Long Island Sound In Connecticut are

MPS_68-1 seeking to renew their license. If renewed, these

reactors will be up and running for another 20 years,

yet there are no emergency plans In place for eastern

Long Island In the event of an Incident or accident at

the facility. I also understand that the DEIS tor

this relicensing Ignores the safety threats to Long Island. New York residents and the environmental

Impacts of the aging reactors.

I oppose the relicensing of these reactors for the

olowing reasons:

1. The Millstone DEIS Is completely silent on

Impacts to Long Island. A nuclear power plant in

Shoreham. Long Island did not come on line because an

evacuation plan could not be put in place. particularly for Eastern Long Island.

MPS68-2 2. Millstone has been operating with an expired Clean Water Act discharge permit since 1997. The Clean

Water Act mandates permit holders to obtain frie-year permits so that every five years they will have to

demonstrate that they have impfemented best available

technology to reduce or elrminate pollution if they

want their permits renewed. Mllstone has been able

to operate with non-updated technology for an

additional live years with no consequence. MPS-68-3 3. Millstone Is responsible for the depletion of

native fish species through the operations of Rts

Intake structures. All these assaults on the

environment would end U (a) Millstone were shut down

or (b) It Milstone converted to closed cooling

system. This important Issue certainly affects Long Island because of the dispersion of toxic and

radioactive waste byproducts by tidal and wave action.

,Vo Vo /3,-494 r " ~ ~ .? ) 5 ~ <4~~~k 69 ke&Z.r _ 

NUREG-1437, Supplement 22 A-346 July 2005
Appendix A

Richard Emch - Millstone Power Plant relicensing ____Page 2i

MPS-68-4 Ptease do not allow this power plant to reopen without - -

mitigation of the above impacts.

Thank you.

Sincerely.

Kathleen Cunningham Faraone

Celebrate Yahool's 10th Birthdayt

Yahoo! Netrospective: 100 Moments of the Web

http:/ibirlhday.yahoo.con/netrospectiveI S- - ,,

I . . . I , .

,. ~.. I:.

July 2005 . A-347 NUREG-1 437, Supplement 22
; i

. i

i

. I

I

I

Appendix A

: Ricard Emch - I Oppose Millstone Ucenso Extension

r . . 51

Page 1

15.m '

alldld!OSMPS-69-1

MPS-69-2

MPS-69-3

From: Kersten Elenteny <Melenteny~mac corn>

To: .crlelnrc gov>

Date: 3/2/05 11:30AM

Subject, I Oppose Millstone License Extension

Dear Mr. Ernch -

t am writing to Inform you that as a resident of New London County, I am In opposition of the license

extension of Millstone. The plant has a negative envlronrrental Impact on our waterways and wildlife. In

addition to the harnful health hazards posed to humans.

Please deny the Millstone license extension. Feel free to contact me with any questions or for further

discussion

Kersten Etenteny

33 Essex Street 6tN / , "ytic. CT 06355

CC: cpmcquown mac.con>

- YV9 '-)

,,_ _ ,2:z <-o 3

c ZZ-45

NUREG-1 437, Supplement 22 A-348 July 2005
Appendix A

Richard Enich - relicensing of Millstone Page I i - - i . :C' -: ' V; . . I -I - . : , . , - - _- - ' - - A )6 Ad-- 

_4   - , , 1,  , - - op-0/05

From: , . Andy Greene <aJgreeneuaoptonzinn.net.

To:. <rleonrc.gov>

Date: 3S 5 12 42PM -- < r > 7

Subject: relicensing of Millstone -

Dear Mr. Emch:

Kindly accept the following as my comments on the DEIS related to the relicensing of Millstone.

MPS-70-1.I lam appalled that the Millstone DEIS is completely silent on impacts to Long Island. I live less than

25 miles from Millstone, In an area that is downwind from the plant several months a year. There Is no

question my family would be directly Impacted In the event of any accident or a terrorist attack. How is It

possible that you can Ignore Long island when considering Millstone?

MPS-70-2 2. MiUstone has been operating with an expired Clean WaterAct discharge permit since 1997. The Clean

Water Act mandates permit holders to obtain five-year permits so that every five years they will have to

demonstrate that they have Implemented best available technology to reduce or eliminate pollution It they

want their permits renewed. Millstone has been able to get away with operating with non-updated

technology an extra five years. Why Is Millstone allowed to subvert the Intent of the law?

MPS-70-3 9. Milstone is responsible for the depletion of native fish species through the operations of its intake

structures. All these assaults on the environment would end If (a) Millstone were shut down or (b) If

Millstone converted to closed coo6ing system. This Important Issue certainly affects Long Island because

of the dispersion of toxic and radioactive waste byproducts by tidal and wave action.

I hope that these crucial matters will be considered In the final DEIS.

Sincerely yours.

Andrew Greene

1220 Sigsbee Road

Mattituck. NY 11952

.. -4 -,::-

-14-"- -0/:F.

15-A- air--,, &_145) , .' - ,- .

July 2005- A-349 .-t NUREG-1437, Supplement 22
Appendix A

MillstoneEISI- Page 1i opposing the ro licensing of Mitistones Units 2 & 3 -L -

From: Rory MacNish <rm246@comentedu>

To: <MilstoneElS~nrcgov>

Date: Fr. Feb 25.2005 321 PM

Subject: opposing the re Ncensing of Millstones Units 2 & 3

To Whom it may Concern.

MPS-71-1 My famil (which consists of my4 children and my wife) and myself are opposed to the re licensing of Millstones Units 2 & 3.

Thank you.

Rory MacNish

370 Pacific Street

Mattituck NY 11952

rmacnish~optonline.net

,-3

CC: <cjennifer.gunnCmail.house.gov>,. dimbIshopomafLhouse.gov>.

<jon.schn9ider~mail.house.gov>. cacampop0assombly.stateny.us>. <Umrrcofm OaoLcom>

re = 0 3,

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NUREG-1437, Supplement 22 A-350 July 2005
Appendix A

MilstoneIIS - Millstone iener.rn ra

OFFICIAL COMMENTS OF THE TOWN OF SOUTHOLD

P.O. Box 1179

Southold, NY 11971-0959

Tel.: (631)765-1889 .--

Fax: (631)765-1823. . . :

March 2. 2005

Chief. Rules and Directives Branch

Divsion of Administrative Sernices

Office of Administration -

Ma-lstop T-6D 59 -

U.S. Nuclear Regulatory Co.mission

Washington. D.C. .20555-01

RE: objections to DEIS, Millstone PowerrStation Unfts 2 and 3

To Whom It May Concern: *

I am Supervisor of the Town of Southoldd the eastem-most town on the North

Fork of Long Island. located on a narrow peninsula directly opposite the Millstone plant

MPS-72-1 across the Long Iand Sound. On January 11. 20051 appeared and made comments

on the record on behalf of the residents of the Town of Southold at the public hearing on

* the Draft Environmental Impact Statement (DEIS) for the proposed renewal of the

operating licienses for the Millstone Power Station. Units 2 and 3. Those comments

stand; thoe" written comments serve as supplemental objections to the renewal of those

licenses in the absence of the due consideration for the safety of the affected nearby

ars Lon g Island residents. On J r 1

Furthermore, I hereby join In the request of other parties. Including, without

imitation, the Connecticut Coalition Against Millstone, for an extension of time In which

to submit written comments due to the failure of the NRC to make available for review

relevant documents such as the transcript of the January 11n 2005 hearing.

In the first instance. I object that the Town of Southold was given no notice

whatsoever of the -scoping process that was apparently held In this purportedly public

environmental review procedure. It is precisely because we were not Included in this

process, and not af orded the opportunity to identify the significant Issues to be

analyzed in depth, that critical Issue of the safety of Long Island residents has been

completely omitted from the environmental review.

. . . .. _ . .

July 2005 A-351 NUREG-1 437. Sunolement 22 J : , _ _ - r
Appendix A

minstontiQs - Millstone ienter.m ,ags z

; ~ .

U.S NuclearRegulatoryCommission

March 2,2005

MPS-72-2 This safety issue fallssquarelyunder the topical severe accident mitigation. which the DEIS Is mandated to analyze in detail. However. completely omitted from all

review was the topic d an evacuation plan for the residents di Southold Town or

elsewhere on eastern Long Island. The reason for such omission is simple: no such I

plan exists, nor has one ever been studied or even considered. The geography o Long Island creates an extremely dangerous situation for those residents in the case of a

severe accident at Millstone. At the very end of a narrow strip d land, there is only one

direction for these residents to travel in the case of an emergency - West. There is. in

some cases, only one road on which to travel - New York State Route 25 in the event of

a Millstone-induced emergency. Southold residents will be unaccounted for by the NRC.

By the time Southold residents evacuate and reach the mainland of Long Island, we will

be lined up on the Long Island Expressway behind the literally millions of other Long i

Island residents who have the same one and only direction to travel. This is a natural

recipe for a manmade disaster that must be avoided. f

To the extent that the drafters of DEIS seek to avoid creating an evacuatin plan for the Town of Southold and eastern Long Island on the purported grounds that federal

regulations only require such plans to do so within a 10 mile radius. they should and

must consider the extreme circumstances that are present The North Fork of Long

Island is cirectly across the Long Island Sound. Strong prevairing winds blow across the

water directly to our shores. We are the first affected residents to the south of this plant. To say that we are beyond the affected area is just wrong and cannot be the basis for a - A

proper EIS. With that knowledge. I believe it is imperative that the NRC expand the

scope of its evacuation planning to include the residents of the Town of Southold and

other affected areas of eastern Long Island.

MPS-72-3 Clearly, as far as safety od affected residents is concemed, the environmental

review process has not yet begun. Since this isa matter d federal corcem, and which ii

is the subject of federal regulation, it is crucial that the NRC seek and heed the input di

the federal elective otficials in the surrounding areas for their input regarding the

concerns of their constituents. The NRC must, therefore, seek formal input from the r

Senators and Representatives in New York as well as Connecticut

Furthermore, the NRC must appropriate funding and conduct a proper study for

the evacuation of eastern Long Island residents, which should then be included as part . of the DEIS, and subject to public input, at a forum Long Island residents can attend - on

Long Island. The DEIS must not, and cannot move forward until these crucial matters

are property considered and integrated into the document. K

Very truly yours,

Joshua Y. Horton

Supervisor

NUREG-1437, Supplement 22 A-352 July 2005
Appendix A

From: Gwynn Schroeder <gdsnfecOoptonHlne.net>

To: -cMiitstoneEIS~nrc.gov>

Date: Tue. Mar 1,2005 4:58 PM

Subject: Millstone Ucensure Renewal

March 1,2005 ;, , - S < 37

Mr. Richard Emch, Jr.

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

United States Nuclear RegulatoryCommission Washington DC 20555

Dear Mr. Emch:

North Fork Environmental Council (NFEC) Is a grassroots advocacygroup

established in 1972. We are located In Mattituck, New York and represent

over 1500 members in the Townships of Riverhead, Southold and Shelter Island.

MPS-73-1 On behalf of NFEC, I am writing to strongly oppose the relicensure of the

Millstone Nuclear Reactors and to express my grave concerns about their

continued operation. The Millstone reactors are ocated hi Waterford, i, Connecticut and although the facility is located only 11 mites from the

Town of Southold, the Nuclear Regulatory Commission continues to ignore the

safety and environmental concerns held by the residents of the North Fork

when considering the continued operations of these aging reactors.

MPS-73-2 If the NRC is not prepared to deny the request of Dominion to renew theoperating icense for the Millstone reactors, we request, at the very

least, that the NRC hold an additionalpublic hearing on Long Island. The

actions of the NRC in this licensing renewal process will affect residents .- d the North Fork and it Is morally reprehensible to deny our voice In the

process. The Januaryhearing held in Ct was poortynoticed. Although the

hearing may have met the legal requirements for notification, very few

stakeholders on the North Fork were aware of the hearing. or for that

matter, the entre scoping process. We certainly wore not given ample time'A

to luilytadconsiderand prepare thoughtfulcommentson the Generic

Environmental Impact Statement (GEIS) for Ucense Renewal of Nuclear Plants

or the 449 page draft Supplemental Environmental Impact Statement (SEIS)

which examines the renewal of the Millstone licenses specifically.

MPS-73-3 Residents, dvic and environmental groups have Joined many elected

officials from the East End and across Long Island and called for the

extension of the emergency planning zone from the current I 0-miles radius

to a 50 miles mile radius. By doing so, emergency planning for the North

Fork would be required.

Because the North Fork Is essentially a peninsula. surroundedby water on

three sides, we have only one direction to evacuate west Residents In

Orient only have one Road heading west until Greenport. There are only two

roads from Greenport to Matituck. three from Mattituck to Riverhead. In

the event of an emergency, evacuation of the 20.000 year round North Fork

residents, or 30,000 summer residents would be virtually impossible not to

mentions the hundreds of thousands dl Long Island residents to the

west Because evacuation of Long Island Is impossible, the Shoreham

Nuclear Plant wa shut down. Many d us live closer to Millstone than to

Xe-e25), - A bt -z' 3 i;

f~,a¢g, em1cL~ GizL~c- t- )?.b l (,tL

;v

July 2005:, A-353 NUREG-1437,-Supplement 22
Appendix A

MPS-73-3 Shoreham.

MPS-734 It is common knowledge that nuclear power plants and Ihe adjacent spent fuel pools are vulnerable to terrorist attack. In addition to living in

close proximity to Millstone. North Fork residents live very close to other

potential terrorist targets Including the Plum Island Animal Disease Center

(PIADC). If there were an incident at the Millstone Faciity. there are no

emergency plans in place for PIADC. The NRC would be negligent it these

facts were not considered in your deliberations.

Sincerely,

Gwynn Schroeder

Executive Director

I

I

I

Gwynn Schroeder

Executive Director

North Fork Environmental Council

P.O. Box 799

Mattituck. New York 11952

631-298-8880 -

Fax 631-2984649

E-mail: gdsntecOoptonline.net

www.nfecl.org

NUREG-1437, Supplement 22 A-354 July 2005
Appendix A

MilIstoneEIS - Comments, Millstone Power Station. NUREG-1437 [Virus checked] Pace 1

.. . . . . * A

From:: -

To: -, Date:

Sublect:

.Diane-iazirskyv bos.doi.gov>

<MiflstoneEIS~nic.gov>

Mon. Feb28.2005 11:11 AM'

Comments, Millstone Power Station, NUREG-1437 [Virus checked)

Dear Mr. Emch:

Please see the attached file for the Department of the Interior's comments

on the draft Supplemental Environmental Impact Statement (SEIS) Millstone

Power Station. Units 2 and 3, Waterford. Connecticut. Thank you and

please feet free to contact me lt you have any questions.

Sincerely.

Diane Lazinsky

Diane Lazlnsky U.S. Department of the Interior

Of race of the Secretary Office of Environmental Policy and Compriance

408 Atlantic Avenue., Room 142 - -

Boston.MA 02210-3334. .

Phone: 617-223-8565 Fax: 617-223-8569

I . . . .. .

- "~ . j I1 ..- ,

July 200/3

July 2005

NURE1 3 =4 Supp-ement 22

G! .=. eC'-4 (r. r-)

A-355 NUREG-1 437, Supplement 22
Appendix A

United States Department of the Interior

OFFICE OF THE SECRETARY

onice of Environm ent] Policy and Compliancc

40S Attantic Avenue-Room 142

Boston, Massachusens 02210-3334

TAKE PRDtor

ItAIM ERICA

February 28,2005

ER 041921

Richard L. Emch. Jr.

U.S. Nuclear Regulatory Commission

Mail Stop 01 IFI

Washington, DC 20555-0001

RE: COMMENTS

Review ora Draft Supplemental Enslronmental Impact Statement (SEIS),

NUREG-1437, Supplement 22, License Renewnl, Dominion Nuclear Connecticut,

Millstone Power Station, Units 2 and 3, Vaterford, Connecticut

Dcar Mr. Emch:

Thc Department of the Interior (Department) has reviewed the Draft Supplemental

Environmental Impact Statement (SEIS), NUREG-1437, Supplement 22, regarding

Millstone Power Station, Units 2 and 3. Thc Dcpartment has no comment on, or conccrn with

the Draft Supplcmental Environmental Impact StatemcnL

Thank you for your attention to these comments.

Sincerely,

Andrew L. Raddant Isl

Regional Environmental Officer

NUREG-1437, Supplement 22 A-356 July 2005
Appendix A

:,- -r rz .-

. rIIItSy Caub *nt fl iuaj:IIm SII %Ataust~ U~bPUvJUUI tv 1U- LIt-es _ _ _ _ -- ratsI I

- - - , _ . _--'

From: WALLMULLER <JWALLY063CAOLCOM> , - , - /

To: <operliclnrc.gov>

Dt: ,. 1117105 1:08PM

Subject: . Response from 'Contact Us About Operator Llcensing',, -

- Below is the result of your feedback form. It was submitted by ' . -

WALLMULLER (JWALLYo63@AOL.COM) on Monday, January 17, 2005 at 13:07. 10

recipient location: Washington. DC (Hdqtrs.) -

MPS-75-1 comments: I am against Millstone Nuclear Power Plant which Is located In Connecticut renewing Hs

operating licenses. ,, ,'

organization:

addressl: PO BOX 1312

address2:

city. SMITHTOWN

state: NY

zip: 11787

country USA '

phone:

__ _ _

, . I 1

July 2065

./ . .C . .

C7,-e- /' =f f$ t- 3 -: -

A-357 NUREG-1437; Supplement 22
Appendix A

Richard Emch - NO. TO MLLSTONEIII Page II

IfP . /, g _ 

From: <Carjam10@aol.com>

To: <opa~nrc.gov>

Date: 1116/0511:36PM

Subject: NO.TO MtLLSTONEIII

The Millstone spokesman adds that the company is In the beginning of the

license renewal process so North Fork residents still have time to voice their

opinions. MPS-76-1 I am saying NO to this proposed Millstone license renewal. One can hardly

get off Long Island now without there being a catastrophet This renewal would

put too many lives here on Long Island In danger should anything happen al the

Millstone Nuclear ptanL.There Is no leasable escape route possible for so many Long Island Inhabitants.

A NUCLEAR LEAK OR ACCIDENT WOULD BE WORSE THAN A TSUNAMI HITTING LONG

ISLANDIII

NO. NO. NO TO THIS RENEWAU

, ;,-- )5 i -y =4) ., 3f /A' )

NUREG-1437, Supplement 22 A-358 July 2005
Appendix A

!MinstoneElS- Comments of Connecticut DEP on Document NUREG. 437. Supptement22 Page 1

From: *Merrily Gore' cnerrily.gere~po state.ctLus=;

To: .cMillstoneEISlnrc gov>

Date: Tue. Mar 8. 2005 9:45 AM

Subject: Comments of Connecbicut DEP on Document NUREG4i437. Supplement22

Attached please find the comments of the Connecticut Department of Environmental Protection Bureau oa

Air Management on the Draft Generic Impact Statement for the LUcense Renewal of the Millstone Power

Staton Units 2 and 3 (NUREG-1437, Supplement 22). These comments wrll also arrive by U.S. mail.

MerrilyA.Gero

Environmental A

Connecticut Dep Bureau oa Air Ma

79 Elm Street

Hartford. CT 061

TeL (860)424-3

To conserve, Imn

natural resourcr

: I

n~alyst 2

artment of Environmental Protection

nagement

06-5127

416

prove and protect the

es and environment oa the State,

CC: Edward Wids' <edward.wlds~postateocLus> '

i

I

I

i

- -- -----&eeA*&e4 (A)

July 2005: A-359 NUREG-1437, Supplement 22 -
Appendix A

M ?d[stoneElS - Comment on Millstone, reticensina final.doc panae,

VIA ELECTRONIC AND REGULAR MAI

March 2,.2005

Chtief. Rules and Directives flraneh

U.S. Nuclear Regulatory Commnission

Mail Stop T6-D59

WVashington, DC 20555-000I

MillstoncElSQnrcev_

Re:~ Comments of thre Connecticut Department of Environmental Protection -

Bureau of AirMAnoragement -

Draft Generic Impacd Statem ent for LIcense Renewalof oNu clar PlantsRegarding

Afilhisone Power Station, Units 2 and`3

NUREG-1437Z Supplement 22

To the Chief of the Rules and Directive Branch:

The Connecticut Department of Environmental Protection Bureau ofrAir Management (the

Bureau) submits these comments on the U.S. Nuclear Regulatory Commnission's; (NRCs) Draft

Genseric Fn tironmental Impact Statement for Lkense Renewal of Nuclear Plants Regarding

Milbt one PoverStation. Units 2 and3 (Draft E3S). The Draft EIS discusses the environmental

impacts or the proposal to renew the operaiting licenses for Units 2 and 3 of the Millstone Power

MPS-77-1 Station. including the alternatives to license renewal. The Bureau has considered the alternatives

presented Id the Draft EIS and is concerned that any fossil-fueled alternative electricity supply

will hawe negative air quality Impacts as compared to re-licensing the Millstone units.

If the license for the Millstone units is not renewed, additional fossil-fueled generation would

likely be necessary to meet the state demand for electricity. as an alternative consisting only of

demand reduction. energy elricrincy and altemnative energy sources is not feasible in the given

time-firane. Moreover, teConnecticut EnergyAdvisory Board's 2004 energplan specirically

identified the Inadequacy of the State's transmission Infrastructure. Falure to re-icens units 2

and 3 will further exacerbate this problem. The Bureau supports the use ofrclean alternative

energy sources and measures thatt reduce electricity demand, However. the Bureau recognizes

that such measures require Immediate and substantial changes In behavior with regard to energy

use, a substantial Investment in low- and no-emitting resources and large-scale implementation

of energy conservation and load reduction measures by residential and Industrial energy users.

Such changes can only occur over a longer timeframe than that allowed by denial or the license

renewal.

The air quality impact or replacing the electricity generated by the Millstone units with electricity

generation by large-scale fossil-fujeled electric generators is substantiaL As the Draft EIS

identifies, emissions ornitrogen oxides (NOx), sulfur oxides, carbon monoxide, particulate

NUREG-1 437, Supplement 22 A-360 A30Jl20 July 2005

I
Appendix A

i MilistoneEIS - Comment on Millstone relicensino final.doc Pano 21

MPS-77-1 matter and hazardous air pollutants would increase. Increased NOx emissions are a particular

July 2005 i- A-361 NUREG-1 437, Supplement 22
Appendix A

ft.hlistoneEIS-Comment on Millstone relicensing finaI.doc Page 3i

Chief. Rules and Directives Branch

Page 2

MPS-77-1 concern to the Bureau since reductions in emissions of ozone precursors are of immediate

importance to Connecticut's strategy to attain and maintain the national ambient air quality

standards (NAAQS) for ozone. In order to attain the new 8-hour ozone NAAQS statewide by

2010. as required by the U.S. Environmental Protection Agency (EPA), Connecticut is now in the

process of identifying additional reductions that may be obtained from a variety of sources in the

state Furthermore, the same assessment is underway for fine particulate matter, in order to

comply with EPA's designations under the NAAQS for particulate matter less than 2.5 microns

in diameter.

The Bureau appreciates the opportunity to submit these comments and wvill be glad to provide

any additional information that you may require.

Sincerely,

Is/Anne R. Gobin. Chief

Bureau of Air Management

ARGIMAG/mag

NUREG-1437, Supplement 22 A-362 July 2005
.Appendix A

I Richard Emch - Millstone Uconse Renewal - Letter of Opposition and Contact Information Page 1I

;.... It . . .- . ,- : 8 ! .I--/I_

.-- ~ .: - -R 1g -t, /OS

From:

To:

Date:

Subject:

dirrcomm~aol.com>

<bxzOnrc.gov>

1112105 11:54PM

Millstone Lcense Renewal - Letter of Opposition and Contact Inform

Dear Mr. Zakeman.

I would like to take this opportunity to thank you for iistening to our

concems as it related to cutting short the NRCs presentation at the Millstone

Meeting on Tuesday. I also appreciate the fact that myself Mike Domino and

Supervisor Horon were given the opportunity to speak first as we had to catch

a 5:00 Ferry back to Long Island.

The attached email Is from Assemblywoman Pat Acampora of Mattituck. Please

take a moment to review her comments that were forwarded to Mr. Emch.

MPS-78-1 Lastly. I would like to provide you with contact Information of our local

representatives who should be put on your list of people to cbntacr

representing Long Island & NYS. These Individuals should be advised of future

meetings as it relates to the Millstone Power Plant license renewal or other matters

relating to this plant. Please ensure your community affairs people have

this information for future reference. Additionally, would like to recommend

conducting this ficensing meeting on Long Island for *pubtic feedback. If

you would like to plan a meeting on Long Island. I recommend you contact one

of the Individuals listed below to determine a mutually agreeable location.

The following information applies:

Southold Town Supervisor

Joshua Horton

631 765 1889

_Joshua.Horton~town-southold.ny.us_

(maBlo:Joshua.Horton~town.southold.ny.us)

JoshhortonO3Oyahoo zom_ (maiito:JoshhortonO3Cyahoo.com)

Assemblywoman

Patricia Acampora

631 727 1363 (Long Island Y)

5184555294 (Albany#)

-acameoooassemblvstate.nv.us (mailto acamooooassemblvstate nv.us)

nation. , .

Sq/p@'

softX37

.

. .

....

. ,

... .. . . .

. . . X .

. .. . ..

. .

. . .

. .

. .

. . . ..

Congressman

TIm Bishop 3680 Route 112 Sulte C

Coram. NY 11727

631 696 6500 (Coram) ask for Jennifer Gunn

631 259 8450 (Southampton Ofrice)

_Tim.BishopCmall.house gov_ (malto:rim.BlshopOmaD.house.gov)

_Jennlfer.Gunncman.house.gorv- (maillo:Jennlfer.GunnOmal.house.gov)

County Legislator

Michael Caracciolo

423 Grifng Avenue

Riverhead. NY11901 -

,--' 6q-22 0 e -f&/

1=.-4 r- = ,.6P-b,-0 -O *

July 2005 A-363- NUREG-1437, Supplement 22
Appendix A

Richard Emch - Millstone License Renewal - Letter of Opposition andl Contact Inlormation Page 2

631 852 3200

_Michael.Caracciotobco.sutfotk.ny.us_

(mailto:MkchaeLCaracclolo~co.sulrotk ny.us)

Senator

Ken LaValle

631 696 6900

_LAVALLEOsenate.slale.ny.us_ (maifto:LAVALLEOsenate.stateny.us)

Governor

George Pataki

212 681 4580

631 952 6583

I would also like to add:

North Fork Environmental Council

Gwynn Schroeder

Executive Director

631298 8880

5gdsnfecOoptonfine.neL (mailtogdsnfec optonlinenet)

Marie Domen'ci

631 2987103

_LircommOaol.com_ (mailto:Lirrcomm @aoLcom)

Thank you for taking the time to review this information and please feet

free to contact me should you have any questions regarding this Inlormation.

Sincerely,

Marie Domenic'

CC: <gdsn1ecOopionIano.net>. rleOnrc.gov>, iJdSoutholdOaol.com>

NUREG-1437, Supplement 22 A-364 July 2005
Appendix A

.'

STATE OF CONNECTICUT

DEPAMRTNT OF PUBIC LJ77M' CONTROL

.qA ~

VOKALW W. VOWNES - MA R I ,: ..

Nils J. Diaz

Chairman . , -

* U.S. Nuclear Reg

Washington, DC:

6uatory Commission

20555-0001

I

i

I

I

I

RE: Millstone ,owpr Qlion Application. or.RenewedpOpeattngU ce nse

Dear Chairman Diaz:

MPS-79.1 The Connecticut Department of Public Utility Control (Department) submits this letter in

support of the Application for Renewed Operating U.cense for Millstone Power Station,

located In Waterford,- Connecticut. Millstone Power Station consists of Unit 2 and Unit

3. Unit 2 Is solely owned and operated by Dominlon Nuclear Connecticut., Inc.

(Dorminion) and Unit 3 is 4olntly.owned by-Domin ortqetrdeIVyermont Public Service

Corporatlin and Massauciiuetts MunicipblV C . is

.the .operator~o~f. Unit 3'anid buthoriiedio act as ag $ortheJont d nbrs~bDominloniss

seeking renewal of the operatlng licenie for a Period bf 20 years beyond'ilie eipiration

date 61 the current ojperating license for both units (Unit 2 current depiration date Is July

31.2015; Unit 3 current explrallioidate Is November25. 2025). This letter is in support

of both applications forthe units, colfectwvety referred to herein as Millstone.

The Department belleves.that Dominion is boe bf.ihe best nucler plant operators In the

countryand that It his demon'strated an cxcelleht history of nuclear plant operation and

safety. The Department would like to offer two additional reasons for granting

Millstone's request.

MPS-79-2 First, from a regional and Connecticut energy needs point of view, Millstone has been

an essential resource for the existing bulk power system: This essential resource need

Is expected to continue as such Into the future. . It Is for this reason that Millstone's

license etednsloh is Impoitant to continue 6' serve New England and Connecticut

energy needs. -.The Independent System Operator for the New England bulk power

supply system (ISO-NE) publishes an annual regional system plan meant to Identify

system,needs lhatlcan impact regional.useriiand Identify system solutions that will

benetithe entfi ireiregion._. Its mcost.rhceht annual reporl;:dated Jhnuary,4,20D5, stales

Pi~ n~ d - .. r~.i'* ...

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An Equal opp~onuuoly Eaployer (:  C., = '- -/_ -" e-; -. r- e C 4 - cez-1 _-)

July 2005 A-365 NUREG-1437, Supplement 22
Appendix A

The ISO-NE annual report states that New England could face a capacity shortage If

there Is high demand for electricity beginning In 2006 and continuing Into the future. Id,

page 6. Possible means of resolving this looming problem includes. inter alla, additional

-* generation. Accordingly, the Department is greatly concerned that existing, reliable,

sare. high capacity factor units.such as Millstone be allowed to continue and extend

operation. This Is especially true given the high demand for fossil fuels upon which

MPS-79-3 most new generation Is based. Keeping Millstone operational greatly adds to the

diversity of fuel supply In Connecticut and the region.

Second, on August 28.2001 Connecticut and the New England region committed to a

Climate Charige Action Plan. The goal of.this plan Is to mitigate the release or

greenhouse gases that are emitted by-the-combustion.bfossil fuels..Asislwellknown, the greenhouse gaseriisions fromn nuclear power plants are negligible. Continued

operation or Millstone past Its present license expiration dates will displace fossil

generation, helping the region to meet Its greenhouse gas reduction targets. Extension

of the licenses forthe Millstone units Is very important to meeting this goal.

The Department urges the Commission to consider the above factors in reviewing the

request for the Millstone license extension.

Sincerely,

Donal W.es

Chairman

Public Utilities Control Commission

NUREG-1437, Supplement 22 A-366 July 2005
Appendix A

i MinstoneElS -testimony Pace I -

' I . . I .

From: .cSLKaleeCaol.com>

io: emilisioneElwnrc.gov> ... - -

Date: Fri. Mar11.2005 8:15AM -

Subject: testimony

MPS-80-1 Do you believe that true costs are considered when assessments, such as the

one you are about to read of, are done? Pollution from mining. -

transportation, processing, waste products and their disposal as well as the health and

MPS-80-2 environmental costs. etc. make up those unaccounted for costs. If we reallywant to cut C02 emissions we need to look at the big picture, wind, solar.

geothermal. bie-diesel, methane from dumps used as a fuel source. forest

conservation, green building. etc. - -

11 we take a nuclear power plant otl line, clearly any wind generated power

will not make a dent In the C02 until there Is more electricity produced from

the wind source than by the nuclear power plant .. and don't forget those

hidden costs. How much C02 Is produced in the processing, and other the other

steps mentioned before? Have you ever heard of someone getting cancer from a

wind generator or Its by-products? How about the danger oe a terrorist

attack on a wind generator (shades of Don Quixote)? Is there a Price

Anderson Bil to cover the Insurance for wind generators and do we find an exclusion

h our home insurance polices for damage caused by an accident or an attack

upon a wind generator? And one last qustion. Is there a good evacuationplan In case of a major problem with a wind generator?

Larry Kaley

From:

httpifvw.wirod.comrrdAvrctaiivo/13.O2~uzcloar.htmi

IC91 IF119-L

craft 2'1,V

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Nuclear NowlI

How clean. green atomic energy can stop global warmig

By Peter Schwartz and Spencer ReissPage

. .- I , - '. r4 ,, - .. :-- - . . .

Peter Schwartz (peterschwartz@ gbn~com) is chair of Global Business

Network, a scenario-planning fiNm. Contributing editor Spencer Reiss

(sponcerO upporroad net) wrote about pebble-bed nuclear reactors In issue

13.01. Additional research by Chris Coidewey.

On a cool spring moming a quarter century ago, a place In Pennsylvania

caled Three Mile Island exploded Into the headlines and stopped the US

nuclear power Industry In Its tracks. What had been billed as the clean, _

cheap, limitless energy source for a shining future was suddenly too hot to

handle. : - - -. .

In the years since, we've searched for altematives, pouring billions of -

dollars hito windmills, solar panels, and bloluels. Weve designed

fantastically efficient lightbulbs. air conditioners. and refrigerators. -

We'Ve built enough gas-fired generators to bankrupt Califomha. But mainly. -

each year wo hack 400 million more tons of coal out of Earth's crust than we

did a quarter century belore, light It on tire. and shoot the proceeds Into -

the atmosphere.

I .

. . 0. . .

. 1 . . . ' -

The consequences aren't pretty. Burning coal and other fossil fuels is * I t -' '

driving climate change, which Is blamed for everything from western lorest - -- -

'T.r.5/

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July 2005' A-367 NUREG-1437, Supplement 22
Appendix A

MillsloneEIS - testimony Page 2

rtos and Florida hurricanes to melting polar Ice sheets and flooded

Himalayan hamlets. On top of that, coal-buming electric power plants have

fouled the air with enough heavy metals and other noxious pollutants to

cause 15,000 premature deaths annually in the US alone. according to a

Harvard School of Public Health study. Believe It or not, a coal-fired plant releases 100 times more radioactive material than an equivalent nuclear

reactor - right Into the air, too, not Into some carefuily guarded storage site. (And, by the way, more than 5,200 Chinese coal miners perished In

accidents last year.)

Burning hydrocarbons Is a luxury that a planet with 6 billion energy-hungry souls can't afford. There's only one sane, practical allemative: nuclear

power.

We now know that the risks of splitting atoms pale beside the dreadful toll

exacted by fossil fuels. Radiation containment, waste disposal, and nuclear

weapons proliferation are manageable problems In a way that global warming Is not. Unlike the usual green ahemativos - water, wind, solar, and

biomass - nuclear energy Is here, now, In Industrial quantities. Sure, nuke

plants are expensive to build - upward of S2 billion apiece - but they start

to look cheap when you factor In the true cost to people and the planet of

burning fossil fuels. And nuclear Is otr best hope for cleanly and

elficlently generating hydrogen, which would end our other ugly hydrocarbon addiction - dependence on gasoline and diesel for transport.

Some of the world's most thoughtful greens have discovered the logic of

nuclear power. including Gala theorist James Lovelock. Greenpeace cofounder

Patrick Moore. and Britain's Bishop Hugh Montefiore, a longtime board member

of Friends of the Earth (see 'Green vs. Green. page 82). Western Europe is

quietly backing away from planned nuclear phaseouts. Finland has ordered a

big reactor specifically to meet the terms of the Kyoto Protocol on climate

change. China's new nuke plants - 26 by 2025 -are part of a desperate effort at smog controL.

Even the shel-shocked US nuclear industry Is coming out of Its stupor. The

2001 report of Vice President Cheney's energy task force was only the most

high profile in a series of pro-nuke developments. Nuke boosters are

especially buoyed by more efficient plant designs. streamlined licensing procedures, and the prospect of federal subsidies.

In fact, new plants are on the way, however tentatively. Three groups of

generating companies have entered a bureaucratic maze expected to lead to

formal applications for plants by 2008.11 everything breaks right, the

first new reactors In decades will be online by 2014. 11 this seems

ambitious, It's not: the industry hopes merely to hold on to nuclears

current 20 percent of the rapidly growing US electric power market.

Thars not nearly enough. We should be shooting to match France. which gets 77 percent of its electricity from nukes. Irs past time for a decisive leap out of the hydrocarbon era, time to send King Coal and, soon after. Big Oil

shambling off to their well-deserved final resting places - maybe on a

nostalgic old steam locomotive.

Besides. wouldn't it be a blast to barrel down the freeway In a hydrogen Hummer with a clean conscience as your copilot? Or not to feel like a planet

NUREG-1437, Supplement 22 A-368 July 2005
Appendix A

I MiltstoneElS - testrmony Page 3

killer every time you frick on the A/C? Thars how the future could be, 11

only we would get over our fear of the nuclear bogeyman and forge ahead -

for real this time - Into the atomic age.

The granola crowd likes to talk about conservation and efficlency, and

surety substantial gains can be made In those areas. But energy Is not a -

luxury people can do without, like a gym membership or hair gel. The

developed world built Its wealth on cheap power - burning firewood, coal,

petroleum, and natural gas, with carbon emissions the Inevitable byproduct.'

Indeed, material progress can be tracked In what gets pumped out of

smokestacks. An hour of coal-generated 100-watt electric light creates 0.05

pounds of atmospheric carbon, a bucket of Ice makes 0.3 pounds, an houres

car ride S. The average American sends nearly half a ton of carbon spewing -

Into the atmosphere every month. Europe and Japan are a little more - --

economical, but even the most remote forest-burning peasants happily do

their part. - , :

And the worst - by far - Is yet to come. An Mrr study forecasts that

worldwide energy demand could triple by2050. China could build a Three

Gorges Dam every year forever and still not meet its growing demand for

electricity. Even the carbon reductons required by the Kyolo Protocolwhich pointedly exempts developing countries like China - will be a drop tri

the atmospheric sewer. - -.

What is a rapidly carbonizing world to do? The high-minded answer, of.

course, Is renewables. But the notion that wind, water, solar, or biomass

will save the day Is at least as fanciful as the once-popular Idea that

nuclear energy would be too cheap to meter. Jesse Ausubel, director of the

human environment program at New York's Rockefeller University. calls,

renewable energy sources false gods - attractive but powerless. They're

capital- and land-Intensive, and solar Is not yet remotely cost-competitive. -

Despite alt the hype, tax breaks, and Incentives, the proportion of US - .

electricity production from renewables has actually fallen hi the past 5S

years, from 11.0 percent to 9.1 percent. . -

The decline would be even worse without hydropower, which accounts for 92

percent of Ihe worlds renewable electricity. While dams In the US are under

attack from environmentalists trying to protect wild fish populations, the - . -

Chinese are building them on an ever grander scale. But even China's -

autocrats cant get past Nimby. Stung bycritcism of the monumental Three

Gorges project - which required the forcible relocation of t million

people - of rcials have suspended an even bigger project on the Nu Jiang

River In the country's remote southwest. Or maybe someone In Beijing

questioned the wisdom of reacting to climate change with a -

muftibillion-dobar bet on rainfall. - * - --

Solar power doesn't look much better. Its number-one problem Is cost: While

the price of photovoltaic cells has been slowly dropping. solar-generated

electricity Is still tour times more expensive than nuclear (and more than

five times the cost of coal). Maybe someday we'll all live In houses with

photovoltaic roof tiles, but hi the real world, a run-of-the-mill

1,000-megawatt photovoltalc plant will require about 60 square miles of

panes alone. In other words, the largest Industrial structure ever built.

July 2005 - A-369 NUREG-1437, S T , :u, pple ment  . 22
Appendix A

I MillstoneEIS - testimony Page 41

Wind is more promising. which Is one reason Itrs the lone renewable

attracting serious Interest from big-timo equipment manufacturers like

General Electric. But even though price and performance are expected to

improve. wind, like solar, is inherenUy ficke, hard to capture, and widely dispersed And wind turbines take up a lot of space; Ausubel points out that

the wind equivalent of a typical utility plant would require 300 square mrlesof turbines plus costly transmission tlines from the wind-scoured

fields of. say. North Dakota. Alternatively, there's California's Altamont

Pass. where 5.400 windmills slice and dice some 1,300 birds of prey

annually.

What about biomass? Ethanol Is clean, but growing the amount of cellulose

required to shift US electricity production to biomass would require farming - no wilting organics. please - an area the size of I 0 lowas.

Among fossil fuels. natural gas holds some allure; it emits a third as much

carbon as coal. Thars an Improvement but not enough it you're serious about

rolling back carbon levels. Washington's favorite solution is so-called

clean coal. ballyhooed In stump speeches by both President Bush (who offered a $2 billion research program) and challenger John Kerry (who upped the ante

to $10 billion). But most of the work so far has been aimed at reducing acid

rain by cutting sulphur dioxide and nitrogen oxide emissions. and more

recently gasifying coal to make it bum cleaner. Actual zero-emissions coal

Is still a lab experiment that even fans say could double or triple generating costs. It would also leave the question of what to do with 1

million tons of extracted carbon each year.

By contrast. nuclear power Is thriving around the world despite decades of

obituaries. Belgkim derives 58 percent of Its electricity from nukes, Sweden

45 percent. South Korea 40, Switzerland 37 percent. Japan 31 percent. Spain

27 percent. and the UK 23 percent. Turkey plans to build three plants over

the next several years. South Korea has eight more reactors coming, Japan

13, China at least 20. France, where nukes generate more than three-quarters of the countrys electricity. Is privatzig a third of its state-owned

nuclear energy group. Areva, to deal with the rush of new business.

The last US nuke plant to be built was ordered In 1973, yet nuclear power is

growing here as well. With clever engineering and smart management, nukes

have steadily increased their share of generating capacity In the US.The

103 reactors operating In the US pump out electricity at more than 90

percent of capacity up from 60 percent when Three Mile Island made

headlines. That increase Is the equivalent of adding 40 new reactors.

without bothering anyone's backyard or spewing any more carbon Into the air.

So alornic power Is less expensive than it used to be - but could it possibly be cost-effective? Even before Three Mile Island sank, the US nuclear

Industry was foundering on the shoals of economics. Regulatory delays and

billion-dollar construction-cost overruns turned the business Into a

financial nightmare. But Increasing experience end efficiency gains have

changed all that. Current operating costs are the lowest ever - 1.82 cents

per kilowatt-hour versus 2.13 cents for coal-fired plants and 3.69 cents for

natural gas. The ultimate vindication of nuclear economics is playing out in

the stock market- Over the past five years. the stocks of leading nuclear

generating companies such as Exelon and Entergy have more than doubled.

Indeed. Exelon Is feeling so flush that It bought New Jersey's Public

NUREG-1437, Supplement 22 A-370 July 2005
Appendix A

I MillstoneEIS -testimony __-

Service Enterprise Group In December, adding four reactors to Its former

roster of 17. , - - -

v

Pace 51 . s

:

, 

.

This remarkable success suggests that nuclear energy realistically could

replace coal in the US without a cost Increase and ultimately lead the way

lo a clean, green future. The trick is to stan building nuke plants and - -

keep building them at a furious pace. Anything less leaves carbon In thoe

climatic driver's seat.

A decade ago, anyone thinking about constructing nuclear plants in the US

would have been dismissed as out of touch with reality. But today, for the -

first time since the building of Three Mile Island. now nukes in the US

seem

possble. Thanks to Improvements in reactor design and Increasing - '

encouragement from Washington. DC, the nuclear Industry ts posed for

unlikely revival. AII the planets seem lo be coming Into alignment, says

David Brown. VP for congressional altairs at Exelon.-

The original US nuclear plants, built during the 1950s and '60s, were

descended frorn propulsIon units in t950s-vintage nuclear submarines, now

known as generation I. During the '80s and SOs, when new construction *

hailted In the US, the major reactor makers - GE Power Systems, British-owned

Westinghouse. France's Framatome (part of Areva), and Canada's AECL- went

after customers in Europe. This new round of business led to system

Improvements that could eventually, after some prototyping. be deployed back

in the US.

By all accounts, the latest reactors, generation iII+, are a big

Improvement. Theyre fuel-eficient. They employ passive safety -

technologies, such as gravity-fed emergency cooling rather than pumps.

Thanks to standardized construction, they may even be cost-competitivo to

butld - S1,20 per kilowatt-hour of generating capacity versus more than

$1,300 for the latest low-emission (which Is not to say low-carbon) coal

plants. But there's no way to know for sure until someone actually builds

one. And even then, the first few will almost certainly cost more.' . . 7 . ,

Prodded by the Cheney report, the US Department of Energy agreed In 2002 to

pick up the tab of the first hurdle - getling from engineering design to

working blueprints. Three groups of utility companIes and reactor makers

have stepped up lor tho program, optimistically dubbed Nuclear Power 2010.

The govemment's bill to taxpayers for this stage of development could top

S500 million, but at least wel get working reactors ralher than 'promising

technologies.,

But newer, better designs don't free the Industry Irom the Intense public :

oversight that has been nuclear power's special burden Irom the starL - -- . .

Betieve It or not. Three Mile Island wasn't the ultimate nightmare; that --

would be Shoroham. the Long Island power plant shuttered In 1994 atter a

nine-year legal battle, without ever having sold a single electron. -

Constuction was alreadycomplete when opponents challenged the plant's

application for an operating license. Wall Street won't Invest billions In - :

new plants (S5.5 billion In Shoreham's case) without a clear path through e

the maze of judges and regulators. I - - t -

Shorehamn ridn't die completely in vain. The 1992 Energy PolicyAct aims to '

forestall such debacles byauthorzhng the Nuclear Regulatory Commission to

. I I I - iI

I - I -

July 2005' A-371 NUREG-1437, Supplement 22
Appendix A

I MillstoneEIS - testimony Page 61

Issue combined construction and operating lkenses. It also allows the NRC

to pro-certify specific reactor models and the energy companies to bank

preapproved sites. Utility executives fret that no one has ever road-tested

the new process. which still requirei public hearings and shelves of

supporting documents. An kIo reactor site at Browns Ferry. Alabama. could

be an early test case: the Tennessee Valley Authority Is exploring options

to refurbish it rather than start from scratch.

Meanwhile. Congress looks ready to provide a boost to the nuclear energy

Industry. Pete Domenicl (R-New Mexico). chair of the Senate's energy

committee and the patron saint of nuclear power in Washington. has vowed to

revive last years energy bil which died In the Senate. Earlier versions

Included a 1.85 cent per-kilowatt-hour production tax credit for the first

half-dozen nuke plants to come onrine. That could add up to as much as SB

billion In federal outlays and should go a long way toward luring Wall

Street back Into the fray. As pork goes the provision Is easy to defend.

Nuclear power's extraordinary startup costs and safety risks make It a

special case for government intervention. And the amount Is precisely the same bounty Washington spends annually in tax credits for wind. biomass, and

other zero-emission kilowattage.

Safer plants. more sensible regulation, and even a helping hand from

Congress - al are on the way. Whats stll missNg Is a place to put

radioactive waste. By law, US companies that generate nuclear power pay the

Feds a tenth of a cent per kilowatt-hour to dispose of their spent fuel. The

fund - currently $24 billon and counting - is supposed to rnance a permanent waste repository the ill-fated Yucca Mountain In Nevada. Two

decades ago when the payments started, opening day was scheduled for January

31.1998 But the Nevada facility remains embroiled In hearings, debates

and studies. and waste Is piling up at 30-odd sites around the country.

Nobody will build a nuke plant unti Washington offers a better answer than

'keep piling

At Yucca Mountain, perfection has been the enemy of adequacy. It's fun to

discuss what the design life of an underground nuclear waste facility ought

to be. One hundred years? Two hundred years? How about 100.000? A quarter of

a million? Science fiction meets the US govemrnment budgeting process. In

courtl

But throwing waste into a black hole at Yucca Mountain Isnt such a great

Idea anyway. For one thing. In coming decades we might devise better

disposal methods, such as corrosin-proof containers that can withstand

millennia of heat and moisture. For another. used nuclear fuel can be

recycled as a source for the production of more energy. Either way, It's

clear that the whole waste disposal problem has been misconstrued. We don't

need a million-year solution. A hundred years will do just fine - long

enough to lot the stuff coot down and allow us to decide what to do with It.

The name for this approach Is Interim storage: Find a few patches of

Isolated real estate - we're not talking about taking It over tar eternityand pour nice big concrete pads, add floodlights, motion detectors, and

razor wire: truck in nuclear waste In bombproof 20-foot-high concrete casks.

Voilb: safe storage while you wait for either Yucca Mountain or plan B.

Two dozen reactor sites around the country already have their own interim

facilities; a private company has applied with the NRC to open one on the

NUREG-1437, Supplement 22 A-372 July 2005
Appendix A

I MitisloneElS - testimony Page 7

Goshute Indian reservation In Skull Valley, Utah. Establishing a halldozon

federally managed sites Is closer to the right Idea. Domenicl says he'll

Introduce legIslation this year for a national Interim storage system.

A handful of new US plants wilt be a fine start. but the real goal has to be

dethroning King Coal and - until something better comes along - pushing

nuclear power out front as the worlds default energy source. Kicking carbon -

cold turkey won't be easy, but h can bo done. Four crucial steps can help:-

Increase the momentumn Regulate carbon emissions, revamp the fuel cycle.

rekindle Innovation In nuclear technology, and, finally, replace gasoine

with hydrogen.

. Regulate carbon emissions. Nuclear plants have to account for every

radioactive atom of waste. Meanwhile, coal-fired plants dump tons of deadly

refuse into the atmosphere at zero cost. Its time for that tree ride to

end, but only the government can make It happen.

The industry seems ready to pay up. Andy White. CEO of GE Energy's nuclear

division, recently asked a roomful of US utility executives what they -- -- . -: - - I

thought about the possibility of regulating carbon emissions. The idea

didn't faze them. 'The only question any of them had, he says, 'was when

andhow much. - -

- .  I -  . . , . , 4

I..I.,

-.- . , . __ 4 . 7 .- i . - - . . I I. - : - - . , - ,

. , - i I -

J4

July 2005- A-373 NUREG-1437, Supplement 22
Appendix A

MinsloneElS - Millstono license Page 1

'From: Connecticut chapter~slerraclub.org,.

*-To: miltstoneeIs~nrcrgov>.

Date: Fri. Mar18. 2005 955 AM

Subject:' Millstone license

Dear NRC

MPS-81-1 The Connecticut. United States. and worldwide community demands are clearifts time to phase out

nuclear power. It's an experiment that didn't work for a number of reasons.

MPS-8 1-2 It an accident happened we could not evacuate the population (we cant even got home during rush

hour).

MPS-81-2 We have no way to deal with the contamination should an accident occur.

MPS-81-3 It appears we have not dealt with the environmental justice Issue of shipping nuclear waste to poor communities.

MPS-81 4 Milstone has had radiation releases Into the local environment many times.

MPS-81-5 And now we have to spend money on terrorist precautions. (It nuclear powerwas so safe. why do we

have to worry about terrorists attacks? rIe never heard of a terrorist attack on a solar panel)

Gemnany (the old Europe) as already started to phase out all nuclear power. We have the technology and money to do the same in the US. Yes. this does mean in the next two decades you will have to look

MPS-81-5 for anotherjob. Can I interest you In something related to hydrogen fuel cells? (hydrogen produce from

clean sources not nuclear)

MPS-81 -6 The recent successes of hybrid cars and solar Incentive programs are pointing to the same thing.-do not

renew the Millstone license . Nuclear power Itself Is over and Millstone's record are arguments enough to

move on from nuclear. Besidos. we have enough cancer In the US. without having to worry about another

source like nuclear power.

John D. Calandrelil

State Coordinator

for 12.500 members of the CT Sierra Club

CC: <secyOnrcgova'

e hr>. -D

NUREG-1437, Supplement 22 A-374 July 2005
Appendix A:

CONNECTJCIJT COALITION AGAINST MILLSTONEI

www.mothballmillstone or'

March 16, 2005

Chief

Rules and Directives Branch

Division of Administrative Services'

Office of Administration

Mailstop T-6D59 '

U.S. Nuclear Regulatory Commission

Washington DC 20555-0001

Re: Millstone Nuclear Power Station/Draft Environmental Impact

Statement/Supplemental Comments -

Dear Sirs: ' '

The NRC Is committed to protecting the public health and safety.

- Statement of NRC's Organizational Values'

The Connecticut Coalition Against Millstone submits herewith its

supplemental comments concerning the draft Efivir6nmental Impact

Statement (SEIS) which the NRC staff has prepared 'in support of

relicensing of Millstone nuclear reactors Units2 arid 3 to extend their terms

to the years 2035 and 2045 respectively. These comments were preceded

by preliminary comments submitted on March 2, 2005.,

Unfortunately, our review of the SEIS and our interaction with NRC's

SEIS staff concerning its evaluation of the operational history of the

Millstone Nuclear Power Station lead us to conclude that in this instance

the NRC has entirely departed from its self-defined organizational'

values (see above).

Indeed, we are driven to conclude that, in,this instance, the NRC,,

staff is not even remotely concerned about the effects of Millstone -

releases of radiation to the public health and safety and to the

environment.

*.- . . .: a-,~ . ~ .':.

July 2005,. A-375- NUREG-1437, Supplement 22:.
Appendix A

Nor has the NRC staff adhered to the 'Principles of Good Regulation' heralded on the NRC's website.'

The standard defining evaluation criteria for the NRC staffs

environmental review is defined in 10 CFR 51.95( c )(4) as follows:

... whether or not the adverse environmental impacts of license

renewal are so great that preserving the option of license renewal for

energy planning decisionmakers would be unreasonable.

MPS-82-1 The NRC staff has preliminarily concluded in its draft Environmental

Impact Statement that the adverse environmental impacts of license

renewal are not so great that preserving the option of license renewal for

energy planning decisionmakers would be unreasonable.

This conclusion is clearly erroneous and based on incorrect and

incomplete information, industry bias and flawed analysis. It also

manifests a profound disregard for the health and welfare of the

community.

This conclusion ignores substantial available evidence that

Millstone operations have had and will continue to have devastating

health Impacts on a wide scale and will continue to cause irreversible

environmental damage on a wide scale.

Our detailed comments follow. Following the Introduction, our comments

appear in sequence conforming to the appearance of topics in the draft

Environmental Impact Statement (SEIS). Our comments today address the

SEIS up to 5.0 ('Environmental Impacts of Postulated Accidents").

Additional comments addressed to Section 5.0 et seq. will be provided

subsequently hereto.

Introduction

The U.S. Nuclear Regulatory Commission ("NRC") is considering

relicensing of the Millsone Nuclear Power Station, Units 2 and 3 for

additional 20-year terms. Without relicensing, Unit 2's operating license

See NRCs 'Principles of Good Regulation, attached. 1

NUREG-1437, Supplement 22 A-376 July 2005
; - - -, 'Appendix A

- . .- -

would expire in the year 2015 and Unit 3's operating license would expire in

the year 2025. ' -

MPS-82-2 Together with Unit .1, these reactors have had an operational history

since 1970 which Is among the ugliest in the annals of the nuclear

industry.2 Millstone's radioactive releases have beenlamong the highest of

all nuclear reactors in the United States.3 Millstone's routine radiation

releases were linked early-on with cancers and other diseases.4 Millstone's

treatment of its workforce by way of exposing It to unnecessary radiation

levels5 and Its treatment of nuclear whistleblowers'b'y ostracism and

retaliatory firings have made it notorious within the nuclear industry.6 While

full-time inspectors from the NRC were onsite, Millstone lost two highly

radioactive spent fuel rods. These irradiated rods contain plutonium and

other fission'elemrents which may be diverted to create dirty bombs. While

Millstone's environmental monitoring program was beinig monitored by the

NRC and Connecticut's Department of Environmental Protection ('DEP"),

Millstone's personnel brazenly falsified environmental monitoring reports to

the NRC and DEP and sabotaged the sample-taking activities.7

MPS-82-3 Connecticut's regulatory apparatus has failed to'safeguard the public.

Millstone's five-year National Pollution Discharge Elimination System'

("NPDES") permit expired on December 14, 1997- eight years ago - and it

has not been renewed. Nevertheless, DEP has permitted Millstone to -

operate under the 1992 permit in brazen violation of the letter and spirit of

the federal Clean Water Act. Former DEP Commissioner Arthur J. Rocque,'

MPS-82-4 2 For this reason, each of the environmental issues required foriconsideration In the

Environmental Impact Statement process should be considered to be a Category 2

issue, subject to site-specific consideration. - .

3 See Millstone & Me: Sex. Lies and Radiation in Southeastern Connecticut by Michael

Steinberg (Black Rain Press 1998).

4 See Testimony of Ernest J. Stemglass, Ph.D., presented to a Congressional

Committee Investigating nuclear power issues.

5 See. e.g., www.mothballmillstone.ora. experience of Charles D. Douton. Jr.

8 See. James Plumb v. Northeast Nuclear Energy Companv (Superior Court, Judicial

District of New London); Clarence 0. Reynolds v. Department of Public Utility Control

(Superior Court, Judicial District of New Britain); John DelCore v. Northeast Nuclear

Energy Co, U.S. District Court. District of Connecticut.

7 See 'Owner of Connecticut Nuclear Plant Accepts a Record Fine' (The New York

Times September 28, 1999), attached.

July 2005 ' A-377 -.- NUREG-1437, Supplement 22
MPS-82-3 Jr., routinely authorized 'emergency authorizations" ("EAs') while

recognizing his lack of legal authority to do so.8 These EAs - of indefinite

duration permitting releases of toxic and carcinogenic substances without

enforceable limits - permit Millstone's owners and operators to do, inter

alla, what Northeast Utilities pleaded guilty to doing wilfully and illegally

when it pleaded guilty in the U.S. District Court in September 1999 to

committing environmental felonies at Millstone and paying a $10 million

fine. Clearly, the Clean Water Act prohibits major waivers of NPDES permit

conditions without notice to the public and a meaningful opportunity for

public input. Commissioner Rocque issued sequential EAs without notice to

the public and he did not provide an opportunity for public comment. To our

knowledge, Rocque's successor, DEP Commissioner Gina McCarthy, has

done nothing to bring the Millstone operations into compliance with the law.

She has permitted the status quo to reign. Connecticut Attorney General

Richard S. Blumenthal is complicit in the illegal Millstone activities. Mr.

Blumenthal successfully suppressed the truth of Millstone's illegal

operations in litigation brought to require Millstone operations to comply

with existing laws.

Regardless of whether Millstone has been technically out of compliance

with the law during much or all of its 35-year operational life, its operations

have systematically endangered the public health and safety.

Millstone operations are a clear and present danger to the public

health, safety and welfare.

MPS-82-5 Although Millst6ne's reactors have been operating since 1970, and thus

have generated a 35-year history of operations and record of

environmental impact, the NRC selected only a three-yearperiod (2001,

2002 and 2003) to review to assess Millstone radiological emissions for

purposes of its SEIS evaluation. Necessarily, the NRC staffs superficial

MPS-82-3 6 The Coalition attaches hereto the 'Emergency Authorization' issued on October 13,

2000 which legalizes' violations of the expired NPDES permit and which exCommissioner Rocque 'transferred' to Dominion when it was a paper company without

assets. Prior to issuing EAs for Millstone operations, Commissioner Rocque admitted in

writing he lacked authority to issue emergency authorizations on an emergency basis

for unlimited durations. The EA attached hereto has been in effect on an emergency basis since 2000 premised on a "finding- that it was required to avert an imminent

threat to health or safety.The SEIS makes no reference to this EA.

4

NUREG-1437, Supplement 22 A-378 July 2005
Appendix A

MPS-82-5 and selective review deprived it of the opportunity to engage in a

meaningful assessment of the environmental impacts of Millstone's

complete operating history to inform the evaluation necessary to evaluate'

the full scope of future effects during a potential period of license extension.

MPS-82-6 At the same time, the NRC staff virtually ignored the information

available to it even in the limited area it selected for review: the years 2001-

2003." -

The most glaring example we may provideyou 'of this appears as the

preliminary comment we provided to you on,' together with theddeclaration

of Ernest J. Sternglass, Ph.D.10 Dr. Sternglass evalu'ated Dominion Nuclear

Connecticut, Inc.'s reports of strontium-90 levels sampled in goat milk five

miles from Millstone'during 2001, 2002 and 2003.-Although one sample

measurement reported by Northeast Utilities in 2001 'was at a level nearly

twice the highest level of measured strntium-90 concentration in

Connecticut milk-during the height of the atmospheric nuclear weapons

testing in the 1960s, -this fact is not reported in the SEIS nor is'it analyzed,

nor are the'other high'strontium-90 measurements in goat milk sampled,

five miles downwind from Millstone analyzed.1 - ' '

MPS-82-7 We perceive a determined lack of dedication by the NRC staff to

genuinely'understand the full scope of environmental - Including human

health - impacts of continued operations of Millstone. Documents which we

provided to the NRC have apparently been destroyed.'2-Comments made

in relicensing proceedings attended by the SEIS staff and documents

submitted in such proceedings were ignored or disregarded by the SEIS

staff.' - .

9 Webster's Dictionary defines misfeasance as 'the performance of a lawful action in an

illegal or improper manner.: - -.

10 Refer to the Coalition's March 2. 2005 submission and attachments thereto.:

A Webster's Dictionary defines malfeasance as 'wrongful conduct, especially by a

public official."

1 See Response of Richard L. Emch, Jr. to the Coalition's February 5. 2005 queries,

Paragraph 7 (attached): Documents responsive to this request were presented to the

NRC by the Coalition as attachments to the Affidavit of Cynthia M. Besade dated -

August 5,2005. - , - -

See Transcript of January 11, 2005 public informational meeting sponsored by the

NRC's SEIS staff at the Waterford CT Town Hall.

S.

July 2005 A-379 .' NUREG-1 437, Supplement 22'
Appendix A

MPS-82-7 We continue to be troubled by the fact that documents produced by the

SEIS staff in response to our queries about the SEIS submitted to the SEIS

staff on January 23, 2005 were withheld by the NRC's own Freedom of

Information staff and have yet to be released.1 4

MPS-82-8 Similarly, we are astonished that the NRC staff most involved with the

SEIS declined our invitation to attend the press conference we gave on the

Niantic Bay shoreline 1.5 miles from Millstone on March 10, 2005. At our

press conference, we introduced Zachary M. Hartley, a 7-year-old boy born

with a rare cancer in his jawbone.15 During critical months of her

pregnancy, Zachary's mother swam regularly and.unknowingly in the

nuclear 'mixing zone"16 which is known locally as the Hole-in-the-Wall

Beach. We invited the entire NRC to attend the press conference and

address questions to our expert, Dr. Helen Caldicott, world-renowned

pediatrician, co-founder of Physicians for Social Responsibility and a

leading authority on the health effects of low-level Ionizing radiation such as

is routinely emitted by Millstone. Zachary's medical records were available

for NRC review. Not a single representative of the NRC appeared, not even

one of the resident inspectors assigned to Millstone. Dr. Caldicott linked

young Zachary's rare jawbone cancer to Millstone's radiological and toxic

chemical emissions as being the likely causative agent. Dr. Caldicott

acknowledged that, while there cannot be a 100-per-cent certainty that

Millstone caused Zachary's medical condition, cesium-137 which Northeast

Utilities found in a fish in the same nuclear 'mixing zone" in 1997 - the year

of Zachary's mother's pregnancy - and which contamination it admitted

was discharged by Millstone, Is known to be associated with cancer,

including cancer of the bone. We are transcribing Dr. Caldicott's comments

and will provide the NRC with a copy as soon as the transcription is

available.

In light of the facts which have come light regarding Zachary M. Hartley,

the Coalition has requested that the Connecticut General Assembly's

Public Health and Environment Committees convene a special public

14 The Coalition will address this issue In a subsequent filing.

'5 Press clippings from the Hartford Courant, Norwich Bulletin and The New London

Day are attached.

16 See SEIS at 4.1.3.

6

NUREG-1437, Supplement 22 A-380 July 2005
Appendix A

hearing to consider our request to close the Niantic shoreline beaches.'7

We understand that the legislature may find it necessary, in order to - -

adequately protect the public health and safety, to'enact legislation to close

Millstone forthwith. Governor M. Jodi Rell has referred our request to the

Commissioner of Public Health; we are asking him to exercise his authority

to close the Niantic beaches as a health hazard. We further anticipate that

the Connecticut DEP will orderthat Millstone convert from Its once-through

cooling system to a closed cooling system, thereby virtually eliminating the

discharge of radioactive and toxic chemical contaminants to the Niantic and

MPS-82-9 Waterford shorelines. The SEIS does not address the prospect that '

Millstone will undergo a major refurbishment in the conversion from the

once-through to a closed cooling system. This is a major omission in the

SEIS. :

We recognize that the events in question in Zachary's life arose in 1997,

prior to Dominion's takeover of Millstone in 2001. However, Zachary's

sickness is a factor which must be considered in the operational history of

Millstone. Under Dominion ownership, Millstone has continued to release

the same radioactive and toxic chemical waste byproducts as NU before.

MPS-82-10 Indeed. Dominion is currently seeking permission from CTDEP to-add

new chemicals to the "mixing zone' and continue the routine discharge of

others. Nowhere in the SEIS is it stated that the NRC staff reviewed

Dominion's application for renewal of the NPDES permit. Nowhere are

these'facts assessed in 'the SEIS. - .

MPS-82-11 'The SEIS fails tomheaningfully consider the routine environmental

impacts of Millstone's radiological releases, relying on'the 'conclusion" in

the NRC's GenericErnvironmental Impact Staterment that all the nation's"'

nuclear power plants release radiation within levels-pernitted under the

NRC's regulations and therefore may be expected to continue to do so in

the future. These conclusions do not apply to Millstone. See discussion at

infra. '- -

Even NRC's Generic Environmental Impact Statem'ent (AGEIST) states

that cesium-137 -for one - may be expected to bloaccumulate such

that its buildup in the environment will increase by 35 per cent during17 See Coalition letter to Connecticut General Assembly Public Health and Environment

Committees dated March 4. 2005, attached.7 X ,.

July 2005 A-381 NUREG-1 437, Supplement 22
Appendix A

the postulated renewal period at each of the nation's nuclear power

plants undergoing relicensing.1 8

GEIS section 4.6.1.1 states in part as follows:

To determine whether the added period of operation following license

renewal would, by virtue of buildup, result In significant (double)

added dose, the ratios of buildup factors for midlives of 30 to midlives

of 20 years were evaluated. These ratios amount to a 35 per cent

increase for Cesium-137 and a 6 per cent increase for cobalt-60.

In certain cases, the bioaccumulation factors may require

reexamination. These principally involve fish (in the human food

chain) that are bottom feeders. Bottom feeders may ingest

worms and other blota that may remobilize radioactive materials

accumulated in the sediments.

Accumulation of radioactive materials in the environment is of

concern not only to license renewal but also to operation under

present licenses.

(Emphasis added.)

MPS-82-12 This reference is entirely omitted from consideration in the SEIS. The

SEIS omits any analysis of the predicted buildup of cesium-1 37 or cobalt60 or any other radionuclides in the environment surrounding Millstone. To

the extent that cesium-137 released to the environment will have enhanced

effects, the NRC's staff's failure to assess the impact to the health and

safety of the community - including Niantic Bay beachgoers who may be

pregnant - borders on reckless endangerment.

It is known that cobalt-60 released by Millstone bioaccumulates in the

sediment of Jordan Cove and is therefore subject to being ingested by

worms and thereby enter the food chain.'9 Yet, the SEIS fails to reexamine' this phenomenon - and the potential for bloaccumulation of other

radionuclides in the environment surrounding Millstone - consistent with

GEIS section 4.6.1.1.

's GElS 4.6.1.1.

19 See [citation to follow]

NUREG-1437, Supplement 22 A-382 July 2005
Appendix A

MPS-82-13 ; Nor does the SEIS examine the quality of environmental stewardship

exercised by Dominion in its other corporate activities.

We suggest you review the October 2003 report by Public Citizen,

"Dominion Resources, Inc.; A Public Citizen Corporate Profile." 20 Public

Citizen reports that "MIen April 2003,-Dominlon's VEPCO agreed to a $1.2

billion enforcement settlement with the US Department of Justice and the

US Environmental Protection Agency for violations of the Clean Air Act." -- '

(Emphasis added.)

The report further states that Dominion's VEPCO failed to install

pollution control equipment at its coal-fired Mount Storm Power Plant in

West Virginia after it made significant modifications that increased powergenerating capacity. This was a violation of the Clean Air Act and,

"according to the EPA, resulted in the release of 'massive amounts' of

sulfur dioxide, nitrogen oxide, and particulate matter."

Dominion's Dominion Energy, owner of the Brayton Point Power Station

in Massachusetts, releases 240 pounds of toxic rriercu'ry annually from that:

facility- enough to poison 120 million pounds of fish part of the Dominion

network of companies, according to the Providence (RI) Joumal of March

11, 2005.21 Eating mercury In fish and shellfish presents a danger to ' -

children and pregnant mothers by harming developing nervous systems.

Dominion Energy has been served with a notice of Intent to sue by the

Conservation Law Foundation, according to the newspaper report.'

According to the SEIS, four states and all or parts of 15 counties fall

within the 50-mile radius of Millstone (eight In Connecticut, four in Rhode

Island, two in Massachusetts and one in New York). An estimated '

2,868,207 people live within this area. This equates to'a population density

of 219 persons/square kilometer or 567 persons per siquare mile. In the

GEIS matrix of rank of sparseness (Category 4) and proximity (Category 4)

result in the conclusion that Millstone is located in a high-population area.

MPS-82-14 Moreover, the population within a 10-mile'radius of Millstone increases

seasonally as a result of an influx of approximately '10,500 summer

2 A copy of the report is attached. - -. - -

22 See 'Conservation Group Sues Brayton Point' (Providence'Journal, March 11, 2005).

attached.

July0015_ ., A-383- NUREG-1437, Supplement 22
Appendix A

MPS-82-14 residents. The SEIS contains no figures of the seasonal influx of visitors to

the eastern end of Long Island although it is within the 50-mile radius of

Millstone.

MPS-82-15 In conclusion, it is clear that the adverse environmental impacts of

license renewal are so great that preserving the option of license

renewal for energy planning decislonmakers would be beyond

"unreasonable" - license renewal for Millstone is a license to kill.

This conclusion is unassailable when the full scope of available

information about Millstone's environmental impacts is properly

considered.

Detailed Comments

GEIS Is Inapplicable to the Millstone EIS

MPS-82-16 The Millstone Draft Environmental Impact Statement analysis largely

avoids the primary issue presented by the prospect of relicensing

Millstone Units 2 and 3 for additional 20-year terms: the effects of routine

releases of radiological and toxic chemical releases to human health and

the environment surrounding the nuclear facility.

The troubled nuclear industry knew that if the truth about the radiological

impacts of nuclear power plant operations could be addressed in

relicensing proceedings, no community in American would accept the

prospect to hosting a nuclear power plant beyond its initial 40-year

licensing term. The GEIS is a fiction contrived by the nuclear industry and

adopted by the NRC to deny the public an opportunity to challenge

relicensing of nuclear power plants based on radiological impacts to human

health and the environment.

MPS-82-17 The NRC's Generic Environmental Impact Statement ('GEIS") was

published in the year 1996, or nine (9) years prior to the NRC's invitation

for public comment on the SEIS, at a time when Unit 2 had operated for 26

years, Unit I for 21 and Unit 3 for 10 years. Necessarily, when the GEIS

refers to 'current levels of radiation, it is referring to radiation levels which

were 'current' in 1996 or earlier. The GEIS is not itself current, but is

I0

NUREG-1437, Supplement 22 A-384 July 2005
Appendix A

MPS-82-17 outdated and fails to account for the past nine (9) years of operations within

the U.S. nuclear industry. C. ! --

The GEIS itself is obsolete. Although the NRC staff states in the SEIS it

was not required to consider site-specific aspects of Millstone's routine

radiological emissions because Millstone site-specific routine radiological

emissions were considered in the GEIS at Appendix E, GEIS Appendix E is

limited to 'routine' radiological emissions during the years 1985-1987. No

explanation Is given why a report published by the NRC in 1996 relies on

10-year-old data, when its purpose is to project radiation levels five

decades into the future. At best, GEIS's radiological analysis of "routine"

Millstone radiological emissions is incomplete an'd'superficial.

More significantly, the GEIS fails to account for any of the following facts

and circumstances - routine and extraordinary which have occurred at

Millstone since 1996, including the following: ' .

MPS-82-18 1. The NRC placed the entire Millstone Nuclear Power Station on its

'Watch Listr and ordered an unprecedented three-reactor two-year

.shutdown in 1996 because of national media exposure of wilful,

systemic disregard for safety standards and licensing requirements;

Unit I never restarted, Unit 3 restarted in 1996 and Unit 3 restarted in

.1999; :-:-Mt -; t.*.

MPS-82-19 2. In 1996, after-workers in the site maintenance department at

Millstone were diagnosed with brain cancers and Northeast Utilities

dismissed the entire department - after securing releases the

--;-workers would not sue Northeast Utilities if the company paid them

double severence pay - and hired transient contract workers to

perform hot and dirty tasks within the plant, two of the workers died

untimely deaths due to their brain cancers. - , ' ''

3.- On December.16,1997, Zachary M. Hartley was born with a rare

jawbone cancer which required major life-threatening surgery. His

mother swam regularly in the nuclear/chemical mixing zone"

otherwise known as the Hole-in-the-Wall Beach on the Niantic Bay

shoreline during critical months of her pregnancy with Zachary.

4. In 1997, Northeast Utilities caught a fish contaminated with cesium137, a deadly carcinogen, it admitted releasing into Niantic Bay, in

the nuclear/chemical _mixing zone" which stretches from the Millstone:

., -: . .1 - * * .. ii . ; ; - , , -- s ,.t s 7

July 2005' A-385' NUREG-1437, Supplement 22
Appendix A

MPS-82-19 discharge point to the Niantic Bay shoreline, a popular summer

destination for families with young children.

5. On or before 1997, Millstone dispensed with its measurement of

strontium-90 In quarterly composited air particulate filters, relying

instead on infrequent sampling of goat milk in the community to

determine whether its strontium-90 emissions reached harmful levels

after-the-fact.

MPS-82-20 6. In September 1999, Northeast Utilities, predecessor to Dominion,

pleaded guilty to committing environmental felonies including

falsifying environmental monitoring records and releasing hydrazine,

a carcinogen, illegally into the Long Island Sound.2 i

MPS-82-21 7. A Connecticut Superior Court judge enjoined the restart of Millstone

Unit 2 in 1999 because he was persuaded that the health and

stability of the indigenous Niantic winter flounder stocks were

endangered by operations of the Millstone intake structures through

entrainment and impingement. Fish Unlimited v.! Northeast Utilities.

8. In 2000, two commercial fishermen sued Northeast Utilities for

tortiously causing the collapse of the formerly commercially viable

Niantic winter flounder fishing stocks; their suit remains pending. MPS-82-22 9. In 2000, Northeast Utilities acknowledged that - even under daily

supervision by onsite inspectors of the NRC - it had lost two highly

radioactive spent fuel rods from the Unit I spent fuel pool'.

10. In 2000, the Connecticut Department of Public Utility Control

('DPUC") oversaw a 'public auction" by' Northeast Utilities to sell the

Millstone Nuclear Power Station; the public was excluded from the

'public auction"; virtually all key 'public auction" documents were

redacted and ordered sealed by the DPUC; over public protest, and

despite the Coalition's disclosure that Dominion had the worst safety

record in the nuclear industry including the deaths of seven nuclear

workers at its nuclear facilities in Virginia, the DPUC approved the

sale of Millstone to Dominion Nuclear Connecticut, Inc., ('DNC") at

the time a paper entity with no assets with only a post office box in

Niantic, Connecticut: when the Connecticut Coalition Against

Millstone obtained a Superior Court hearing date for a judge to

consider its challenge to the rigged sale and the prospective transfer

of expired environmental permits to DNC, lawyers for Northeast

Utilities and DNC met ex parte with Superior Court Chief

22 See 'Owner of Connecticut Nuclear Plant Accepts a Record Fine' (New York Times

September 28, 1999). attached.

1n

NUREG-1437, Supplement 22 A-386 July 2005
Appendix A

Administrative Judge John J. Langenbach and obtained an order

suspending the hearing so the sale could proceed without court

review, when the matter was brought to the Connecticut Supreme

Court,-Justice Christine Vertefeuille, ben'eficiary of a Northeast

Utilities 401K plan, recused herself; Connecticut Attorney General

Richard S. Blumenthal, although entitled to automatic' party status in

the DPUCproceedings, declined participation. So occurred the

'public auction' of Connecticut's worst polluter.' -

MPS-82-23 - 1.' In April 2001, Connecticut's Commissioner of Environmental

Protection, Arthur J. Rocque, Jr.. "transferred"an expired NPDES

(National Pollution' Discharge Elimination System) permit '(it had

expired four years earlier) and "emergency authorizations" (which he

admitted in writing he lacked legal authority to issue) to "Dominion

Nuclear Connecticut,'Inc.," at that time a paper company with a post

office box in Niantic but no assets. Dominion has'been operating

'under the authority of the expired permit for fouryears and DEP has

not renewed the permit in the intervening time.'

MPS-82-24 12." 'In 2001, Dominion reported concentration levels of strontium-90

contamination In goat milk-sampled within five (5) miles downwind of

the Millstone Nuclear Power Station nearly twice as high as the

highest recording measurement of strontium-90 concentrations in

Connecticut milk during the height of the .1960s atmospheric nuclear

weapons testing.

MPS-82-25 13. in 2001, terrorists who had targeted nuclear power plants--

hijacked a passenger jet and flew over the Indian Point Nuclear

Power Plant 29 miles of New York City before slamming into the

World Trade Center. The U.S. Department of Homeland Security,

subsequently created, designated the Millstone Nuclear Power Plant

- a terrorist's target of choice. -

14. In 2004, Connecticut State Senator Melodie Peters, Chairman

of the powerful Energy and Technology Committee, took a paying job

with Dominion In public relations to advocate for Millstone relicensing,

l without giving up her legislative commitments.-. -

MPS-82-26 11. On August 16, 2003, Joseph H. Besade became the seventh known

pipefitter to die prematurely from workplace exposures at Millstone.

MPS-82-27 15. , - On August 5, 2004, Cynthia M. Besade reported to the NRC in

an affidavit her personal knowledge of some 67 cancers in persons

known directly or indirectly to her, all living within or close to the fivemile radius'surrounding Millstone, including childhood cancers and

13

July 2005 - A-387 NUREG-1437, Supplement 22
Appendix A

MPS-82-27 the case of a 17-year-old Waterford high school student diagnosed

with ovarian cancer, from one street alone - Seabreeze Drive, northnortheast and less than two miles downwind of Millstone - seven (7)

cases of cancer were reported.

MPS-82-28 16. On August 5, 2004, Richard Heaton drove seven (7) hours from

the University of Pennsylvania Medical Center to New London to

participate in a press conference and proceeding before the NRC to

share the facts of his daughter's rare thyroid cancer which developed

following her exposure to Millstone effluents at age 10.

MPS-82-29 17. In 2004, Dominion rejected the U.S. Department of Homeland

Security's offer of a free security enhancement to protect the three

Millstone Intake structures from terrorist attack.2 3

MPS-82-30 18. In February 2005, the Coalition discovered that Zachary M.

Hartley's rare jawbone cancer, believed caused by his mother's in

utero exposure to Millstone radiological and chemical effluents in the

nuclear/chemical 'mixing zone" in 1997, was knowingly excluded

from listing in the State of Connecticut's Tumor Registry because part

of the orange-size cancerous tumor removed from Zachary's mouth

in life-saving surgery was determined to be benign.

MPS-82-31 19. On March 10, 2005, Dr. Helen Caldicott, world-renowned

pediatrician, authority on the health effects of low-level ionizing

radiation and co-founder of Physicians for Social Responsibility,

declared the likelihood that 7-year-old Zachary M. Hartley's rare

jawbone cancer was caused by his mother's exposure to Millstone's

radiological and chemical effluents.

MPS-82-32 Moreover, Millstone is unique in the annals of the U.S. nuclear industry:

Millstone has released the highest levels of radionuclides of any nuclear

power station in the country at various times over the past 35 years of its

operational history.

From 1970 to 1987, Millstone had released a total reported release of

32 curies of radioactive iodine and particulates into the air, which included

the highly carcinogenic strontium-90 and iodine-1 31, together with 6.7

million curies of total fission and activation gases such as xenon and

krypton. During the same period, Millstone released 581 curies or 581

trillion picoCuries of radiation in the highest liquid volume of such releases

23 See Millstone Owner Turned Down Free Homeland Security Device' (The New

London Day. March 9, 2005)

14

NUREG-1437, Supplement 22 A-388 July 2005
Appendix A

MPS-82-32 of mixed fission and activation products of any nuclear~plant in the United

States.2 1 .

In a single year, 1975, Millstone released a record reported high of 9.99

curies of iodine and particulates into the'air and 199 curies of liquid mixed

fission and activation products into the Long Islahd Sound, also a record for

all U.S. reactors.25 Id.

MPS-82-33 While the strontium-90 concentration In milk declined for the United

States as a whole between 1970 and 1975, from 8 pCiA to 3 pCiA, it rose,

from 9.8 in'1970 to a high of 15.8 in 1973 and 14.8 in ,1974 near Millstone,

remaining at 10.7 by 1975. This is far in excess of the U.S. average of 3

pCiA, ruling out any significant contribution to the local milk from bomb test

fallout by France and China that continued until 1980.26

The calculated yearly radiation dose to bone of a child due to excess

strontium-90 within 10 to 15 miles of Millstone, in excess of the yearly dose

for the United States, rose from 33 millirem per year in the first full year of

operation to 204 millirem per year by 1974, nearly three times the normal

background level of 70 millirems per year in Connecticut.2 -

These doses of strontium-90 alone may be compared with the 15 -

millirem per year to any organ permitted under current NRC regulations,

the 2 millirem produced to bone marrow in a typical X-ray of a child, and

the 80 millirem per year to a developing fetus found to produce a doubling

of the rate of childhood leukemia In the studies'of the renowned Dr. Alice

Stewart. 28

MPS-82=34 Given all these facts and circumstances, the application of a 'Generic

Environmental Impact Statement' to Millstone, thereby precluding site24 See Declaration of Emest J. Sternglass. Ph.D., In the Matter of Dominion Nuclear

Connecticut. Inc.: Docket No. 50-336-LR. 50-423-LR, ASLBP No. 04-824-01 -LR

(August8,2004)_':''

25Id. : -. -- ' -. ,--- - . .. I ;

26'' 2TId . - ' t -

28 I

Id.

July 2005, A-389 NUREG-1437, Supplement 22
Appendix A

MPS-82-34 specific analysis in the Environmental Impact Statement, is so deeply

flawed as to be fraudulent.

The Coalition and others have provided "new and significant"

information which compels the NRC to conduct a site-specific analysis of

the environmental impacts of relicensing Millstone Units 2 and 3. See

discussion at pages 32 et seq. infra.

MPS-82-35 At the very least, the NRC should be required to evaluate the

environmental impact of Millstone's radiological and chemical effluents -

singly, in synergy and cumulatively - under site-specific analysis to qualify

under the standards of the National Environmental Policy Act.

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls

In this section, the SEIS describes the liquid, gaseous and solid waste

management systems presently in place to collect and treat the radioactive

materials which are produced as a by-product of the nuclear plant

operations.

The SEIS states as follows:

Radioactive material produced from fission of uranium-235 and

neutron activation of metals in the reactor coolant system is the

primary source of liquid, gaseous and solid waste. The radioactive

fission products build up within the fuel. Most of these fission

products are contained in the fuel pellets and sealed fuel rods, but

small quantities escape from the fuel rods into the reactor coolant.

Neutron activation of trace concentrations of metals entrained in

reactor coolant such as zirconium, iron and cobalt creates radioactive

isotopes of these metals. Both fission and activation products in liquid

and gaseous forms are continuously removed from reactor coolant

and captured on several different types of filter media. Units 2 and 3

operate separate liquid and gaseous processing systems. Gaseous

discharges for each unit are monitored separately before they are

discharged to the stack or to other designated release points for each

unit. All liquid discharges are directed to a canal which terminates in

the old quarry and the quarry discharges to Long Island Sound.

16

NUREG-1437, Supplement 22 A-390 July 2005
Appendix A

MPS-82-36 Despite these comrnments, it is clear that station monitoring of radioactive

effluents is presently inadequate and incomplete and that some

radionuclides are released into the environment without measurement or

documentation.

For example, In 1997, Northeast Utilities reported in its Annual

Radiological Environmental Operating Report as follows:

Section 4.5 'Air Particulate' Strontium (Table '5)

Table 5 in past years was used to report the measurement of Sr-89

and Sr-90 in quarterly composited air particulate filters. These,,

'measurements are not required by the Radiological Efflueni

Monitoring Manual (REMM) and have'been discontinued.

Previous data has' shown the lack of detectable station activity in this

. media. This fact, and the fact that milk samples are a much more

sensitive indicator of fission product existence in the environment,

prompted the decision for discontinuation.-In the event of widespread

plant related contamination or special events such as the Chernobyl

incident, these measurements may be made."> ,

MPS-82-37 As Dr. Stemglass has pointed out,29 in 2001, Dominion recorded

concentrations of strontium-90 In goat milk sampled five miles from

Millstone at a level nearly twice that of the highest recorded concentration

of strontium-90 in milk in Connecticut during the peak of atmospheric

atomic bomb testing in the 1960s. ,

MPS-82-38 In 1997 alone, there were numerous reported incidences of station

radiation monitors being inoperable: - - i'T

- -:; ..*., ,, - - -;a. j Nr..

Unit 1 Liquid Radwaste Effluent Monitor (inoperable 67/96 - 3125/97

-83 days in 1997, 291 days total) i -- -

Unit 1 Service Water Effluent Monitor (inoperable 6/9/96- 7/18/97 -

* -98 days in 1997, 404 days total) ---

29 See Coalition's March 2, 2005 filing to the NRC.

17

July 2005 A-391' J 0 47, S m . 2. NUREG-1 437, Supple menit 22'
Appendix A

MPS-82-38 Unit 2 Steam Generator Blowdown Monitor (inoperable 2/22/96 -

8/26/97 - 237 days in 1997, 551 days total)(NU claims no discharges

were made during this period)

Unit 2 Clean Waste Monitor Tank Radiation Monitor (inoperable

5/25/97 - 7/1/97-37 days)(NU claims no discharges were made

during this period)

Even the GEIS acknowledges that some airborne radioactive effluent

releases are not monitored, recorded or documented.

Within the entire body of radioactive airborne effluents released by

Millstone over the course of its 35-year operational life, the SEIS only

specifically considers those reported by Dominion in 2002 as follows:

Unit 2: Total fission and activation gas activity released 128

Curies

lodine-131 4.90 X 10-3 Curies

Particulates 1.22 X 10 -5 Curies

Tritium 31.2 Curies

Unit 3: Total; fission and activation gas activity released 2.45

Curies

lodine-131 1.52 X 10-6 Curies

Particulates 6.08 X 10 -5 Curies

Tritium 47.3 Curies

MPS-82-39 These figures do not break down the radioisotopes released, other than

for todine-131 and Tritium, and do not identify nor quantify which

radioactive gases are emitted, such as xenon-137 (with a half-life of 3.9

minutes decaying to cesium-137 with a half-life of 30 years); xenon-135

(with a half-life of 9.17 hours decaying to cesium-1 35 with a half-life of

3,000,000 years); nor krypton-89 (with a half-life of 3.2 minutes decaying to

strontium-89 with a half-life of 52 days). These radioactive materials are

long-lived and have cumulative impacts. The SEIS does not analyze these

environmental impacts.

IX

NUREG-1437, Supplement 22 A-392 July 2005
Appendix A

The SEIS states: 'These releases from both units are typical of annual

releases from Millstone and are not expected to increase during the

renewal period." :

MPS-82-40 Since the SEIS analysis was self-limited to the years'2001, 2002 and

2003, and annual releases for the 32 other years Millstone has been

operating were not considered, the statement that 'These releases from

both units are typical of annual releases from Millstone' is not, -

substantiated. - - -

Moreover, the SEIS statement, that [these releases] are not expected to

increase during the renewal period' is incorrect.-First, releases of tritium, a

known cancer-causing radioactive toxic with a half-life of 12.3 years. are

trending upward. Second, as Units 2 and 3 operate for longer periods at

full capacity, airborne radioactive emissions will increase. Similarly, if

during the renewal period Millstone Units 2 or 3 receive'approval for'power

upgrades, airborrie radioactive emissions will increase'. The consequences - of these reasonably foreseeable' circumstances were not analyzed in the

SEIS.

MPS-82-41 Moreover, the SEIS does not identify nor quantify strontium-90 releases,

nor note thie absence of strontium-90 monitoring from the station stack,

while strontium-90 concentrations are regularly found to be Inordinately'

high in goat milk taken from samples five miles from Millstone.

2.2.7 Radiological Impacts ' ' '

In section'2.2.7, Radiological Impacts,'on page 2-43, the section,

concludes, "The applicant does not anticipate any significant changes to

the radioactive effluent releases or exposures from Millstone operations

during the renewal period and, therefore, the' irripa'cts to the environment

are not expected to change." -

MPS-8242 However, in Dominion Nuclear Connecticut Millstone Station Annual

Radiological Operating Report 2003, in section 4.14, Seawater, on page 4-

9, it is stated, "since the restart of Unit 3 in 1998 and Unit 2 in 1999, tritium

'0 See discussion at page 20 infra.

19

July 2005 A-393: J NUREG-1437, Supplement 22 '
Appendix A

MPS-82-42 releases in liquid effluents have risen to levels at or above [emphasis

added] those observed during pre-shutdown period."

Dominion records indicate that Millstone released 1854 curies of liquid

radiation in 2000, an all time high. Such reported releases totaled 1273

curies in 2001, 1537 in 2002 and 1278 in 2003. NRC records for Millstone's

liquid tritium releases totaled from 1970-1994 totaled 11,550 curies. The

total from 1995-2003 was 8551 curies.

This trend of increasing amounts of tritium releases is dangerous

because tritium has carcinogenic, mutagenic. teratogenic and

transmutational properties whose effect upon the environment which have

not been considered in the SEIS.31

The coastline around Millstone is lined with beaches and shoreline

communities, with many summer residents as well. Human activities in the

area include swimming, boating, fishing, clamming, scalloping. Thus there

are ample opportunities for liquid tritium contamination of people and shore

and marine life.

MPS-82-43 It is undeniable that the more the pressurized water reactors of Units 2

and 3 operate, the more tritium by-products they will create and release

into the environment.

The current stated policy of both Dominion and the nuclear power

industry in general is to operate power reactors as close to maximum

capacity as possible. In 2003 Millstone 3 operated at almost 100%

capacity. Millstone 2 operated at 80% capacity, but only because it shut

down for refueling.

The increasing amounts of tritium discharged into Long Island Sound

means that Dominion's claim that it "does not anticipate any significant

changes to radioactive releases or exposures from Millstone operations

during the renewal period" is false. Therefore the NRC's conclusion that

'impacts to the environment are not expected to change" is also false.

3' See The Carcinogen, Mutagenic, Teratogenic and Transmutational Effects of

Tritium," Citizens Awareness Network, April 1994.

20

NUREG-1437, Supplement 22 A-394 July 2005
Appendix A

MPS-82-44 Given this history, the NRC should mandate the immediate installation

of filters to mitigate liquid tritium discharges from Millstone units 2 and 3.

In addition, the NRC should mandate-the testing of drinking water, well

water and groundwater and in 'marine life in'areas'affected by Millstone for

the presence of tritium. At present only sea water is tested for tritium.

Until these measures have been put into place and monitoring results

have been made public until Millstone's current operating licenses expire,

or units 2 and 3 permanently shut down','the NRC should not consider

granting license extensions for Millstone units 2 and 3, in consideration of

the health and safety-of the public.

4.1 Cooling System -

MPS-82-45 The GEIS identifies the issue of scouring caused by discharged cooling

water as a Category 1 issue. As a 'Category 1 " issue, the NRC staff will not

review it on a Millstone site-specific basis in the absence of 'new and

significant information."

The SEIS states the NRC staff "has not identified any significant new

information during its independent review of the Dominion ER, the staff's

site visit, the scoping process, its review of monitoring programs, or its

evaluation of other available information."--

MPS-82-45 Yet, scouring caused by discharged cooling water was identified by a

technician in the Millstone Environmental Laboratory as an irreversible

environmental impact during a recent public presentation on Dominion's

environmental Impacts presented at the Three Rivers Community College.

Accordingly, the NRC staff should request Dominion to release details to -

it of this 'new and significant information."' *-' --

4.1.1 Entrainment of Fish and Shellfish'in Early Life Stages,

Entrainment of winter flounder larvae at the Millstone intakes is a major

issue and it is one which has been 'the subject of much-litigation in the

Connecticut courts. Lawsuits' have been brought by local fishermen

21-

July 605 ": A-395' ' NUREG-1437, Supplement 22
Appendix A

complaining that Millstone intake structures have driven the indigenous

Niantic winter flounder population to near-extinction. The fishermen have

successfully resisted dilatory and repetitive motions on the part of Dominion

and Northeast Utilities to dismiss their claims.

The SEIS states:

"The staff independently reviewed the Millstone Units 2 and 3 ER

[Environmental Report], visited the site, and reviewed the applicant's

NPDES permit. The staff also reviewed relevant scientific articles and

agency documents (CTDEP) and NOAA (National Oceanic and

Atmospheric Administration) Fisheries (also known as National Marine

Fisheries Service [NMFS]. interviewed agency staff, and interviewed a

faculty member at the University of Connecticut who has conducted

research on entrainment at Millstone." [Crivello 20031

MPS-82-46 Astonishingly, the NRC staff does not report any attempt to consult with

the fishermen who are targeted in the SEIS for the demise of the Niantic

winter flounder population. Had the NRC staff attempted to locate

commercial fishermen who fish for Niantic winter flounder near Millstone, it

would have learned that the resource has vanished and, with it, the

fishermen and a way of life.

Nor, apparently, did the NRC staff make any effort to consult with the

experts who have testified in court proceedings to the overwhelming

evidence that the suction action of the Millstone intake structures is the

predominant cause of the collapse of the Niantic winter flounder population

and has been since 1986, when Millstone Unit 3 went online.

Northeast Utilities obtained operating licenses for Millstone in the 1970s

based on projections - possibly knowingly bogus - that the Millstone intake

structures would have a far less devastating effect on the Niantic winter

flounder larvae than has in fact occurred.

MPS-82.47 Although NRC staff spoke with Prof. Crivello of the University of

Connecticut, who has studied Millstone entrainment, the staff does not

explicitly identify Prof. Crivello as a paid consultant to Millstone's owners

and operators each time his name appears in the SEIS.

NUREG-1437, Supplement 22 A-396 July 2005
Appendix A

MPS-82-48 Why did the NRC staff not meet with DEP's Victor Crecco, author of

reports debunking'Dominion's theorizing about the Millstone impacts on the

Niantic winter flounder collapse?

MPS-82-49 The SEIS analysis of the collapse of the indigenous fishing stocks does

not mention the discovery of a fish caught in Niantic.Bay in 1997

contaminated with cesiurn-1 37- nor Northeast Utilities' acknowledgment

that the cesium-I 37 originated in its nuclear operations.32

The SEIS analysis does not mention the build-up of cobalt-60 in Jordan

Cove near the Millstone discharge point33 nor does .the SEIS analyze the

contribution of cobalt-60 buildup in sediment as a contributing factor in the

collapse of the population of the bottom-feeding Niantic winter flounder.

MPS-82-50 Attributing the collapse of the fishing stocks to elevated water

temperatures, the SEIS fails to consider the contribution-of Millstone's 24-

hour-a-day,' seven-day-a-week thermal discharges t6 the Long Island

Sound.

MPS-82-51 While the SEIS reports that Ache CTDEP [Division of Marine Fisheries

which has been analyzing this issue for nearly a decade] believes that

Millstone is having a significant impact due to entrainment of winter

flounder larvae," the SEIS relies on NOAA and NMFS reports - which

contain no data of the unique conditions at Niantic Bay but are devoted to a

broad, regional analysis of fishing stocks - to discredit CTDEP Division of

Marine Fisheries, as follows: -

Regulatory agencies concerned with the management of winter -

flounder have concluded that the resource Is overfished and

overexploited (NOAA 1998; NMFS 2003) and have instituted

measures to reduce fishing pressure throughout Long Island Sound

and the southern New England-middle-Atlantic region. Thus, there is

ample evidence to suggest that fishing pressure is directly

-contributing to the decline both local and regional levels'at and

32 See Northeast Utilities 1997 Annual Radiological Environmental Operating Report at

Section 4.17.2 ("Cs-1 37 was detected In one sample from the Niantic Bay (location 35).

Positive indications are seldom seen in this media outside of the immediate discharge

vicinity.')

3 See [citation to follow] - --

July 2005 A-397- NUREG-1437, Supple ment 22
Appendix A

MPS-82-51 may represent the major impact to this resource. The extent to which

Dominion contributes to or exacerbates the problem in the Niantic

River system is not elucidated by fish population studies reviewed in

this SEIS." [Emphasis added.]

As stated, the SEIS does not identify either a NOAA or NFSS study

specific to the Niantic River winter flounder nor the recent fishing habits of

commercial fishermen in the area; thus, its failure to accord credit to the

CTDEP for its insights appears to be result-driven, to obscure and

downplay the fact that the Millstone Nuclear Power State has been the

primary factor in driving indigenous fishing stocks to collapse. Or, as Rhode

Island expert on Niantic winter flounder. Mark Gibson - a witness whose

testimony aided Connecticut Superior Court Judge Robert Hale in issuing a

temporary restraining order keeping Millstone Unit 2 shut down during the

1999 spawning season to avoid harmful entrainment effects to the fish

population - has stated, Millstone is the worst predator of fish in the

Northeast.

The SEIS concludes:

The staffs evaluation of past impacts of entrainment on Niantic River

winter flounder is inconclusive because unresolved questions remain

about population dynamics, life history, and unknown factors that may

be impacting the population. The available data do not allow us to

unequivocally link or decouple population declines with Millstone

operations ... Because the spawning adult population is very low,

and in consideration of the 20-year license renewal period, the staffs

conclusion is that the impacts would be moderate.

MPS-82-52 The Coalition has reference to Figure 2-6 ('Comparison of Winter

Flounder Population Trends in Niantic River and Long Island Sound". 34 This

figure illustrates clearly that while the winter flounder fishing stocks in the

region are rebounding - perhaps due in part to fishing restrictions that

apply throughout the region - the Niantic River winter flounder population

continues its collapse.

34 Draft NUREG-1437. Supplement 22. 2-26 (December 2004)

24

NUREG-1437, Supplement 22 A-398 July 2005
Appendix A

MPS-82-52 The facts available to the NRC staff demonstrate that the sole factor

which has prevented the Niantic River winter flounder population from

enjoying a rebound as has the species elsewhere'in the region due to

tightened fishing restrictions is the most obvious one: the Millstone Nuclear

Power Station.-'

It is submitted that if the SEIS staff had pondered the ramifications of

Figure 2-6in'consultation with the Niantic fishermen 'who have gone out of

business and the fishermen's expert witnesses and CTDEP's marine

biologist Victor Crecco, in light of all the facts and circumstances, the NRC

staff would have been compelled to categorize the impact to Niantic winter

flounder from continued operations of Millstone in a license renewal period

to be 'major" and devastating and probably irreversible. -

The weight of credible evidence is that the operations of the Millstone

Nuclear Power Station have driven the winter flounder to virtual extinction,

a phenomenon not contemplated in the original Millstone environmental

impact statement. Future entrainment during the license renewal period will

definitely assure that the once-abundant, commercially important resource

will never return.

4.1.2.1 Impingement Monitoring

4.1.2.2. Impingement Mortality

At the request of Northeast Utilities, CT DEP permitted routine

impingement monitoring for Unit 2 to cease In December 1987. Unit 2 did

not have a fish return and all impinged marine organisms were presumed

lost. Routine impingement monitoring has never been conducted for Unit 3.

MPS-82-53 The most recent data for Unit 2 involves sampling collected biweekly

from July 2000 to June 2001. It is questionable whether the Unit 2 fish

return was In operation during such period.35 Data for Unit 3 involve

samplings collected biweekly from January to December 1993.

These samplings do not suffice in frequency to form a data base to

support conclusions about impingement during the 35-year operations of

Millstone, nor to provide an adequate basis for extrapolation to the future.

35 Report of a commercial lobsterman to the Coalition.

25

July 2005 A-399 NUREG-1437, Supplement 22
Appendix A

MPS-82-53 Thus, the SEIS statement:

Based on the assessment to date, the staff expects that the

measures in place at Millstone Units 2 and 3 (i.e., aquatic organism

return systems) provide mitigation for impacts related to

impingement, and no new mitigation measures are warranted.

is not supported by genuine evidence.

4.1.3 Heat Shock

MPS-82-54 The SEIS states:

Millstone has remained in compliance with the NPDES thermal and

discharge volume limits at the quarry cut [SEIS at page 4-28]

Yet, the SEIS report is absent any indicia of an independent basis from

which to render such a conclusion.

The SEIS states:

The [NRC] staff also independently reviewed monitoring reports for

the cooling-water discharge mixing zone... .the boundary of the

mixing zone cannot exceed a radius of 2438 m (8000 ft) from

discharge outlet at the quarry cut.

The SEIS report does not identify a single monitoring report by date or

otherwise; any conclusions regarding the cooling-water discharge mixing

zone are utterly unsubstantiated.

4.3 Radiological Impacts of Normal Operations'

The NRC SEIS staff review of Millstone data on the most critical issue of

.radiological impacts of normal operations' was self-limited to the years

2001, 2002 and 2003.

26

NUREG-1437, Supplement 22 A-400 July 2005
Appendix A

MPS-82-55 The NRC GEIS staff review of Millstone data on the most critical issue

of "radiological impacts of normal operations" was self-limited to the years

1985, 1986 and 1987.36 - '

Thus, in its consideration of whether the Millstone Nuclear Power

Station should be permitted to operate in the years 2015-2025 (Unit 2) and

2025-2045 (Unit 3), the NRC deliberately failed to consider the 'radiological

impacts of normal operations for the years 1970-1984,"1988-2000 and

2004 to the present.,

Put another way, the NRC considered Millstone's 'radiological impacts

of normal operations" for only 6 of the 35 years the Millstone nuclear

reactors have been routinely releasing harmful radiation into the

environment - just 17 per cent of Millstone's operational history. Twentynine (29) years of Millstone's routine releases of harmful radiation releases

to the environment are not evaluated in either the GEIS or the SEIS.

By limiting the pool of data considered in the GEIS and the SEIS to a

period of time which encompasses only 17 per cent of Millstone's,

operational history of harmful radiation releases to the environment, the

NRC failed to consider all available information. The NRC's evaluation of

future impacts based on past impacts rests of an inadequate data base and

its conclusions are accordingly unreliable, if not invalid. Certainly, the NRC

staffs consideration of 4cumulative" impacts (SEIS section 4.8.3) is

scientifically unsound if not indeed scientifically fraudulent, since the NRC

staff did not review, tabulate or assess the full scope of past Impacts to be

able to !accumulate" cumulate impacts.. -

On its website, www.nrc.govlwho-we-are/values.html, the NRC states

that it 'adheres" to 'Principles of Good Regulation' which include the

following: . . -

Independence:.. . Final decisions must be based on objective,

unbiased assessments of all information, and must be documented

with reasons explicitly stated."

36 See GEISS Appendix E.19

27

July 2005' A-401 NUREG-1437, Supplement 22
Appendix A

The SEIS and GEIS systematically exclude all available information

concerning Millstone's radiological effluents for the years 1970-1985, 1988-

2000 and 2004 to the present. No reason for such exclusion is explicitly

stated.

The GEIS addresses radiological impacts of 'normal' operations of

nuclear power plants during a projected renewal period as follows:

Radiation exposures to public (license renewal term):

GEIS: 'Radiation doses to the public will continue at current levels

associated with normal operations." (GEIS 4.6.2)

Occupational radiation exposures (license renewal term):

GEIS: 'Projected maximum occupational doses during the license

renewal term are within the range of doses experienced during

normal operations and normal maintenance outages, and would be

well below regulatory limits.

The GEIS categorizes the issue of 'radiological impacts of normal

operations' as a Category I issue, meaning that the SEIS reviewing staff

need not consider site-specific issues at all in the absence of "new and

significant information."

MPS-82-56 The Coalition believes that 'radiological impacts of normal operations'

must be considered on a site-specific basis with regard to Millstone Units 2

and 3 as a Category 2 issue. See discussion at page 32 et seq. infra.

Because the SEIS did not consider the issue as a Category 2 issue. the

SEIS is deeply flawed and inadequate and falls far short of meeting the

NRC's Principles of Good Regulation."

MPS-82-57 Finally, as stated, the SEIS states that the NRC staff is not required to

evaluate Millstone radiation releases on a site-specific basis because

Millstone releases were subjected to site-specific analysis in the GEIS

which found them to be 'well within regulatory limits." This statement is

most misleading in that it fails to acknowledge that the NRC GEIS staff

limited itself to reviewing Millstone's reported radiological emissions for the

2K

NUREG-1437, Supplement 22 A-402 July 2005
Appendix A

MPS-82-57 years 1985, 1986 and 1987 only.37 Millstone's largest reactor, the 1,220-

megaWatt Unit 3- was still under construction in 19 85.-By the year 1987, it

had not established an operational record; it has since substantially :

increased output and, hence, 'routine' radiological emissions.

GEIS Section 4.6 ("Radiological Impacts of Normal Operation")'"

provides in pertinent part as follows: - ; _f. . .- ,: . af

This section provides an'evaluation of the radiological impacts on

'occupational personnel and members of the public'during normal

operation following license renewal. This evaluation extends to all

118 nuclear'powier reactors. Radiation exposures occurring after

-license renewal are projected based on present levels of exposures.

' Estimates of additional maintenance,' testing and Inspections as'a

result of a variety of age-related changes in operational procedures

were made based on the anticipated changes to current operation

-and are detailed in' Section 2.6 ard Appendix B Added maintenance,

testing, and inspection will be'accompanied by increased exposure

time to members of the work force but are not expected to

significantly Influence dose to members of the public.

As noted,38 the GEIS was published in 1996. Hence the above

statement, Radiation exposures occurring after license renewal are

projected based on present levels of exposures," must be read with regard

to 1996-or-earlier levels of exposure, rather than actual *current"

exposures. However,'the NRC SEIS staff limited Its review to 2001-2003

data, rather than actual current" exposures. As also noted, the NRC GElS

staff only reviewed Millstone's 1 985-1 987 exposure data.

With regard to the above statement: -

Estimates of additional maintenance, testing and inspections as a

result of a variety of age-related changes in operatiorial procedures

were made based on the anticipated changes too current operation

and are detailed in Section 2.6 and Appendix B.-

3 See GEIS, Table E19. - ; " - -

38 See discussion at page 10 supra. - : - i i

2')

July 2005 . A-403 NUREG-1 437, Supplement 22:
Appendix A

MPS-82-58 the SEIS fails to identify or evaluate any 'additional maintenance, testing

and inspections as a result of a variety of age-related changes in

operational procedures" at Millstone.

With regard to the above statement:

Added maintenance, testing, and inspection will be accompanied by

increased exposure time to members of the work force but are not

expected to significantly influence dose to members of the public

the SEIS fails to identify or evaluate any "added maintenance, testing, and

inspection 'at Millstone and hence fails to evaluate increased exposure

time to members of the work force and members of the public during the

proposed renewal period.

MPS-82-59 The SEIS also fails to consider the environmental Impact of Dominion's

August 24, 2004 submittal to the NRC requesting approval of the 'Nuclear

Facility Quality Assurance Program Description." According to an Request

for Additional Information ('RAI'), dated February 24, 2005, this program

deletes from the Millstone Quality Assurance program radiological

protection responsibilities which include maintaining records and reports

on radioactive contamination levels." If this application is approved, a

safeguard to protect against excessive worker radiological contamination

will be lost and there will be no basis for the NRC to conclude now that

occupational radiation exposures during the license renewal term will be

small and within regulatory limits.

MPS-82-60 The NRC SEIS staff accepted at face value Dominion's self-assessment

that it would not conduct 'major refurbishment in the future. Thus, the NRC

SEIS staff considered neither 'major' or minor" refurbishments. The NRC

SEIS staff's conclusions about the radiological impacts during

refurbishment are therefore necessarily flawed. Given the strong likelihood

that major refurbishment In the form of a stationwide conversion from oncethrough cooling to closed cooling systems will be ordered by the

Connecticut DEP - to avoid future exposure of pregnant women and others

to harmful radioactive and toxic waste effluents in the 'mixing zone' and to

avoid irreversible impacts to the indigenous Niantic winter flounder - the

radiological impacts from such refurbishment should have been fully

explored and analyzed in the SEIS.

p0

NUREG-1437, Supplement 22 A-404 July 2005

I
Appendix A

The NRC's GEIS further states at section 4.6.1.1:

To determine whether the added period of operation following license

renewal would, by virtue of buildup, result in significant (double)

added dose, the ratios of buildup factors for midlives of 30 to midlives

of 20 years were evaluated. These ratios amount to a 35 per cent

' ''increase for Cesium-137 and a 6 per cent increase for cobalt-60.

This added Increase due to buildup will not significantly change the

total dose to members of the public.

In certain cases, the bioaccumulation factors rmay require

reexarmination. These'prinicipally involve fish (in the human food

chain) that are bottom feeders. Bottom feeders may ingest worms

and other biota that may remobilize radioactive materials

accumulated in the sediments. .,

Accumulation of radioactive materials in the environment is of

concern not only to license renewal but also to operation under

present licenses. ' - ,iMPS-82-61 ' As stated,39 the bioaccumulation of cobalt-60 in sediment in Jordan

Cove near the Millstone discharge point has been established. The SEIS

does not address this phenomenon, even though required by theGElS.

Millstone's monitoring of the aquatic environmentfIn the area of the

discharge has also revealed the presence of the following plant-related

radionuclides: cobalt-60, zinc-65, silver-I 10 and cesium-1 37.*,

In 1997 and at other times, "['Wndications of plant releases were

-observed in aquatic flora, including detectable levels of cobalt-60, zinc-65-

and silver-I 10. According to the 1997 Radiological Environmental report

filed by Northeast Utilities, -,, i, . - -

The detection of these fradio]nuclides throughout the year, as

witnessed by positives detected in other aquatic media, correspond to

radioactive liquid discharges from the three Millstone units. Sampling

39 See discussion at page 8 supra. a ,- , - -

40 See 1997 Annual Radiological Environmental Monitoring Program Report.

31

July 2005 A-405 ' NUREG-1437, Supplement 22
Appendix A

MPS-82-61 of this media provides useful information because it is very sensitive

to plant discharges. However, since seaweed is not consumed, other

media are utilized in the determination of dose consequences (e.g.,

see Shellfish and Fish results)

The presence of cesium-1 37 in a fish caught in the mixing zone" within

the Niantic Bay - as identified as a plant-related contamination in the 1997

Millstone effluent report - suggests widespread bioaccumulation of that

carcinogenic radioisotope within the environment, requiring a 'reexamination pursuant to GEIS standards.

The radiological impacts of normal operations" should be analyzed as a

site-specific Category 2 issue.

4.4 Socioeconomic Impacts of Plant Operations During the License

Renewal Period

MPS-82-62 The SEIS considers the economic contribution to the community

through payment of Dominion's workforce; however, the SEIS does not

separate out the economic investment made in maintaining a workforce to

monitor Unit 1, a nuclear power plant undergoing decommissioning, and its

repository of spent nuclear fuel. Nor does the SEIS consider the prospect

of a continuing workforce required to maintain Units 2 and 3 in the event

each or both units is/are decommissioned or prematurely shut down before

or during the renewal period.

MPS-82-63 The SEIS does not consider the enormous health care costs associated

with the community's long-term exposure to low-level ionizing radiation, nor

worker illnesses related to their exposures. We are aware of a recent

surgery, upon a patient whose cancer is fairly linked to Millstone

radiological and toxic chemical emissions, which cost In excess of $2.5

million. This does not include follow-up or lifelong care.

The SEIS is incomplete and inaccurate in its assessment of

socioeconomic impacts.

4.4.6 Environmental Justice

NUREG-1437, Supplement 22 A-406 July 2005

I
Appendix A

MPS-82-64 The SEIS does not address the environmental justice issues involved in

the transportation and storage of nuclear waste generate-by the Millstone

Nuclear Power Station, either during its 35 years of operations or in the

future. Transportation through poor urban areas and storage -of Millstone's

nuclear waste in poor rural communities both implicat6 enivironmental

justice concerns; neither aspect was addressed In the SEIS.

4.7 Evaluation of Potential New and Significant Information on

Impacts of Operations During the Renewal Term

The Connecticut Coalition Against Millstone and others have provided

the SEIS staff with *new and significant information" which, once

considered, dictates'site-specific review as Category 2 issues or, in the

alternative, rejection of the SEIS in toto.

The 'new and significant' information may be summarized as follows:

Millstone causes cancer and

Millstone is responsible

for an increased cancer incidence

in the surrounding community.

The SEIS states that "commentators have provided 'no evidence to

support a causal relationship between increased cancer incidence and

Millstone operations."

The NRC's SEIS staff concluded that the information provided

during the scoping process was not new and significant with respect

to the findings of the GEIS on the health effects to the public from

radiological effluent releases due to the Millstone operations." s;

MPS-82-65 To the contrary: the Coalition and others have presented overwhelming

and unrebutted evidence of a causal relationship between' increased

cancer incidence and Millstone operations.

33

July 2005 -'- A-407 NUREG-1437, Supplement 22
Appendix A

While these facts are "significant," they are not "new."

Since practically the onset of Millstone nuclear operations, Millstone's

radiological emissions have been linked to heightened cancer incidences."

This is hardly surprising.

Since the onset of its operations, Millstone's owners and operators

have submitted reports to the NRC and the DEP detailing their

radiological 4 2 and chemical43 effluent emissions to the air and water.

Millstone routinely releases to the air and water the following

radioactive materials:

Ag

Be-7

Ce-144

Co-57

Co-58

Co-60

Cr-51

Cs-1 34

Cs-1 37

Fe-55

Fe-59

1-131

1-133

Kr-85

Kr-88

La-140

Mn-54

Mo-99

Na-24

Nb-95

Nb-97

"See footnote 4 supra. '2 See the list of radionuclides listed at pages 34-35. 43 See the list of chemical effluent emissions listed at pages 36-40. 34

NUREG-1437, Supplement 22 A-408 July 2005

I
Appendix A

Ru-1 05

Sb-122

Sb-124 -

Sb-125

Sn-113

Sr-89 I

Sr-90 ;

Sr-92

TC-99M-'

TC-101

`TC-104

Tritium '

Xe-1 33

Xe-1 35

Zn-69M

Zr-95

Zr-9744

* -4.. - -

This list is not exhaustive. : ;*"'- - -

MPS-82-66 All radionuclides released by Millstone cause cancer.

According to the U.S. Environmental Protection Agency,

Radioactive materials that decay spontaneously produce

ionizing radiation. Any living tissue in the human body can be

damaged by Ionizing radiation. Cancer is considered by most

people the primary health effect from radiation exposure.

Simply put, cancer is the uncontrolled growth'of cells.

Ordinarily, natural processes control the rate at which cells grow

and replace themselves. They also control the body's processes

for repairing and replacing damages tissue. Damage occurring

at the cellular or molecular level can disrupt the control -

processes, permitting the uncontrolled growth of cells - cancer.

This is why ionizing radiation's ability to break chemical bonds

" Fission and Activation Products - Millstone Unit 2 Liquid Effluents - Batch Sampling -

1997 as reported in 1997 Radiological Environmental Monitoring Program. - -- - 4' See selected bibliography prepared by Nuclear Information Resource Service.

attached. .. -

35

July 2005 A-409 NUREG-1437, Supplement 22
Appendix A

MPS-82-66 in atoms and molecules makes it such a potent carcinogen....

There is no firm basis for setting a "safe" level of exposure

above background for stochastic effects [those resulting from

long-term, low-level exposure to radiation].... Other than

cancer, the most prominent long-term health effects [from

radiation exposure] are teratogenic [those that result from the

exposure of fetuses or unborn children to radiation] and genetic

[those that can be passed from parent to child] mutations.46

According to the U.S. Nuclear Regulatory Commission, genetic

effects and the development of cancer are the primary health

concerns attributed to radiation exposure.' 7

MPS-82-67 Many chemicals discharged by Millstone are known carcinogens,

such as hydrazine, hexavalent chromium, cadmium, lead and benzene

and many others.

Millstone routinely discharges into the nuclear/chemical "mixing

zone" which extends 8,000 feet toward the Niantic and Waterford

shorelines, the following chemicals and others:43

Chemicals & Metals "Known or Suspected Present" in Discharge

[156 compounds listedl

Aluminum

Antimony

Ammonia

Ammonium Hydroxide

Arsenic

Barium

Beryllium

Boric Acid

Boron

46 U.S. Environmental Protection Agency website. 'Understanding Radiation: Health

Effects' (3116(05) 4 U.S. Nuclear Regulatory Commission website, 'Fact Sheet: Biological Effects of

Radiation. (3/26105)

'5 Millstone 1997 Radiological Environmental Monitoring Program Report and

documents filed with Connecticut DEP.

36

NUREG-1437, Supplement 22 A-41 0 July 2005
Appendix A

Bromide

Bulab 6002

Cadmium

Carbohydrazide

Chlorine

Chromium

Cobalt

Conquor 3585 (methoxypropylamine and diethylhydroxylamine)

Copper

Cyanide

Dietylhydroxylamine

Epichlorohydrin

Ethanolomine

Fluoride

Freon

Hexavalent Chromium

Hydrazine - i .

Hydrogen Peroxide

Iron

Methoxypropylamine

Molybdate

Molybdenum

Nalcolyte

Nickel

Nitrogen

Oil & Grease

Phosphorus

Selenium . . - -

Silver

Styrene

Sulfate

Sulfide

Sulfite

Surfactants

Thallium - ,. - -

Ti n

Titanium .

Tolyltriazole

Xylene

37.

A-411 - NUREG-1437. Supplement 22 July 2005
Appendix A

Zinc

Zirconium

Volatiles

Acrolein

Acrylonitrile

Benzene

Bromoform

Carbon Tetrachloride

Chlorobenzene

Chlorodibromomethane

Chloroethane

2-Chloroethylvinyl Ether

Chloroform

Dichlorobromomethane

1, 1-Dichloroethane

1, 2-Dichloroethane

1, 1-Dichloroethylene

1, 2-Dichloropropane

1, 3-Dichloropropylene

Ethylbenzene

Methylbromide

Methylchloride

Methylene Chloride

1, 1, 2, 2, -Tetrachloroethane

Tetrachloroethylene

Toluene

1, 2-Trans-Dichloroethylene

1, 1, 1-Trichloroethane

1, 1, 2-Trichloroethane

Trichloroethylene

Vinyl Chloride

GCUMS Fraction Acid ComDounds

2-Chlorophenol

2, 4-Dichlorophenol

2, 4-Dimethylphenol

4, 6-Dinitro-O-Cresol

2, 4-Dinitrophenol

NUREG-1437, Supplement 22 A-412 July 2005
Appendix A

2-Nitrophenol

4-Nitrophenol

P-Chloro-M-Cresol

Pentachlorophenol

Phenol

2, 4, 6-Trichlorophenol

Base Neutral Compounds

Acenaothylene

Benzidine

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(ghi)perylene

Benzo(k)fluoranthene

Bis(2-Chloroethyl) Ether

Bis(2-Ethylhexyl)phthalate

Chrysene

Dibenzo(ah)anthracene

1 ,2-Dichlorobenzene

1 .3-Dichlorobenzene

1 .4-Dichlorobenzene

3.3-Dichlorobenzidines

Diethyl phthalate

Dimethyl phthalate

Di-n-butyl phthalate

2,4-Dinitrotoulene

1 ,2-Diphenylhydrazine

Fluoranthene

Fluorene

Hexachlorobenzene

Hexachlorocyclopentadiene

Hexachloroethane

Indenoll ,2,3-ed)pyrene

Isophorone;

Nurobenzene

N-Nitrosodimethylamine

N-Nitrosodiphenylamine

Phenanthrene

Pyrene

V

. --. 4 .  - - - I - .. i . ... . . ,, -

- -:, , , 17: -; : ", , , z ,

39

July 2005 A-ii'3 - NUREG-1437, Supplement 22
Appendix A

Pesticides

Aldrin

Chlordane

DDT

DOE

Dieldrin

Endosulfan(alpha)

Endosulfan (beta)

Endosulfan Sulfae

Endrin

Endrin Aldehyde

Heptachlor

Heotachlor epoxide

Arochlor 1016(PCB)

Arochlor 1232(PCB)

Arochlor 1242(PCB)

Arochlor 1248 (PCB)

Arochlor 1254 (PCB)

Arochlor 1260 (PCB)

Toxaphene

Other Substances

Ammonia

Benzo(b)fluoranthene

Chlorine

Hexachlorocyclohexane (Alpha)

Hexachlorocyclohexane (Beta)

Hexachlorocyclohexane (Gamma)

2,3,7,8-TCDD

MPS_82-68 The interaction of radionuclides and chemicals has been

established to create a synergy, multiplying the harmful effects of

each.49

49 See Memorandum of Ernest J. Stemglass. Ph.D. dated March 8. 2005 ('Synergistic

Interaction of radiation. Air Pollution and Chemicals') and references therein (copy

40

NUREG-1437, Supplement 22 A-41 4 July 2005
Appendix'A

MPS-82-69 Millstone discharges these radionuclides and chemicals - and

more - into the air and into the nuclear/chemical "mixing zone"

known as Niantic Bay, Pleasure Beach and Jordan Cove, defined as

an area within 8,000 feet of the Millstone discharge point.

Some of the radionuclides, such as ceslumr-137, have' been' found

In fish swimminrg in Niantic Bay.50

Some of the radionuclides, such as cobalt-60, have been found in

the sediment of Jordan Cove where they enter the food chain when

they are ingested by worms.61

Some of the radionuclides and toxic chemicals very likely entered

Zachary M. Hartley's mother while she was swimming in the,'.,:

nuclearlchemical"mixing zone" popularly. knwn as Hole-in-the-Wall

Beach during critical months of her pregnancy with Zichary,

according to an expert on the health effects of low-level ionizing

radiation, Dr. Helen Caldicott.52 Four pathways are possible:

breathing, swallowing, skin contact and eating a radioactive fish.

Zachary was b6rn with a rare cancer In his Jawbone requiring

lifesaving surgery.

In SEIS section 4.7, beginning on page 4-53, the NRC states, "During

scoping, some commentators suggested that operation of Millstone

resulted in excess cancers in populations around the plant site," and "other

support of these positions at the May 2004 public meeting or thereafter

commentators suggested there is no relationship between cancer incidence

and nuclear power plants."-. ;,

MPS-82-70 Millstone's cumulative dose to the environment and humans, based on

annual Millstone reports filed with the NRC since 1970, totals over 6.5

curies. As reported in the response to section 2.2.7, releases of tritium into

attached). And see Health Effects of selected Industrial Chernicals and Radionuclides'

(STAND Technical Report 2003-2) at page 5 (copy attached).

See 1997 Annual Radiological Environmental Operating Report at page 4-5.

sI See [citation to follow] *, *

2 See footnote 14 supra. 41

July 2005 A-415 NUREG-1437, Supplement 22
Appendix A

MPS-82-70 Long Island Sound since Millstone's restart in 1998 are at all time highs in

its operating history.

Current annual plant reports indicate that Millstone Units 2 and 3, as in

the years since 1970, have been releasing radionuclides such as strontium90, cesium-137, iodine-131, -133 and -135, cobalt -58 and -60, krypton-85,

xenon-131, -133 and -135. and other such radioactive chemicals, all known

to be carcinogenic.

The NRC's denial of a causal relationship between Millstone's 35 years

of radioactive releases and elevated cancer rates in nearby towns, and in.

New London County as a whole, does not hold up to scrutiny.

The most glaring example of the NRC's denial in the- Millstone SEIS is

its complete omission of consideration of the August 17, 2004'declaration

of Dr. Ernest J. Sternglass. The Millstone SEIS lists, on' page C-9, Dr.'

Stemglass' declaration as received on August 17, 2004. This is the only

mention of it in the SEIS.

Consequently, the declaration was omitted from the NRC's evaluation of

potential new and significant information in section 4.7.

In his declaration, Dr. Sternglass presents his credentials as an expert

in the field of radiation and human health. He has written and published

numerous studies in this field in peer reviewed scientificJojurnals and

testified to Congress and other government agencies on this subject.

The NRC knows full well who Dr. Stemglass is. He first brought up the

problem of radioactive releases in relation to increasing cancer rates

around nuclear plants, and in towns near Millstone in particular, to the

public eye in the 1970s. He has conducted and published studies informing

the public of this continuing problem ever since.-

In his declaration, Dr. Sternglass methodically outlines the "causal

relationship between abnormally high doses of strontium-90 in milk

produced near Millstone and the pattern of cancer changes at various

distances from the Millstone plant.

MPS-82-71 Dr. Sternglass also states in his declaration, "It is my professional

opinion that the radioactive releases from the Millstone Nuclear Power

42

NUREG-1437, Supplement 22 A-416 July 2005,
Appendix A

MPS-82-71 Station since its startup have caused and will continue to cause

[emphasis added] excess infant mortality, low birthweight, leukemia and

cancer as well as increased rates of both chronic and infectious diseases in

the towns around Millstone as well as in New London County and

Connecticut as a whole."

For the NRC to exclude Dr. Stemglass' declaration from section 47 is'a

glaring major error in that in and of itself invalidates the NRC's conclusion

that "information provided during the scoping process was not new and

significant with respect to the findings of the GEIS on the health effects to

the public from radiological effluent releases due to the Millstone

operations."

This statement rather is indicative of the NRC's determination to support

the nuclear industry's-and in this case Dominion's-rush to relicense old

unsafe nuclear plants, to the detriment of the public'sihealth and safety.

This bias is repeated in statements and omission throughout section 4.7, as

the following will demonstrate.

MPS-82-72 For example, in dealing with the Connecticut Tumor Registry's report.,

Cancer Incidence in Connecticut Counties 1995-99," the NRC does report

that New London County "had the highest incidence rate of all invasive

tumors for females," but omits that this rate was second highest for males,

as was reported at the May 2004 public meeting. .;

Furthermore, the NRC characterizes information in the report indicating

that New London County had the highest rate for 12,specific kinds of

cancers as "several forms," a choice of words that seeks to minimize a

major health crisis.

The NRC also fails to mention information from the report, which was

testified to at the May 2004 public meeting, that New London County had

the second highest rate for six more kinds of cancer, third highest for five

additional ones, and fourth highest for seven more, totally 30 out of 39

kinds of cancers in which New London County was counted separately.

All of the above reveals a deliberate and systematic attempt to exclude

the most important "new and significant" information about Millstone -

radioactive releases and its effects on human health;. ,

:'- : : i.

43

July 2005 A-417- NUREG-1437, Supplement 22
Appendix A

MPS-82-73 Similarly, in dealing with a 2003 study by Joseph Mangano et at,

presented at the May 2004 public meeting, "Elevated Childhood Cancer

Incidence Proximate to U.S. Nuclear Power Plants," the SEIS selectively

focuses on information from the study that indicates there may not be a

causal relationship between Millstone's radioactive releases and health

problems. So the NRC states the study "reported no significant difference

in childhood cancer mortality rates between counties surrounding the

nuclear plants and the U.S. population.'

This would be fine and fair if the agency did not also exclude the major

finding of the study, which is that "cancer incidence for children less than

10 years of age, who live within 30 miles of each of 14 plants [one of which

is Millstonel in the eastern U.S. (49 counties with a population of more than

16 million) exceeds the national average. The excess 12.4% suggests that

1 in 9 cancers among children who reside near nuclear reactors is linked to

radioactive emissions."

Once again, this omission is deliberate and systematic, serving the

nuclear industry's interests to the detriment of the public's health and

safety.

MPS-82-74 The NRC also failed to mention numerous other studies listed in the

bibliography of study that have linked radioactive releases from nuclear

facilities to elevated cancers.

MPS-82-75 Another example of this exclusion of new and significant information is

the NRC's treatment of the 1990 National Cancer Institute study of cancer

in counties near nuclear power plants.

That study found that the risk for leukemia in children under 10 in New

London County was over 3 times higher than for same aged children in

"control counties" used for comparison. The NRC focused'on NRC

information that sought to downplay of that finding.

MPS-82-76 However, the NRC excluded other NCI information cited by Joseph

Mangano in his report, also presented and testified to at the May 2004

public meeting, entitled "2500 Excess Cancer Cases in New London -

County Since 1970; Radioactive Emissions From Millstone May Be Cause."

In that report Mangano stated, "in Millstone's first 14 years, leukemia cases

44

NUREG-1437, Supplement 22 A-418 July 2005

I
Appendix A

MPS-82-76 for New London County children under 10 were 55% higher than the state,

and leukemia deaths 45% higher. All scientists agree that children are

most sensitive to low-level radiation's effects." -

Once again, the NRC's failure to give equal weight to critical evidence

invalidates its analysis and makes its conclusions false, as well as

disqualifying Itself as a Just arbiter. - -

Another example Is its treatment of another Connecticut Tumor Registry

report, which examines cancer incidence in Connecticut towns 1995-99,

rather than by county. -

First of all, this report was not brought in by the public during the

scoping process. The NRC decided to do so on its own as part of its

response to information presented at the May 2004'public meeting and

thereafter. Why? The NRC reported on the results of the study for only one

town,'Waterford, site of Millstone. The NRC reported "The town of

Waterford does not have the highest ratio of observed cancers to expected

cancers for any form of cancer analyzed."

MPS 82-77 As the NRC well knows, there is no barrier to prevent Millstone

radioactive emissions from traveling beyond the boundaries of the town of

Waterford. A more comprehensive such analysis would have Included other

towns near Millstone. But the NRC didn't do that, once again excluding

critical information.

However, investigative journalist and author Michael Steinberg of

Niantic, CT, did perform such'an analysis, including the town's of Waterford,

East Lyme, Old Lyme, New London and Groton together. Steinberg's

analysis, included herein, found higher than expected incidence of cancer

in these towns together for: all female cancers, lung crancer for females,

colorectal cancers for females, prostate cancer for males, breast cancer-for.

females, melanoma for both males and females, and cervical cancer for

females..3

These findings are consistent with findings presented from the

Connecticut Tumor Registry's study of Connecticut Counties 1995-99, as

, See Cancer Incidences in Connecticut Towns 1995-1999.".as compiled by Michael

Steinberg, attached.. -,*

45

July 2005 A-419 NUREG-1437, Supplement 22 '
Appendix A

MPS-82-77 well as Information presented in Mangano's 1998 study "2500 Excess

Cancer Cases...", Stemglass' declaration, and a new study by Mangano

presented at the January 11, 2005 meeting.

MPS-82-78 Finally, the NRC reports in section 4.7 that a 2000 study by the

Connecticut Academy of Science and Engineering (CASE) found that 'The

town of Waterford was not in the highest ratio category for any cancer

except thyroid cancer, and at least three other town had higher ratios for

thyroid cancer. At least 30 town had higher ratios for pediatric leukemia

(ages 0 to 14) than Waterford."

First of all, this analysis, as reported above, is defective by limiting it to

Waterford. Secondly, the CASE study focused on the Connecticut Yankee

Nuclear Plant, and Millstone is never mentioned in it. Therefore radioactive

emissions from Millstone are not considered in its analysis. Furthermore,

information for cancer is not reported statistically by town, other than in

maps where towns are not identified specifically but are marked by varying

shades of white to black.

Nevertheless, the maps do indicate elevated cancers in towns around

Millstone for all the specific kinds of cancers studied: thyroid cancer is

elevated not only in Waterford, but also in Groton, Old Lyme and

Stonington. Multiple myeloma is elevated for Waterford. And acute adult

leukemia is elevated for Groton and Ledyard, both downwind of Millstone.

However, while the CASE study uses information from the Connecticut

Tumor Registry for 1976-95, i does not look for trends over those years

(e.g. by comparing cancer rate increases or decreases over 5 year periods,

as was done in studies by Sternglass and Mangano).

The CASE study was initiated in 1997. At that time, all three Millstone

reactors had been shut down for two years because of gross

mismanagement and harassment of whistleblowers. At that time Northeast

Utilities owned and operated Millstone, and still owned the permanently

shut down Connecticut Yankee Nuclear Plant. CASE reports that Northeast

Utilities was one of its top financial supporters at that time, and its website

still shows NU at the top of its list of financial supporters.54

54 We attach a study critical of the CASE report, entitled 'Epidemiological Evaluation of

the CASE Report Entitled 'Study of Radiation Exposure from the Connecticut Yankee

Nuclear Power Plant'(Suzanne Gutter and Edwin van Wijngarden)(February 21, 2001)

46

NUREG-1437, Supplement 22 A-420 July 2005
Appendix A

Thus NU in effect was a major funder of the CASEstudy, which means

CASE had a major conflict of interest, 'one that put pressure on it to come

up with results that would please the hand that feeds it.

MPS-82-79 All the above'points to the failure of the NRC to conduct alfair and

unbiased analysis of the critical information given as-public testimony at the

May 2004 pubic meeting in Waterford, Connecticut, and in documents

presented there and thereafter to the NRC.

As a result the NRC's conclusion that there Is'not new and significant

information is fatally flawed. The agency excluded and downplayed the

critical Information that was presented, information that establishes a strong

and clear relationship between Millstone's 35 years of radioactive

emissions and the concurrent rise of cancers and other diseases in towns

around Millstone and in New'London County; as well~as across Connecticut

and into Rhode Island. C a w E s ao Conectcu

MPS-82-80 While the Connecticut Tumor Registry is a source of much information

about the heightened incidence of cancer and related diseases in'the area

surrounding Millstone, it is not a completely reliable source of information.

Zachary M. Hartley is not the only victim of Millstone's radiological and

toxic chemical releases. In any individual cancer case,'a'100 per cent

positive correlation with a suspected causative agent cannot be made. That

is why we rely on all available Information obtained formally such as the.

Connecticut Tumor Registry and epidemiological research - as well as

informally,'through reports of victims themselves or their family members to'

understand the scope of this public health emergency.

Although Zachary was bom in Connecticut with a life-threatening cancer

in his jaw and although a tumor the size of an orange was removed from

his face when he was 14 months of age, the Connecticut Tumor Registrydoes not list Zachary's cancer. The Registry's explanation is that a portion

of Zachary's tumor was benign and therefore it does not qualify for listing in

the Connecticut Tumor Registry. - --

MPS-82-81 The NRC SEIS staff relies on a report of the National Cancer Institute

(NCI 1990), which in turn relies on data of the Connecticut Tumor Registry.

47

July 2005 A-421 NUREG-1 437, Supplement 22 -
Appendix A

MPS-82-81 According to the Connecticut Tumor Registry website, it obtains its funding

from the National Cancer Institute.55 The NCI report is fifteen (15) years

old. The NCI report was released four (4) years after Millstone Unit 3

commenced generating nuclear energy and long before many cancers

associated with its dangerous emissions might be detected. It does not

reflect the extremely high concentrations of strontium-90, a carcinogen,

found in goat milk sampled within five miles of Millstone in 2001. It does not

report the case of Zachary M. Hartley. It does not report the case of Rachel

Heaton. who developed a rare form of thyroid cancer years after swimming

in the Niantic shoreline 'mixing zone' because she moved from the area.

Nor does it report the brain tumor of Charles D. Douton, Jr., one of three

former Millstone site maintenance workers who developed brain tumors

and were dismissed from their jobs at Millstone by Northeast Utilities, as

identified by Cynthia M. Besade in her August 5, 2004 affidaviL The NCI

report does not include any of the seven (7) cancer cases recently

identified to the NRC SEIS staff among residents or former residents of a

single road - Seabreeze Drive - in Waterford two miles downwind from

Millstone. The Connecticut Coalition Against Millstone is actively

investigating to determine to what extent the Connecticut Tumor Registry

fails to maintain records of other Millstone victims.

The Connecticut Coalition Against Millstone is also actively investigating

information it has received of rare cancers Including a fatal skin cancer

confined to the feet of a woman who frequently waded for long periods in

the nucleartchemical mixing zone" to the east of the Millstone discharge

point - In the community surrounding Millstone. The information under

review includes dozens of cases of early childhood death and disease.

MPS-82-82 The Coalition attaches a selected Bibliography compiled by the Nuclear

Information Resource Service ("NIRS") linking nuclear power plant

radiological emissions with cancers in their communities. For example,

NIRS reports a 400 per cent Increase in leukemia incidence in the

population living downwind from the Pilgrim (MA) Nuclear Power Plant

during the first five years after nuclear fuel was known to have leaked

excess radioactivity. A necessary review of Millstone records will reveal the

occurrence of leaking fuel at Unit 2 after Dominion assumed ownership.

55 See www.dph.state.ct.usIOPPE/hptumor.htm4J

NUREG-1437, Supplement 22 A-422 July 2005

I
Appendix A

MPS-82-83 The Coalition notes that the European Committee on Radiation Risk

("ECRR') has'reported that radiation dose models employed by the NRC

and other governmental agencies are probably 100 to 1,000 times too high

to be accurate.56

The NRC SEIS staff had to be reminded at the NRC's January 11, 2005

public meeting on the SEIS that the Coalition and others had previously

submitted documentation to the NRC establishing a causative link between

Millstone' radiological and toxic effluent emissions and the heightened

cancer rates In the area surrounding Millstone.', -.- -

The NRC SEIS staff did not adhere to the NRC's Principles of Good

Regulation, which require in part:

Independence: Nothing but the highest possible standards of ethical

performance and professionalism should influence regulation.

However, independence does not imply isolation. All available facts

and opinions must be sought openly from licensees and other

interested members of the public;.The many and possibly conflicting

- public interests involved must be considered.-

The SEIS states that the NRC staff

and Its contractors discussed Millstone's history of radiological

effluent and environmental monitoring with officials from CTDEP's

-Division of Radiation. The reports cited above by CTDPH, CASE and

the national Cancer Institute were-also discussed. CTDEP conducts

-its - own radiological environmental monitoring program around

Millstone. STDEP had also reviewed the reports by CTDPH, CASE

and the National Cancer Institute. CTDEP concluded that Millstone's

radiological effluent and environmental monitoring data were

accurate. 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."

________________________________- - . S - * . a, ,. @ . .. _ . :

5 See 'ECRR Report Challenges Entrenches Radiation Assumptions' (MIRS, February

21,2003)

49

July2005 A-423 NUREG-1 437, Supplement 22
Appendix A

The Connecticut Coalition Against Millstone has sent correspondence to

Dr. Edward C. Wilds, Director of the DEP Radiation Bureau, to determine

what conversations occurred with the SEIS staff, whether the DEP staff

agrees with the characterizations of its conduct and input in the SEIS.

Finally, the Coalition asked Dr. Wilds if he agreed with the SEIS statement

that CTDEP concluded that Millstone's radiological effluent and

environmental monitoring data were accurate.' and if so, to specify what

radiological effluent and environmental monitoring data were referenced

and, further, if so, how such statement could be reconciled with Northeast

Utilities' plea of guilty in 1999 in the U.S. District Court to committing

environmental felonies, including falsifying environmental monitoring

records.

To date, Dr. Wilds has failed to respond to the Coalition's request.

4.8.3.Cumulative Radiological Impacts

The GEIS did not perform a meaningful analysis of cumulative

radiological impacts because its data base was limited to Millstone effluent

discharges from 1985-1987.

The GEIS further states:

In addition, the radiological environmental monitoring program

conducted by Dominion in the vicinity of Millstone measures radiation

and radioactive material from all sources, including Millstone;

therefore, the monitoring program measures cumulative radiological

impacts.

The Health Physics Society defines cumulative dose as follows:

The total dose resulting from repeated exposures of ionizing radiation

to the same portion of the body, or to the whole body, over a period of

time.

MPS-82-84 Correspondingly, the SEIS failed to conduct the analysis required by

virtue of GEIS 4.6.1.1, which provides:

co

NUREG-1437, Supplement 22 A-424 July 2005
Appendix A

MPS-82-84 To determine whether the added period of operation following license

renewal would, by virtue of buildup, result in significant (double)

added dose, the ratios of buildup factors for midlives of 30 to midlives

of 20 years were evaluated. These ratios amount to a 35 per cent

increase for Cesium-137 and a 6 per cent increase for cobalt-60.-

This added increase due to buildup will not significantly change the

total dose to members of the public. -

In certain cases', the bioaccumulation factors may require

reexamination. These principally involve fish (in the human food

chain) that are bottom feeders. Botorn feeders may ingest worms

and other bioia that may remobilize radioactive'materials

accumulated in the sediments.

Accumulation of radioactive materials in the environment is of

concern not only to license renewal but also to operation under

present licenses.

Accordingly, the SEIS is substantially flawed on the issue of cumulative

radiological impacts. - ; ;

51

July 2005 A-425 NUREG-1437, Supplement 22
Appendix A

Conclusion

It has been demonstrated herein that the adverse environmental

impacts of Millstone license renewal are so great that preserving the option

of license renewal for energy planning decisionmakers would be

unreasonable. The NRC should reach such a conclusion in its final

Environmental Impact Statement.

In the alternative, the NRC should recognize that its staff has failed to

consider the full scope of the environmental impacts of present or future

Millstone operations, and similarly, the licensee has failed to fully apprise

the NRC of all pertinent facts and circumstances sufficient to enable the

NRC to undertake meaningful review; in the absence of such complete

evaluation the NRC must deny relicensing.

CONNECTICUT COALITION

AGAINST MILLSTONE

Nancy Burton

147 Cross Highway

Redding Ridge CT 06876

Tel. 203-938-3952

52

NUREG-1437, Supplement 22 A-426 July 2005
Appendix A

Memo to: Nancy Burton, Esq.

From: E. J. Stemglass C

Date: March 8, 2005 - ;.

Subject: Synergistic interaction of radiation, air pollutants and chemicals

The synergistic or "super-additivc" action of radioactivity and chemicals or air pollutants

has been discussed extensively in the scientific literature. A very comprehensive revicw

of the subject wvas published in a monograph by Wriedt in the Department of Labor and

Health of the City of Hamburg, Germany in 1989 (1). Particularly strong-syncrgistic - -

effects have been found for radiation exposure combined with such chemicals as lead,

mercury, magnesium, sulfate and carbon-tetrachloride known or suspected to be emitted

by the Millstone Nuclear Plant together with fission products and neutron'-activated

radioactive elements - --

Also, an unexpected super-additive effect was discovered for the action of tranquilizers

taken by a woman during pregnancy with radiation exposure in the cancer mortality of

her children (2).'

The synergistic action of smoke particles and radioactive gases and particulates, such as

exist in uranium mines and in heavily polluted urban areas near nuclear plants, was

discussed in an article by Radford and Hunt as long ago as 1963 (3)

The increase in cancer rates due to the combination of small airborne particles such as

cigarette smoke and iadioactive gases was studied by a series of authors beginning as

early as 1938 (4)(5)(6). This explains the extremely high incidence of lung cancer in

uranium miners who smoked.In the particular case of radioactive gases such as Radon

and other radioactive gases such as Xenon and Krypton isotopes that are routinely

emitted in large quantities by nuclear. plants. Thus, Cassarett pointed out in his

introductory article in "Radionuclide Carcinogenesise in 1972 (7) that the lung is highly

vulnerable to the potential cancer promoting action of localized damage resulting from

infections and inflammatory conditions caused by other air pollutants."

Increased risk of infections is known to be produced by the fission product Strontium-90

emitted from nuclear plants due to its action on the cells of the immune system produced

in the bone marrow, and so are inflamnatory conditions produced by'abnormal wvhite

cells mutated by the beta particles emitted by Strontium-90 and other bone-seecing

fission products such as Barium-140 Moreover, Yttnrium-90; the highly radioactive

daughter product of Strontium-90, is known to seek out soft tissues like the lung, causing

inflammation and cancer. This is strongly supported by the fact reported by the U.S.-

Department of Health and Human Services in the report "Health in the United States

1994 and 1996" that the age-adjusted respiratory cancer mortality of white U.S. females

over 16 years of age began to rise only after 1960, increasing more than five-fold from 5

to 28 per hundred thousand by 1995, while the percent smoking actually declined from

35 to 23% (See enclosed graph).

;, , . =.,; :: 7-:

July'2005- A-427 NUREG-1437, Supplement 22 -
Appendix A

Not only cancer but also infant mortality, first linked to Strontium-90 releases in nuclear

weapons testing (8). can be increased by the synergistic interaction with fine particulates

in the urban atmosphere (9). Thus, the 2002 rise in infant mortality (10) which was the

first increase since 1958 following the largest atmospheric tests in Nevada in 1957, wvas

probably due to the combination of urban Diesel exhaust and nuclear fission product

releases that increased in direct relation to the record rise in nuclear energy generated per

reactor as capacity factors were pushed from 58 to over 90% (11) with decreased time

for inspection, maintenance and repair of aging nuclear power plants.

Still another way in which the airborne releases from nuclear power plants produce

unforeseen biological damage to humnans as well as to animals and plants arises from the

interaction of the radioactive rare gases Krypton-85 and Xenon-133 that cannot be readily

filtered out of the effluent with the nitrogen and oxygen molecules in clean air. This has

been described in detail by Graeub (12), who reviewed the evidence that the radiation

emitted by these gases ionizes the air just as ultraviolet radiation from the Sun does,

resulting in the formation of toxic ozone and nitric oxides. The ozone in turn interacts

with the chemicals emitted in automobile exhaust, producing smog that damages the

lung, and contributes to the dying of the trees seen downwind from nuclear plants.

Furthermore, when the nitric oxides are brought down by precipitation, they act like

fertilizer run-off that is carried by the rivers into the estuaries where they lead to

blooming plankton that produce dead-zones depleted in oxygen where marine animals

live, leading to declines in shrimp and other fisheries as recently seen especially in the

Gulf of Mexico.

Thus, not only human life but marine life and the life of birds, land animals and plants is

adversely affected not only by the direct effect of fission and neutron-activated

radioactive chemicals released from nuclear plants, but also by the indirect effects

involving clean air as well as chemical and particulate pollutants..

REFERENCES

(1) H. Wriedt, Department of Labor, Health and Social Services, Hamburger Strasse

47. 2000 Hamburg 76, Germany, December 1989.

(2) L. AN. Kinnier-Wilson, G. W. Kneal and A. M. Stewart, Lancet I 1 .314-315

(1981)

(3) E. P. Radford and V. R. Hunt. Science 143, January 12,. 247-249. (1964)

(4) J. C. Mottram, Am. J. Cancer 32, 76 (1938)

(5) P. Shubik et al, Nature,171, 934 (l953)

(6) F. G. Bock and G. E. Moore J. Nat'l. Cancer Institute 22, 401 (1959)

NUREG-1437, Supplement 22 A-428 July 2005
Appendix A

(7) G. W. Cassarctt, Radionuclide Carcinogenesis C. L. Sanders et al Editors, U. S.

Atomic Energy Commission, Office of Inf. Services CONF-720505, 15-24, June

1973

(8) E, J. Sternglass, Radiation Biology of the Fetal ahd Juvenile Mammal, Edited by -- M. R. Sikow and D. D. Mahlum, U. S. Atomic Energy Commission, 693-717, December 1969.

(9) T. J. Woodruff, J. Grillo and K. C. Schoendorf, Environmental Health

Perspectives 105, 608-612 (1997)

(10) Health United States 2004, Table 19, Center for Disease Control, Dep't of Health

and Human Services. .

(I 1) Nuclear Regulatory Commission (NRC) Information Digest 2000 Edition, NUREG 1350, Vol. 12.

(1 2) R. Gracub, The Petkau Effect: Nuclear Radiation, People and Trees. Four 'Walls

Eight WUindows, New York (1992).

Ernest J. Sternglass, Ph.D.

Professor Eineritus of~adiology

University of Pittsburgh School of Medicine

Home address:

4601 Fifth Ave. #824

Pittsburgh, PA 15213

J 2A-429 1UREG-1437, Suplement- 22

July 200
CD

z AGE-ADJUSY11 RUESPIRNA'ORY CANCER MORTALITrY m WHITEl U.S. ' FE-MALES OVER 18 YEARS AND PERCENT c)__SMOKING a

= >

c', 

PMCE?(SMOKING -

CD 30.0 -

30

SOUgCIs US. Dtrrnop JIm:nl AMD IJU^NA SWtVICsiv KII!A11ll UHNT1 SrfXl5 1994 AND 1996

0

0

0

0

' 20 .0t

L 

/

- . CANCIt e MM

E

1010 -

10

NULA YER ISL'0 ANDoG~tr LAST AT14t xrFHERIC ___OUN

0'60 YSAR '8D 90 01d , 

-. ._ .,, .. ......

. . .,- 

.
Appendix A

21 February 2003. WVISFPMRS Nudear MAonla. ,5239

ECRR REPORT CHALLENGES

ENTRENCHED RADIATION.-;

ASSUMPTIONS

A recently-released report claims that the radiation dose model of the International

Commission on Radiological Protection (ICRP) Is Inadequate for Internal

irradiation, and proposes a new model. The report made headlines with its

predictions of over 61 million deaths from cancer attributable to nuclear activities

since 1945.

(583.5493) NIRS - The European Committee on Radiation Risk (ECRR) Is an Independent committee

formed in 1997 after a meeting at the European Parilamnent to review the controversial issue of low-level

radiation. -

Shortly after it was set up. a meeting of the European Parliament's Scientific and Technological Options

Assessment unit (STOA) considered evidence that low-level exposure to man-made radiation caused ill

health and that models used by ICRP failed to predict these effects.

The ECRR was asked to come up with an altemative analysis.

The resulting report. 2003 Recommendations ofithe Europan Commiieeon Radiation Risk addresses not

only the science behind the low-dose debate, but also the ethical basis for allowable radiation exposures.

The Intellectual breadth and depth. and scientific Inclusiveness of this report are a refreshing change from*

current radiation establishment tctics.

If society is ever to have a proper debate on the effects of low-doses and dose rates of ionizing radiation. it

must challenge the very basis of radiation dose and risk assessment. This report does.

For Its models. the ICRP uses ethlcaljustifications which are based on overall societal benefit rather thar.

individual benefit This does not account for rights-based philosophies which are pan of the UN declarato.n

of human rights. Since any dose of radiation has a small probability of fatal harm. the ECRR argues. the

.celective dose' should be employed for all practices and tirne scales dealing with axoidable radiation

exposure.

Among Inadequacies In the ICRP risk model. the ICRP makes assumptions that are Lased on a series of

value judgments. Often the risk model rnus counter to actual and epidemiological study results.

Additinally. population dose Is rot accurate for each Individual since It averages the effects of many

people who are genetically variable.

Current ICPP risk models do not differentiate enough between radiation delivered externally and that

delivered Internally: a difference the report likens to 'a man warming himself in front of a fire and a man

eating a red hot coal.'

Further. the ICR? risk model takes a high dose to a single cell and averages It over a larger tissue mass.

July 2005 A-431 - NUREG-1437, Supplement 22
Appendix A

The ECRR accepts the ICRP s linear no threshold model for external Irradiation. I lowever. because of

the complex mechanism of cells. the ECRR says that the current linear damage model is not suitable for

internal irradiation. The linear model must. according to the corrmmittee. be superseded in favor of

relationships that show much higher effects al low doses.

To help correct for these shortcomings. ECRR has developed mathematical terms that extend the

risk model of the ICRP. Thev Include two new weighting factors in the calculation of effective dose (for

intemal exposures) which address ionization density In time and space at the cellular level. Ionization

densities vary by radiation type (alpha. beta or gamma).

The committee also makes weighting adjustments for certain types of radionucildes which undergo

damaging transmutation: and they make enhancement weightings based on biological and biophysical

aspects of certain exposures.

ECRR derives these weighting factors from studies showing harm from low-dose exposures.

The committee recommends:

-the total maximum permissible dose to members of the public from all human nuclear practices be not

more than 0. ImSv and 5rnSv for workers

- all new nuclear practices mnust be justified by considering thie rights of all Individuals.

- total consequences of radioactive discharge rrust be assessed for both direct and Indirect effects

on all living systems.

- radiation exposures must be kept as low as reasonably achievabieusing best available technology.

For more information, visit the committee website at www.euradcom.org.

Source and contact: Cindy Folkers at NIRS (cindyf@'nlrs org)

NUREG-1437, Supplement 22 A-432 July 2005
Appendix A

J

Cancer Incidences in Connecticut Towns 1995-1999

.Source: Connecticut Tumor Registry , c

All Sites - Female

Town Cancers

East Lyme ': 251

Groton 475

New London 365

Old Lyme 134

Waterford ' 320

TOTAL 1,545

Expected - -

239.04

469.02

302.10

114.58

323.42

1,448.16

- SIR

;-- 1.05

1.05

1.21

1.17

.: ': .99

1.0-

;1.07

Town Cancers

East Lyme 222

Groton - . 448

New London 314

Old Lyme 143

Waterford 325

TOTAL 1,452

All Sites - Male

- : Expected

.- 253.68

- 468.98

-. 292.52

134.05

-. t 337.83

1, 1.

SIR

-. .88

+ . .96

1.07

F ,1.07

1. S 96

1,487.06 I'll. .98

Lung (Males)

Town . _ Cancers

East Lyme - 24

Groton . 69

New London - 54

Old Lyme -- -10

Waterford 46

- Expected

-- 38.59

. .69.92

- 43.70

. 20.88

52.39

. SIR

.r 62

.99

.1.24

. .48

.88

TOTAL

East Lyme

203

32

225.48

Lung (Females)

29.81

.90

1.07

July 2005 A-433 NUREG-1437, Supplement 22
Appendix A

Groton

New London

Old Lyme

Waterford

TOTAL

67

51

16

48

214

58.87

37.51

14.86

42.56

183.61

1.14

1.36

1.08

1.13

1.17

East Lyme

Groton

New London

Old Lyme

TOTAL

26

55

32

46

170

Colorectal (Males)

29.62

55.58

34.99

41.08

177.2

.88

.99

.91

1.12

.96

Colorectal (Female)

East Lyme

Groton

New London

Old Lyme

Waterford

TOTAL

East Lyme

Groton

New London

Old Lyme

Waterford

TOTAL

24

77

50

13

40

204

26.32

57.58

37.79

13.21

41.37

176.27

.91

1.34

1.32

.98

.97

1.16

Prostate

80

118

83

57

97

435

71.88

128.37

79.67

39.00

97.22

416.14

1.11

.92

1.04

1.46

1.00

1.05

I

i

II

i

Breast, Females

NUREG-1437, Supplement 22 A-434 July 2005
.Appendix A

East Lyme

Groton

New London

Old Lyme,

Waterford

TOTAL

78

139

103

53

78

451

77.33 1.01

143.17 .97

91.22 1.13

36.62 1.45

98.17 .79

446.51 1.01

Melanoma. Males

East Lyme

Groton

New London

Old Lyme

Waterford

TOTAL

15

33

10

13

12

83

11.63

21.42 - 13.33

5.79

14.53 -

1.29

1.54:

.75

2.25

-.84

66.53. 1.25

East Lyme

Groton

New London

Old Lyme

Waterford

TOTAL

Melanoma, Females

18

17

13

6

14

8.92

16.48

10.57

3.95

10.46

2.02

1.03

1.23

1.52

1.34

68 50.38 1.35

Uterine/Cervix

East Lyme 7

Groton 9

New London 9

Old Lyme 3

Waterford 6

- 4.72

8.52

5.44

1.98

5.10

,_-. I -

- -1.48

1.06

,',,r: 1.65

1.52

1.18

TOTAL 34 25.76 1.32

July 2005. A-435 r, NUREG-1437, Supplement 22
Appendix A

Health Effects

of Selected'Industrial Chemicals

and Radionuclides:

an introduction

STAND

Technical Report 2003 - 2

July 2003

NUREG-1437, Supplement 22 A-436 July 2005
Appendix A

STAND is a SOI (c)(3) nan-profit grassroots organization

dedicated to government

that is accountable toshe communft,

-to citizen responsibilityfor the welfare of our communities.

and

to aforwn for public debate in which to find solutions.

STAND's goal is L

the protection of humnan health and the long-term

preservation of the natural resources entnisted to our care.

Supported by a grant from the

Citizens'NMonitoring and Trchnical Assessment Fund.

July 2005 A-437:- NUREG-1 437, Supplement 22
Appendix A

Health Effects

of Selected Industrial Chemicals

and Radionuclides:

an introduction

by

Valerie Navab, M.S., Rachael Hawkins, M.S.

and Marvin Resnikoff Ph.D.

Radioactive wa2ste Management Associates

prepared for

ISTAND

July 2003

NUREG-1437, Supplement 22 A-438 July 2005
Appendix A

TABLE OF CONTENTS

inrduto . .................................... . i

Introduction .pagel1

Chlorinated Solvents ..... ...... .. page 6

High Explosives Compoundss.......... page II

Fuel Components and other Organic Chemicals .... page 14

Metals .-. .. . page 24

Pesticides ......... ; .;:_ page 32

Radionuclides . .p. .page 39

Appendix I - Abbreviations and Acronyms ...... pagc 42

Appendix 2- Glossary ........... - page 43

Appendix 3-Bibliography.-.. .... - -. page ; 44

July2005 - A-439 NUREG-1 437, Supplement 22
Appendix A

Introduction

he purpose of this report is to provide information about the health

hazards that exposures to industrial chernicals and radionuclides may

pose to the community. Sources of additional information are providcd in Appendix 3. In this way, the community might better understand the heath issues and hazards related to these chemicals and

contaminants.

Determining and classifying health hazards to humans exposed to

varying amounts of contaminants is difficult and subtle. The risks of

serious illness as a function of exposure is not the same for all compounds, and one should not be misled by the similarities of the health

effects due to the different toxic chemicals inventoried in this report.

The quantitative aspects of exposure are as important as the seriousncss of the health consequences. Indeed, the geographical spread of

the containuants and their temporal evolutions would also varty leading us to nantrafly consider the seriousness of contamination as a

function of quantity, consequences. and also temporal evolution.

Therefore, the notion of "acceptable' risk levels for a site goes much

further than just establishing a list of contaminants and their legal

dose limits.

Some of the reasons that make the understanding or 'acceptable'

exposure more subtle than it firt appears are provided below.

Regulating Agencies and Guidelines

The federal government is charged with developing regulations and

recommendations to protect public health. These regulations can be

enforced by law.

Federal agencies that develop regulations for toxic substances include

the Environmental Protection Agency (EPA), the Occupational Safcty

and Health Administration (OSHA), and the Food and Drug Administration (FDA). Recommendations provide valuable guidelines to

protect public health but cannot be enforced by law. Federal orpanizations that develop recommendations for toxic substances include

the Agency for Toxic Substances and Disease Registry (ATSDR) and

the National Institute for Occupational Safety and Health (NIOSH).

It is important to remember in this regard that as far as radioactive

materials are concerned, the Department of Energy (DOE) regulates

NUREG-1437, Supplement 22 A-440 July 2005
Appendix A

its own facilides. Through its contractors, DOE also operates these

facilities. DOE funds health studies that determine the hazard of

radioactive materials.

National Primary Drinking WaterRegulations are determined by the

EPA for certain toxic and radioactive chemicals. These regulations.

known as the Maximum Contaminant Level (MCL), are legally enforceable in the United States. These legal standards set limits to the

amount of contaminadon in the public drinking water supply.

-.Many other agencies study the effects and patterns of some toxic

materials. such as the World Health Organization (WHO). the International Agency for Research on Cancer (IARC). and the United States

.Decpartent of Health and Human Senvices (US DHHS).These orga-

-z- . uzations recomrmend limits on the coccentradons, or amounts, of

contamination to be allowed in drinking water.

In this report. many of the chemicals discussed do not have assigned

-MCLs. In these cases, add itional guidelines are provided. The Amenriean Conference of Governmental Industrial Hygienists (ACGIH) has

set Threshold Limit Values (ACGIH TLV); tiese values are time-

- weighted avnrages to which a worker can be exposed in a normal 8-

hour day, 40-hour workweek without any effect on hunan health.

The NIOSH has determined Recommended Exposure LiUmits (REL)

which are guidelines based on risk evaluations using human hcalth

- effects for levels feasibly achieved and measured by engincering controls. However, these two guidelines are difficult to compare. In ad-

- dition, the WHO has set its own recommended levels for contaninants allowed In drinking water.

Standards

Reguladons ad recommendations can be expressed in !not-to-exeed" levelsinairwatersoil,orfoodthatareusuallybasedonlevels

that affect animals, then adjusted toprotectpeople. Sometimes thesc

not-to-exceed' levels differ among federal organizations because of

different exposure times (an 8-hour workday or a 24-hour day). the

use of different animal studies, or other factors. Recommendations

and regulations are also periodically updated and change as mnore

information becomes available. Unfortunately, the number of new

chemicals introduced into the workplace each year numbers in the

hundreds or thousands. completely over-whelming thc ability or fcdcal agencies to determine thc hazards of each. -

.2

July 2005. A-441 . NUREG-1 437, Supplement 22.
Appendix A

So. it is not uncommon that different studies reach different conclusions about which contaminants are most prevalent or of highest pri- ority. Similarly. die Hazard Rating (HR) assigned to each material in

the form of a number (1, 2. and 3) that briefly identifies the level of

toxicity or hazard varies according to different agencies and organi.

zations.

Factors

Vhien a substance is released from a large area, such as an industrial

plant, or a container, such as a drum or bottle, it enters the environ.

ment. This release does not always lead to exposure. One can be

exposed to a substance only when in contact with it by breathing. eating, touching, or drinking. The consequences may vary in each case.

When exposed to a chemical, many factors determine whether a per- son would likely be harmed or n. These facton include the dose

(how much), the duration (how long), the form (which chemical com- pound). and the way the contact occus Other important parameters could be the presence of otberchemicals that enhance ordiminish the

toxicity, and the age, sex diet, family traits, lifestyle. and state of

health of the person. Therefore. classifying the health hazards to

humans becomes difficult and research-intensive. VaWng test environments and procedures will alterresulu in the patient Also. health

effects for the majority of these chemicals are better known for animals than humans. The same effects seen in animals may also be seen in humans to some extent However, humans do not react in the same way when exposed to the same chemicals and, therefore, more research is needed to determine the full extent of harn to human health.

In addition, medical tests on individuals todetect and evaluate expo. sures to a chemical may have used * arious techniques' and resulted

in contradictory results. Measurements in the blood, feces, or urine can determine if one has been exposed to larger-than-normal amounts

of chemicals. But these measurements will obviously depend on each

individual their overall health and how long after the exposure the

measuremcnt is taken.

It is difficult to obtain information on target organs. For example, all

the persons suspected of having died prematurely because of a pre- cise exposure have not necessarily been autopsicd so the inrirmation

3

NUREG-1437, Supplement 22 A-442 July 2005
Appendix A

about which organs have been partially or completely damaged is

lacking.

Furthe. correlations can be difficult to establish. An organ may not

be lethally damaged. but its malfunction could aecclerate the dcterioration of another part of the body and lead to a fatality. For exampic.

-smoking or chronic bronchiis due to exposure to dust would make a

.person more sensitive to radioactivity.

-Fetses, children, and adults also exhibit different susceptibilities to

various contaminants.

Cancer Reviews and Classifications

Along with other agencies, the U.N. International Agency for Rcsearch on Cancer (IARC) examines suspected potential carcinogens.

The results, which vary widely between anirals and humans, usually

fall into one of three groups defined as follows:

1) Class I- Confirmed Carcinogens

These substances are eapablc of causing cancerin exposed

humans. . .

.... :

2) Class I - Suspected Carcinogens

- hesc substances may be capable of causing cancer in ex-

- posed humans. The evidence is suggestive, but not su.fi.

cient to convince expert review commirtees. Somee entries

have not yet had expert review, but contain experimental

reports of carcinogenic activity,

As more studies are published, marny Class 11 carcinogens

.-- u I-V ul- U~AILruJXy "Iume uscune o a nn, uul 

- somer may be judged non carcinogenic.

3) Class Ill - Questionable Carcinogens

- These entries have minimal published evidence of possiblc

carcinogenic activity. The reported endpoint is often ncoplastic growth with no spread or invasion characteristic of

.:carcinogenic pathology.-- *

It should be noted that these three categories refer only to

the strength of the experimental cvidence that a chemical is

carcinogenic, and not to the extent of its carcinogenic activ4 -

July' 2005 A-443 NUREG-1437, Supplement 22
Appendix A

i

I

I

iI

I

i

i

i

i

i

ity nor to the mechanism involved. The classification of any

chemical may change as new information becomes available.

For a substance to belong in Class ITT. the report may simply

have lacked control animals, may have used a very small

sample size. lacked complete pathology reporting, or may

have suffered other design defects. Many of these were designed for other than-earcinogenie evaluation, and the reported carcinogenic effect is a by-product of the study. not

the goal. The data wore presented because some of the substances may be carcinogens. There are simply insufficient

data to afflum or deny the possibility.

Synergistic Effects of Multiple Contaminants

Complicating the assessment of toxicity fora contaminated site is the

presence of a mixture of contaminants. Aggregated chemicals could

mean aggregated risks.

In a survey of 91 DOE waste sites, for example. Riley and Zachara

(1992) found that tnmhtures of two or more compounds uere present

at 65 % of the sites. In soils the most frequently occurring mixtures

were metals combined with radionuclides. but various combinations

of metals and radionuclides with organic contaminants were also obscrved at some sites. In groundwater. the most common mixtures were

metals and chlorinated hydrocarbons.

The consequences of the synergy, linked to the presence of several

contaminants at a time in a contaminated site, still need to be thoroughly examined. Chemical and radioactive risks are generally increased if these substances are carcinogenic to the same organ.

Other auxiliary parameters may also interfere with the total toxic

impact of chemicals. and should not be underestimated. For example.

a smoker with damaged cilia in his lung passages will not be able to

properly expel radioactive materials, and therefore could be subject

to greatly increased health effects. Weather and temperatue, for example. may also have favorable or deleterious consequences.

5

NUREG-1437, Supplement 22 A-444 July 2005
Appendix A

Chlorinated Solvents

A solvent is typically a Equid that dissolves another substance,

thereby forming a solution. A chlorinated solvent is ouc that is a

chlorine compound. As chlorinated solvents move through the

ground, the materials act as an oily liquid. Groundwater flowing in

the soil will dissolve only a small portion of the contaminant and

the rest enters and contuminates the groundwater.

A dioxin is a specific type of chlorinated solvent; diokits ae- i

group of 219 different toxic chlorinated solvents These solvents

are fat-soluble and therefore accumulate in the tissucs of animals

and humans in the food chain. Humans are typically exposed to

these chemicals through the consumption of fish. meat, and milk.

Dioxins are formed through the burning of chlorine-based compounds. Dioxins may be transported great distances if airborne.:

Materials that enter the water vill bind to sediments and are

transported along with marine wildlife through ingestion. Similady, dioxins can settle on the leaves of plants and arm ingested by

animals. . - -

Exposure results in a drop in sperm count. an increase in testicular

and prostate cancer, endometriosis. and an increased risk of

developing breast cancer. The toxicity of these chemicals varies

but dioxins have sirnilarpotinckes.' Results of exposure to dioxins

create adverse health effects and vary depending on the leel of

exposure, time of exposure. and length of exposure. Typical cffects

as a result of exposure to large amounts of dioxin include skin

rashes.-skin discoloration. excessive body hair, and possibly mild

liver damage. Cancer as a result of excessive dioxin cxposure is a

main concern in adults.

Although the carcinogenicityof chlorinated solvents remns

unknown, cancer as a result of exposure is a great concern.

Carbon ltrnachlorlde - * -

Carbon tetrachloride, also known as carbon chloride, methane tctrachloride. perchloromethance tertrachlorocthane, or benziform. is a

clear liquid with a sweet smcll that can be detected at low-levels.

This synthetic chemical was nost typically used in the production of

refrigeration fluid and propellants for aerosol cans, as a pesticide, as

July 2005: A-445 NUREG-1437, Supplement 22
Appendix A

a cleaning fluid and degreasing agent, in fime extinguishers, and in

spot removers. It is now only used in some industrial applications as a result of its harmful health effects. High-levels ofexposurethrougS inhalation and ingestion and possibly through exposure to the skin can cause live;, kidney, and ceniral nervous system damage. The

liver and kidney cells are damaged or destroyed by this chemical.

Kidney and liver repair can occur when low-levels of exposure are stopped. High-levels of exposure affect the nervous system, including the brain. This chemical has been linked to brain cancer. Effects

of exposure include headaches, intoxication, dizziness, drowsiness.

nausea, and vomiting, and can lead to coma and even death. The US

DHHS has determined this chemical is a probable carcinogen. The

MCL is set at 0.005 mgIL and the ACGI TLV is set at 5 ppm. The

NIOSH REL is set at 2 ppm or 12.6 mgzn3'.

Chloride

Chloride has a very low toxicity. Ingestion of large amounts of chloride may lead to fluid retention and altered acid-base balance. Chlorine as agas or liquid is irritating and toxic. The main source of

exposure is through the consumption of salt. Effects of long-term

exposure are unknown.

Chlorobenzene

Chlorobcnzenc. also known as benzene chloride, veas used to make

other chemicals such as phenol and DDT. Currently, this chernical is

used as a solvent to make other chenicals; This chemical is a strong narcotic with slight irritant qualities. Health effects from repeated low-levels of exposure are unknown. Symptoms ofexposure includeirritation to the eyes skin, and nose, drowsiness, incoordination, and

central nervous system depression. The carcinogenicity of this chemical is unknown. The ACGIH TLV is set at 10 ppm.

Chloroform

Chloroform, also known as trichloromethane and methyl trichloride.

Is a colorless liquid with a plcasant, nonirritating odor and a slightly

sweet taste. This chemical sill burn only when it reaches very high

temperatures. Initially, chloroform was used as an anesthetic. Currently, it is used to make othcrchemicals. Inhalation results in irritation to the respiratory tract, and effects on the central nervous system including headache, drowsiness, and dizziness Results of inhalation

may also lead to unconsciousness, liver injury, blood disorders, and even death. Ingestion results in severe burning to the mouth and

7

NUREG-1437, Supplement 22 A-446 July 2005
Appendix A

throat, vomiting and similar results as inhalation. Sores develop on

skin with contact to large amounts of chloroform. The US DHHS

declares chloroform to be a probable carcinogen. The MCL is not

determined for this chemical. but the ACGIH TLY is set at I0 ppm.

The NIOSH REL is set at 2 ppm or 9.78 mglm'.

. - , . ,: - .. . - .

Chloromethane - .

aMoromethane is also known as methyl chloride. Symptoms often

seen includc: convulsions, nausca or vomiting, dziness, drowsinss,

Incoordination, confusion, abdominal pains hiccoughs, diplopia.

delirium, convulsions. irritation to the eye, coma, and even death.

High levels of exposure greatly affect the nervous system, liver. lddneys, and hear. No evidence exists to Imply that chloromethane is a

carcinogen. How. ever, the EPA has determined that it is a probable

carcinogen. The ACGIH nLV is set at 50 ppm. The NIOSH REL is

: setatl 0ppin -.

Dibromochloromethane

-Dibromocloromerhane is also known as chlorodibromomaehane.

Symptoms often seen include: irritation and narcoc effects. No

cases of cancer are seen in hurmans exposed to this chemical. Mhc

MCLforthischetnicalissctatO.lOppm.' - -

Dkhlorodifluornmethane- -

Dichlorodifluoromethane exposure symptoms often seen include:

dizziness, tremor, asphyxia. unconsciousness, cardia arrhythiias.

cardiac arresconjunctiva irritation. firosingaheolids, liverchanges,

and narcotic effects. The ACGIH TLV and NIOSH REL are set at

IOW pprn

Freon-113

Freon-l 13, alsoknown as l,l,2-Trichloro-l,22-trifluorocthanc. is a

mildly toxic chemical. Symptoms often seen Include. irritation to

skin and throat, drowsiness, dermatitis, and central nerous system

depression. Thc NIOSH REL is set at 1 OOO ppm.

Methylene Chloride

Methylene Chloride, also know n as dichloromrihanc, is jnot found

naunrally in the environment. This chemical is a colorless liquid vith

a mild. sweet odor used as an industrial solvent and paint stripper.

Inhalation of low-lcvls results in a person becoming less attentive

and less accurate. Effects of inhalation athigh-levels have a narcotic

July 2005 A-447 NUREG-1437, Supplement 22
Appendix A

effect. Symptoms often seen include: dizziness, nausea, mental confusion, fatigue, vomiting, headaches, and a tingling sensation in the

fingers and toes. Contact with this chemical by skin results In irritation, redness, pain and even buffing. The WHO declares methylene

chloride as carcinogenic to hum=s. The US DHHS and the EPA

have determined that this chemical is a probable carcinogen. The

.1CL has not been determined for this chenical, but the ACGIH *rLV

has been set at 50 ppm.

Octschlorodibenzo-p-dioxin (OCDD)

Octacliorodibenzo-p-dioxin (OCDD) is an experimental teratogen

and an Irritant to the eyc. Ingestion of this chemical results in poisoning. These solvents are fat-soluble and therefore accumulate in the

tissues of animals and humans in the food chain. Humans are tpically exposed to these chemicals through the consumption of fish,

nmat, and milk. Exposure to dioxins results in a drop in sperm count.

an increase in testicular and prostate cancer, endometriosis, and an

increased risk of developing breast cancer. The NICL and ACGIH

TLV have not been determined for this chemical.

Pentachlorinated dibenzofurans

Pentachlorinated dibenzofhnns is a chemical with great health effects to the human body. A significant reduction of thymus vweight

and suppression of the activity of cytotoxic T lymphocytes, in addition to a suppression on both cell-mediated and humorai immunity.

The .MCL and ACG2HTLV have not been determiuned for this chemicaL

Perchloroethytene (PCE)

PCE, also known as perrhloroethylene or tetrachloroethylene. is a

moderately toxic chemical. Inhalation results in conjunctiva irritation. general anesthesia, hallucinations, distorted perceptions, local

anesthesia, coma, and pulmonary changes. Symptoms of exposure

may include irritation to eyes, skin, nose, throat, and respiratory system, as well as nausea, dizziness, incoordination, headache, drowsinesS skin erythea, and liv damage. Ingestion results in irritation

to the gastrointestinal tract. This chemical Is a potential carcinogen.

The .NCL has not been determined for this chemical, but the ACGIH

TLVis set at S0 ppm. The .NIOSH RELrecomnmends that workplace

exposure is minimized.

_ 9

NUREG-1 437, Supplement 22 A-448 July 2f005
Appendix A

Titanium tetrachloride

Titanium tetrachloride is a colorless to pale yellow liquid that has

fumes with a strong odor. If It comes in contact witwater, it rapidly

forms hydrochloric acid, as well as titanium compounds. It is not

found naturally in the environment and is made firom inicrals that

contain titanium. It is used to make titanium metal and other titanium-containing compounds, such as titanium dioxide, which is used

as a whitc pigment in paints and other products.

Titanium tetrachloride is very irritating to the eyes, skin, mucous

rnembraDns, and the lungs. Breathing in large amcmnts can injure the

lungs seriously enough to cause death. Therc is no evidence that

chronic exposure to titanium tetrachloride causes cancer In humans.

The MCL and ACGIH TiV haven't been determined for this chemi.

cal. TheNIOSH RELisset at 0.001 mg/n'. ; .

1,2,4-TrichIorobtnzene

1,2,4-Trichlrobenzene is an experimental teratogen. This ehemical

is an iritant to the eyes, skin, and mucous membrane. Symptoms

often affect the liver, kidney. and adrenal gland. The carcinogenicity

of this chemical is unknown. The MCS, is sct at 0.07 mglL. The

ACGIH T1V is set at ppm.

Il,l-trichlorioethane -

1.ll-trichloroethanc is synthetic material that is alsown astncthyl chloroform. Symptoms often seen Include. dizziness, conjunctiva irritation, hallucinations or distorted perceptions. motor activity

changes, irritability, aggression, hypermotility, diarrhea, poor equi.

brium, dermatitis, nausea or vomiting, cardiac arrhythmias, and other

gastrointestinal changes. The IARC has determined the carcinogenicity of this chemical is not classifiable. The ACGIH TLV and

NMOSH REL are sct at 350 ppm.

Trichloroethylene (TCE) -

TCE is also known as trichloroethylene. Symptomns of inhalation

and ingestion are mildly toxic to humans and include: eye Irritation,

somnolence, hallucinations or distorted perceptions, gastrointestinal

changes, and jaundice. Addictionresults in those that work with the

chemical. High-levels of exposure lead to headache and drowsiness.

and ecvntual vcntricular fibrillation resulting in cardixc failure, which

in turn damages the liver and other organs. NIOSH has detcnnined

this chemical to be a potential occupational earcidogen'. thc recom-

*10

July 2005 A-449 NUREG-1 437, Supplement 22
Appendix A

mended REL is2 ppm. The.%CL is set at 0005 mg/L and the ACGIH

ILV is set at 50 ppm.

Tetrahydrofuran

Tetrahydrofuran. also known as tetrametbylene oxide or 7lF is a

mildly toxic chemical. Symptoms often seen include: general anesthesi. irritant to eyes, mucous membrancS, and upper respiratory

system, narcotie in high concentrations, liver and kidney damage.

and central nervous system depression. The NIOSH REL is set at

200 ppm.

Vinyl Chloride

Vinyl Chloride is moderately toxic by ingestion and a severe irritant

to skin, eyes, and mucous membranes. High concentrations of vinyl

chloride act as an anesthetc and chronic exposure can lead to liver

injury. The carcinogenicity of vinyl chloddeis conflrmed in producing a ramz cancer in the liver and blood tumors. The production of

vinyl chloride is also a source of dioxins." Th MCL is set at 0.002

mgtL and the ACGIH TLV is set at 5 ppm.

High Explosives Compounds

Explosives are chemical compounds or mixtures that are typically

used in detonators in bombs. Lage amounts of gas and heat are generated with the production of sudden pressure effects. As a resuI4 the explosives vary in intensity and resistance.- fixing of chemnicals produces varied effects and intensities upon explosion.

1,3-Dinitrobenzene

1,3-dinitroberene, also known as 2,4-dinitrobenzene. is a synthetic

explosive formed as a by-product from the manufacturing of TNT.

Mixting this chemical with tesranitromethanc results in a high explosive that is very sensitive to sparks. No odor or tastc is associated

with this chemical. This chemical is slightly soluble in waver and

does not stick strongly to soil and as a resulttravls through the soil

into the groundwater. Symptoms of exposure include headache, anoxia, cyanosis, visual disturbance, central scotomas, bad taste, burning mouth,dry throat thirst.anenia. liverdamage, nauseaand dizziness Long-tcrtn exposurc results in a reduction of the numberof red

blood cells. The carcinogenicity of this chemical is undetermined

for humans. Thc NIOSH REL is set at I mg/nO.

t11

NUREG-1437, Supplement 22 A-450 July 2005
Appendix A

Dinitrotoluene (DN7) - -

. Dinitrotoluene (DNT) is a poison that is carcinogenic with experi.

mental curnorigenic and terazogenicdata. Symptoms of exposure may

include anozia, cyanosis, anemis jaundicc. and reproductive effects.

Tbc MCL has not been determined for this chemical but the ACOTH

TLV is set at 1.5 mg/m'. The NIOSH REL is set at 1.5 mghrn'.

2,6.Dinitrotoluene - ' -

Z6-Dinirotolucne is a synthetic explosive that is one of the six forms

of chemicals otdinitrotoluene. This chemical is a pale yellow solid

with a slight odor. Health effects from exposure to this chemical arc

uncertain. The nervous system and blood of exposed iosrkers may

be affected. The IARC has determined that this chemical Is a potential carcinogen. :

HMX -

HMX, also known as cyclotetramethylene tetranitrate, is an acronym

for High Melting Explosive. Other names for this chemical include:

Octogcn and cydotetramethylene-tetanitramine. It is a colodess solid

that dissolves slightly in water with an unknown taste itld smelL This

chemical is made from other chemicals kn6%n as hexamine, miMno.

nium nitrate, nitric acid. and acetic acid. Thc high volatility of this

chemical enabled its use in explosives, rockec fuels, and burster charg.

'crs No information is known on how you might be exposed to HMX

in the environment and the information on adverse hcahih effects is

linited. The EPA has concluded that the carcinogenicity to humans

Is not classifiable. Tbe MCL and ACGIH TLV have not been deter-

.minedforthischernical.

4-Nitrotoluene

4-Nitrotoluenc is a poison that is moderately toxic by ingestion.

Contact with skin is mildly toxic. This chemical is combustible upon

exposure to heat or flame.' Symptoms of expcsure may include anoxia. cyanosis. hcadachc, wcakness and exhaustion, dizziness. ataxia.

difficulty breathing, tachycardiax niusca. and vorniting. When It is

combined with ictranitromethanc a very sensitive high explosive is

created. The NIOSH REL is set at II mg/m.

4-PETN (Pentser~ythrilol Tetranltrate)

PE-Nl, also'known as Pentacrydtritol Tctranitrate, Is a hazardous

chemical that explodes when shocked or exposed to hcat.' Ingestion

1 2 7 7

July 2005 A-451 NUREG-1437,-Supplement 22
Appendix A

results in dermatitis. Other symptoms of exposure include: headaches, weakness, and fall in blood pressurec The.NICL and ACGIH

TLV have not been determined for this chemical.

4-Perehlorate

Perchlorate is synthetic and man-made. Perchlorates are incredibly

unstable materials. Irritation to the body results in contact with any

perchlorate. Mixtures of this chemical fonr explosives. This chemical affects the functioning of the thyroid gland. Alteration to thyroid

gland functions can potentially lead to the formation of tumors.

4-RDX

RDX, otherwise known as Royal Demolition Explosive, is one of the

most powerful high explosives in use today. Other names for this

chemical include: cyclocrimcthylcne-tziiraminecyclonite, cyclonitc,

and 1 .3,5-trinitro 1,3,-triazine. As a synthetic, white powder, when

RDX is burned fumnes are created. This chemoical is rarely used alone

and is typically combined with other explosives, oils, or waxes. Syrnptoms of exposure to RDX include seizures, nausea, headache, irritability. weakness and exhaustion, tremor, dizziness, insomnia. and

vomiting. Knowledge of birth defects or affects oa reproduction in

humans is yet to bc discovered. The carcinogenic propertes of RDX

are unknown. The MCL has not been determined for this chemical.

but the ACGIH TLV is set at 15 mg/ni. The NIOSH REL is set at

1.5 mg/r'.

Tetryl

Tetryl is also known as nitramine and 2,4,6.trinitrophenyl-n.

methyinitramninc. This explosive is an extremely sensitive high explosive, more so than TNTto shock and friction. When combined on

contact with trioxygen difluoride the chemical explodes on contact.

This chemical is an irritant, sensitizer, and allergen. Symptoms of

exposure may include sensitization derrnatitis, redness, inflammation of the cornei, snecing. anemia, couSh. car)za. irritability, malaise, hcadache. weakness and exhaustion. insomnia, nausea, va.niting. and liver and kidney damage. The MIOSH REL is set at

1.5 mngm'.

2,4,6-Trinitrololuene

2.4.6-Trinitrotoluene is an explosive commonly rcferred to as TN'T.

Ingestion results in hallucinations or distorted pcrmeptions. cyanosis.

and gastrointestinal changes. Contact with this chemical results in

- ~~ 13

NUREG-1437, Supplement 22 A-452 July 2005
Appendix A

: skin irritation. Hcalth effects include jaundice, cyanosis. sneezing,

cough. sore throat, peripheral ncuropathy, muscle pain, kidney damage. cataract, sensitization dermatids, headaches. weakness, anemia.

; and liver injury. The NICL has not been determined for this chernical, but the ACGIHTLV is set at O5 mfem'. The NIOSH REL is set

at 0.5 mg/tn'.

Fuel Components and other Organic Cheniicals

Toxic chemicals are known to disrupt normal bodily functions, in.

cluding the functions of hormones. Hormones provide a number of

services ts natural chemicals to the human body including: act as

messengers, travel through the blood stream, regulate vaious bodily

processes, and coordinate the body's activities to maintain health

through controlling grorwth. development, and bchavior.2

Acenapthylene ;

Acenapthylkne is a Polycyclic Aromatic Hydrocarbon (PA)H. The

presence of this chemical arises from the use of fuel components and

other organic chemicals. This chemical is a danger to humans and

enters In all tissues that contain fat. Acenapthylene is stored mostly

in the kidneys, liver, and fat with smallerarnounts stored in the spleen.

adrenal glands, and ovaries. The US DHHS has determined that

acenapthylene Is a known animal carcinogen: however. the EPA has

determined that the human carcinogenicity Is not classifiable. The

MCL and ACGIH TLV have not been determined for this chemical.

Acetone

Acetone is a colorless liquid with a distinct smell and taste that is

naturally found in the envirotment as well as manufactured. Other

names for this chemical include: diimethylcetone, 2-propanone, and

beta ketopropanc. In small amounts, the liver breaks acetone down

into energy making chemicals used for normal body functions. Exposure results in entry of acetone into the blood stream and is subsequently carried to the rest of the organs. Inhalation of moderate-tohigh amounts for even short periods of time can result in nose, throat.

lung, and eye irritation, headaches, light-headedness, confusion, increased pulse rate, efrccts on blood. nausea, vomiting, unconsciousness and possibly coma, and the shortening of the menstrual cycle in

women. Ingestion of small amounts typically does not cause harm.

,Howevcr, ingestion ofhigh lcels results in nbdomninal pain, nausca,

14

July2005 A-453 NUREG-1 437, Supplement 22
Appendix A

and vomiting. Effects of long-term exposure to acetone include kidney, liver. and nervc damage. increased birth defects, metabolic

changes, and coma. The use of alcoholic beverages enhances the

toxic effects of acetone. The US DHHS, the IARC. and the EPA

have notclassifiled acetone forcarcinogenicity in humans. The MCL

has not been determined for this chemical. The ACGIH 'TV is set at 750 ppm. The NIOSH REL is set at 0.1 ppm.

Ammonia

Ammonia exposure symptoms often seen includc irritation to eyes and mucous membranes. Symptoms often seen include: breathing difficuky, wheezing, chest pain. pulmonary cdema, skin bums, liq- uid. and frostbite. High-levels of exposurc result in blindness, lung damage, heart attack. or death. The US DHHS, IARC, and the EPA

have not classified the carcinogeniciry of ammonia. The ACGIH

TLV and .NIOSH REL are set at 25 ppm.

Anthrmene

Anthracene isaskin irritant and allergen. The carcinogenicity ofthis

chemical is probable.

9,10-Anthracenedione

9,10-Anthracenedionc, also known as anthraquinone. is a mild allergen.

Asbestos

Asbestos is comprised of six different minerals that are found in na- ture This chemical enters the drinking water from natural sources in

addition to corroded asbestos worn away from cement pipes. Thc separabie, heat resistant fibers that make up the minerals are strong and flexible enough to be spun and woven. As a result, asbestos was widely used in building materials. frirteon'products, heat resistant

fabrics, packaging, gaskets, and coatings, Inhalation of lower 1evels

ofasbestos may result in changes called plaques in the linings. Long. term inhalation of asbestos fibers may result in scar-like tissue in the lungs and in the Eining that surrounds the lung. Breathing'difficulties, restricted pulmonary function. and heart enlargements arise as a re- sult of exposure. eventually leading to disability and death. The US DHHIS, the WHO. and the EPA have determined that asbestos is a human carcinogen and produces lung rumors. The MCL is set at 7

million fibers/ and thc ACGIH TLV is set at 2 fibers/cubic centimeMrs1

NUREG-1437, Supplement 22 A-454 July 2005
Appendix A

Benzaldehyde

Benzaldehyde is an allrgen. Symptoms often secn includc: derna.

titis, ccntnal nervous system depression, and anesthetic. The carinogenicity of this chemical is probable.

Benzene

Benzene is a colorless liquid with a sweet odor that Is formed from

natural processes as well as human activities. With is wide distribution throughout the US, the uses of benzene are expansive, some of

which include rubbers, Ibrcants dyesdegreascrs detcrgents. drugs,

pesticides, and as a major component of gasoline. This chemical

enters the drinking water through Icaking underground gasoline and

petroleum tanks or improper waste disposal. Inhalation of high levels of benzene can result in drowsincss, dizziness, rapid heart rate.

headaches. tremors, confusion, unconsciousness, and even death.

Diseases that result from inhalation includc Hodgkin's Disease and

lymphomras. Ingestion of benzene is moderately toxic and is a severe

eye and moderate skin irritant. Long-term exposure results in harmful effects on the bone marrow, leading to mycloid lcukemia, as well

as a decrease in red blood cells that leads to anemia. In addition

excessive bleeding can occur and the immune system can be affected.

Long-term exposure of workers to this chemical is linked to brain

cancer and leukemia. Additionally, other possible health cornplications may arise in reproductive and developmental effects. Thc US

DHHS has determined that benzene is a known human carcinogen.

The MCLis set at O.OQ5 mgIL and the ACGIH TLV is set at 10 ppm.

The NiOSH REL is set at 0.l ppm.

n-Butanol

n-Butanol is also knovwn as n-butyl alcohol. Symptoms often seen

Include: conjunctiva irritation, unspecified rcspiratory systmn and

nasal effects, severe skin and eye irritant comea] inflanmition. slight

headache and dizzness, slight irritation of the nose and throat, and

dermatitis. The ACGIH TLV and NIOSH REL are set at SO pprm.

Delta-BIIC.

Delta-BHC is also known as dela-benzenehexachloride and is a

moderately toxic chemical.

16 - - ..

July 2005 A-455 NUREG-1437, Supplement 22
Appendix A

Gamma BHC

Ganm BHCis alsoknown 6as the gammaiwerotoenzebc h=x loride. Symptoms often seen include: Irritation to the eyes skin, nose.

and throat, headache, nausea, rmpsasory difficulty. convulsions, dyspnea, and cyanosis. This chemical is a known carcinogen. Thc

ACGIH TLV and NIOSH REL are set at 0.5 mng/rn.

Benzo(a)anthrcene

Benzo(a)anthracene is a Polycyclic Aromatic Hydrocarbon (PAH).

The presence of this chemical arises from the use of fuel components

and ocher organic chemicals. This chemical is a danger to humans

and eaten all tissues that contain fat. PAHs arm stored nuoly in the

kidneys, liver, and fat with smaller amounts stored in the spleen, adrenal glands, and ovaries. This chemical is a poison by intravenous

routes that is comimionly an air octaminant of foodL waer, and smoke.

The LRC and the EPA have determined it is a probable hurnan carcinogen. The MCL and ACGIH TLV levels have not been determined.

Benzo(a)pyrene

Denzo(a)pyrene is a Polycyclie Aromatic Hydrocarbon (PAH). The

presence of this cherrical aises from the use of fuel components and

other organic chemicals This chemical is a danger to humans and

enters all tissues that contain fat. PAHs are stored mostly in the kidneys, liver, and fat with smaller amounts stored in the spleen, adrenal

glands, and ovaries. This chemical is a poison via subcutaneous.

intraperitoneal, and intrarenal mrutes that is commonly an air con.

taminant of food, water, and smoke. Expedmental teratogenic and

reproductive effects have been found. The IARC and the EPA have

determined it is a probable human carcinogen. The M.CL is set at

0.0002 msg/L and the ACGIH nv has not been determined for this

chemical.

Benzo(b)fluoranthene

Benzo(b)ftiuornthene is a Polycyclic Aromatic Hydrocarbon (PAll).

The presence of this chemical arises frtm the use of fuel components

and other organic chemicals. This chemical is a danger to humans

and enten% all tissues that contain fas. PAHs ame stored mostly in the

kidneys, liver, and fat with smaller amounts stored in the spleen, adrenal glands, and ovaries. The LARC and the EPA have determined

this chemical to be a possible human carcinogen. The NICL and

ACGIH TLV have nor been determined for this chemicaL

17

NUREG-1437, Supplement 22 A-456 July 2005
Appendix A

Benzo(k)fluoranthene

Benzo(k)fluoamnthenc is a known carcinogen. ,

Benzo(gb,i)perylene

Benzo(g,h~i)perykne is a Polycyclic Aromatic Hydrocarbon (PAH).

The presence of this chemical arises from the use of fuel components

and other organic chemicals. This chemical is a danger to humans

and enters all tissues that contain fat. PAHs arm stored mostly in the

kidneys, liver, and fat %ith smaller amounts stored in the spleen. adrcnal glands, and ovaries. The IARC and the EPA have determined

this chemical not classifiable as to the carcinogenicity to humans.

The MCL and ACGIH TLV have not been determined for this cherni-

~cai.

Bensolc Acid

* Benzoic Acid is found naturally in resins and manufactured synthetically. It is a colorless crystalline solid and Is used as a food preserva.

tive and in pharmaceuticals and cosmetics. Inhalation affects the

human nervous system, dypsnea. and allergic dermatitis. This chemical is a poison by subcutaneous route and is moderately toxic by ingestion and intraperitoneal routes. In addition, it is a severe eye and

skin irritant. The MCL and ACGIH TLV have not been determined

for this chemicaL . - :

Bis-(2-ethylhexyl)phthalate

Bis-(2-echylhexyl)phthalate. also knowu as di-sec-octylphthalate, is

a poison upon entry into the blood stream. Ingestion affects the gastrointestinal tract- In addition, this chemical is a mild skin and eye

irritant and can cause liver damage. This chemical Is a confirmcd

carcinogen with experimental carcinogenic and tmorigcnic daaeThc

MCL is set at 0.006 mgtLand the ACGIH TLV is set at 5 mg/m. The

NIOSH REL is set at 5 mgfmr.

Carbazole - '-- :.

Carbazole is a pesticide poisonous by intraperitoneal routes. Inges.

tion is moderately toxic. It Is a questionable carcinogen. The MCm

and ACGITH TLV havc not been dctcrmincd for this chemicaL

Carbon disulfide - - -

Carbon disulfide is found naiturally as well as a commercially made

chemical. Symptoms often seen include: narcotic and ancsthetic cf18

July 2005 A-457 . NUREG-1437,-Supplement 22
Appendix A

fecus to the central nervous systcm dizziness, headache, poor sleep.

anorexis, weight loss, Parkinson-like syndrome, coronary heart disease. gastritis. kidney, liver injury, eye and skin bums, respiratory

failure, and even death. The US DHHS, the [ARC, and the EPA have

not determined the carcinogenicity of this chemical. The ACGIH

Tv is sct at 10 ppn. The NIOSH REL is set at I ppm.

Chrysene

Chrysenc is a Polycyclie Aromatic Hydrocarbon (PAH). The prcsence of this chemical arises from the use of fuel components and

other organic chemicals. This chemical is a danger to humans and

enters all tissues that contain fax. PAHs are stored mostly in the kidneys. liver, and fat with snaller amounts stored in the spleen, adrenal

glands. and ovaries. The IARC has determined the carcinogenicity is

not dassifiable fiorhuans The EPAhas deternmined that this chemical

is a probable human carcinogen. The !ICL and ACGIH TLV have

not been determined for this chemical.

Cyclohexane

Cyclohexane is also known as benzene hexahydride and

hexahydrobenzene. Symptoms often seen include irritation to eyes.

skin, and respiratory system, drowsiness, derrnatitis, narcosis, and

coma. Th ACGIH nv and .NIOSH REL is set at 300 ppm.

Cyclohexsnone

Cyclohexanone is a severe eye irritant. Symptoms often seen include

changes in the sense of smell, headache, narcosis, coma, dermatitis,

conjunctiva irritation, and unspecified respiratory system changes.

mild narcotic, and a skin and eye irritant The ACGIH TLV and

NIOSH REL are set at 25 ppm.

Dlbmnz(a,h)anthracene

DIbenz(ah)anthracene is a Polycyclic Aromatic Hydrocarbon (PAH).

The presence of this chemical arises from the use of fuel components

and other organic chemicals. This chemical is a danger to humans

and enters all tissues that contain fat. PAHs are stored mostly in the

kidneys, liver, and fat with smaller amounts stored in the spleen, adrenal glands. and ovaries. The US DHHS has determined that this

chemical is a known animal carcinogen. The MCL and ACGIII TLV

have not been determined for this chernical.

19

NUREG-1437, Supplement 22 A-458 July 2005
Appendix A

Di-n-octylphthalater

Di-n-octylphthalate is also known as'di-sec-octylphthalate. Ihis

chemical affects the gastrointestinal tract, central ncrvous system liver,

reproductive system, and gastrointestinal tract. This chemical is also

a mild skin and eye Irritant. This chemical is a known carcinogen.

The ACGIH TLV and NIOSH REL are set at 5 mglmi.

1,2-Diphenylbydrazine

1.2-Diphcnylhydrazine. also known as Hydrazobenzene is a white

solid with no information on smell or flammability. This manufactnred chemical does not dissolve easily in water and when placed in

water it rapidly breaks down into other toxic chemicals. This chemical is currently used in medicines to treat inflammation and a type of

iarthritis. Effects of Ingestion lead to chemical joisoning.

Diphenythydrazine Is a confirmed carcinogen with expe'rimentail carcinogenic and tumotigenic data Poison by ingesidon. 'The MCL and

-ACGIH TLV have not been'determined for this cher'ical. L-"

Ethyl Acetate

Ethyl Acetate is a chemical that can cause dermatitis. Inhalation results in severe irritation to mucous mniebrazies and tipper respiratory

tractpoisoning, human systemic effects such as olfactory changes,

eonjunctivairritation, and pulmonarychanges. Ingestionofthischemnical is mildly toxic in causing irritation to the gastrointestinal tract

iwith symptoms such as nausea, vomiting, and diarrhea. Long-term

exposure yields conjuncdval irritation and corneal clouding. conges.

dion of the liver and kidneys. High concentrations have a narcotic

effect ini addition to resultant liver and kidney dimage. Chronic poisoning may lead to anemia with kukocytosis (a transient in'cease in

the white blood cell count), cloudy swelling, and fatty degeneration

of the viscera. The MCL has not been determined for this chemical

and the ACGIH TLV is set at 400 ppm. The NIOSH REL is sec at

400 ppmri ',

Ethylbenrcne

Ethylbenzene is a moderately toxic chemical. Symptoms often seen

Include: eye, sleep, and pulmonary changes, eye and skin irritation,

headache, dermatitis, narcosis, coma. dizziness, irritation of the nose

and throat, and a sense of constricion in thc chcst.' The ACGIIITLV

and NOSH REL'are set at l00 ppm. ' -,-

July 2005 ' A-459 . NUREG-1 437, Supplement 22 .
Appendix A

Fluoranthene

Fluoranthene is a moderately toxic chemical. The carcinogenicity is

probable.

n-Hexane

n-Hexane is a slightly toxic chemical made from crude oiL Symnp- toms often seen includet irritation to the eyes, skin. respiratory systern, central nervous system, and peripheral nervous system, paraly- sis and hallucinations. he US DHMS, the IARC, and tde EPA have

not classified the carcinogenicity of this chemical. TheACGIHTLV

and NIOSH REL are set at 50 ppm.

2-Hfexanone

2-Hexanone is also known as Butyl methyl ketone or Methyl butyl ketone. This chemical Is moderately toxic. Symptoms often seen include: irritation to the eyes and nose, peripheral neuropathy. weakness, exhaustion, paresthesia, vomiting, dermatitis, headache, and

drowsiness. This chemtical is a skin and eye imitant. The ACGIH

TLV is set at S ppm. TbeNIOSH REL is scs at I ppm.

Indeno(1,2,-cd)pyrtne

Indeno(1,2.3-c.d)pyrene is a Polycyclic Aromatic Hydrocarbon (PAH). The presence of this chemical arises from the use of fuel components and other organic chemicals. This chemical is a danger

to humans and enters all tissues that contain fat. PAHs are stored

mostly in the kidneys, liver, and fat with smaller amounts storcd in

the spleen, adrenal glands, and ovaries. The [ARC has determined

this chemical to be a possible human carcinogen. The MCL and

ACGIH TLV have not been determined for this chemicaL

Mfethyl Ethyl Ketone (NIEK)

Methyl Ethyl Ketone (MEK) is a strong irritant that affects the pc- ripheral nervous system and central nervous systens Effects of inhalation at low.levels of exposure result in human systemic effects, including conjunctiva irritation and cffects on the nosc and respiratorysystem. Inhalation at high levels results in headachcs. dizzincss.

nausca, shortness of breath, and vomiting, in addition to central ncr- vous system depression and unconsciousness. Effects of ingestion result in abdominal pain and nausea. Contact by skin results in redness, itching, and pains; long-term exposure results in dermatitis. Thc

M7CL has not been deternined for this chemical, but thc ACGIH TLV

has been set at 200 ppnm The NIOSH REL is set at 200 ppm.

21

NUREG-1437, Supplement 22 A-460 July 2005
Appendix A

Methyl methacrylate

Methyl mnethacrylatc is a moderately toxic chemical. Symptons often seen include: sleep effects, excitement, anorexia, and blood pres- sure decrease. 'Ihis chemical is a severe skin, eye, nose, and throat

irritan. The ACG-H ILV and NIOSH REL arc set at 100 ppm.

2-Methyinapthalene

2-Methylnapthaliene is a white solid that is found naturally In fossil

fuels. High-levels of exposure damages red blood cclls. Symptoms

of acute poisoning include: fatigue, lackof appetite. restlessness, and

pale skin. Symptoms of a higher exposure include: nause voriting,

diazhea.'blood in the urine. and a yellow color to the skin. The US

DHHS, the IARC, and the EPA have not classified the carcinogenicity of this chemical. The MCL and ACGIH TLV have not been determined for this chemical.

Nitrates

Nitrates ingested in large amounts can result in death. Symptorns

;often seen include- dizziness, abdominal cramps. vomiting. bloody

diarrhea. weakness. convulsions, collapse, aMd even Mcntal impairi ment. The carcinogenicity of this chemical is probable.

Nitrobenzene -

Nitrobenzene is an industrial chemical typically used to manufacture aniline. Symptoms often seen include general anesthetic, anoxia. dernatitis, anemiaprespiatorysdmuladonand vascularchanges.

This chemical is also an eye and skin irritant and is absorbed rcadily

through the skin. The IARC has determined this chemical to be a

probable carcinogen. Thbe ACGIH TLV and NIOSH REL are sct at I

ppn. -

N-nitrosodi-n-propylamine

N-nitrosodi-n-propylamine is a manufactured chemical for use in rescarch and as a weed killer. The effect on humans remains unknown

for this chemical. The US DHHS has determined that n-nitrosodi-npropylamine is a probable carcinogen. The MCL and ACGIH TLV

have not been determined for this chemical.

Octadecanoic acid

Octadecanoic acid is also known as stearic acid. This chemical is a

skin irritant. The carcinogenicity of this chemical is probable.

22

July 2005 A-461 NUREG-1437, Supplement 22
Appendix A

Pentachlorophenol (PCP)

Peatachlomphenol (PCP) occurs as a colorless crystal. The smell

varies with the temperature of this manufactured chemicaL Uses of

this chemical include use ass biocide and wood presrvative.

Symptoms of exposure may include sneezing, cough, weakness

and exhaustion, anorexia. weight loss, sweating, hcadache, dizzi.

ness, nausea. voniting, dyspnea, chest pain, high fever, and damage

to the liver, kidneys, blood, lungs, nervous system, immune system.

and gastrointestinal trat Contact with skin and eyes cause

drmadtitis and irritation. The (ARC has determined that this

chemical is a possible carcinogen to humans. The NICL is set at

0.001 mg/L and the ACGIH TLV is set at 0.5 mg/rn. The NIOSH

REL is set ax0.5 mg/ni'.

Pheneanthrene

Phencanthrene is a Polycyclic Aromatic Hydocarbon (PAH). The

presence of this chemical arises from the use of fuel components and

other organic chemicals. This chemical is a danger to humans and

enters all tissues that contain faL PAHs are stored mostly in the kidneys. liver, and fat with smaller amounts stored in the spleen. adrenal

glands, and ovaries. The US DHHS has determined that

phencanthrene is a known animal carcinogen; howcver, the EPA has

detarmined not classirable to human cascinosenicity. The MCL and

ACGIH nlV have not been determined for this chemicaL

PCBs

PCBs are also known as polychlorinated biphenyls.Of the 109 PCIBs,

many affect hormones and are linked with brain cancer. Tlis chernical is moderately toxic by ingestion and skin contacL The carcinogenicity of this chemical is probable. The MCL is set at 0.0005 mgfL.

but the ACGIH TLV has not been detertmined for this chemical.

Pyrcne

Pyrene is a poison through inhalation. This chemical is a skin irritant. The carcinogenicity of this chemical is probable.

Sulfates

Sulfates arc elements ombined with both sulfur and oxygen. These

materials vary in toxicity.

NUREG-1 437, Supplement 22 A-462 July 2005
Appendix A

Tbluene

Toluene is a poison to hunans via various routes. Inhalation, Intravenous and subcutancous routcs prove to be mildly toxic.' Effects of

Inhalation result in hallucinations. distorted peceptions. tnotor activity changes. antipsychotic, pyschophysiological test changes. and

bone marrow changes. Other Symptoms of exposure may include

irritation to nose and eyes, weakness and exhaustion, confusion, di2-

ziness, headache. anxiety, muscle fatigue, insomrnia, paresthcsia, dermatitis, and liver and kidney damage. This chemical is an irritant to

the eyes and skin and is linked to brain cancer. The MCL is set at I

mglLand the ACGIH TLV Is set at 100ppm. The NIOSH REL is set

at lOOppm..

1,3,S-Trinitrobenzene

1.3,S-Trinitrobenzenc is a powerful explosive that has more power

for shattering than TNT but less sensitive to impacL This chemical

is difficult to produce. Ingestion has proven moderately toxic. The

MCL ndACGIH TLVhave not beea determined for this cheuical.

Metals

Metals are found naturally in the environmcnt and tend to remain

for a long time, thereby increasing a greater likelihood for exposure. Some metals are useful in small amounts and even necessary

for good health. Metals can accumulate in vegetables. grains,

fruits, fish, and shellfish from surrounding soil and water. .Health

effects caused by heavy metals includc reduced growth and

developmnnt, cancer, and organ damtage, which can lead to -

autoinmunity, rheumatoid arthritis, and diseases of the kidnevs.

circulatory system. and nervous system. Metals have a greater

effect on children and exposure can result in learning difficulties,

memory impairment, damage to the nervous system. and behavioral

problems? -

Aluminum - . -

Aluminum occurs naturally and makes up about 8% of the surface of

the earth. It is always found combined with other elerments such as

oxygen, silicon and fluorine. This mctal is silver-whitc and nlexible.

Uses primarily include cooldng utensils, containers. appliances, buildJuly 2005 A-463 NUREG-1437, Supplement 22
Appendix A

ing materials, paints. fireworks. glass, rubber, ceramics and consum- ers products such as antacids, astringents, buffered aspirins. food additives and antiperspirants. Low-level exposure to aluminum from food, airn water, or contact with skin is not thought to harmyourhealth. Aluminum. however, is not a necessary substance for our bodies and

too much may be harmfuL People who are exposed to high lcvels of aluminum may have respiratory problems, bone diseases and skeletal problems, skin rashes and delays in neurological development. The DepartnmentotHealth and Human Services, the International Agency for Research on Cancer. and the EPA have not classified aluminum

forcardcnogenicity.The SNILC is set at 0.05-0.2 mg/L. Both ACGIF and NsIOSH have established guidelines values from 2 mgrnS for soluble salts to 10 mgttn' for aluminum for total dust.

Antimony

Antimony is a silvery-white. corrosive metal found naturally in the eanth's crusL Thpically, antimony is brought into the United States for processing, mixed with alloys for strength, and used in the flame retardant industry. Other uses of this chemical include: ceramics, glass, batties. fireworks, and explosives. Antimony enters the drink- ing water through natural weathering of rock. industrial production, municipal waste disposat ormanufacritng processes. Inhalation of high-levels will result in lung problems. Ingestion of high-levels of antimony will result in heart problems, stomach pain. diarrhea, vom- iting. and stomach ulcers; other unknow n effects may result from in- gestion. Contact with this chemical results in inration and bums. Medicinal uses of antimony exist in treating people infected with parasites. The US DHHS. the [ARC, and the EPA have not classified antimony as to its human carcinogenicity. The .CL is set at 0.006 mg&L and the ACGIH TLV is set at 0.5 mgrnm. The NTOSH RE!L is

set at 0.5 mg/m'.

Arsenic

Arsenic is a naturally occurring clement widely distributed in the earth's crust In the environment. arsenic is combined with oxygen. chlorine and sulfur to form inorganic compounds. Arsenic in animals and plants combines with carbon and hydrogen to form organic ar- senic compounds. It is mainly used to preserve wood. Its use in pes- ticides has been canceled or restricted.

It cannot be destroyed in the environment; it can only change its form. Organic arsenic compounds are less toxic than inorganic arsenic com- pounds.

25

NUREG-1437, Supplement 22 A-464 July 2005
Appendix A

Arsenic was listcd as the most dangerous substance In the Top 20

hazardous substances on the CERCLA priority List of Hazardous

Substances for 2001.

Ingesting high levels of inorganic arsenic can result in death. Lower

levels of arsenic can cause nausea and vomiting, decreased produc.

tion of red and white cells, abnorral heart rhythm, damage to blood

vessels. darkening of the skin, and a sensation of 'pins and needles"

in hand and feet. Arsenic is a human carcinogen and can notably

Increase the risk of cancer in the lung, sidn. bladder, liver, kidney and

prostate. The ?MLC is set at 0.05 mg/L, the ACGIH TLV at 0.5 mg/

m', and the NIOSH RE3L at 0.002 mng/ns. The WHO has established

a provisional guideline value of 0.01 mglL for arsenic in drinking

water

Barium -. i

Barium is a silvery-white netal found in nature nd can be produced

synthetically. This chemical Is typically found in compounds combined with sulfur. carbon, or oxygen and eaters the dinking water

afterdissolving from naturally occurring mirals in the ground. Uses

of bariut include: oil and gas drilling muds, auto paint, bricks, tiles

and jet fuels. The effect on a person's heakh is greatly dependent on

how well the compound dissolves in water. Compounds that do not

dissolve well in water are not generally harmful and are oft en used

for medicinal purposes. Ingestion of high-levels result in difficulties

in breathing, increased blood pressure changes in heart rhythin, stcmnach Irritation, brain swelling, muscle weakness. damage to the liver.

'kidney, heart, and spleen. Symptoms of barium contamination include voitding, colic, diarrhea. slow irregularpulse, transient hypertension, and convulsive tremors and muscular paralysis. Death may

occur in a few hours to a few days. The US DHHS, the IARC, and

the EPA have not classified barium as to its human carcinogenicity.

The MCL is set at 2 mgtL and the ACGIH LV is set at 0.5 mg/m'.

Beryllium

Beryllium in Its purc form is a hard, grayish mceta vith no particular

smeU. Naturally, it can be found in compounds within mineral rocks,

coal, soil, and volcanic dust and enters the drinking water from runoff from mining operations, discharge from processing plants and

improper waste disposal. This chemical is often used in electrical

equipment and electrical componentsc Effects of inhalation depend

on exposure possibly causing lung damage and a disease resembling

pneumonia leading to death. Ingestion of beryllium Is not known to

July 2005 . A-465 NUREG-1437, Supplement 22
Appendix A

cause effects in humans due to the restriction of movement from the

stomach and intestines into the bloodstream However, it is a deadly

poison by intravenous routes. Rashes or ulcers arise from direct contact. The US DHHS has determined that this chemical is a probable

human carcinogen. The MCL is set at 0.004 mg/L and the ACGIH

TLV is set at 0.002 mg/m'. The NIOSH REL is set at 0.0005 mg/rn'.

Bismuth

Bismuth is poisonous to humans. Symptoms often seen include: kidney damage, malaise, albuminuria. diarrhea, skin reactions,

exodermnatids, and even death

Boronl

Boron is an incredibly toxic materiaL Symptoms often seen include:

irtitation of the nose, throat, and eyes, depression of the circulation,

persistent vomiting and diarrhea, shock, coma. and even death. Ingestion of large amounts may damage the stomach, intestines, liver,

kidney, and brain. Health effects for long-term exposure are not

known. The US DHHS, the IARC, and the EPA have not classified

the carcinogenicity of boron.

Cadmium

Cadmium is found naturally In the crust. typically as a mineral combined with other elements. This c1emkal does not corrode easily

and is used in batteries, pigments, metal coatings. and plastics. Inhalation of high levels of cadmium will severely damage the lungs and

can lead to death. Ingestion of high levels of cadmium irritates the

stomach, leading to vomiting and diarrhea. Cadmium will build up

in the kidneys, cause damage to the lungs, and creates fragile bones

through long-term exposure to lower levels of cadmium. Skin contact with cadmium is not known to cause health effects in humans or

animals. Beneficial effects of cadmium are unknown. The US DHHS

has determined cadmium and cadmium compounds are probable carcinogens. The.MCL is set at 0.Q05 mgL and the ACGIH TLV is set

at 0.005 mg/th'.

Chromium

Chromium occurs naturally in the ground with no taste or smell associated with this element. This element is found in a few different

forms, namely chromium (II1) as an essential nutrient and chromium

(VI) and chromium (0) typically produced industrially for use in ekctroplatingofmetals. Runofffromold mining operations and improper

NUREG-1 437, Supplement 22 A-466 July 2005
Appendix A

waste disposal re the modes in which chromium typically enters the

groundwater. Inhalation of high-levels of chromium (VI) causes irritations to the nose, such as runny nose, nosebleeds, ulcers, and holes

in the nasal septum. Ingestion of high-levels of chromium (VI) can

cause stomach upsets and ucers, convulsions, kidney and iverda mage. and even death. Skin contact also results in skn ulcers. Other

symptoms to exposure include severe redness and swelling of the

skin in addition to an increased risk of lung cancer. The'World Health

Organization has determined that chromium (VI) is a bumitan eareinogen. The MCL is set at 0.1 mg/L and the ACGIH TLV is set at 0.5

g/rngm. The NIOSH REL is set at 0.5 ng/r'.

Cobalt

Cobalt is a naturally occurring metal that may cause dermatits or

pulmonary'damage. This metal is important to hunian health as a

part of vitamin B12 and used to treatanenia. However.high levels

of exposure severely affect the lungs. Symptoms often seen from

inhalation include: cough, breathing diff iculty. wheezing, decreased

pulmonary function. weight loss, dermatitis, respiratoryhypersensitivity. and asthma. Ingestion of soluble salts produces nausea and

vomiting. The IARC has determined that cobalt is a probable carcinogen. The ACGIH TLV and NIOSH REL are set at 0.05 mgWm'.

Copper

Copper is an essential element forafl living things. This metal is also

a potentially explosive chemrical. Liquid copper explodes on contact

with water. Symptoms often seen include: nausea and vomiting. dianrhea, stomach cramps, irritation to the eyes and respiratory system.

cough, difficulty breathing. and wheezing. The IARC has determined

the earcinogenicity of this chemical Is unknown. ThecACGIH TMV

and NIOSH REL are set at I mg/m'. --

Fluoride

Fluoride is a pale, yellow-green gas that has a strong sharp odor. Fluorides are found throughout the environment at very low levels. Inhalation of high-levels of hydrogen fluoride gas causes damage to the

lungs and heart and can even lead to death. Low-levels of hydrogen

fluoride gas can irritate the eyes, skin, and lungs. Low-leveis of sodium fluoride do help reduce tooth cavities, while high levels of sodium fluoride are dangerous to one's health. The earcinoginicity of

fluoride has not been determined. The MCL is set at 4 mg/L. but the

ACGIi TL"' has not been determined..

28

July 2005 '.- A-467 NUREG-1437, Supplement 22
Appendix A

Lead

Lead naturally occurs in the crust and is found throughout the environment. This clement is used for many purposes and can affect

nearly every organ and system of the body. It typically entcc the

drinking watersupply through contact of wntrvwith corroded materials containing lead. The effects of inhalation and ingestion are the

samc; however. the major systerns affected by lead poisoning include

the nervous system, blood system, and kidneys. Symptoms of lead

poisoning include decreased reaction time, muscle wcakness, loss of

appetite, anemia, malaise, insomnia, headache, irritability. muscle and

joint pains, tremors, flaccid paralysis without anesthesia. hallucinations, and distorted perceptions. Lead poisoning greatly diminishes

the intellectual capacity o chlldren. creates delays in normal physi- cal and mcntal development in babies and young children, and slight

deficits in attention span. T1he LUS DHHS has determined that more information is needed to determine the carcinogenicity in humans.

Te ,MCL has not been determined for this chemical, but the ACGIH

TLV has becn set at 0.1S tngml. The NIOSH REL is set at

0.05 mgtm'.

Manganese

Manganese is a naturally occuning metal that is critical to human

health in tracc amounts. This chemical reacts violently with certain

compounds. Symptoms often seen include: degenerative brain

changes, change in motor activity, muscle weakness, insomnia, mcn- tal confusion, metal fume fever, dry throat, cough, chest tightness, breathing difficulty. vomiting, malaise, kidney damage. and a skin

and eye irritant. The carcinogenicity of this chemical is probable. High levels of exposure include mental and emotional disturbances

and slow and clumsy body movements. The EPA has determined the

carcinogenicity to be unclassifiable. TheACGIHTLV is set at 5 rig/ i. The NIOSH REL is set at I mgtrn?.

Mercury

Mercury occurs naturally in the environment occupying several rms.

The nervous system is greatly affected by this element. High-klvels ofexposure can lead to permanent damage of the brain, kidneys, and

developing fetus. Other limited effects of long-term effects result in

irritability, shyness, and tremors, changes in vision or heating and

memory problems, This chemical is corrosive to skin, eyes, and mu- cous membrancs. Symptoms of cxposure may include gastrointcsNUREG-1437, Supplement 22 A-468 July 2005
Appendix A

tinal disturbance, muscle weakness, anorexia, weight loss, headache,

tinnitus, hypermoHity, diardwha, liverchanges. derratitis. and fevers.

Mercury builds up in the tissues of fish and can then be ingested by humans. The carcinogenic effect of all forms of mercury is unknown.

However. the EPA has determined that mercuric chloride and methylmercury are possible huma ucarcinogens. The MCLis set at .002

mg/Land the ACGIH TLV is set at O.05 mg/m. The NIOSH RELis

set at 0.05 mg/rn'.

Molybdenum

Molybdenum isi a poison and an experimental teratogcn. Syniptoms

often seen in animals include irritation to the eyes, nose, and throat.

anorexia, diarrhea, weight loss, listlessness, liver, and kidney damage. This chemical reacts violently with oxidants. The ACGIH TLV

is set at 5 rngm'. - -

Nicekd

Nickel is an abundant, hardsilvery-white metal found in nature with no characteristic odor or taste. Uses for nickel are expansive and

include platingjwelry, and as catalysts forchemical reactions. Small

amounts of nickel are possibly essential to human life. -Contact to

skin may include allergic contact dermatitis, pulmonary asthma, conjunctivids, and inflammatory reactions. Inhalation of high-levels of

nickel affects the lungs, including chronic bronchitis and reduced lung

function. Ingestion of high-evels of nickel affects the stomach. blood,

and kidneys. The US DHHS has determined that nickel isaprobable

carcinogen. The MCL has not been determined for this chemical, but

theACGIHTLVissetat I mg/Wr. TbeNIOSHRELissetat0.0lS

mgfmi. - '-- 1

Potassium - T c ;

Potassium is an essential dietary element. This chemical is a danger- ous rim hazard. Ingestion of excessive amounts results in kidney

failure. nausea, vomiting, abdominal discomfort, diarrhea, heart ar- rhythmia leading to cardiac arrest, muscular weakness, and temporary paralysis.. -

Selenium - - - ... -

Selenium is found in the environment in rocks and soil. Inhalation of

sclenium can result in soreness, coughing. labored breathing, and lung

edema. Symptoms of exposure to high-levels include: dizziness, fatigue. irritation, collection of fluid in the lunes. and severe bronchi:

30-

July 2005 .A-469 J 5NUREG-1 437, Supplement 22
Appendix A

uis. Ingestion ofhigh-levels could rcsult in irritadoa to the mouth and

throat, in addition to nausea gastrointestinal disturbance, and vorniting. Other results of exposure include brittle hair. anemia, cirrhosis,

deformed nail, and even dcath Contact with skin results in rashes,

swelling, and pain. Chronic exposure might result in pallor, nervousncss, depression, garlic odor orbreath and swvar, gastrointestittal disturbances, and dermatitis. The US DHHS has declared that seleniumn

sulfide is a probable carcinogen. The EPAhas declared that the carcinogenicity of selenium compounds is not classifiable. Thc MICL is

set at .05 mg/L and theACGlH lLV is set at .2 mgrn?. The NIOSH

REL is set at 0.2 mg/rn.

Silver

Silver occurs naturally and is typically found in the environrmnt combined with other elements. Uses primarily inchudc jcwelry, brazing

alloys and solders, disinfectant of drinking water and water in swimming pools, and as an antibacterial agent Inhalation of Ngh-kvels

may lead to lung and throat irritation, and stomach pains. Ingestion

of high-levels may result in death. Skin contact may result in a rash.

swelling, and inflammation. Exposure at low-levels may result in the

deposition of silvc into the ski Long-tenm exposure at high-levels

may lead to arygria. a discoloration of the skin and other body tissues. The earcinogenicity of silver is unknown for humans. The

MCL is not determined for this chemical, but the ACGIH TnV isset

at 0.1 mgtm. The NOSi REL is set at .l mgrni.

T'in

Tin is a natural element in the earths crust. It is a soft. white, silvery

metal that doesn't dissolve in watcr, 1in is used mainly to make cans.

The EPA has limited Its use in paints. Large amounts of tin compounds can cause stomachaches. anemia, liver and kidney problems.

Breathing or swallowing this chemical can cause breathing problem.

eye irritation, and can interfere with the way yotr brain and nervous

system wodt In severe cases, it can cause death.

There is no evidence that tin or tin compounds cause cancer in humans or animals. and tin hasn't been classified for carcinogenicity.

The .MLC hasn't been determined for this chemical. Both the ACGIH

TLV and the NIOSH REL are set at 2 mg/mr'.

Thallium

Thalliutn is a radionuclide found in nature. Ingestion of this chemical

results in nerve or sheath structural changes, extra-ccular muscle "4

NUREG-1437, Supplement 22 A-470 July 2005
Appendix A

changes, sweating. and other efftcts. The MCL is set at 0.002 mg/L

.. and thc ACGIIl TLV is st at 0.1 mg/m.-

Vanadium ;

Vanadium has a variable toxicity. Exposure to this chemical results

in conjunctivitics, rhinids, reversible irritationism of the respiratory

tract. bronchitis. bronchospasms. and asthma-like diseases in more

severe cascs. Thc MCL and ACGIH TLV have not been detcrrined

for this chemical. . : -

Z7inc.

Zinc is a skin irritant. Symptomsn often seen include: cough dyspnca,

sweating, throat dryness. swcet taste in mouth,eough,k eakncss. aches,

chills. fever, nausea, and vomiting.

Pesticides

After the publication of Rachel Carson's book Silent Spring In J 962,

concern arose for the use of chemical pesticides entering the food

chain. Pesticides are toxic to living organisms and yet little Is lknown

about the extent of health effects on humans. Despite the obvious

benefit to eradicating disease-carrying and crop-eating insects, the

behavior of such chemicals is not completely understood. It is known

that pesticides accumulate in fat deposits in the body. 'A mode of

excretion occurs through breast milk, thereby trantferring the harmful chemicals ingested from mother to child. Pesticides greatly affect

the developing fetus, infants and young children. Health effects resulting from exposure cause serious diseases and disorders, damage

to the nervous system, reproductive system and other organs. developmental and behavioral abnormalities. disruption of normal honmonal

function. and immune dysfunction. - ..

Acrylonirile

Acrylonitrile is synthetic material used to taike other chcmicals. In

the past. acrylonitrile was combined with carbon tetrachloride for

use as a pesticide. Symptoms often seen include: conjunicive kritza.

don. somnolence, general anesthesia, cyanosis, diarrhca,'incicased

salivation, photophobia, deepened respiration. nausei, vomiting.

weakness, headachejaundice, anemia, nose and eye irritant. and Icu.

eocytosis. The effect that this chemical has on the human body in32

July 2005 A-471- NUREG-1 437, Supplement 22..
Appendix A

hibits respiratory enzymes of tissue and renders the tissue cells incapable of oxygen absorption. This chemical is carcinogenic The US

DHHS has determined that acrylonitrile is a probable carcinogen.

The ACGIH LV is set ax 2p Thc leNIOSH REL is set at I ppm.

Aldrin and DieIdrin

Aldrin and DieIdrin are chemicals that arm similar in nature and in

effect on humans. In pure form, both are white powders with a mild

chemical odor and do nor occur nantrally in the environment Aldrin

quickly breaks down into diciduin in the body and in the environment. By 1957 all uses of these chemicals were banned. including the

use as a pesticide and for termite control. These chemicals mainly

affect the central nervous system. Ingestion of significantly highlevels of these chemicals results in buildup, convulsions, coma and

even death. The effects of low-levels of exposure include headaches,

dizziness, vomiting, irmtability, uncontroled muscle movements. The

IARC has determined that both aidrin and dieldrin are not classifiable as to their carcinogenicity to humans. The MCL has not been

determined for these chemicals. TheACGIH TLV and NIOSH REL

for both aldrin and dicldrin is set at 0.25 mginr.

Alpha BIIC

Alpha BHC. also known as Benzene Hexaehloride-aipha-isomer. is a

poison by ingestion. This chemical is a confrumed carcinogen with

experimental carcinogenic. tumorigenie. and neoplastigenie data. The

MCL and ACGIH TiV have not been determined for this chemical.

Beta BHC

Beta BHC is also known as trans-alpha-benzenchexschloride. This

chemical is a conrumcd carcinogen with xperimental neoplastigenic

data. Ingestion of Beta BHC is mildly toxic. The MCL and ACGIH

TLV have not been detennined for this chemical.

Chlordane

Chlordane is a thick liquid whose color ranges from colorless to amber with a mild and irritating smell that was manufactured for use as

a pesticide. Uses of this chemical were completely banned in 19SS

by the EPA. Although chlordane is not very mobile in soils, it is

known to enter the drinking water after application on crops near the

water supply intakes or well. Exposure to this chemical affects the

nervous system. digestive system, and the liver. It has been found

that chlordane Lcks the ability todisrupt hormones by itself but gratly

33

NUREG-1 437, Supplement 22 A-472 July 2005

I
Appendix A

magnifies the ability of other chemnicals to disrupt hormoncs. Inhalation of high-levels of chilordane include: headaches, irritability, confusion, weakness, vision problems. vomiting. stomach cramps, diarrhea, andjaundice have occurred in people who breathed air containing high concentrations of chlordanc or accidentally swallowed small

amounts of chlordane. Ingestion of high-levels leads to convulsions

and death. The IARC has determined that chlordane is not classifiable as to its carcinogeniciy tohumans. The MCLisseetat O.02mg/

L and the ACGIH TlV and NIOSH REL are set at 0.5 mgfm3 .

DDD

DDD, also known as 1,1-bis(4-chloropbenyl)-2.2-di-chloroethane,

was once used asapessicide. Uses for this chemical have been banned.

This chemical contaminates DDTprodus and DDT typically breaks

down into DDE or DDD. The nervous system is greatly affected.

Symptoms often seen include: excitability, tremors, and seizures.

Ingestion results in poisoning. The US DIHHS has not determined

the carcinogenicity for DDD. This pesticide is a known carcinogen.

DDE

DDE, alsoknovn as Z2-Bis(p-Chkonpheyl)l:I.-Di-Chloroethylcne,

sometimes is a contaminant for DDT products with no commercial

use. The US DHHS has not classified DDE as to the carcinogeniciry

to humans. The EPA has determined that this chemical is a probable

carcinogen. The MCL and ACGIH TLV have not becri determined

for ths chemical. ''"

DDr -r

DDT, also called 1,1,1-trichloro-2.2-bis(p-chlorophenyl)cthane, is a

manufactured chemical used as a pesticide. This chemical is a white,

crystalline solid with no odor or taste. The use of this chemical was

banned in the United States, aside from public health emergencies.

Symptoms of exposure may include irritation to the eyes and skin,

anxiety, dizziness, confuslon, discomfort, headache, veakness and

exhaustion convulsions. onmiting. excitability, tremors, and seizures.

Long-term exposure to this chemical affects the nervous system and

results In changesin the levels of liver enzymes: Tbe US DHHS has

determined that this 6hemical is a probable human carcinogen. Thc

MCLhas noi been determined forthischemical,buithe'ACGIH nLV

issetatlngIm 3 . The NIOSHRELis setatO.Smgim'n. ' <

34

July 2005 A-473 - NUREG-1437, Supplement 22
Appendix A

DI-n-butyl phthalate

Di-n-butyl phthalate exposure symptoms often seen Include: cye. stomach. and upper respizatory irritation, hallucinations, distorted percep. dons. nausea orvomiting, and kidney. ureteror bladderchanges. The

ACGIH TLV and NIOSH REL arm set at 5 mg/m`.

Dicambs

Dicamba. also known as 2-.Maethoxy-3,6-Dichlorobcozoic Aeid, is

rnoderately toxic by ingestion. The tCL and ACGIH TLV have not

been deternmined for this chemical.

1,2-Dlchloroethane

1,2-Dichloroethane, also known as ethylene dichloride, is a synthetic chemical that is used to make otherchemicals. Symptoms often seew include: somnolence, cough. jaundice, nausea or vomiting. hypermotlty, diarrhea. ulceration orobelding from the stomach. farty liver degeneration, change in cardiac rate, cyanosis, coma, dermadds. edema of the lungs, toxic effects on the kidneys, and severe cor- neal effects The US DHHS, the IARC and the EPA have not classi.

fied the carcinogenicty oi'this chemical. The ACGIH TLY is st at

10 ppm. The NIOSH REL is set at I ppm.

Dinoseb

Dinoseb, also known as 2-sec-Butyl-4,6-dinitrophenol, is a widely used herbicide. This chemical enters the drinicing water after appli- cation on orchards. vineyards. and other crops. This chemical is a poison by ingestion and a severe irritant to the eyes. Pathways the

chemical may travel into the body include. skin contact, subcutaneous, and intraperitoneal routes. The carcinogenicity is questionable with experimental tumorigenic dat. The .NCL is set at 0.007 mg/L for the chemicaL while the ACGIH TLV has not been detcrmined.

Endosullan n

Endosulfan 11 is a pesticide and wood preservative found in solid

formn as erystals or flakes. This chemical smells similar to turpentine and does not burn. This chemical affects the central nervous system but does not accumulate significantly in human tissue. Symptoms of

exposure may include irritation to the skin, hyperactivity. nausea. dizziness, headache, tremors, or convulsions, and even death may occur. The carcinogenicity of this chemical is unknown. The M1CL

has not been determined for this chemical, but the ACGIH TLV and

NIOSH REL are set at 0.1 mgrnm.

35

NUREG-1437, Supplement 22 A-474 July 2005
Appendix A

Endothall

Endothall is a poison extremely irritating to skin. eyes, and mucus

membranes. Symptoms often include: diarrhea.

Endrin :

Endrin is a pesticide that is i solid, white, almost odorless substance

that is banned from use in the United States. This chemical accumulates in sediments and aquatic and terrestrial biota.' Exposure to endrin can cause various harmful effects including death and severe

central nervous system (brain and spinal cord) injury. Ingestion of

this chemical may cause convulsions and will kill you In a matter of

minutes to a maner of hours. This chemical does not accumulate in

human tissue. Symptoms resulting from exposure include headaches.

dizzincss, nervousness, confusion, nausea, vomiting. and convulsions.

Effects of inhalation or contact are not known. The EPA has dcclared the human carcinogenicity to be unknown. The MCL is set at

0.002 mngL and the ACGIH TLV and NIOSH RELare set at 0.1 mg/

in1.

Gamma-chiordane

Gammhachlordanc is no longer permitted for use as a tcnriticide or

pesdcide.- Symptoms often seen include. tremors, convulsions, excitemeni. diarrhea, jaundice, vomiting, stomach cramps, vision probJerns. ataxia. central nervous system stimulant. and gastritis. The IARC

has not determined the carcinogenicity of this chemical. The ACGIH

ThLVandNIOSHRELaresetatO.5 mgtm'.

fieptachlor and Heplachior Epoxide (Epoxyhcptachioris),

Heptachior and Hcptachlor Epoxide (Epoxyheptachloris) are manufactured chemicals found as a white powder that smeD like camphor

(mothballs). Heptachlor breaksdoin intohepachlorepoxide. These

chemicals were used primarily as insecticides until 1988. Ingestion

of heptachlor results in dizziness, confusion, or convulsions. hbe

full extent of heptachlor and heptachlor epoxide poisoning are unIknown for humans, other than damage to the nervous systenL. Lowlevels of exposure have caused liver damage and the symptoms include tremors, convulsions. kidney damage. respiratory collapse, and

death. The IARC has determined that heptachlor and heptachlor epoxide are not classifiable to their carcinogenicity to humans.-:The

MCL for hepmchlor is set at 0.0004 rng1L and the MCi. for hep.

tachlor epoxide is set at 0.0002 rngL The ACGIH TLV has not

been determined for these chemicals. The NIOSH REL is set at 0.5

m omr. 36

July 2005* A-475 NUREG-1 437, Supplement 22
Appendix A

Heptnchlorinated dibenzo-p-dioxins

Heptachlorinated dibenzo-p-dioxins is a type of dioxin. Dioxins aw understood to function in a similar manner as a steroid hormone. This

implies that the dioxins enter the body and bind to a protein. Acorn.

plex is then formed that attaches to the cell's chromosomes, thereby altering the genetic material and affecting the body in many different

ways. The MNICL and ACGIH TLV have not been determined for

these chemicals.

Isopropanol

Isopropanol is also known as Isopropyl alcohol and is a moderately toxic chemical. Symptoms often seen include: flushing, pulse rate

decrease, blood pressure lowering. anesthesia, narcosis, headache,

dizziness. mental depression, drowsiness, hallucinations, distorted

perceptions, dyspnea respiratory depression. nausea or vomiting, and coma. The ACGIH TLV and NIOSH REL are set at 400 ppm.

Lindane

Undanc, also known as benzene hexachloridc. is a pcsticide that mimics natural bormones Under favorable soil and climatic conditions,

lindane enters the drinking water through runoff of contaminated

raterials into surface water or by leaching into the groundwater. Inhalatioe results human systemic effects by headache, nausea or vom- iting, and fever. Pathways taken by this chemical into the body include: ingestion, skin contact, and subcutaneous routes. This chemical is more toxic than DDT or dieldrin and is shown to damage the nervous system and circulatory system. Undane is a confirmed car- cinogen with experimental carcinogenie, neoplastigenic, and tumorigenie damt by ingestion and skin contact. The .MCI is set at 0.0002

mg/E, but the ACGIH n.V has not been determined for this hchmical.-

Methykne chloride

Methylene chloride is a synthetic material that is also a severe skin

and eye irritant Symptoms often seen include:- dizzincss. naisea,

decreased attentiveness, paresthcsia. somnolence, altered sleep time, convulsions, euphoria, change in cardiac rate, and a severe eye and

skin irritant; The US DHHS. the WHO, and the EPA have determrined that nethylene chloride is a probable carcinogen. lhis chemical is a knomn carcinogen. The ACGIH TLV is set at SO ppm.

37

NUREG-1437, Supplement 22 A-476 July 2005

I
Appendix A

Napthalene

Napthalcne is a naturally occurring material typically used to make

dth insecticide carbaryL Symptoms often seen include: damage to

red blood cells, fatigue, lack of appetite, resdessncss, nausca, skin

and eye irritant, headache, diaphorcsis, hemannia, fever, anrnia, liver

damage. vomiting,renal shutdown.corneal damagc convulsions, and

coma. The US DHHS, the IARC, and the EPA have determined the

carcinogenicity of this chendcm l is not classifrable. TbeACGrHTLV

and N1OSH REL ar set at 10 ppm.

Pentachlorophenol

Pentachlorophenol is a synthcdc chemical that is extremely dangcrous and was used as a pesticide. Symptoms often seen include: acute

poisoning marked by weakness, changes in respiration, blood pressure, and urinary output, dcrmatitis, convulsions and collapse. anorexa, weight loss, sweating, headache, dizziness, nausea, vomiting,

breathing difficulty, chest pain, and livcr and kidncy injury. The EPA

and the IARC have determined this chemical to be a probable carcinogen. This chemical is a known carcinogen. The ACG[H TLV

and NIOSH REL are set at 0.5 rnmgtm. - .

Phenol --

Phenol is a synthetic chemical that was widely used as a pesticide.

Symptoms often seen include: severe eye and skin irritation, kidney,

liver, pancreas, and spleen damage, edemna of the lungs;'anorexia,

weight loss, weakness and exhaustion, muscle ache, pain. corrosion

of the lips, mouth. duat, esophagus and stomach, gangrene and even

deiad. The careinogenicity of this chemical is unknown. The ACGIH

TLV andI.IOSH RELare set at 5 ppmt.

Toxaphene

Toxaphene, also known as Ctlorinated Camphene, is ari insecticide

that mimics natural hormones. Ingestion and skin contact result in

somnolence, convulsions or effect on seizure thOshold coma. and

illergic'skindermatitis. Symptoms of exposur may Include nausxa,

confusion, agitation, tremor. convulsions. unconsciousness, or dry

and redskin. Carcinogenicityoftoxaphencis probablc.The MCLis

set at 0.003 mglL and the ACGIH TLV is sct at 0.5 mgmg.

2,4,S-Tn - - -

2,4,5-TP, also known as (2.4.5-Trichlorophcnoxyl)Propmionic Acid,

'is comin6nlytreferrcd to as Silvex. Ingesiion results in poisoning.

July 2005 .. A-477 NUREG-1437, Supplement 22 -
Appendix A

The carcinogenicity of Silvex is probable. The NICL is set at 0.05

mngi.. but the ACGIHI ThV has not been determined.

2,4,5.T

2.J.5.T, also known as Z,4.S-trichlorephenoxyactic acid, is readily

absorbed through inhalation and ingestion and slowly through contact. Effects ofcexposure include: weakniess, letharg. anorexia, diar-:

rhtea. rentricular fibrillation. Chronic exposure can result in cardiac

atrest and even death. The NICL has not been determined, but the

ACGIH TLV and NIOSH REL are set at 10 mrgrn1

.

Xylene

Xylemi is a naturally occurring material in petroleurn and coal tar.

This chemnical is a severe skin and eye irritant and greatly affects the

brain. Symptoms often seen include: olfactory changes, conjunctiva

irritation, puilmonary changes, headaches, lack ot muscle coordinaLion, dizziness, confusion difficulty breathing. and gastrointestinal

discomfort 'This chemical is a dangerous frut hazard when exposed '

to heat or flamne. T'he IARC has determined the carcinogenicity of

this chemical is not classifiable. The ACGIHTMY is set at 1 00 ppm.r

o-Xylene

o-Xylene. also known as 1.2.Dimethylbenzese. is a mildly toxic

chemnical. This chernical is a very dangerous fire hazar when ex- posed to heat or flame. Symptoms often seen include: irritation to

the eyes, sgin. nose, and throat, dizziness, excitement, drowsiness.

incoordination. staggering gait. corneal vacuolization, anorexia. nauSea, vomiting, abdominal pain and dermatitis. T'he ACGIJH TLV

and NlOSH REL aresewat IOU ppm.

Radionuclides

RPadlonuclides are atoms with structures that are out of balance.

The atoms are continually changing, or decaying, into a mor stable

form. The decay process releases energy. otherwise known ais

radiation, Any alteration to the delicate balance that atoms maintain

affects the structure and stability of the cell, As radiation strikes an

atom, die balance is disrupted and the atom, gains a positive or

negative charge. These stoma are called ions and the ionizaion of

atoms and molecules inside a living cell results in damage to the

cell.

39

NUREG-1 437, Supplement 22 A-478 July 2005

I
Appendix A

Ionizing radiation results in health problems. There are three _

important types of radiation that cause ionizing radiation: alpha and

beta particles, and gamma rays. Alpha particles are large enough

particles that the outer layer of dead skit wil prevent the penetration of alpha particles into the human body. -However. if an alpha

particle does indeed enter into the lungs. the ionizing energy will -

break through cell walls. These particles have a charge of I2. The

positive charge enables these particles to be effective ionizers that

travel at relatively slow speeds and short ranges. -

Beta particles are smaller negatively charged particles thiat are the

equivalent to electrons. These particles originate in the nucleus

whereas electrons originate outside the nucleus. Although beta

particles are not radioactive, the atoms that emit the particles re.

The energy and speed result in damage to cells. Solid objects stop

these particles easily.

Gamma rays have incredibly high energy and can easily pass

through lead and several feet of concrete. These parices don't

need to be ingested or inhaled to seriously damage the human body.

Damage brought aboutby exposure to radioactivity results in

cancer. All radionudides are known carcinogens. In regards to

other chemicals, the carcinogenicity is not always certain.

Plutonium

Plutonium is a radionuclide that is extremely dangerous. Plutonium-236 is an alpha cmitter. The high radiotoxicity of plutonium

determines the toxicity of plutonium compounds in addition to

other atoms in the compounds they formn. Any event that fizther

spreads this radionuclide into the environment is dangerous to the

life and land. This chemical was created expansively in nuclear

weapons production and nuckar power plants. -The MCL Is set at

15 pCi/L f l...* .

Strontium ; - -

Strontium isa radionuclide with similai properties to calciurn.aStrondurm-90 is a beta emitter The stable form has low toxicity

and ignites spontaneously in air. N'Vhen strontium is combined with

water or steam. it reacts vigorously to evolve into hydrogen. The

MCL is set at 50 pCifL.

July 2005 A-479 NUREG-1 437, Supplement 22.
Appendix A

'torium

Thorium is a radionuclide found in nature. Thorium .232 is an

alpha emitter. The carcinogenicity of thorium is probable. The

MCL. is set at 15 pCi/L

Titium

Tridtum is a radionuclide that is not an external radiation hazard.

This radionuclide is an alpha ernitter. When tridated water is

ingested. the blood distributes the materials equally among all of

the body fluids. As a human is exposed to tritium, the soft tissues

are irradiated. The MCL is set at 20.000 pCIIL

Uranium

Uranium is a radionuclide found in the envimonment that is highly

toxic on an acute basis. Uranium-238 is an alpha eminer Exposure at higb-levels to uranium results in kidney damage, acute

arterial lesions, and cancee Soluble uranium compounds can be

absorbed rapidly into the body. The MCL is set at 20 pg/L and the

ACGIH TLV is set at 0.2 mg/rnm.

ENDNOIES

' Rachel-s Environmental Health News. #640 -Chlorine Chemistry

News. March 04. 1999.

2 Rachel's Environmnental Health News. 4498 - Dangers of Chemical Combinations, June 13, 1996

3 htrtn/N.'w cnv mroelrhnctbnn otrhoxics'hreawv rmertal

41

NUREG-1437, Supplement 22 A-480 July 2005

I
Appendix A

APPENDIX 1. Abbreviations and

Acronyms -

ACGIH- American Conference of Governmental

Industrial Hygienists

ATSDR -Agency forToxic Substances and Disease

Registry

DHHS - Department of Health and Human Services

DOE - U.S. Department of Energy

EPA - Environmental Agency

FDA - Food and Drug Administration

HR-HazardRating , . IARC - International Agency for Research on

Cancer

MCL -Maximum Contaminants Levels (mg/L)

NIOSH - National Institute for Occupational Safety

and Health

OSHA - Occupational Safety and Health Administration

The OSHA scts permissible exposure limits

(PELs) to protect workers against adverse

health effects resulting from exposure to

hazardous substances.

PAH - Polycyclic Aromatic Hydrocarbon

PCB - Polychlorinated biphenyl

pCi - pico-Curies. measurement of radioactivity

PELs - Permissible Exposure Limits

The PELs determined hazardous substances

are enforceable, regulatory limits on allowable indoor air concentrations.

PETN - Pentaerythritol tetranitrate

REL - Recommended Exposure Level

SMCL - Secondary Maximum Contaminants

Levels (mgIL)

TLV -Threshold Limit Value

WHO - World Health Organization

42

A-481 ^ ~ NUREG-1437, Supplement 22 July 2005
Appendix A

APPENDIX 2. Glossary

* Anemia: A decreased ability of the blood to

transport oxygen

* Carcinogen: Any substance that produces

or promotes cancer

* Carcinogenldty- Ability to cause cancer

* Irritant. Abnormal reaction to a substance

* Long-term: 365 days or longer

* Milligram (mg): One thousandth of a gram

* Ibmor: An abnormal mass of tissue

i

i

i

i

43

NUREG-1437, Supplement 22 A-482 July 2005
Appendix A

APPENDIX 3. Bibliography

BWXT.Pantex, LLC. "2000 Site Environmental eport for

Pantex Plant", DE-AC04-00AL66620, May 2001: Tables 6.1-

62..

Lxwis, Richard J. "Hazardous Chemicals Desk Reference,"

1993.

Olflce or the Federal Registry Nationsl AmThives an eRecords

Administration. Code of Fedel Rguhlations: Pmreciion of

Eniironment Volume 40, Parts 100 to 149. Revised as of July

1, 1994: p. 722.742.

Offlce of Water, US EPA: "Drinking WaterStandards and

Health Advisories", EPA 822-B1-00001, Summer 2000.

SAM Stoller Corporation. "Final FY 2000 Summary and

Progress Report for Groundwater Investigations at DOE

Pantex Plant", Volume L.January 29,2001.

,websites:

ATSDR. "lb2FAQs: Frequently Asked Questions about

Contaminants Found at Hazardous WVaste Sites5, <htt!Q1I

w-,'w~atsdr.cdcIrovhoxfaq.hfmr.

ESER Program. "Gross Alpha Radiation", "Gross Beta

Radiation". <hlt;AwstoneresrcmtFactShee#>.

National Institute for Occupational Safety and Health.

"NIOSH Pocket Guide to Chemical Hazards", Pdtt

-vw.cdc.gov/nkioshn tnrpg h1mlm.

US EPA. "Chemicals in the Environment: OPPT Chemical

Fact Sheets", April 25,2001, <.cwwwepa.govopptintr/

ractswhtrn>.

US EPA. "Current Drinking WaterStandards", January 23,

2002, <httpl/www.epa.gov/satewvaterlmcl.html>.

July 2005 A-483 NUREG-1437, Supplement 22
Appendix A

US EPA. "IRIS Substance List", <hit l//wwwp2a.eovAri' substlnde%,htm>.

US EPA. "List of Contaminants and MCLs", 4titas pa 2ov/safe2Atr/nwIhImI,<http' /v- - ena IovL

.rtewtedrekcfrrIS .ndf>.

WHO. "Gnideiines for drinking waterquality." <Ich tte

wwwewhopInt/water uniantlon hen1t2IGDWO/. -

Reigart, J. & Roberts, J. "Recognition and MAnagement or Pestidde Poisonings", Fiflh Edition, 1999: <h1g:/t wwwmenar Ipvloeav IhretbvhidIhcahandbookW

handy p L/dfr. el

httpil/vrgis~usioedut-sanduktdpaperigisca/flodC14.htmI

45r

NUREG-1437, Supplement 22 A-484 July 2005
Appendix A

Radiation Chart Page 1 of 4

--- Pemet : IeasinCnerIaide, CbuPrtaiyarndOtbi He2tEffects of

HurnmEzposueto lonimigRwidikm

ltXDO 1.1 _ . r _

Ii IwI H

* .1

-A, 

Iwo

:IC"

., 9 OM I

ff U

FI

- 2 3 * 5 67 is 9 10 1 1a id Is 16 to la t9 tz2 21 22 25 D 25 Z s29 D Jr 32 33 Jo as X tat

-m Seiacdtozreupor& ztee ;isu ~r & ~fII (@

Legend for "Percent Increase in Cancer Incidence, Cancer Mortality, and Other Healtl

Effects of Human Exposure to Ionizing Radiation" ;

1. 15 00% increase in incidence of testicular and ovarian cancer in children on Navaho reservation in

uranium mining area

2. :S00% increase in bone cancer in children afeeted by uranium .

3. 2500/. increase in leukemia (all ages) in the Navaho population' -

4. 200% increase in each of the following non-cancer effects: miscarriage, infant death, congenital

defects, genetic abnormalities, learning disorders.

Baseline for 1-4: Navajo residents living near Uranium facilities were compared to Navajo resider

in non-uranium areas

5. 5000/c increase in bith'defects when compared to the national average.

(Southwest Research and Information Center. "Uranium Legacy." The 1%'orkbooA, v 8, no 6.

.Albuquerque,NM: 1983.) - . . v..

6. 4000,o increase in leukemia incidence in the population living downwind of the Pilgrim nuclear poi

reactor in Massachusetts in the first 5 years after fuel *as know to have leaked excess radioactivit%

Baseline: Discase in population before and after Pilgrim radioactive releases and comparison to

htp://wwnwv.nirs.org/radiation/radcbart.htm 03113/2005

005 A-485 NUREG-1437, Supplement 22 July 2(
Appendix A

Radiation Chart Page 2 of4

upwind population.

(Morris M. Knorr R. The Southeastern m assachusells Health Study 1978-1986-Report of the

A'fassacihusents Department of Public Health. October 1990. See also: Clapp R. Cobb S. et al.

"Leukemia Near Massachusetts Nuclear Power Plant." Letter in Lancer. December 5, 1937.)

7. 300-400% increase in lung cancer in the general population within the plume of the Three Mile

Island accident releases

S. 600-700%/a increase in leukemia in the general population within the plume of Three Mile Island

accident releases Baseline: Disease in population upwind (out of the radiation plume path) is

compared to disease in population downwind (in the pollution plume.)

(Wing S. Richardson D. et al. "A Reevaluation of Cancer Incidence Near the Three Mile Island

Nuclear Power Plant: The Collision of Evidence and Assumptions." Environmental Health

Perspectives, v 105, no 1. National Institutes of Health. Bethesda, Maryland. January 1997.)

9. 50% increase in childhood cancer incidence in the Three Mile Island area for each 10 millirern

increase in radiation exposure per year.

Baseline: Children living with different radiation levels are compared for evidence of disease.E

(Hatch M. et al. 'Background Gamma Radiation and Childhood Cancers Within Ten Miles of a U.'

Nuclear Power Plant." InternationalJournalofEpidemiology, v 19, no 3. 1990.)

10. 8000 0h0 increase in thyroid cancer in Belarussian children living near Chernobyl, reported 6 years a

the meltdown.

Baseline: Comparison of population health before and after the Chemobyl explosion.

(Hudson RL. 'Child Cancers Found to Rise Near Chernobyl." The Wall Street Journal.-September

1992. The article they quote was published in Mature on the same day and was researched by the

WlVorldHealth Organization.)

Further effects found in victims of the Chernobyl accident less than ten years after the meltd.

II. 500% increase in thyroid cancer in Ukrainian children.

12. 75% increased incidence of heart disease

13. 200% increase in respiratory and digestive disease

14. 200% increase in birth defects

15. 200% increase in spontaneous abortions

Baseline: Comparison of population health before and after the Chemobyl explosion

(Rupert J. "Illness Tied to Disaster Still on Rise." The Washington Post. June 24, 1995.Ihe reportu

was quoting Britain's Imperial Cancer Research Fund The Ukrainian Health Minisoy and the U.:

Nations.)

16. 63% increase in leukemia incidence among workers at Oak Ridge National Laboratories(US) who

received very low doses of external (gamma) radiation on the job.

17. 123% increase in leukemia incidence in the same population where there wvere also very low intern

doses of radioactivity Baseline: Cohort comparison of worker deaths and radiation exposure levels

(Wing S. Shy C. et al. "Mortality Among Workers at Oak Ridge National Laboratory: Evidence of

Radiation Effects in Follow-up Through 1984." JAVA, v 265 no 11. March 20, 1991.)

IS. 80%1 increase in eight types of cancer deaths in Department of Energy atomic workers exposed to

httpiJ/wwwav.nirs.orgfradiation/radchart.him 03/13/2005

NUREG-1 437, Supplement 22 A-486 July 2005
Appendix A

Radiation Chart Page 3 or 4

external doses of radiation. Baseline: Various baselines. Usually cohort comparison of workers wi

various doses and their deaths from resulting diseases were used. -:

(Mancuso TF. Stewart A. Kneale G. "Radiation Exposures of Hanford Workers Dying From Canci

and Other Causes." HealthPhysics, v 33. Pergamon Press,-Great Britain. November 1977.)

19. 200% increase in leukemiain children ofatomicworkers Baseline: The parents of children -%ith

cancer were compared for occupation to discern if those adults who worked with radiation hid moi

children with cancer than those who worked in otherjobs. - -

(Roman E. et al.2Case-control Study of Leukemia and Non-Hodgkin's Lymphoma Arong Childn

Aged 04 years Living in West Berkshire and North Hamnpshire Health Districts." Boot 1993 #306.

20. 287% increase in cancer incidence in children of nuclear workers who received internal radiation ii

England

Baseline: Theparents of children with cancerwere compared foroccupation to discern if thoseadt

who worked with radiation had more children with cancer than those who worked in other jobs.

(Sorahan T.-Roberts PJ. Childhood Cancerand Patemal Exposure to Ionizing Radiation: Prelirnin

Findings From the Oxford Survey of Childhood Cancers."AmericanJournalofIndustrialMedicin

23: 343-354. 1993.)

21. 2500/o increase in all cancers among atomic workers

22. 190%/o increase in leukemia incidence , -Baseline: General Population ;

(Kendall. GM. et a]. "Mortality and Occupational Exposure to Radiation: First Analysis of the

National Registry for Radiation Workers." BMJv 304: 220-5. 1992.);

23. 500% increase in childhood leukemia in children visiting the beach once a week near the French

nuclear reprocessing facility at LaHague - . - : .

24. 760% increase in childhood leukemia if they ate the local fish regularly

25. 345% increase in childhood leukemia associated with drinking well water from the vicinity of the

nuclearfacility

- Baseline: Observed leukemia cases were compared to expected leukemia cases.

(Viel JF. Pobel D. Incidence of Leukaemia in Young People Around the La Hague Nuclear Waste

Reprocessing Plant: A Sensitivity Analysis." Statistics in Medicine. v 14: 2459-2472. 1995.) --

26. 1200% increase in all cancers exist around the Sellafield, (formerly Windscale) reprocessing facilil

and of these,

27. 600-1000% increase in leukemia of children whose fathers were exposed to certain amounts of

radiation prior to conception

28. 1000% increase in lymphoma was found in children near a reprocessing facility in Cumbria.

Baseline: Local and Area Controls - . ,. (Gardner et al. Results of Case-control Stud) of Leukemia and Lymphoma Among Young People

Near Sellafield NuclearPlant in West Cumbria." RB.Jv 300. February 17, 1990.)

29. 1000% increase in leukemia incidence in children living near a nuclear reprocessing facility

Baseline: Children of the same age in the same area prior to the facility's operation.

(Heasman et al. "Childhood Leukemia in Northern Scotland." Lancet, v 1:266. 1986.)

30. 27.3% increase in all cancer deaths among atomic wvorkers exposed to internal doses of radiation

Baseline: Comparison of worker deaths and radiation exposure levels.

(Morgenstern H. Froines J. Epidemiologic Study to Determine Possible Adverse Effects to

Rocketdyne/Atomics International Workekrs from Exposure to Ionizing Radiation. State of Califorr

hnp://S snirs.orglradiation.radchart.htm- -. 0311312005

July 2005 A-487 , NUREG-1 437, Supplement 22
Appendix A

* . Radiation Chart Page 4 of 4

Health and Welfare Agency. June 1997.)

31. 500%,49 increase in leukemia among Utah nuclear bomb test Dowvnwinders

32. 121% increase in thyroid cancer incidence in the same group 33. 200%/a increase in breast cancer

34. 700%rO increase in bone cancer

Baseline: Utah Mormons exposed to bomb fallout are compared to'all Utah Mormons.

(Johnson Cl. "Cancer Incidence in an Area of Radioactive Fallout Downwind From the Nevada Te

Site." JAMA, v251 n 2: 231-6. January 13, 1984.)

35. a greater then 120%/e increase in thyroid cancer in those who drank milk laced with Iodine-I 31 fron

atmospheric nuclear weapons tests

Baseline: Estimated cases are based on dose reconstruction where estimated exposures were betwe

6-112 raids per individual child in the bombs' plumes.

(Ortmeyer P. Makhijani A. "Let Them Drink Milk." The Bulletin of the Atomic Scientists, Nov/Det

1997.)

36. 200% increase in lung cancer in women who received radiation treatments for breast cancer

Baseline: Breast cancer patients treated with radiation were compared to those who were treated o, by other methods.

(Bishop JE. 'Study Links Breast Cancer Treatment to Higher Risk of the Disease in Lungs." The V

Street Journal, May 14, 1993: B6.)

37. 66-96% increase in early cancer deaths due to background radiation

Baseline: Deaths of children living with different radiation levels are compared for cancer.

(Kneale GW. Stewart AM. 'Childhood Cancers in the UK and their Relation to Background Radiation." Radlation amd Health. 1987.)

This list was compiled by Cindy Folkers & Mary Olson on 4/24/98, Nuclear Information & Resource

Service, 1424 16 th St, NW Suite 404, Washington, DC 20036 (202)328-0002 - it is arbitrarily based on

what studies are on file at NIRS.

A partial list of non-cancer health effects of human exposure to radiation:

Downs Syndrome

Hydrocephaly

Microhydrocephaly

Cleft Lip and Palate

Epilepsy

Kidney and Liver Damage

Thyroid Disease

Low Birthweight

Increased Infant Mortality

Increased Stillbirth

Genetic MutationsiChrom osom al Aberrations

Spinal Defects

Congenital Malformations

http: /Azovnv.nirs.org'radiation/radchart.htm 03/13/2005

NUREG-1437, Supplement 22 A-488 July 2005
Appendix A

Richard Emch A Millstone - Notice of Intent to Sue Pane I I

}D7 A6 A7e-- . .

From: .cNancyBurtonEsq~aol.comr

To: <rftonrc.gov>

Date: 3121105 12:13PM

Subject: Millstone - Nolce of Intent to Sue - - -

Mr. Emch

Please Include this message and the attachmnent In your EIS review.

Thank you. -

Nancy Burton

CONNECTICUT COALITION AGAINST MILLSTONE -

_www.mothbalmlllstone.org_ (httprAlvwwmothbanmfllstoneorg)

COALITION ANNOUNCES SUIT AGAINST MILLSTONE: -

CHARGES ILLEGAL DISCHARGES ENDANGER HEALTH AND ENVIRONMENT . ;,. ,. .. - ; ':- ^-.

For Immediate Release: March 21, 2005

Contact: Nancy Burton 203.938-3952

Waterford--The Connecticut Coalition Against Millstone announced today

It will bring a federal lawsult to slop alleged Illegal discharges of

chemical and radioactive waste Into the Long Island Sound by the Millstone Nuclear

PowerStatkin. -

The Coalition served Dominion Nuclear Connecticut, Inc.. owner and

operator of the nuclear facility, with a formal notice of Intent to sue, a legal

pre-requishe to bring a federal lawsuit under the provisions of the Federal

Clean Water Act.

The Coalition's notice alleges that permits Issued by Connecticuts

Department of Environmental Protection have expired, were issued beyond DEPis

authority and were illegally transferred to Dominion by Northeast Utlilles In

2001.

/.1

1 af 0 C; ' - X/-/-

.1 ..1

. .  7

Dominion and its predecessor, Northeast Utilities, have treated the

Long Island Sound as If It were their private nuclear and toxic waste dump.'

sald Nancy Burton, a Coalition leader.

'With this lawsuit, Dominion's dumping days wilt be over. Burton said.

The CoaRition tisled 38 radioactive Isotopes and 146 metals and

chemicals - many of them carcinogens - which are believed to be routinely

discharged Into the Long Island Sound under permits which have expired or aro illegal.

The Long Island Sound would be spared contamination by these deadly

radioactive and toxic agents If the government ordered Millstone to convert to

a closed cooling system such as we have advocated since 1999." Burton said.

The links between Millstone's effluent discharges - which are washed

by the tides and currents onto the shorelines of Waterford and East Lyme -

and human health effects are established." Burton said.

On March 10. 2005. at a press conference convened by the Coalition. Dr.

Helen Caldicott, a world-recognized authority on the health effects of

low-level Ionizing radiation, publicly linked Millstone effluents with the rare

jawbone cancer found In Zachary M. Hartley when he was born on December 16.

6 i a Z.,"r

July 2005 . A-489 .'- NUREG-1437, Supplement 22 -
Appendix A

Richard Emch - Millstone - Notice of Intent to Sue Page 2

1997.

Zachary's mother swam daily during critical months of her pregnancy at

the HoleI~n-the-Wall beach on Niantic Say 1.5 miles from Millstone's

discharge point

Under the permits which the Coalition says have expired and were

illegally issued. Millstone Is permitted to discharge radioactive and toxic

chemical effluents at heightened concentrations to a 'mixing zone' which Is defined

as the area in Long Island Sound within 8.000 feet - or roughly 1.5 miles -

from Its discharge point.

One radfnuclide - cesium-1 37. which Dr. Caldicott Identified as a possible factor In Zachary's jawbone cancer-was found In a fish caught by NU

In Niantic Bay In 1997. the year of Zachary's gestation. NU admitted the

contamination originated fom= Its effluent releases.

The Coalition is investigating other Instances of cancers which have

developed in people who have swum and sunbathed on the Niantic and Watertord

shorelines near Millslone.

Note to Editors: The Coalition's Notice od Intent to Sue (10 pages) Is

attached.

-30-

CC: <ajkl Onrcmgov>. <secyOnrc gov,

NUREG-1437, Supplement 22 A-490 July 2005
Appendix A

i Rkhard Emch -CCAMNoaicelntentTo~ueDominion32105.cfoc Pa elT

CONNECTICUT COALITION AGAINST MILLSTONE - . - www.mothballmillstone.orp

March 21, 2005

Dominion Nuclear Connecticut, Inc.

Millstone Nuclear Power Station

314 Rope Ferry Road -

Waterford CT 06385

Dominion Generation

P.O. Box26666

Richmond VA 23261

Re: Notice of Intent to Sue

i

MPS-83-1

i

t

I

Dear Sirs:

The Connecticut Coalition Against Millstone ("the Coalition" is an

organization uniting statewide clean-energy groups, Millstone.

whistleblowers and families and individuals who reside In Connecticut

and elsewhere, Including within the emergency evacuation zone of

the Millstone Nuclear Power Station ("Millstone*).

Section 505(b) of the Clean Water Act ("CWA"), 33 U.S.C.

Section 1365(b) requires that sixty days prior to filing a citizen suit In

federal court under section 505(a) of the CWA; 33 U.S.C. Section

1365(a), the alleged violators, the U.S. Environmental Protection

Agency and the state In which the alleged violations occur be given

notice of the alleged violations.

The Coalition hereby places Dominion Nuclear Connecticut, Inc.

and Dominion Generation and their related Dominion corporate

entitles (collectively, "Dominion) on notice pursuant to section 505(b)

of the CWA, 33 U.S.C. section 1365(b), that it believes that Dominion

has violated and continues to violate "an effluent standard or *

limitation" under section 505(a)(1)(A) of the CWA, 33 U.S.C. Section

1365(a)(1)(A), by failing to comply with National Pollution Discharge

Elimination System ("NPDES") permit nuimber CT0003253, issued

July 2005., A-491 NUREG-1 437, Supplement 22 -
Appendix A

i Richard Emche CCAMNoliceintentToSueDomnon32tO5.doc Page 2

MPS-83-1 pursuant to section 402(b) of the CWA, 33 U.S.C. Section 1342(b) by

the Connecticut Department of Environmental Protection ('DEP")

pursuant to authority delegated to It.

MPS-83-2 Based on records maintained by the DEP, the Coalition believes

that Dominion has discharged and will continue to discharge

pollutants into the Long Island Sound in violation of effluent

standards or limitations of the NPDES permit Issued on December

15, 1992 in one or more of the following ways:

1. NPDES permit number CT0003253 expired on December 14,

1999 and has been of no lawful effect since such date;

accordingly, all effluent discharges otherwise permitted under

the terms of the permit since such date have occurred in

violation of the CWA effluent standards and limitations;

2. The DEP, commencing on or about 1998 and consistently

thereafter, has Issued and renewed 'emergency authorizations

for indefinite periods purportedly pursuant to Connecticut

General Statutes Section 22a-6(k) for purposes of permitting effluent discharges otherwise disallowed by the 1992 NPDES

permit which expired on December 14, 1997 and all in the

absence of notice to the public and an opportunity for

meaningful public comment; accordingly, all effluent discharges

released pursuant to said "emergency authorizations" since

1998 have occurred in violation of CWA effluent standards and

limitations. The most recent such "emergency authorization'

("EA"), which Is of indefinite duration, was issued by DEP on

October 20, 2000 and has been 1in effect" since such date;

3. On or about April 1, 2001, DEP purported to authorize the

transfer of NPDES permit number CT0003253 and the 'EA"

from the Northeast Nuclear Energy Company ("NNECO') to

Dominion; subsequent thereto, NNECO 'transferred" the

expired NPDES permit number CT0003253 and the EA to

Dominion;

4. Insofar as DEP lacked lawful authority to transfer the expired

NPDES permit and to transfer the EA, insofar as such EA had

been issued initially in the absence of legal authority, all

2

NUREG-1 437, Supplement 22 A-492 July 2005

I
Appendix A

Richard Emch - CCAMNoticelntentToSueDornknion32105.doc Page 3

effluent discharges reledsed by Dominion since April 1, 2001

Into the Long Island Sound have occurred without legal

authority and in violation of CWA effluent standards and

limitations; -

5. It appears that DEP issued the EA and Its'predecessor

"emergbncy authorizations' In knowing violation of the law,

Connecticut General Statutes Section 22a-6(k), which limits the

Issuance of emergency authorizations to address discrete

events Involving "an Imminent threat to human health or the

environment" and not for terms of unlimited duration;

6. On or about December 20, 1999, Arthur J. Rocque, Jr., thenDEP Commissioner, authorized renewal of one such

"emergency authorization" concerning discharges from the

Millstone Unit 3 nuclear reactor after noting as follows:

HI really hate these [NNECO requests for renewal of emergency

authorizations]. Statutes are very limited In what thely) define

as 'emergency.' Continuing emergency Is not even

contemplated." (Emphasis In original)

A copy of the Internal DEP memorandum on which Rocque

wrote such statement in his own handwriting is attached

hereto;

7. In September 1999, NNECO pleaded guilty in the U.S. District

Court for the District of Connecticut to committing

environmental felonies in violation of the terms and conditions

of the said NPDES permit number CT0003253;

8. Dominion, through Its corporate-related entities, recently settled

an environmental lawsuit brought by the U.S. Department of

Justice and the U.S. Environmental Protection Agency for

violations of the Clean Air Act for $1.2 billion;

9. On or about March 11, 2005, the Conservation Law Foundation

announced Its Intent to sue Dominion's corporate related

entities for alleged Illegal discharges of mercury Into the

3

July 2005' A-493 NUREG-1437, Supplement 22
Appendix A

I Richard Emch - CCAMNoticolntenZToSueDominion32lO5.doc - Page 4I

environment;

10. In consideration of these and other illegal activities

carried out by NNECO at Millstone and by Dominion's

corporate related entities at Millstone and elsewhere.

Connecticut DEP lacks legal authority to renew the NPDES

permit;

lI. Dominion routinely discharges radioactive and toxic

chemical and metal discharges into the Long Island Sound

through its Millstone operations and it has done so

continuously since on or about April 1, 2001 to the present;

12. Dominion routinely discharges some or all of the following radionuclides, chemicals and metals into the Long Island

Sound, all in knowing and continuing violation of the CWA:

Ag

Be-7

Ce-144

Co-57

Co-58

Co-60

Cr-51

Cs-134

Cs-1 37

Fe-55

Fe-59

1-131

1-133

Kr-85

Kr-88

La-140

Mn-54

Mo-99

Na-24

Nb-95

Nb-97

Ru-1 05

NUREG-1437, Supplement 22 A-494 July 2005
*Appendix A

I Richard Emrch -CCAMNoltcelntentToSueDominion32105.doc . Pa go 5 1

Sb-122

Sb-124

Sb-125

Sn-113

Sr-89

Sr-90

Sr-92

TC-99M

TC-101

TC-104

Tritium

Xe-133

Xe-135

Zn-69M

Zr-95

Zr-97

Aluminum

Antimony

Ammonia

Ammonium Hydroxide

Arsenic

Barium

Beryllium

Boric Acid

Boron

Bromide

Bulab 6002

Cadmium

Carbohydrazide

Chlorine

Chromium

Cobalt

Conquor 3585 (methoxypropylamine and diethylhydroxylamine).

Copper

Cyanide

Dietylhydroxylamine

Epichlorohydrin *y-.-

Ethanolomine

Fluoride - -

Freon:

July 2005 A-495 .r J NUREG-1437, Supplement 22
Appendix A

Richard Emch - CCAMNoticeIntentToSueDominion32105.doc Page 6

Hexavalent Chromium

Hydrazine

Hydrogen Peroxide

Iron

Methoxypropylamine

Molybdate

Molybdenum

Nalcolyte

Nickel

Nitrogen

Oil & Grease

Phosphorus

Selenium

Silver

Styrene

Sulfate

Sulfide

Sulfite

Surfactants

Thallium

Tin

Titanium

Tolyltriazole

Xylene

Zinc

Zirconium

Acrofein

Acrylonitrile

Benzene

Bromoform

Carbon Tetrachloride

Chlorobenzene

Chlorodibromomethane

Chloroethan6

2-Chloroethylvinyl Ether

Chloroform

Dichlorobromomethane

1, 1-Dichloroethane

1, 2-Dichloroethane

1, 1 -Dichloroethylene

NUREG-1437, Supplement 22 A-496 July 2005
Appendix A

I Richard Emch - CCAMNolicelntentToSueDominion32105.doc _Page 7

I

I

I

i

i

I

i

t

1, 2-Dichloropropane

1, 3-Dichloropropylene

Ethylbenzene

Methylbromide

Methylchforide

Methylene Chloride

1, 1, 2, 2, -Tetrachloroethane

Tetrachloroethylene

Toluene

1, 2-Trans-Dichloroethylene

1, 1, 1-Trichloroethane

1, 1, 2-Trichloroethane

Trichloroethylene

Vinyl Chloride

2-Chlorophenol

2, 4-Dichlorophenol

2, 4-Dimethylphenol

4, 6-Dinitro-O-Cresol

2, 4-Dinitrophenol

2-Nitrophenol

4-Nitrophenol

P-Chloro-M-Cresol

Pentachlorophenol

Phenol

2, 4, 6-Trichlorophenol

Acenaothylene

Benzidine

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(ghi)perylene

Benzo(k)fiuoranthene

Bis(2-Chloroethyl) Ether

Bis(2-Ethylhexylphthalate

Chrysene

Dibenzo(ah)anthracene

1 ,2-Dichlorobenzene

1 .3-Dichlorobenzene

1 .4-Dichlorobenzene

3.3-Dichlorobenzidines

Diethyl phthalate

. . j

V.

f, .

I . I - I..

. I . . ,-

r -, -, -,.j : ,

r -'-:

i

I

4

r

7

July 2005 A-497 NUREG-1437, Supplement 22
Appendix A

Richard Emch - CCAMNoticelnteniToSueDominion32105.doc Page a

Dlmethyl phthalate

Di-n-butyl phthalate

2,4-Dinitrotoulene

1 ,2-Diphenylhydrazine

Fluoranthene

Fluorene

Hexachlorobenzene

Hexachlorocyclopentadiene

Hexachloroethane

Indenoll ,2,3-ed)pyrene

Isophorona

Nurobenzene

N-Nitrosodimethylamine

N-Nitrosodiphenylamine

Phenanthrene

Pyrene

Aldrin

Chlordane

DDT

DDE

Dieldrin

Endosulfan(alpha)

Endosulfan (beta)

Endosulfan Sulfae

Endrin

Endrin Aldehyde

Heptachlor

Heotachlor epoxide

Arochlor 1016(PCB)

Arochlor 1232(PCB)

Arochlor 1242(PCB)

Arochlor 1248 (PCB)

Arochlor 1254 (PCB)

Arochlor 1260 (PCB)

Toxaphene

Ammonia

Benzo(b)fluoranthene

Chlorine

Hexachlorocyclohexane (Alpha)

Hexachlorocyclohexane (Beta)

NUREG-1437, Supplement 22 A-498 July 2005
Appendix A

Richard Emch - CCAMNoticelntentToSueDominion32105.doc Pago 9I

Hexachlorocyclohexanie (Gamma) -.

2,3,7,8-TCDD

13. The conduct described herein may involve knowing and

deliberate violation of federal law by Dominion, NNECO and : DEP. R-; -- < . -

MPS-83-3 The Coalition believes that the Millstone discharges as described

above are causing grave and irreparable harm to the marine

environment and to human health and that such conduct Imperils the

health and safety of its membership.

MPS-83-4 The Coalition further represents that some or all of the discharges

to the Long Island Sound as listed hereinabove are unnecessary; if

the Millstone Nuclear Power Station were to convert from a oncethrough7 to a 3

closed" cooling system, some or all of these harmful

discharges to the Long Island Sound would be eliminated.

MPS-83-5 The Millstone discharges as described above are believed to be

directly associated with the rare jawbone cancer found in Zachary M.

Hartley at his birth on December 16, 1997. The Millstone discharges

as described above are believed to be directly associated with a high

and increasing Incidence of cancer and related diseases among the

human population that resides near the Millstone Nuclear Power

Station and utilizes the surrounding beaches at Niantic Bay and

Jordan Cove, if not beyond.

The Coalition hereby places Dominion on notice of its grounds for

Initiation of legal action pursuant to the Clean Water Act. The

Coalition reserves its rights to include any additional violations in the

forthcoming complaint. If you have any questions or wish to discuss

this matter with us, please do not hesitate to contact us.

Very truly yours,

Nancy Burton

Please reply to:

Nancy Burton

147 Cross Highway

9

July 2005' A'-499- NUREG-1437, Supplement 22
Appendix A

.Richard Emch - CCAMNoticelntentToSueDominion32105.doc PagioinI

Redding Ridge CT 06876

Tel. 203-938-3952

cc:

Northeast Nuclear Energy Company

Northeast Utilities Service Company

Connecticut Ught & Power Company

P.O. Box 270

Hartford CT 06141-0270

Attorney General

Department of Justice

10h Street and Constitution Avenue NW

Washington DC 20530

Environmental Protection Agency

1200 Pennsylvania Avenue NW

Washington DC 20460

Regional Administrator

Environmental Protection Agency

I Congress Street.

Suite 1100 (RAA)

Boston MA 02114-2023

Hon. Gina McCarthy

Commissioner

Department of Environmental Protection

79 Elm Street

Hartford CT 06106

10

NUREG-1437, Supplement 22 A-500 July 2005

I
Appendix B

Contributors to the Supplement
- - Appendix B ' ' ---

Contributors to the Suppleineint

The overall responsibility for the preparation of this supplement was assigned to the Office of

Nuclear Reactor Regulation, U.S. Nuclear Regulatory Comisioi (NRC). The statement was

prepared by members of the Office of Nuclear Reactor Regulation with assistance from other

NRC organizations, the Los Alamos National Laboratory, and the Pacific Northwest National

Laboratory.

I

Name Affiliation Function or Expertise

NUCLEAR REGULATORY COMMISSION

Richard Emch, Jr. Nuclear Reactor Regulation Project Manager

Leslie Fields Nuclear Reactor Regulation Backup Project Manager

John Tappert Nuclear Reactor Regulation Section Chief

Andrew Kugler Nuclear Reactor Regulation Section Chief

Barry Zalcman Nuclear Reactor Regulation Program Manager

Michael T. Masnik Nuclear Reactor Regulation Ecology

James Wilson Nuclear Reactor Regulation Ecology

Jennifer Davis Nuclear Reactor Regulation Project Support

Stacey Imboden Nuclear Reactor Regulation Project Support

Harriet Nash Nuclear Reactor Regulation Project Support

Meghan Thorpe- Nuclear Reactor Regulation Project Support

Kavanaugh

Samuel Nuclear Reactor Regulation Project Support

HernandezQuinones

Mark Rubin Nuclear Reactor Regulation Severe Accident Mitigation Alternatives, Section Chief

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation Alternatives

Nina Barnett Nuclear Reactor Regulation Administrative Support

Los ALAmOS NATIONAL LABoRATORY1a)

Ted B. Doerr Task Leader

Keeley Costigan Air Quality

Brian Colby Decommissioning, Radiation Protection

Bruce Gallaher Water Use, Hydrology

Samuel R. Loftin Terrestrial Ecology

Lisa J. Henne Aquatic Ecology

W. Bruce Masse Cultural Resources

Dan Pava Socioeconomics, Land Use, Related Federal Programs

Vin LoPresti Technical Editor

Teresa Hiteman Document Design

Jolene Catron Document Design

PACIFic NORTHWEST NATIONAL LABORATORYlb)

Jeffrey Ward Aquatic Ecology

I

I

I

July 2005 Bali NUREG-1437, Supplement 22
Appendix B

Name Affiliation Function or Expertise

INFORMATION SYSTEMS LABORATORY

Kim Green Severe Accident Mitigation Alternatives

Bob Schmidt Severe Accident Mitigation Alternatives

(a) Los Alamos National Laboratory is operated for the U.S. Department of Energy by the University of

California.

(b) Pacific Northwest National Laboratory is operated for the U.S. Department of Energy by Battelle Memorial

Institute.

NUREG-1 437, Supplement 22 B2Jl20 B-2 July 2005

I
Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Related to Dominion Nuclear Connecticut, Inc.'s

Applications for License Renewal of I

Millstone Power Station, Units 2 and 3
Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Related to-Dominion Nuclear Connecticut, Inc.'s

Applications for License Renewal of

Millstone Power Station, Units 2 and 3

This appendix contains a chronological listing of correspondence between the U.S. Nuclear

Regulatory Commission'(NRC) and Dominion Nuclear Conn-cticiut, Inc. (DNC) and othercorrespondence related to the NRC staff's-envirorimental review, inder 10 CFR Part 51, of

DNC's applications for renewal of the Millstone'Power Station '(Millstone), Units 2 and 3,

operating licenses. All documents, with the exception of-those'containing proprietary

information, have been placed in the Commission's Public Document Room, at One White Flint

North, 11555 Rockville Pike (first floor),-Rockville, MD, and are available electronically frorh the

Public Electronic Reading Room found on the Internet at the following Web address:

<http.//www.nrc.gov/reading-rrn.html>. From this site, the public can gain access to the NRC's

Agencywide-Documents Access and Management System (ADAMS), which provides text and

image files of NRC's public documents in the publicly available records component of ADAMS.

The ADAMS accession number for each document is included below.

January 20,2004 Letter from Mr. David A. Christian, DNC, to NRC submitting the

;- m -- -':-' - applications for the renewal of theropeiating licenses for Millstone Power

Station, Units 2 and 3 (Accession No. ML040260070).

January 23,2004 <'NRC Press Release No. 04-011 "NRC Makes License Renewal

-. ' Application Available for the Millstone'Nuclear Power Plant"

- (AccessioriNo';ML040230280).

January 28, 2004 NRC staff letter to Mr. David A. Christian regarding the receipt and

' availability of the license renewal apjlidations for Millstone Power Station',

- Units 2'and 3 (Accession No. ML040280258).

.. : :,. .. . - : .. ; - i, e . .. ; ; i

February 5,2004 NRC staff letter t6 Ms. Mildred Hodge, Library Director, Thames River

Campus, Norwich, Connecticut, regarding the maintenance of reference

material for public access related to the'Millstone'Power Station license

renewal 'environmental review (Accession' No. ML040400181).

July 2005 -- C-1 NUREG-1437, Supplement 22 '
Appendix C

February 5, 2004

February 6, 2004

March 8, 2004

March 17, 2004

March 18, 2004

March 25, 2004

March 29, 2004

March 30, 2004

NRC staff letter to Ms. Judy Liskov, Assistant Director, Waterford Public

Library, Waterford, Connecticut; regarding the maintenance of reference

material for public access related to the Millstone Power Station license

renewal environmental review (Accession No. ML040400209).

NRC Press Release No. 04-002 UNRC to Hold Public Meeting in

Connecticut on License Renewal Application for Millstone 2 and 3"

(Accession No. ML040370209).

NRC staff letter to Mr. David A. Christian regarding the determination of

acceptability and sufficiency for docketing, proposed review schedule,

and opportunity for hearing regarding the license renewal applications for

Millstone Power Station, Units 2 and 3 (Accession No. ML040680968).

NRC staff letter to Ms. Patricia A. Kurkul, Regional Administrator,

National Marine Fisheries Service (NOAA Fisheries), Request for List of

Protected Species Within the Area Under Evaluation for the Millstone

Power Station, Units 2 and 3, License Renewal (Accession No.

ML040770760).

NRC staff letter to Mr. Marvin Moriarty, Regional Director, U.S. Fish and

Wildlife Service, Request for List of Protected Species Within the Area

Under Evaluation for the Millstone Power Station, Units 2 and 3, License

Renewal (Accession No. ML040780653).

Memo from Mr. Richard Gallagher, Dominion, regarding

telecommunication on March 22, 2004 to NRC requests for Documents

which Pertain to the Study of the Winter Flounder Population in the area

around Millstone (Accession No. ML040930048).

Memo from Mr. Richard Gallagher, Dominion, regarding

telecommunication on March 22, 2004 to NRC requests for Documents

Pertaining to the Study of the Winter Flounder Population in the area

around Millstone (Accession No. ML040930259).

NRC staff letter to Mr. Paul Loether, Director, Connecticut Historical

Commission, regarding Millstone Power Station, Units 2 and 3, License

Renewal Review (Accession No. ML040900503).

NUREG-1 437, Supplement 22 C-2 July 2005

I
Appendix C

March ~31, 2(

April 8, 2004

oX4 - -' 'NRC staff letter to Mr. David A. Christian' Senior Vice President and

Chief Nuclear Officer, DNC, Notice of Intent to Prepare an Environmental

Impact Statement and Conduct Scoping Process for License Renewal for

the Millstone Power Station, Units 2 and 3 (Accession No.

ML040920231).

April 12, 200

April 14, 200

April 14, 200

NRC staff letter to Mr. Dona Klima; Dir6ctor, Office of Federal Agency

Programs, Advisory Council on Historic Preservation, Regarding Millstone

Power Station, Units 2 and 3, License Renewal Review (Accession No.

ML041000158). - -

)4 Notice of Public Meeting'to Discuss Environmental Scoping Process for

Millstone Power Station, Units 2 and 3, License Renewal Application

'(Accession No. ML041050788).

4 NRC staff letter to the Honorable Matthew Thomas, Chief Sachem,

Narragansett Indian Tribe, Request for Comments Concerning Millstone

Power Station, Units 2 and 3, Operating License Renewal

(Accessiorn No. ML041050878)-.

4 NRC staff letter to the Honorable Michael J.'Thomas, Chairman,

Mashantucket Pequot Tribal Nation, Request for Comments Concerning

Millstone Power Station, Units 2 and 3, Operating License Renewal

(Accession No. ML041050880).

I

iI

April 15, 2004 Letter from Mr. Michael J. Amaral, U.S. Fish and Wildlife Service,

providing a response to the March 18, 2004, NRC staff letter requesting

information regarding threatenied and endarigered species in the vicinity

of the Millstone Power Station, Units 2'and'3'(Accession No.

ML041190230). - '

April 16, 2004 Memo from Mr. Richard Gallagher, DNC to NRC, regarding email on

April 15,2004, requesting documents pertaining to the study of the winter

;flounder population in the area around Millstone

(Accession No. MLO41120271). -

April 19, 2004 Email to Mr Ted B. Doerrfrori NRC, providing comments regarding the

Site Audit Needs (Accession N.'N MLO41240396).

July 2005 C-3 NUREG-1437. .Sunolement , , . 22_
Appendix C

I

I

I

April 26, 2004

April 27, 2004

April 29, 2004

May 11, 2004

May 18, 2004

May 24, 2004

May 24, 2004

May 24, 2004

May 24, 2004

Email to Mr. Richard Gallagher from NRC, regarding questions and

comments on the List of Onsite Data Needs (Accession No.

ML041240402).

Letter from Mr. Charles H. Evans, Director, Connecticut Department of

Environmental Protection, Office of Long Island Sound Programs to NRC

and Dominion regarding coastal zone consistency concurrence

(Accession No. ML041320497).

Email from Richard Gallagher, Dominion, to NRC, requesting additional

information regarding severe accident mitigation alternatives review for

Millstone (Accession No. ML041240405).

NRC Press Release No. 04-030 "NRC Seeks Public Input On

Environmental Impact Statement For Proposed Millstone Nuclear Plant

License Renewal" (Accession No. ML041320568).

NRC Public Meeting Feedback Form "Public Scoping Meetings to

Discuss Environmental Issues Pertaining to the Application for License

Renewal of Millstone Power Station, Units 2 and 3"

(Accession No. ML041700578).

Note to file regarding the docketing of additional documents pertaining to

winter flounder in support of the environmental review of Millstone Power

Station, Units 2 and 3 license renewal application (Accession No.

ML041460138).

Note to file regarding the docketing of additional documents pertaining to

winter flounder in support of the environmental review of Millstone Power

Station, Units 2 and 3 license renewal application (Accession No.

ML041460283).

Note to file regarding the docketing of emails sent to DNC in support of

the environmental review of Millstone Power Station, Units 2 and 3

license renewal application (Accession No. ML041460250).

Comment letter from the Honorable Fred W. Thiele, Jr., Assemblyman,

regarding the environmental review of Millstone Power Station, Units 2

and 3 license renewal application (Accession No. ML041620373).

i

II

I

I

NUREG-1437, Supplement 22 C-4 July 2005
Appendix C

June 1, 2004 Note to file regarding the docketing of documents pertaining to winter

- flounder in support of the environmental review of Millstone Power

Station, Units 2 and 3 license renewal application'(Accession No.

ML041560169). -

June 1, 2004

C. , - ; Email from Mr. Charles D. Stephani providing scoping comments

regarding Millstone Power Station, Units 2 and 3 license renewal review

(Accession No. ML041770290). -' ' -

June 2, 2004' '7' Email from Hortense and Ralph'Carpenter providing scoping comments

- ; regarding Millstone 'Power Station,- Units 2 and 3 license renewal review

'Accession'No.' ML041 770288).

June 3, 2004 Email from Kelly L. Streich providing scoping comments regarding

Millstone Power Station, Units 2 aid 3 license renewal review (Accession

-No. ML041770177).

June 4, 2004 Email from Mr. Douglas Schwartz providing scoping comments regarding

Millstone Power Station,' Units 2 and 3 license renewal review

- (Accession No. ML041770175).

June 4, 2004 '- Letter from Ms. Nancy Burton, Esq., to NRC staff regarding the Millstone

Power Station, Units 2 and 3 license renewal review (Accession No.

MIL041770182).

I

I

June 22, 2004' NRC sitaff letter to Mr. David A. Christian,'DNC, forwarding request for

additional information 'regarding severe accident mitigation alternatives

for the Millstone Power Station, Units 2 and 3 license renewal review

(Accession No. ML0417401 75). -' ' - - -

;. . - !- -.... ,_ '_:!:_* ** _ I

June 24, 2004 Summary of Public Scoping Meetings'to Support Review to support the

review of Millstone Power Station, Units 2 and 3 license renewal review

- (Accession No. ML041830272). -' - K "- -'-

July 27, 2004 NRC letter to DNC forwardirig the summary of site audit to support the

review of Milstone Power Station; Units 2 and 3 license renewal review

(Accession No. ML042100293).

I

I .

I'

July 28, 2004 Letter from First Selectman Paul B. Eccard, Town of Waterford, to NRC

regarding Millstone Power Station, Units 2 and 3 license renewal review

(Accession No. ML042160111).

July 2005 C-5" NUREG-1437, Supplement 22
Appendix C

I

I

I

August 13, 2004

August 17, 2004

August 27, 2004

September 16, 2004

September 21, 2004

September 24, 2004

September 24, 2004

October 6, 2004

I

I

Letter from Leslie N. Hartz, DNC, to NRD forwarding response to request

for additional information regarding Millstone Power Station, Units 2 and

3 license renewal review (Accession No. ML042320613).

NRC staff letter to Mr. Paul B. Eccard, acknowledging receipt of

comments regarding Millstone Power Station, Units 2 and 3 license

renewal review (Acces-,on No. ML042320342).

NRC staff letter to Mr. David A. Christian, DNC, forwarding the

environmental scoping summary report associated with the staff's review

of Millstone Power Station, Units 2 and 3 applications (Accession No.

ML042400543).

Email correspondence between NRC staff and DNC regarding the SAMA

review for Millstone Power Station, Units 2 and 3 applications

(Accession No. ML042710222).

Letter from Ms. Mary A. Colligan, NOAA Fisheries, to P.T. Kuo, NRC,

providing a response to the March 18, 2004, NRC staff letter requesting

information regarding threatened and endangered species in the vicinity

of the Millstone Power Station, Units 2 and 3 (Accession No.

ML042810294).

Summary of telephone conference conducted with the Town of Waterford

regarding Millstone Power Station, Units 2 and 3 applications

(Accession No. ML042710257).

Summary of telephone conference regarding the SAMA review of

Millstone Power Station, Units 2 and 3 applications (Accession No.

ML0427110529).

Letter from Mr J. Paul Loether, Connecticut State Historic Preservation

Officer, to P.T. Kuo, NRC, providing comments regarding Millstone Power

Station, Units 2 and 3 License Renewal Application effect on historic

properties (Accession No. ML042880497).

I

NUREG-1437, Supplement 22 C-6 July 2005.~
Appendix C

October 6, 2004

October 25, 2004 4

Letter from First Selectman Paul B. Ec6ard, Town of Waterford,-to

-Richard L. Emch, Jr., NRC, response to September 24, 2004, letter from

NRC regarding Millstone Power Station, Units 2 and 3 license renewal

review (Accession No. ML043210191).

Note to File from Richard L. Emch, Jr.','NRC. Subject: Summary of

Telephone Conference Regarding SAMA Analyses Conducted on

October 7, 2004, with Dominion'Conne6ticut'Nuclear, Inc. In Support'of

the Environmental Review of the License Renewai Application for

Millst6oe Power Station Units 2 and 3.-(Accession No. ML043000449).

October 29, 2004 Note to File from Richard L. Emch,-Jr.,;NRC. Subject: Correction of

Summary Dated September 24, 2004,'of Telephone Conference

Regarding SAMA Analyses Conducted on September 13, 2004, with

Dominion Connecticut Nuclear,]Ind.-in-Support of the Environimental'--

Review of the License Renewal Application'for'Millstone Power Station

Units 2 and 3. (Accession No. ML 043030362).

November 9, 2004 NRC staff letter to Ms. Patricia A. Kurkul, Regional Administrator, NOAA

Fisheries, Request for Concurrence - Biological Assessment for Millstone

Power Station, Units 2 and 3 (Accession No. ML043170594).

November 9, 2004 NRC staff letter to Mr. Marvin Moriarty, Regional Director, U.S. Fish and

Wildlife Service, Request for Concurrence - Biological Assessment for

Millstone Power Station, Units 2 and 3 (Accession No. ML043170643).

December 2, 2004 NRC staff letter to U.S. Environmental Protection Agency, Filing of Draft

- ':: i- - Supplement 22 to NUREG-1437 (Accession No. ML043370472).

December 2, 2004 NRC staff letter to Mr. David A. Christian, Senior Vice President and

; -- -: --- Chief Nuiclear Officer, Dominion Nuclear Connicticut, In., Notice of

Availability'of Draft Supplement 22 to NUREG-1 437 (Accession No.

ML043370478).

December 9, 2004 NRC press release announcing the publidcmeeting regarding the Draft

Supplement 22 to NUREG-1437 (Accession No. ML043440093).

December 20, 2004 NRC memorandum regarding the publi6 meeting for the Draft

Supplement 22 to NUREG-1437, including the meeting agenda and

I- . :-'' * notice : (Accession No: ML043560137) .'- - ' . -

July 2005 C-7 NUREG-1437,'Supplement 22
Appendix C

January 5, 2005

January 11, 2005

January 12, 2005

January 23, 2005

January 31, 2005

February 2, 2005

February 2, 2005

February 4, 2005

February 8, 2005

February 10, 2005

February 10, 2005

February 15, 2005

February 18, 2005

Letter from Mr. Michael J. Amaral, Endangered Species Specialist, U.S.

Fish and Wildlife Service, to Mr. P.T. Kuo, NRC, Concurrence and

consultation closure (Accession No. ML050210354).

Email from Ms. Nancy Burton to R. Emch, NRC, requesting copies of

RAls and RAI responses (Accession No. ML051330301).

Letter from Ms. Patricia A. Kurkul, Regional Administrator, NOAA

Fisheries, to P.T. Kuo, NRC, Millstone Power Station, Units 2 and 3

license renewal (Accession No. ML051021054).

Email from Ms. Nancy Burton to R. Emch, NRC, submitting a FOIA

request (Accession No. ML051330300).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding FOIA

response schedule (Accession No. ML-051330298).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions

about the DSEIS (Accession No. ML051330296).

NRC staff letter to Mr. Joshua Y. Horton, Supervisor, Southold Town,

response regarding Millstone Power Station, Units 2 and 3 license

renewal review (Accession No. ML050340609).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions

about the DSEIS (Accession No. ML051330292).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions

about the DSEIS (Accession No. ML051330285).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions

about the DSEIS (Accession No. ML051330297).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions

about the DSEIS (Accession No. ML051330293).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions

about the DSEIS (Accession No. ML051330290).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding the schedule

for meeting transcripts (Accession No. ML051330286).

NUREG-1437, Supplement 22 C-8 July 2005
Appendix C

February 18, 2005 Email from R. Emch, NRC, to Ms. Nancy Burton including attached

transcripts from the public meeting (AccessionNo. ML051330034).

February 21, 2005 Email from Ms. Nancy Burton to A. Kugler, NRC, regarding questions

about the DSEIS (Accession No. ML051330352).

February 23,'2005 Email from R. Emch, NRC, to Ms- Nancy Burton regarding questions

- about the DSEIS (Accession No. ML-051330072).

February 23, 2005 Email from R. Emch;-NRC, to Ms. Nancy Burton regarding questions

about the DSEIS (Accession No. ML051330077).

February 24, 2005 Email from Ms. Nancy Burton to A. Kugler, NRC, regarding questions

if about the DSEIS (Accession No. ML051330349).

February 24, 2005 Email from Ms. Nancy Burton to R. Ernch, NRC, regarding questions

about the DSEIS (Accession No. ML051330141).

February 24, 2005 Email ' from A. Kugler, NRC, to Ms. Nancy Burton regarding'questions

about the DSEIS (Accession No. ML051470090). -

February 24, 2005 Email from R Erch, NRC, to Ms. Nancy Burton regarding questions

about the DSEIS (Accession No. ML051330083).-

February 24, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions

about the DSEIS (Accession No. ML051330138).

February 25, 2005 Summary of the public meeting for the Draft Supplement 22 toNUREG-1437 (Accession No. ML050610357).'

February 28,'2005 Ermail from Ms. Nancy Burton to' A: Kugler,'NRC, requesting extension of

-: ;- - the comment period (Accession No.' ML0513301 35).

February 28, 2005 ' Email from Ms. Nancy Burton to the NRC Commissioners requesting

- - extension of the comment period (Accession No. ML050670486). I _ ' -, ~- ' C 'C '- E!'

February 28, 2005 Email from R.-Emch, NRC,' to Ms.' Nncy Burton regarding request for

extension of the comment period (Accession No. ML051330040).

March 9, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions

about the DSEIS (Accession No. ML-051330132).

July 2005 C-9 NUREG-1437. Sunplement 22 *, I _- ---- -- - --- w -- rr--
Appendix C

March 9, 2005

March 9, 2005

March 10, 2005

March 11, 2005

March 11, 2005

March 11, 2005

March 12, 2005

March 13, 2005

March 14, 2005

March 15, 2005

March 16, 2005

March 16, 2005

Email from Ms. Nancy Burton to R. Emch, NRC, inviting the NRC to a

press conference (Accession No. ML051330126).

Email from R. Emch, NRC, to Ms. Nancy Burton regarding her FOIA

request (Accession No. ML051330143).

Email from A. Kugler, NRC, to Ms. Nancy Burton declining her invitation

to the press conference (Accession No. ML05133032).

Email from Ms. Nancy Burton to A. Kugler, NRC, sending a news article

about Millstone (Accession No. ML051330118).

Email from Ms. Nancy Burton to A. Kugler, NRC, sending a news article

about Millstone (Accession No. ML051330115).

Email from Ms. Nancy Burton to A. Kugler, NRC, sending a news article

about Millstone (Accession No. ML0513301 10).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding comments on

the DSEIS (Accession No. ML051330097).

Email from Ms. Nancy Burton to R. Emch, NRC, requesting a cited

reference from the NRC (Accession No. ML051330095).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding comments

about the DSEIS (Accession No. ML051330088).

Email from R. Emch, NRC, to Ms. Nancy Burton regarding questions

about the DSEIS (Accession No. ML051330050).

Email from Ms. Nancy Burton to R. Emch, NRC, indicating that her

supplemental comments are attached (Accession No. ML051330082).

Email from Ms. Nancy Burton to R. Emch, NRC, including the

supplemental comments that were not attached to previous email

(Accession No. ML051330078). [Ms. Burton submitted a corrected

version of these comments on March 22, 2005, by email; the corrected

version is included in Appendix A.]

NUREG-1437, Supplement 22 C-10 July 2005
Appendix C

March 21,2005 -Email from Ms. Nancy Burton to R. Emch, NRC, notifying the NRC of the

- Connecticut Coalition Against Millstone's intent to sue Dominion

(Accession No. ML051330092).- - ':- - -

March 27, 2005 Email from Ms.- Nancy Burton to R. Errich, NRC, requesting information -^

- -about NRC's offsite visits (Accession No. ML051330075).

March 28, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, regarding questions

about the DSEIS (Accession No. ML051330079).

March 28, 2005 Email from Ms. Nancy Burton to R. Emch, NRC, requesting a document

-(Accession No. ML051330089).

I1

-I

-I

March 28,2005

March 28,2005

March 28, 2005

March 28, 2005

March 30, 2005

March 30,2005

March 30, 2005

March 30, 2005

- . . . . . f , I - . . I . - ,. ................................... . .- , , ,

Email from Ms. Nancy Burton to Commissioner McCarthy, Connecticut

Department of Environmental Protection, regarding the coastal zone

management consistency review (Accession No. ML051330100).

I

I

I

Email from Ms. Nancy Burton to R. Emch, NRC, regarding comments on

the DSEIS (Accession No. ML051330103).

Email from R. Emch, NRC, to Ms. Nancy Burton regarding closure of the

comment period (Accession No. ML051330063).

Email from R. Emch, NRC, to Ms. Nancy Burton sending her a requested

document (Accession No. ML051330057).

Email from Ms. Nancy Burton to R. Emch, NRC, with her attached letter

to the editor sent to The New London Day

(Accession No. ML051330107).

Email from R. Emch, NRC, to Ms. Nancy Burton regarding the closure of

the comment period (Accession No. ML051330090).

Email from Ms. Nancy Burton to R. Emch, NRC, regarding comments on

the DSEIS (Accession No. ML051330113).

Email from Ms. Nancy Burton to R. Emch, NRC, submitting a press

release about Millstone (Accession No. ML051330119).

July 2005 - C-11 NUREG-1437, Supplement 22
Appendix C

April 8, 2005

April 14, 2005

May 17, 2005

May 17, 2005

Email from Ms. Nancy Burton to C. Santos, NRC, notifying the Advisory

Committee on Reactor Safeguards of documents submitted to the NRC

(Accession No. ML051330125).

Email from Ms. Nancy Burton to R. Emch, NRC, providing copy of letter

from Ms. Burton to Donald W. Downes, Connecticut Department of Public

Utility (Accession No. ML051330137).

Note to file from R. Emch summarizing telephone conference with EPA,

Region 1, on April 5, 2005 (Accession No. ML051380272).

Note to file from R. Emch summarizing telephone discussion with

representative of Connecticut Tumor Registry on April 8, 2005

(Accession No. ML051380488).

NUREG-1 437, Supplement 22 C-12 July 2005

I
Appendix D

Organizations Contacted
Appendix D

Organizations Contacted..

During the course of the staff's independent review of environmental impacts from operations

during the renewal term, the following Federal, State, regional,]local, and Native American tribal

agencies were contacted:'

Chamber of Commerce of Eastern Connecticut, Inc., Gales Ferry, CT

Connecticut Commercial Realty, New London, CT

Connecticut Department of Environmental Protection, Bureau of Air Management, Division of

Radiation, Hartford, CT

Connecticut Department of Environmental Protection, Bureau of Waste Management, Hartford,

CT

Connecticut Department of Environmental Protection, Bureau of Water Management, Hartford,

CT

Connecticut Department of Environmental Protection, Marine Fisheries Division, Old Lyme, CT

Connecticut Department of Environmental Protection, Office of Long Island Sound Programs,

Hartford, CT

Connecticut Department of Public Health, Connecticut Tumor Registry, Hartford, CT

Connecticut Historical Commission, Hartford, CT

National Oceanic and Atmospheric Administration, National Marine Fisheries Service, Northeast

Fisheries Science Center, Milford Laboratory, Milford, CT

Southeastern Connecticut Council of Governments, Norwich, CT

Southeastern Connecticut Enterprise Region, New London, CT

Town of Waterford, CT

U.S. Environmental Protection Agency, Region 1, Boston, MA.

July 2005 -. D-1 NUREG-1437, Supplement 22
Appendix D

U.S. Geological Survey, Woods Hole, MA

United Way of Southeastern Connecticut, Gales Ferry, CT

University of Connecticut, Department of Physiology and Neurobiology, Storrs, CT

Waterford Public Schools, Waterford, CT

NUREG-1437, Supplement 22 D-2 July 2004
Appendix E

Millstone Compliance Status and Consultation Correspondence
Appendix E

. Millstone Compliance Status and Consultation Correspondence

Correspondence received during the process of evaluation of the application for renewal of the

operating licenses for Millstone Power'Station Units 2 and 3 (Millstone) are identified in

Table E-1. Copies of the correspondence are included at the end of this appendix.

The licenses, permits, consultations, and other approvals obtained from

regional, and local authorities for Millstone are listed in Table E-2.

Table E-1. Consultation Correspondence

Federal, State,- -

Source Recipient Date of Letter

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

U.S. Fish and Wildlife Service

(M. J. Amaral)

Connecticut Department of

Environmental Protection

(C. H. Evans)

NOAA Fisheries

(M. A. Colligan)

NOAA Fisheries (P.-A. Kurkul)

U.S. Fish and Wildlife Service

(M. Moriarty)

Connecticut Historical Commission

(Paul Loether)

Advisory Council on Historic

Preservation (D. Klima)

Narragansett Indian Tribe

(M. Thomas, Chief Sachem)

Mashantucket Pequot Tribal Nation

(M. J. Thomas)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

U.S. Nuclear Regulatory

Commission (R. Emch)

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

March 17, 2004 March 2004 18, 

March 18, 2004

March 30. 2004

April 8, 2004

April 14,2004

April 14,2004

April 15,2004

April 27, 2004

September 21, 2004 I

I

July 2005 E-1- NUREG-1437, Supplement 22
Appendix E

Table E-1. Consultation Correspondence (contd.)

Source Recipient Date of Letter

State of Connecticut

Commission on Culture and

Tourism (J. Paul Loether)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

U.S. Fish and Wildlife Service

(M. Amaral)

NOAA Fisheries

(P. Kurkul)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

NOAA Fisheries

(P. A. Kurkul)

U.S. Fish and Wildlife Service

(M. Moriarty)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

U.S. Nuclear Regulatory

Commission (P. T. Kuo)

October 6, 2004

November 9, 2004

November 9, 2004

January 5, 2005

January 12, 2005

NUREG-1437, Supplement 22 E-2 July 2005
C- --C

0

0

. U,

Table E-2. Federal, State, Local, and Regional Licenses, Permits, Consultations, and Other Approvals for Millstone

I Issue Expiratlon

Agency Authority Description Number Date Date Remarks

NRC 10 CFR Part 50 Operating license, DPR-65 - 09/26175 07/31/15- Authorizes operation of Unit 2.' I

NRC

USACE,

USACE

10 CFR Part 50

Section 10, River and

Harbor Act (33 USC

403)

Section 10, River and

Harbor Act (33 USC

403)

Millstone Unit 2

Operating license,

Millstone Unit 3

Permit - -

NPF-49

CT-NIAN-78-507

01/31(86 11/25/25 Authorizes operation of Unit 3. I

10/11178 No expiration Install andimaintain

date sandbag dike for ecology

laboratory mariculture work.

Permit CT-NIAN-77-377

(LOP)

09/19177X No expiration

date

Install and maintain

ecology laboratory seawater

intake pipes.

USDOT.

,m

49 USC 5108

Migratory Bird Treaty Act

(16 USC 703-712)

Registration l

FWS Depredation Permit

061202550034KL

MB728673-0

06/13/02 06/30/04

06/07/03 06/30/04

Shipment of hazardous

materials.

Removal of birds, eggs and

nests from utility structures and

property. -

I

FWS

I f

.I , . ,. , _

NMFS

Section 7 of the

Endangered Species Act

(16 USC 1536)

Section 7 of the

Endangered Species Act

(16 USC 1536)

Consultation

Con sl ato.

Consultation

01/05/05

01/12/05

Requires a Federal agency to

consult with FWS regarding

whether a proposed action

would affect endangered or'

threatened species.- K'; '"-

Requires a Federal agency to

consult with NOAA Fisheries

regarding whether a proposed

action would affect endangered

or threatened species.

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CA)

Table E-2. (contd.)

-1

W I

Ct

I , Issue Expiration Agency Authority Description Number Date Date * Remarks Connecticut Section 106 of the Consultation The National HistoricCD

0.

X

Historical m7

Commission

National Historic

Preservation Act

(16 USC 470f)

Preservation Act requires

Federal agencies to take into

account the effect of any undertaking on any district, site,

building, structure, or object that

is included in or eligible for

Inclusion in the National Register

of Historic Places.

Connecticut

Department of

Environmental

Protection

(CTDEP)

CTDEP

Section 307 of the Coastal

Zone Management Act [16

USC 1456(c)(3)(A)]

CGS 4-182, 22a-430, 22a430-1 et seq.

Consistency

determination with

the Connecticut

Coastal

Management

Program

The Connecticut Department of

Environmental Protection waived

the review to coordinate with the

State NPDES permit review

process.

Renewal application submitted

6113/97; plant discharges to

Long Island Sound.

m

National Pollution

Discharge

Elimination System

Permit

NPDES permit

CT0003263

12/14/92

CTDEP CGS 22a-430b

CGS 22a-6K

General Permit for

stormwater

discharges

Emergency

Authorization

GS1001430

EA 0100176

09/25/03

10/13/00

Stormwater discharges;

industrial activities.

Transferred 3/31/01: plant

discharges to Long Island

Sound.

CTDEP

I

CTDEP CGS 22a-430 General Permit for

Discharge of Minor

Photographic

Processing

Wastewater

GPHOO0354 10/20/95 10/20/05 Discharge of minor photographic

process wastewater to municipal

sewer

C-I

C

0

0

01

CTDEP CGS 22a-430 General Permit for

the Discharge of

Water Treatment

Wastewater

GWT 000175 03/26/01 05/01/05 Water treatment wastewater.
vC- C_

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0

I31

Table E-2. (contd)

Issue Expiration : ' - ;

Agency Authority - Description Number Date Date Remarks

CTDEP CGS 22a-430 General Permit for GM1000012 03/13/02 04/30/11 Wastewater discharaes from

Miscellaneous

Discharges of

Sewer Compatible

Wastewater

Fire Training Facility.

.I,: :

I

CTDEP

CTDEP

Ct. P.A. 82-402.

Section 4

i . I . .

Ct. P.A. 82-402,

Section 4

Registration 2000-018-PWR-SU 07/12/83

(Unit 2) -

Registration

m

n

CTDEP

CTDEP

,.., . ~ : f

z

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- mm

.,n (4- 

CD

3

I CD

I an

CTDEP

CTDEP

CTDEP

CGS 22a-174

CGS 22a-174

." ... .-

CGS 22a-174

CGS 22a-174

CGS 22a-174

Permit

Permit

Permit

Permit

Permit

2000-019-PWR-SU

(Unit 3)

199-0003-0043

199-0003-0044

199-0003-0045

199-0003-0046

199-0004-0056

08/10/00

04/27/99

04/27/99

04/27/99

07/12/83

Transferred on 03/31/01;

No expiration date;

Divert large volume of

water from Long Island

Sound for steam -

condenser cooling

water.

Transferred on 03/31/01;

No expiration date;

Divert large volume of

water from Long Island

Sound for steam

condenser cooling

water. .

Emissions from fire training

mock-up facility and two

propane-fired water pumps.

- i ,i v - i tt;- s- he

Emissions from diesel-fired trash

water pump.

Emissions from diesel-fired

motorpool air compressor

Operate diesel-fired motorpool

air compressor.

11/09/99 Emissions from Unit 2

emergency diesel generator (1

of 2).

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-1

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Table E-2. (contd.)

Issue Expiration Agency Authority Description Number Date Date I _ Remarks CTDEP CGS 22a-174 Permit 199-0003-0055 11/09/99 Emissions from Unit 2

emergency diesel generator (2

of 2).

'O

CDXm

CTDEP

CTDEP

CGS 22a-174

CGS 22a-174

CGS 22a-174

Permit

Permit

Permit

199-0003-0007

199-0003-0008

199-0003-0009

01/24/86

01/24/86

05/21/85

Emissions from Unit 3 auxiliary boiler (1 of 2).

Emissions from Unit 3 auxiliary

boiler (2 of 2).

Emissions from Unit 

3

emergency diesel generator

(1 of 2).

CTDEP

CTDEP

I

CGS 22a-174

CGS 22a-174

m

a)

Permit

Permit

199-0003-0010

199-0003-0017

05/21/85

08/25/92

Emissions from Unit 

3

emergency diesel generator

(2 of 2).

Emissions from station blackout

emergency diesel generator

(3of3)

CTDEP

CTDEP CGS 22a-174 Permit 199-0003-0053 05/27/99

I Emissions from Unit 3 ESF

diesel compressor.

CTDEP

I

CGS 22a-449

CGS 22a-449

Notification Site ID

Notification Site ID

170-8414

170-8414

03/27/01

03/27/01

Unit 3 emergency generator

underground storage tank E6,

#2 diesel oil.

Unit 3 emergency generator

underground storage tank E7,

#2 diesel oil.

CTDEP

CTDEP

I

CGS 22a-449

CGS 22a-449

Notification Site ID

Notification Site ID

170-8414

170-8414

03/27/01

03/27/01

Unit 3 auxiliary boiler

underground storage tank F8, #4

heating oil.

Unit 3 auxiliary boiler

underground storage tank F9, #4

heating oil.

C- 00

MI

CTDEP

I
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en

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Table E-2. (contd.)

Issue Expiration

Agency Authority Description Number Date Date Remarks

CTDEP CGS 22a-449 Notification Site ID 170-8425 03/27/01 Simulator building underground

storage tank, #2 heating oil.

CTDEP CGS 22a-449 Notification Site ID 170-8486 03/27/01 Unit 2 emergency diesel

underground storage tank, #2

fuel oil. This tank has been

retired.

South Carolina South Carolina; Permit - 0013-06-04 - 12110/03 12/31/04 Transport radioactive wastes.

Department of Radioactive Waste

Health and Transportation and:;'

Environmental Disposal Act (Act No. 429 -

Control of 1980)

Tennessee Rule 1200-2-10.32 License T-CT003-L04 12/02/03 12/31(04 Ship radioactive materials.

Department of

Environment and

Conservation

CTDEP CGS 26-60 Scientific Collector 219 01/17/03 01/16/06 Collect fish and lobsters.

Permit

CTDEP CGS Title 22a, Chapter Permit (Part A not applicable- 12/22/00 Store radioactive hazardous

445C - application) - (i.e., mixed) waste.

CGS 22a-174* Permit -- 199-0038-TV / 01/29/03- 01/29/08 Emissions (Title V permit).

CFR = Code of Federal Regulations * -

USACE = U.S. Army Corps of Engineers

USDOT = U.S. Department of Transportation

FWS = U.S. Fish and Wildlife Service

NRC = U.S. Nuclear Regulatory Commission

EPA = U.S. Environmental Protection Agency

NOAA = National Oceanic and Atmospheric Administration

USC = United States Code

CGS = Connecticut'General Statutes

ESF = Engineered Safeguards Features

CD

0.

mL
Appendix E

UNITED STATES

- tNUCLEAR REGULATORY COMMISSION

i BWASHINGTON, D.C. 20555-01

March 17, 2004

Patricia A. Kurkul. Regional Administrator

NOAA Fisheries

Northeast Regional Office

One Blackburn Drive

Gloucester, MA 09130-2298

SUBJECT: REQUEST FOR LIST OF PROTECTED SPECIES WITHIN THE AREA UNDER

EVALUATION FOR MILLSTONE POWER STATION, UNITS 2 AND 3, LICENSE

RENEWAL

Dear Ms. Kurkul:

The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application submitted by

Dominion Nuclear Connecticut Inc. (DNC) for the renewal of the operating licenses for Millstone

Power Station, Units 2 and 3 (MPS). MPS Is located on the north shore of Long Island Sound

In Waterford. Connecticut. approximately 40 miles southeast of Hartford, Connecticut. As part

of the review of the license renewal application, the NRC is preparing a Supplemental

Environmental Impact Statement (SEIS) under the provisions of the National Environmental

Policy Act (NEPA) of 1969, as amended, which include an analysis of pertinent environmental

issues, Including endangered or threatened species and impacts to fish and wildlife. This letter

Is being submitted under the provisions of the Endangered Species Act of 1973, as amended,

and the Fish and Wildlife Coordination Act of 1934. as amended.

The proposed action would include the use and continued maintenance of existing plant

facilities and transmission lines. The MPS site covers approximately 525 acres, of which

approximately 220 acres are industrial. The area surrounding MPS is characterized by old field.

mesic hardwood forest, coastal marsh and beach habitats. DNC also maintains a 50-acre

wildlife refuge In the eastem portion of the MPS site.

Each MPS unit uses a once-through open-cycle cooling system with intakes on Niantic Bay and

surface discharges to an old quarry cut, which empties into Long Island Sound. Occasional

dredging or de-muclong at the intakes is performed as a normal part of operation.

For the specific purpose of connecting MPS to the regional transmission system, there is a total

of approximately 91 miles of transmission line corridors that occupy approximately 3.052 acres

of land. These transmission line coridors are being evaluated as part of the SEIS process.

The transmission line corridors traverse New London, Toland, Hartford. Middlesex, and New

Haven Counties. The corridors pass through land that is primarily agricultural and forest land.

The enclosed transmission line map shows the transmission system that is being evaluated In

the SEIS. Four 345-kilovolt (kV) lines connect MPS to the electric grid. All four transmission

lines run northward from the plant In a common corridor (415 to 500 feet wide) for 9.1 miles to

Hunts Brook Junction. At Hunts Brook Junction, the lines diverge, with two lines running north

NUREG-1 437, Supplement 22 E-8 July 2005
Appendix E

P. Kurkul 2

to the Card and Manchester Substations, one line running east to the Montville Station, and one

line running west to the Southinglon Substation. These four lines share corridors with other

previously existing transmission Ones.

To support the EIS preparation process and to ensure compliance with Section 7 of the

Endangered Species Act of 1973. the NRC requests a fist of endangered, threatened.

candidate, and proposed species. and designated and proposed critical habitat under the'

jurisdiction of NOAA Fisheries, that may be In the vicinity of MPS site and its transmission line

corridors. In addition, please provide any Information you consider appropriate under Ihe

provisions of the Fish and Wildlife Coordination Act The NRC has also contacted the Fish and

Wildlife Service and requested a list of species and Information on protected, proposed, and

candidate species and critical habitat that may be in the vicinity of MPS and Its associated

transmission lines.

We plan to hold two public NEPA scoping meetings on May 18 2004. at the Waterford Town

Hall Auditorium 5 i Rope Ferry Road In Waterford. Connecticut. On May 19,2004. we plan to

conduct a site audit You and your staff are Invited to attend both the site audit and the public

meetings. Your office will receive a copy of the draft SEIS along with a request for comments.

The anticipated publication date for the draft SEIS is December 2004. ;

If you have any questions concerning the NRC staff review of this license renewal application,

please contact Mr. Richard L Emch. Jr.. Senior Project Manager at 301-415-1590 or

RLE@nrc.gov. -

Sincerely,

./2 Pao-Tsin Kuo, Program Director

"-License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

23

sion Line Map

Docket Nos.: 50-336 and 50-4

Enclosures: 1. MPS Transmis!

2. MPS Site Layout

cc wdend.: See next page

en_..~ .. .

July 2005. - E-9 NUREG-1437, Supplement 22
Appendix E

Millstone Power Station. Units 2 and 3

Application for Renewed Operating Licenses

Chapter 3 Appendix E - Environmental Report

Figure 3-2

Transmission Line Map

Mm. Peen Be,". M

raptM e 5C', w la

wlkljw

LkW FI.URE .

Shft Sawa Transmlsson UnLie Map

Page E-3-13 January2004

NUREG-1437, Supplement 22 E-10 July 2005
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Appendix E

9 pUNITED STATES

Ng-UCLEAR REGULATORY COMMISSION

,WASHIVGTOlk D.C. :D0S5OOOI

flarch 18, 2004

* we

Marvin Moriarty. Regional Director

Northeast Regional Office

U.S. Fish and Wildlife Service

300 Westgate Center Drive

Hadley, MA 01035-9589

SUBJECT: REOUEST FOR LIST OF PROTECTED SPECIES WITHIN THE AREA UNDER

EVALUATION FOR THE MILLSTONE POWER STATION, UNITS 2 AND 3

UCENSE RENEWAL

Dear Mr. Moriarty.

The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application submitted by

Dominion Nuclear Connecticut Inc. (DNC) for the renewal of the operating licenses for Millstone

Power Station. Units 2 and 3 (MPS). MPS Is located on the north shore of Long Island Sound

in Waterfond, Connecticut. approximately 40 miles southeast of Hartford, Connecticut As part

of the review of the license renewal application, the NRC is preparing a Supplemental

Environmental Impact Statement (SEIS) under the provisions of the National Environmental

Policy Act (NEPA) of 1969. as amended, which includes an analysis of pertinent environmental

issues, including endangered or threatened species and Impacts to fish and wildlife. This letter

is being submitted under the provisions of the Endangered Species Act of 1973. as amended,

and the Fish and Wildlife Coordination Act of 1934. as amended.

The proposed action would include the use and continued maintenance of existing plant facilities and transmission lines. The MPS site covers approximately 525 acres, of which

approximately 220 acres is Industrial. The area surrounding MPS is characterized by old field,

mesic hardwood forest, coastal marsh and beach habitats. DNC also maintains a 50-acre

wildlife refuge in the eastern portion of the MPS site.

Each MPS unit uses a once-through open-cycle cooling system with Intakes on Niantic Bay and

surface discharges to an old quarry cut, which empties into Long Island Sound. Occasional

dredging or de-mucking at the Intakes is performed as a normal part of operation.

For the specific purpose of connecting MPS to the regional transmission system, there Is a total

of approximately 91 miles of transmission line corridors that occupy approximately 3,052 acres

of land. These transmission line corridors are being evaluated as part of the SElS process. The transmission line corridors traverse New London, Toland, Hartford, Middlesex, and New

Haven Counties. The corridors pass through land that Is primarily agricultural and forest land.

The enclosed transmission line map shows the transmission system that is being evaluated in

the SEIS. Four 345-kilovolt (kV) lines connect MPS to the electric grid. All four transmission

mines run northward from the plant in a common corridor (415 to 500 feet wide) for 9.1 miles to

Hunts Brook Junction. At Hunts Brook Junction, the lines diverge, with two lines running north

NUREG-1437, Supplement 22 E-12 July2005

I
Appendix E

M. Moriarty -2 -

to the Card and Manchester Substations, one line running east to the Montville Station, and one

line running west to the Southington Substation. These four lines share corridors with other

previously existing transmission lines.

To support the SEIS preparation process and to ensure compliance with Section 7 of the

Endangered Species Act, the NRC requests a list of species and Information on protected,

proposed. and candidate species and critical habitat that may be In the vicinity of MPS and Its

associated transmission lines. In addition, please provide any Information you consider

appropriate under the provisionis of the Fish and Wildlife Coordination Act.

We plan to hold two public NEPA scoping meetings on May 18. 2004, at the Waterford Town

Hall Auditorium, 15 Rope Ferry Road in Waterford, Connecticut. On May 19. 2004, we plan to

conduct a site audit. You and your staff are invited to attend both the site audit and the public

meetings. Your office will receive a copy of the draft SEIS along with a request for comments.

The anticipated publication date for the draft SEIS Is December 2004.

If you have any questions concerning the NRC staff review of this license renewal application,

please contact Mr. Richard L Emch, Jr., Senior Project Manager at 301-415-1590 or

RLEOnrc.aov. . ,-

Sincerely,

: ' -4,.' .. ',, - Pao-Tsin Kuo, Program Director

License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-336, 50-423

Enclosures: 1. MPS Transmission Line Map

2. MPS Site Layout

cc w/encl.: See next page -

July 2005 E-13 NUREG-1 437, Supplement 22
Appendix E

Millstone Power Station. Units 2 and 3

Application for Renewed Operating Licenses

Chapter 3 Appendix E - Environmental Report

Figure 3-2

Transmission Line Map

H-I-a 'VI \n d - *

S-f alk

IE" o

T7unbsnIon Line FIGURE 3-2

ftBoundaries \ MTransmission Une Map

Pe 3S1 E J ns ua ry00

Page E-3 13 January 2004

NUREG-1437, Supplement 22 E-14 July 2005
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Appendix E

so9' UtI1TED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

Match 30, 20O.

Mr. Paul Loether. Director

Connecticut Historical Commission

59 South Prospect Street

Hartford. CT 06106

SUBJECT: MILLSTONE POWER STATION. UNITS 2 AND 3 LiCENSE RENEWAL

REVIEW

Dear Mr. Loether

The U.S. Nuclear Regulatory Comrrission (NRC) staff Is reviewing an application to renew the

operating licenses for Millstone Power Station, Units 2 and 3 (MPS), which Is located on the

north shore of Long Island Sound In Waterford. Connecticut, approximately 40 miles southeast

of Hartford. Connecicut MPS is operated by Dominion Nuclear Connecticut Inc. (DNC). The

application for renewal was submitted by DNC on January 22. 2004, pursuant to NRC

requirements at Tide 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54). The

NRC has established that, as pat of the stall review of any nuclear power plant license renewal

action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its *Generio

Environmental Impact Statement for License Renewal of Nuclear Plants' (GEIS),

NUREG-1437, will be prepared under the provisions of 10 CFR Part 51. the NRC rules that

implement the National Environmental Policy Act of 1969 (NEPA). In accordance with

36 CFR 800.8. the SEtS will include analyses of potential impacts to historic and archaeological

resources.

In the context of the National Historic Preservation Act of 1968, as amended, the NRC staff has

determined that the area of potential effect (APE) for a license renewal action Is the area at the

power plant site and its Immediate environs that may be Impacted by post-lcense renewal landdisturbing operations or projected refurbishment activities associated with the proposed action.

The APE may extend beyond the Immediate environs in those Instances where post-license

renewal land-disturbing operations or projected retunbishment activities, specifically related to

license renewal. may potentially have an effect on known or proposed historic sites. This

determination Is made irrespective of ownership or control of the lands of Interest.

While preparing its application, ONC contacted your office by letter dated July 31, 2003. In its

letter. DNC stated there are no plans to significantly alter current operations over the license

renewal period. DNC further stated that no expansion of existing facilities is planned, and no

major structural modifications have been Identif led for the purpose of supporting license

renewal. In addition, no land-disturbing activities are anticipated beyond those required for

routine maintenance and repairs. Your office responded in a letter dated August 5 2003,

stating that the proposed undertaking will have no effect on historic, architectural, or

archaeological resources listed on or eligible for the National Register of Historic Places.

NUREG-1437, Supplement 22 E-1 6 July 2005
Appendix E

P. Loether 2

On May 18, 2004, the NRC wit! conduct two public NEPA scoping meetings at the Waterford

Town Hall Auditorium, 15 Rope Ferry Road in Waterford. Connecticut. You and your staff are

invited to attend. Your of fice will receive a copy of the draft SEIS along with a request for

comments. The anticipated publication date for the draft SEIS Is December 2004. If you have

any questions or require additional Information, please contact Mr. Richard L Emch. Jr., Senior

Project Manager at 301-415-1590 or RLE@nrc rov. ;

Sincerely,

nAKuo. Division Kof P gra Irector Ll~ense Renewa and Environmental Impacts of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-336,50-423

Enclosure: As stated

cc wlo encl.: See next page

July 2005: E-1 7 NUREG-1437, Supplerment 22 -
Appendix E

0 UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 2055S-0001

Aprol 8, 2004

Mr. Don Kluima, Director

Office of Federal Agency Programs

Advisory Council on Historic Preservation

Old Post Office Builcding

1100 Pennsylvania Avenue. NW, Suite 809

Washington, DC 20004

SUBJECT: MILLSTONE POWER STATION. UNITS 2 AND 3 LICENSE RENEWAL

REVIEW

Dear Mr. Klima:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an application to renew the

operating licenses for Millstone Power Station. Units 2 and 3 (MPS), which is located on the

ncrh shore of Long Island Sound in Waterford, Connecticut, approximately 40 miles southeast

of Hartford, Connecticut. MPS is operated by Dominion Nuclear Connecticut Inc. (DNC). The

application for renewal was submitted by DNC on January 22,2004, pursuant to NRC

requirements at Title l1ot the Code of Federal Regulations Part 54(10 CFR Part 54). The

NRC has established that, as part of the staff review of any nuclear power plant license renewal

action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its Generic

Environmental Impact Statement for License Renewal of Nuclear Plantse (GElS).

NUREG-1437, will be prepared under the provisions of 10 CMA Part 51. which Implements the

National Environmental Policy Act of 1969 (NEPA). In accordance with 38 CFR 800.8. the

SEIS will include analyses of potential impacts to historic and cultural resources. A draft SEIS

is scheduled for publication in December of 2004, and will be provided to you for review and

comment

If you have any questions or require additional information, please contact the Senior Project

Manager for the Millstone project, Mr. Richard L Emch, Jr.. at 301-415-1590 or RLE@nrc.gov.

Sincerely.

PIo.Tsin Kuo, rogram Director

License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-336, 50-423

cc: See next page

NUREG-1437, Supplement 22 E-18 July 2005
Appendix E

April 14. 2004 - - *:

The Honorable Matthew Thomas, Chief Sachem

Narragansett Indian Tribe -

P.O. Box 268 - - Charlestown, RI 02813

SUBJECT: U.S. NUCLEAR REGULATORY COMMISSION REVIEW OF MILLSTONE

POWER STATION, UNITS 2 AND 3 UCENSE RENEWAL APPUCATIONS

Dear Chief Thomas:

The U.S. Nuclear Regulatory Corntission (NRC) Is seeking Input for Its envkonmental review

of applications from the Dominion Nuclear Connecticut. Inc. (DNC) to renew the operating licenses for the Milsiona Power Station, Units 2 and 3 (UPS). -UPS is located on the north

shore of Long Island Sound in Waterford, Connecticut, approximately 40 niles southeast of

Hartford. Connecticut. MPS Is In close proximity to lands that may be of Interest to the

Narragansett Indian Tribe. As described belovK the NRC process includes an opportunity for

pubic and hiter-governmental participation In the environmental review. We want to ensure

that you are aware of our efforts and. pursuant to 10 CFR 51.28(b). the NRC invites the

Narragansett Indian Tribe to provide input to the scoping process relating to the NRC's

environmental review of the application. A copy of this letter Is also being forwarded to

M.r John Brown, your Tribal Preservation Officer. In addition, as outlined in 36 CFR 800.8. the

NRC plans to coordinate cormpliance with Section 108 of the National Historic Preservation Act

of 1968 through the requirements of the National Environmental Policy Act of 1969.

Under NRC regulations, the original operating loens fora nuclear power plant is issued for up.

to 40 years. The license may be renewed for up to an additional 20 years If NRC requirements

are met. The current operating licenses for MPS Units 2 and 3 wll expire hI July2015 and

November 2025. respectively. DNC submitted its application for renewal of the MPS operating

licensesonJanuary22.2004. , *.-

The NRC Is gathering Information for a MPS-speclfc supplement to ts *Generic Environmental

Impact Statement for Ucense Renewal of Nuclear Plants (GEIS), NUREG-1437. The

supplement WI1 contain the results of the review of the environmental lnpects on the area

surrounding the MPS site that are related to terrestrial ecology, aquatic ecology, hydrology, historic and archaeological resources, and socioeconomic issues (among others) and will

cont in a recorrendation regarding the environmental acceptabilty of the icense renewal

action. ,. -

The NRC vWI hold two public scoping meetings for the MPS license renewal supplement to the

GElS on May 18,2004, at the Waterford Town Hal Auditorium, 15 Rope Ferry Road in

Waterford Connecticut 06385. There will be two sessions to cconmnodate intrested partes. The first session will convene at 1:30 p.m. and vil continue until 4:30 pm., as necessary. The

second session will convene at 7:00 p.m.. with a repeat of the overview portions of the meeting, and will continue until 10;00 p.m., as necessary. Additionally, the NRC staff will host informal

discussions one hour before the start of each session. To be considered, comments must be

provided either at the transcrbed public meetings or in writing. No formal conmments on the

proposed scope of the supplement to the GEIS will be accepted during informal discussions.

July2005.. E-19 - NUREG-1437, Supplement 22;'
Appendix E

Chief M. Thomas -2 -

The application is electronically available for inspection from the Publicly Available Records

component of NRC's Agencywide Documents Access and Management System (ADAMS)

under Accession Number ML040260070. ADAMS is accessible at httpto/w nrc govo

readin-nmVadams.htmj which provides access through the NRC's Public Electronic Reading

Room (PERR) link. If you do not have access to ADAMS or if there are problems in accessing

the documents located in ADAMS. contact the NRC's Pubic Document Room (PDR) Reference

staff at 1-800-397-4209, 1-301 415-4737. orby e-mail at pdrsnrc.gov. In addition, the

application can be viewed on the Internet at Nito 11wmw nrc.govlreactors.ooeratin9.licensingJ

renewalfaoplicalions html

A paper copy of the application can be viewed at the NRC's PDR. located at One White Flint

North, 11555 Rockville Pike (first floor), Rockville, Maryland, 20852-2738: the Waterford Public

Library, located at 49 Rope Ferry Road, Waterford, Connecticut. 06385: and at the Thames

River Campus Library at Three Rivers Community College. 574 New London Turnpike,

Norwich. Connecticut. 06360. The GEIS. which assesses the scope and impact of

environmental effects that would be associated with license renewal at any nuclear power plant

site, can also be found on the NRC's 'ebsite or at the NRCs PDR.

Please submit any written comments that the Narragansett Indian Trbe may have to offer on

the scope of the environmental review by June 4, 2004. Comments should be submitted by

mad to the Chief, Rules and Directives Branch, Division of Administrative Services. Mail Stop

T-6D59. U.S. Nuclear Regulatory Commission, Washington D.C. 20555-0001. or by e-mail to

MitstoneEIS@nrcngov. At the conclusion of the scoping process, the NRC staffwill prepare a

summary of the significant issues identified and the conclusions reached and will mail a copy to

you.

The NRC wilt issue the draft supplemental environmental impact statement (SEIS) for publc

comment (anticipated publicabon date. December 2004), and lt hold another set of public

meetings in the site vicinity to solicit comments on the draft A copy of the draft SEIS wil be

sent to you for your review and cornment. After con sideration of public comnments received on

the draft, the NRC will prepare a final SEIS. The issuance of a final SEIS for MPS is planned

forJuly 2005. If you need additional information regarding the environmental review process.

please contact Mr. Richard L. Emch, Jr.. Senior Environmental Project Manager, at

(301) 415-1590.

Sincerely,

IRAI

Pao-Tsin Kuo, Program Director

License Renewal and Environmental Impacts Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-338, 50-423

NUREG-1 437, Supplement 22 E-20 July 2005
Appendix E

Chief M. Thomas -2-

The application is electronically available for inspection from the Publicly Available Records

component of NRC's Agencywide Documents Access and Management System (ADAMS)

under Accession Number ML040260070, ADAMS s accessible at http .vww nrc aovI

readin-rnriadams himl which provides access through the NRC's Public Electronic Reading

Room (PERR) link. If you do not have access to ADAMS or if there are problems in accessing

the documents located In ADAMS, contact the NRC's Public Document Room (PDR) Reference

staff at 1-800-397-4209, 1-301415-4737. or by e-mail at pdrtgnrc.gov. In addition, the

application can be viewed on the Intemet at htlprfwwv nrc.govreactorslooeratinp'licensing!

renewalra olications html,

A paper copy of the application can be viewed at the NRCs PDR. located at One White Flint

North, 11555 Rockville Pike (first floor), Rockville, Marytand. 20852.2738: the Waterford Public

Library, located at 49 Rope Ferry Road, Waterford, Connecticut. 06385; and at the Thames

River Campus Ubrary at Three Rivers Community Colege, 574 New London Tumpike.

Norwich, Connecticut, 06360. The GElS, which assesses the scope and impact of

environmental effects that would be associated with license renewal at any nuclear power plant

site, can also be found on the NRC's website or at the NRCs PDR.

Please submit any wntten comments that the Narragansett Tribal Community may have to offer

on the scope of the environmental review by June 4. 2004. Comments should be submitted by

mall to the Chief. Rules and Directives Branch, Division of Administrative Services. Mail Stop

T-6D59. U.S. Nudear Regulatory Commission, Washington D.C. 20555-0001, or by e-mail to

Mi~stoneEIS@nrrg-ov. At the conclusion of the scoping process, the NRC staff will prepare a

sumvmary of the significant issues Identified and the conclusions reached and will mail a copy to

you,

The NRC wilt issue the draft supplemental environmental impact statement (SEIS) for public

comment (antcipated publication date. December 2004), and will hold another set of public

meetings in the site vicinity to solicit comments on the drafL A copy of the draft SEIS wl be

sent to you for your review and conment. After consideration of public comments received on

the draft, the NRC will prepare a final SEIS The issuance of a final SEIS for MPS is planned

for July 2005. If you need additional information regarding the environmental review process.

please contact Mr. Richard L Emch, Jr.. Senior Environmental Project Manager, at

(301) 415-1590.

Sincerely,

IRAf

Pao-Tsin Kuo, Program Director

License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-336 and 50423

Distrbulion: See next page

Accession No ML041050878

C %ORPCheckoutFiIeNETWlL041050878 wpd

OFFICE LA:RLEP GS: LEP PM RLEP OGC (NLO) SCRLEP PD RLEP

NAME MJenkins- JOavis REmch Chlarco' JTappen PTKuo

DATE 03r29.04 03.29.04 03429:04 0417104 04f1 3104 04214204

OFFICIAL RECORD COPY

July 2005 - E-21 -.- NUREG-1437, Supplement 22
Appendix E

DISTRIBUTION LUr to The Honorable IChief) M Thomas Rep Minsione Dated: AOil 14 2004

Accession No. ML041050875

DMatthewsFGlilespie

PTKuo

REmch

JTappert

LFields

JOavis

RArighi

JEads

CMarro

VNerses

JTrapp. RGN I

MSchenider. RGN I

SKennedy. RGN I

KManagan. RGN I

TDoerr (LANL)

RLEP R/F

NUREG-1437, Supplement 22 E-22 July 2005
Appendix E

I

Millstone Power Station, Units 2 and 3

cc

Lilian M, Cuoco, Esquire

Senior Counsel

Dominion Resources Services, Inc,

Rope Ferry Road

Waterford, CT 06385

Edward L Wilds, Jr., Ph D.

Director. Division of Radiation

Department of Environmental Protection

79 Elm Street

Hanford, CT 06106-5127

Regional Administrator, Region I

U.S. Nuclear Regulatory Commission

475 Allendale Road

King of Prussia. PA 19406

Paul Eccard

First Selectman

Town of Watefford

15 Rope Ferry Road

Waterford, CT 06385

Mr. P. J. Parulbs

Manager- Nuclear Oversight

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

Mr. W. R. Matthews

Senior Vice President- Nuclear Operations

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

Mr. John Markowcz

Co-Chair

Nuclear Energy Advisory Council

9 Susan Terrace

Waterford, CT 06385

Mr. Evan W. Woollacott

Co-Chair

Nuclear Energy Advisory Council

128 Terry's Plain Road

Simsbury, CT 06070

Senior Resident Inspector

Millstone Power Station

cdo U.S Nuclear Regulatory Commission

P.O. Box 513

Nianbc, CT 06357

Mr. G. D. Hicks

Director- Nuclear Station Safety

and Ucensing

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

Ms. Nancy Burton

147 Cross Highway

Redding Ridge. CT 00870

Mr. Wiliam D. Melnert

Nuclear Engineer

Massachusetts Municipal Wholesale

Electric Company

Moody Street

P.O. Box 426

Ludlow, MA 01056

Mr. J. Alan Pricei - Site Vice President

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

Mr. Chris L. Funderburk

Director, Nuclear Licensing and

Operations Support

Dominion Resources Services. Inc.

Innsbrook Technical Center

5000 Dominion Boulevard

Glen Allen, VA 230604711

Mr. David W. Dodson - - - Licensing Supervisor -

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

July 2005 E-23 - NUREG-1437, Supplement 22
Appendix E

Millstone Power Station, Units 2 and 3

cc

Mr. S E. Scace Mr. John Brown

Assistant to the Site Vice President Tribal Preservation Officer

Dominion Nuclear Connecticut, Inc. Narragansett Indian Tnbe

Rope Ferry Road P 0. Box 700

Waterford. CT 06385 Wyoming, RI 02898

Mr. M. J. Wilson

Manager - Nuclear Training Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 08385

Mr. A. J. Jordan. Jr.

Director - Nuclear Engineering

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford. CT 06385

Mr. S. P. Sarver

Director - Nuclear Station Operations

and Maintenance

Dominion NuclearConnecticut. Inc

Rope Fenry Road

Waterford, CT 06385

Mr. Charles Brinkman, Director

Washington Operations Nuclear Services

Westinghouse Electric Company 12300 Twinbrook Pkwy. Suite 330

Rockville, MD 20852

Mr. David A Christian

Sr. Vce President and Chief Nuclear Officer

Dominion Nuclear Connecticut. Inc.

Innsbrook Technical Center

5000 Dominion Boulevard

Glen Allen, VA 23060-8711

Mr. Fred Emerson

Nuclear Energy Institute

1776 1 Street. NW, Suite 400

Washington. DC 20006-3708

Ms. Judy Liskov, Assistant Director

Waterford Public Library

49 Rope Ferry Road

Waterford. CT 06385

Three Rivers Community College

Thames River Campus Library

574 New London Tumpike

Norwich, CT 06360

NUREG-1437, Supplement 22 E-24 July 2005
Appendix E

AprIl 14,2004

The Honorable Michael J. Thomas, Chairman

Mashantucket Pequot Tribal Nation - - .

P.O. Box 268, Indian Town Road --

Mashantucket, CT 06339-3060 -

SUBJECT: U.S. NUCLEAR REGULATORY COMMISSION REVIEW OF MILLSTONE

POWER STATION, UNITS 2 AND 3 LICENSE RENEWAL APPUCATIONS

Dear Chairman Thomas: - -

The U.S. Nuclear Regulatory Comnission (NRC) Is seeking input for as environmental review

of applications from the Dominion Nuclear Connecticut. Inc. (DNC) to renew the operating

licenses for the Millstone Power Station. Units 2 and 3 (MPS). MPS is located on the north

shore of Long Island Sound in Waterford, Connecticut, approximately 40 miles southeast of

Hartford, Connecticut. MPS is in close proxirity to lands that may be of Interest to the

Mashantucket Pequot Tribal Nation. As described below, the NRC process includes an

opportunity for public and inter governmental participation in the environmental review. We

want to ensure that you are aware of our efforts and, pursuant to 10 CFR 51.28(b), the NRC

invites the Mashantucket Pequot Tribal Nation to provide input to the scoping process relating

to the NRC's environmental reviewof the application. In addition, as outlined In 36 CFR 800.8,

the NRC plans to coordinate compliance with Section 106 of the National Historic Preservation

Act of 1966 through the requirements of the National Environmental Policy Act of 1969. -

Under NRC regulations, the original operating license for a nuclear power plant is issued for up

to 40 years. The license may be renewed for up to an additional 20 years if NRC requirements

are met. The current operating licenses for MPS Units 2 and 3 wil expire in July 2015 and

November 2025, respectively. DNC submitted its application for renewal of the MPS operating

lIcenses on January 22,2004.

The NRC Is gathering information for a MPS-specific supplement to its 'Generic Environmental

Impact Statement for License Renewal of Nuclear Plants' (GEIS), NUREG-1437. The .:

supplement wil contain the results of the review of the environmental Impacts on the area

surrounding the MPS site that are related to terrestrial ecology, aquatic ecotogy, hydrology,

historic and archaeological resources, and socioeconomic issues (among others) and will

contain a reconmnendation regarding the environmental acceptability of the license renewal

action.

The NRC wiN hold two publie scoping meetings for the MPS icense renewal supplement to the

GEIS on May 18, 2004. at the Waterford Town Han Auditonum. 15 Rope Ferry Road in

Waterford, Connecticut, 06385. There wil be two sessions to accommodate interested parties.

The first session vill convene at 1:30 p.m. and wi1l continue until 4:30 pm., as necessary. The

second session will convene at 7.00 p.m., with a repeat of the overview portions of the meeting.

and will continue untl 10:00 p.m., as necessary. Additionally, the NRC staff will host informal

discussions one hour before the start of each session. To be considered, comments must be

provided either at the transcribed public meetings orin writing. No formal comments on the

proposed scope of the supplement to the GEIS will be accepted during informal discussions.

July 2005- E-25 5 NUREG-1437, Supplement 22
Appendix E

Chairmlan M. Thomas -2 -

The application is electronically available for inspection from the Publicly Available Records

component of NRCs Agencywide Documents Access and Management System (ADAMS)

under Accession Number ML040260070. ADAMS is accessible at httpI./NW# nrc gov!

reading-rmladams hitml Which provides access through the NRC's Public Electronic Reading

Room (PERR) link. If you do not have access to ADAMS or if there are problems in accessing

the documents located in ADAMS, contact the NRC's Public Document Room (PDR) Reference

staff at 1-800-397-4209. 1-301-415-4737. or by e-mail at pdnrnrcrgov. In addition, the

application can be viewed on the Internet at htto twvw,.nrc govlreactorsfooeratingflicensingI

renewallapplications html.

A paper copy of the application can be viewed at the NRC s PDR, located at One White Flint

North. 1 1555 Rockville Pike (first floor). Rockville, Maryland. 20852-2738, the Waterford Public

Library. located at 49 Rope Ferry Road, Waterford. Connecticut. 08385; and at the Thames

River Campus Library at Three Rivers Community College. 574 New London Turnpike.

Norwich, Connecticut. 08360. The GEIS, which assesses the scope and impact of

environmental effects that would be associated with license renewal at any nuclear power plant

site, can also be found on the NRC's website or at htto:Itwv.nrc.povfreadin-rmvodr.html

NRC's PDR.

Please submit any wntten comments that the Mashantucket Pequot Tribal Nation may have to

offer on the scope of the environmental review by June 4. 2004. Comments should be

submitted by mail to the Chief, Rules and Directives Branch. Division of Administrative

Services. Mail Stop T-6D59. U.S. Nuclear Regulatory Commnission, Washington D.C. 20555-

0001, or by e-mail to M1IistonegiS@nrcgov,. At the conclusion of the scoping process, the

NRC staff will prepare a summary of the significant issues identified and the conclusions

reached and will mail a copy to you.

The NRC will issue the draft supplemental environmental impact statement (SEIS) for public

comment (anticipated publication date, December 2004), and silt hold another set of public

meetings in the site vicinity to solicit comments on the dralt. A copy of the draft SEIS wilt be

sent to you for your review and commient. Afler consideration or public comments received on

the draft. the NRC will prepare a final SEIS. The issuance of a final SEIS for MPS is planned

for July 2005. If you need additional information regarding the environmental review process,

please contact Mr. Richard L Emch. Jr.. Senior Environmental Project Manager, at

301-415-1590.

Sincerely.

/RAI

Pao.Tsin Kuo. Program Director

License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-336.50-423

NUREG-1437, Supplement 22 E-26 July 2005
Appendix E

Chairman M. Thomas -2-

The application is electronically available for inspection from the Publicly Available Records

component of NRC's Agencywide Documents Access and Management System (ADAMS)

under Accression Number ML040260070. ADAMS is accessible at htto/mhvw nrc gov!

reading-rm/adarms html which provides access through the NRC's Public Electronic Reading

Room (PERR) link. If you do not have access to ADAMS or If there are problems in accessing

the documents located In ADAMS. contact the NRC's Public Document Room (PDR) Reference

staff at 1-800-3974209. 1-301-4154737, or by e-mail at pdrtnrc.gov. In addition, the

applcation can be viewed on the Internet at htlo 11wyw nrc gooyreactors/ooeratingolicensinal

renewal-apoicationsnmillstone htni

A paper copy of the application can be viewed at the NRCs PDR. located at One While Flint

North, 11555 Rockvifle Pike (first floor), Rockville, Maryland. 20852-2738; the Waterford Public

Library. located at 49 Rope Ferry Road, Waterford, Connecticut. 06385; and at the Thames

River Campus Ubrary at Three Rivers Community Coflege, 574 New London Tumpike.

Norwich, Connecticut, 06360, The GEIS, which assesses the scope and Impact of

environmental effects that would be associated with license renewal at any nuclear power plant

site, can also be found on the NRCs website or at htto:Ivww nrc.oovtreadina-rm!odr.html

NRC's PDR.

Please submit any written comments that the Mashantucket Pequot Tribal Community may

have to offer on the scope of the environmental review by June 4,2004. Comments should be

submitted by mail to the Chief. Rules and Directives Branch, Division of Administrative

Services. Mail Stop T-6 059. U.S. Nuclear Regulatory Commission, Washington D.C. 20555-

0001, or by e-mail to MiktsfoneE1S~nrcgov. At the conclusion of the scoping process, the NRC

staff wiU prepare a summary of the significant issues identified and the conclusions reached

and will mail a copy to you.

The NRC wil ssue the draft supplemental environmental impact statement (SEIS) for public

comment (anticipated publication date, December 2004). and Wil hold another set of public

meetings in the site vicinity to solicit comments on the draft A copy of the draft SEIS Will be

sent to you for your review and comnent. After consideration of public conmments received on

the draft, the NRC will prepare a final SEIS. The issuance of a final SEIS for MPS Is planned

forJuly 2005. If you need additional information regarding the environmental review process.

please contact Mr. Richard L Emch, Jr.. Senior Environmental Project Manager, at

301-415-1590 or by e-mail at RLE~nrc.gov.

Sincerely.

Pao-Tsin Kuo, Program Director

Lcense Renewal and Environmental Impacts

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-336 and 50-423

Distribution: See next page

Accession No-ML041050880

C:IORPCheckouf.FileNE1tLO41t 0508 wpd

OFFICE LA:RLEP GS:RLEP PM:RLEP OGC (NLO) SC-RLEP PD RLEP

NAME MJenkins JDavls - REmch' CMarco- JTappert PTKuo

DATE 03.12504 03r254204 O2504 0407104 0413M4 04114.'04

OFFICIAL RECORD COPY

July 2005 .; . E-27` NUREG-1437, Supplement 22
Appendix E

DISTRIBUTION: Lr. to the Honorable M. Thomas Re: Millstone Dated Avril 14 2004

Accession No.ML041050380

DMatthews/FGillespie

PTKuo

REmch

JTappert

LFields

JDavis

RArnighl

JEads

CMarco

VNerses

JTrapp. RGN I

MSchwnider, RGN I

SKennedy. RGN I

KManagan. RGN I

TDoerr (LANL)

RLEP RIF

NUREG-1437, Supplement 22 E-28 July 2005
Appendix E

i

Millstone Power Station, Units 2 and 3

cc

Lillian M Cuoco. Esquire

Senior Counsel

Dominion Resources Services. Inc.

Rope Ferry Road

Waterford, CT 06385

Edw'ard L Wilds, Jr., Ph D.

Director, Division of Radiation

Department of Environmental Protection

79 Elm Street

Hartford, CT 06106-5127

Regional Administrator, Region I

U.S. Nuclear Regulatory Commission

475 Allendale Road

King of Prussia. PA 19406

Paul Eccard

First Selectman

Town of Waterford

15 Rope Ferry Road

Waterford, CT 06385

Mr. P. J. Parubs

Manager . Nuclear Oversight

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

Mr. W. R. Matthews

Senior Vice President - Nuclear Operations

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

Mr. John Markowicz

Co-Chair

Nuclear Energy Advisory Council

9 Susan Terrace

Waterford. CT 06385

Mr. Evan W. Woollacott

Co-Chair

Nuclear Energy Advisory Council

128 Terry's Plain Road

Simsbury, CT 06070

Senior Resident Inspector

Millstone Power Station

vo U.S. Nuclear Regulatory Commission

P. 0. Box 513

Niantic, CT 06357

Mr. G. D. Hicks

Director. Nuclear Station Safety

and Licensing

Dominion Nuclear Connecticut. Inc.

Rope Ferry Road

Waterford, CT 06385

Ms Nancy Burton

147 Cross Highway

Redding Ridge. CT 00870

Mr. Wiliam D. Meinert

Nuclear Engineer

Massachusetts Municipal Wholesale

Electric Company

Moody Street -:

P.O. Box 426

Ludlow, MA 01056

Mr. J. Alan Price

Site Vice President

Dominion NuclearConnecticut, Inc.

Rope Ferry Road -

Waterford, CT 06385

Mr. Chris L Funderburk

Director, Nudear Licensing and

Operations Support -

Dominion Resources Services, Inc,

Innsbrook Technical Center

5000 Dominion Boulevard

Glen Allen, VA 23060-6711

Mr. David W. Dodson -

Licensing Supervisor

Dominion NuclearConnetcut. Inc.

Rope Ferry Road

Waterford, CT 06385'

July 2005. E-29 . NUREG-1 437, Supplemnent 22
Appendix E

Millstone Power Statlion, Units 2 and 3

cc

Mr. S. E. Scace Three Rivers Community College Assistant to the Site Vice President Thames River Campus Library Dominion Nuclear Connecticut. Inc. 574 New London Turnpike Rope Ferry Road Norwich. CT 06360

Waterford, CT 06385

Mr. M. J. Wilson

Manager - Nuclear Training

Dominion Nuclear Connecticut, Inc.

Rope Feny Road

Waterford, CT 06385

Mr. A. J. Jordan. Jr.

Director. Nuclear Engineering

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 08385

Mr. S. P. Sarver

Director. Nuclear Station Operations

and Maintenance

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Walerford. CT 06385

Mr. Charles Brinkman. Director

Washington Operations Nuclear Services

Westinghouse Electric Company

12300 Twinbrook Pkwy. Suite 330

Rockville, MD 20852

Mr. David A. Christian

Sr. Vice President and Chief Nuclear Officer

Dominion Nuclear Connecticut, Inc

Innsbrook Technical Center

5000 Dominion Boulevard

Glen Allen. VA 23060-6711

Mr. Fred Emerson

Nuclear Energy Institute

1776 I Street. NW. Suite 400

Washington. DC 20006.3708

Ms. Judy Liskov. Assistant Director

Walerford Public Library

49 Rope Ferry Road

Waterford, CT 06385

NUREG-1437, Supplement 22 E-30 July 2005
Appendix E

'United States Department of the Jnterior

FISH AND WILDLIFE SERVICE

kNey England Field Office

70 Commercial Street. Suite 300

-,Concord, New Hampshire 03301-5087

RE: License Renewl, Millstone Pover Station Units 2 3 l 

Waterford, CT

Pao-Tsin Kuo

O11ce of Nuclear Reactor Regulation

U.S. NuclearRegulatory Commission

Washington, D.C. 20555-0001

DearMr. Kuo:.

npr I 152004

I have reviewed your request for information on endangered and threatened species and their

habitats for the above-referenced project. The following commnents are provided in accordance

with Section7 oftheEndangered Species Act (ESA) of 1973, as amended (16U.S.C. 1531-1543)

and the Fish and rlddlife Coordination Act (48 Stat, 401. as amended; 16 U.S.C. 661 et seq.).

The following is a list of federally-prolected and candidate species that may be in the vicinity of

MPS and the associated transmission lines: the federally-endangered roscaletem(Strnadowgallii

dougallih) nests on the Atlantic eoastfislands. federally-threatened piping plover (Cizaradrius

inelodus) nests on the Atlantic coast, the federally-threatened puritan tiger beetle (Cicindela

purflana) is found in Middlesex County' the federally-threatened small whorled pogonia (Isolrla

riedeololdes) is found in Hartford/New Haven/Fairfield/New London/Windhartnolland

/Middlesex and Litchfield Counties, and the federally-thteatened bald eagle (Haliaecius

leucocepiaalus) uses the entire state for migratory/nesting purposes. In addition theNewvEngland

cottontail (Syldilagtstirasitlotatls) has been proposed as a canditatefor federal listing. TheNew

England cottontail may be found in the vicinity of the MPS and associated transmission lines.

With regard to our cofinefnsbunder the provisioniof tlicish and WVildlifkCoofdinati5nAct. we

are unable to provide detailed comments on the potential effects of the proposed action on fish and

wildlire resources at this time. %Ve will provide further comments afterwe review the Supplemental

Environmental Impact Statement.

July 2005 .' E-31 NUREG-1437, Supplement 22
Appendix E

- 2-

Tharggyou for your-cooperationand plcasecontactm-rnear 6O3-223-2541 -extendsion 23. fo1

cdangcred species questions, and contact GregMannesto ofour Rhode Island oficeat401-364-

9124 for any other concerns you night have. In the future, in order to expedite your reply,

please direct any inquiries br iihis nature to this orlice at the above address.

Sincerely yours.

Michael J. Amaral

Endangered Species Specialist

New England Field Office

NUREG-1437, Supplement 22 E-32 July 2005
Appendix E

DE- STATE OF CONNECTICUT ,

DEPARTMENT OF ENViRONINMENTAL, PROTECTION

April 27, 2004 -

Mr. Richard Ernch

Environmental Project Manager

USNRC OWFN

11555 Rockville Pike

Rockville,MD 20852

and

Ms. P. F. Fugger.

ViP. and Chief Env. Officer

Dominion

5000 Dominion Blvd.

Glen Allen, VA 23060

RE. Request to reew the opcrating licenses for

Units 2 and 3 of the Millstone Power Station in

Waterford, Connecticut

Dominion NucIear Connecticut, applicant

Dear Mr. Emch and Ms. Faggert:

We are in receipt of a request for Federal coastal consistency concurrence for renewal of the

operating licenses for Units 2 and 3 at the Millstone Power Station in Waterford. Connecticut.

This consistencyconcuffence request was submitted pursuant to 15 CFR 930.50.

Continued operation of the Millstone Nuclear Power plant requires renewal of the NPDES pernit

previously issued for the discharge of cooling waters. A request for that permit renewal was

submitted by the applicant in a timely fashion and is currently pending befure the Dcpailtrnent.

In the interest of permit coordination, we have elected to waive the separate Federal coastal

consistency review for this particular operating licensc application. However, this waiver should

not be construed as our determination that the proposed activities arm consistent with

Connecticut:s approved coastal management program. Instead. the State of Connecticut will

evaluate the consistency or this proposed activity for conformance with the relevant coastal

management policies, standards and criteria in conjunction with the State's NPDES permit

review process as required by the Connecticut Coastal Management Act [Connecticut General

Statutes (CGS) sections 22a-90 through 22a-l 121.

Phone 60.424.3034 Fa SG0.424A054

79 El. Sulaml * HaIfod. CT 06106r-12?

Al Le.. Opp.....;ty Epr..p,

July 2005 E-33 NUREG-1437 Supplement 22
Appendix E

April 27,2004 Page 2

This waiver is provided in response to the Federal coastal consistency concurrencc request and

the supporting documentation submitted to this Office on January 27.2004. Any subsequent

modification. addition or deletion to the proposed activity. regardless of its magnitude or impact,

constitutes a new application for the purposes of federal consistency certification. Accordingly.

all such modifications, additions or deletions must be submitted to the State of Connecticut for a

coastal consistency concurrence pursuant to 15 CFR 930.50.

If you have any questions regarding this matter, you may contact Margaret Welch of this Offce

via e-mail at marmarct welch( oo state.ct.us or by phone at 860.424.3034. Thank you.

Charles H. Evans. Director

Office of Long Island Sound Programs

CHE(MLWT v

cc, Allison Castellan

Charles Nezianya

Edward Wilds

NUREG-1 437, Supplement 22 E-34 July 2005 .
Appendix E

% , UNtTED STATES DEPARTMENT OF COMMERCE

National Oceanic and Atmospheric Administration

NATION MARNE FrS4IERES SERV= \ 1 ') .F NORTEAST REGION -. 0,r - ela rbl D NO " -. ucnerr.NA a2298 "-.

SEP, 2.1 t3:l'

PsO-Tsin Kuo

Program Director

License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs

Otfice of Nuclear Reactor Regulation

US Nuclear Regulatory Commission

MS T-1I Fl

%Vashinzton. DC 20555

Re: Millstone Power Station Units 2 and 3 license renewal

Dcar Mr. Kuo,

This is in response to your letter dated March 17,2004 requesting infornation on the presence of

threatened, endangered, candidate and proposed species listed under the jurisdiction of the

National Marine Fishcries Service (NOAA Fisherics) in the vicinity of the Millstonc Powvcr

Station located ott the north shorc ofLong Island Sound I; Vaterford. Connectcut. The US

Nluciea'Regulatory Commrision (NRC) is reiewving n application submitted by Dominion

NudleakCodnbeciicut Jnc:(DNC)for the rcnefal of the operadng licenses forMillstone Powcr

Statioui.Units 2'ndB3(bPS).:In-support'f6thWisreview; theNRC is curnnily'preparnnga., - Supplemental Environmental Impact Statement (EIS).

Four'specis'of federally thrcatencd br endangered sca turtlcs urnder the jurisdiction'of the"'

National Marine Fisheries-Service (NOAA Fisheries) may oefound seasonally in the wvaters of

Long Island.- Sea turtles are expected to be in the vicinity of the project area In warmer months.

typically from May I to November 15. The sea turtles in northeastern nearshore waters are

typically small juveniles with the most abundant being the federally threatened loggerhead

(Caritta caretto followed by the federally cndangercd Kemp's ridley (Lupidoclielys kemps).

Loggerhead turtles have been found tobe relatively abundant off thc Northeast (from tear Nova

Scotia. Canada to Cape Hatteras, North Carolina). From November to March in 19SS through

1988, 130 cold-stunned turtles were collected along the Long Island shoreline, Including 97.*.

Kemp's ridleys. The waters of Long Island Sound have also been found to be warm enough to

support federally endangered green sea turtles (Cihelonia mydas) from June through October.

The three species ofchelonid turtles found in the Northeast remain very briefly In open occan

witcrs.spending mostof their time'during !hpsummer months in habors and estuarine watcrs.

Fdd'ially.etadangercdteatherbaikscaturties (Dfrmnqclaeys coriacta)n)y be found in the waters

b'fLdIsandSound during the sarrndr:months-as 'well

, .S ..

July 2005- E-35 --- NUREG-1437, Supplement 22
Appendix E

Federally endangered North Atlantic right whales (Eubalbena glaclatis). humpback whales

(Afegaptera novacangtiae). and Ein whales (Bolaenopteraphlysalas) may all also be found

seasonally in Northeast waters. North Atlantic right whales have been documented in the

nearshore waters of New York from January through September. Humpback whales feed during

the spring, summer, and fall over a range that encompasses the eastern coast of the United States.

Fin whales are common in waters of the United States Exclusive Economic Zone, principally

offshore from Cape Hatteras northward. While these whale species are not considered residents

of Long Island Sound. it is possible that transients may enter the area during seasonal migrations.

The entrainment and impingement of sea turtles at several nuclear power plants on the EastCoast has been documented. As sea turtles may be seasonally present in the vicinity of the

intakes associated with the )SPS. NOAA Fisheries recommends that this impact be fully

addressed in the SEIS being prepared in anticipation of license renewal actions. NOAA

FIsheries staff look forvard to reviewing the SEIS and will be available to NRC staff to discuss

any potential impacts on listed species. Please contact Julie Crocker of my staff ((978)281;932

x6530 or iulie.crockernonn -ov) if you would like to set up a conference call or meeting.

Section 7(a)(2) or the Endangered Species Act (ESA) of 1973. as amended, states that each

Federal agency shall, in consultation with the Secrctary, insure that any action they authorize,

fund, orcarry out is not likely tojeopardize the continued existence of a listed species orresult in

the destruction or adverse modification of designated critical habitat. Any discretionary federal

action that may affect a listed species must undergo Section 7 consultation. As listed species

may be present in the project area, the NRC is responsible for determnininjwhethcr the proposed

action is likely to affect any listed species. The NRC should then submit their determination

along wvith a request for concurrence, to the attention of the Endangered Species Coordinator,

NOAA Fisheries. Northeast Regional Office, Protected Resources Division, One Blacklbum

Drive, Gloucester, MA 01930. After reviewing this inforrnation, NOAA Fishedes would then

be able to conduct a consultation under section 7 of the ESA.

Should you have any questions about these comments or about the section 7 consultation process

in general, please contact Julie Crocker at (97S)281-9328 ext. 6530.

Sincerely.

Assistant Regional Administrator

for Protected Resources

Cc: Ludwig, FINER4

Mne Con Sm 7.RC NXtiAkms Norkw Nv'u Pt8

NUREG-1437, Supplement 22 E-36 July 2005. :
Appendix E

STATE OF CONNECTICUT

COMMISSION ON CULTURE AND TOURISM

October 6,2004

Mr. Pao-Tsin Kuo

License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs ' Office of Nuclear Reactor Regulation .

Nuclear Regulatory Commission

WVashington, DC 20555-0001

Subject: Millstone Power Station

Units 2 and 3 License Renewal

Waterfurd, CT '

Dear Mr. IKuo:

The State Historic Preservation Office has reviewed the above-named project. This office

expects that the proposed undertaking %ill have effet on historic, architectural, or

archaeological resources listed on or eligible for the National Register orHistoric Places.

This office appreciates the opportunity to have reviewed and comrmented upon the proposed

undertaking.

We recommend that the responsible agency provide concerned citizens with the opportunity to

review and comment upon the proposed undertaking in accordance with the National Historic

Preservation Act and the Connecticut Environmental Policy Act.

For further information please contact Dr. David A. Poirier, Staff Archaologlst.

J. Paul Loether

Division Director and Deputy

State Historic Preservation Officer

.A10%. Hlistorie Preservntion and Mluseum Division - :

Amos MIt Hlouse.59 South Prospeci Street, 1lartrord, Conneelicut 06106

860-566-3005 . 860-566-5078 [ax

An Equal OppontnIly E*ploevr

July 2005 E-37 NUREG-1437, Supplement 22
Appendix E

UNIT ED STATES

NUCLEAR REGULATORY COMMISSION

WAkS4HOTOH. D.C. 2M5541I

lNovember 9, Z004

Ms. Patricia A. Kurkul, Regional Administrator

NOMA Fisheries

Northeast Regional Office

One Blackburn Drive

Gloucester, MA 09130-2298

SUBJECT: REQUEST FOR CONCURRENCE- BIOLOGICAL ASSESSMENT FOR

MILLS;TONE POWER STATION, UNITS 2 AND 3 LICENSE RENEWAL

Dear Ms. Kurkul:

The U.S. Nuclear Regulatory Comnission (NRC) has prepared the enclosed biological

assessment (8A) to evaluate whether the proposed renewal of the Milstone Power Station,

UnIts 2 and 3 (MPS) operating icanses for a period of an additional 20 years would have

adverse effects on listed species. The proposed action (license renewal) is not a major.

constrction activity. MPS Is located on the north shore of Long island Sound in Waterford.

Connecticut approxImately 40 mles southeast of Hartfoid, Connecticut.

By letter dated March 17, 2004. to the National Oceanio and Atmospherb Administratlon

(NOAA) - Fisheries, the NRC requested a list of Federally threatened or endangered aquatic

specles that may be In the vicinity of MPS and Its assocIated transmission lines. Ina letter

dated September 21 2004, NOM Fisheries provided a lIst of Federally threatened or

endangered specbs. Your office Identified one threatened and three endangered species of

sea turtles that may be seasonally found In the waters of Long Island. These include the

loggerhead (Cara careta), Kemp's ridley (Lspkiochelys kwrpon green turtles (Choks

mydas). and leatherback turtles (Deinnochelys corhacea).- The letter also Identified three other

endangered species known to occur seasonally In Northeast waters, the North Atlantic right

whales (Eubalsfna glacialis) hurspback whales (MFog e rnovaeenglie), and fin whales

(Baelactera physahs). The NRC has also included h its evaluation the andangered

shornose sturgeon (Acipeser brovmswrum); this species b known to occur in the Connecticut

River, which flows into Long Island Sound approxirnately 10 rifles east of the MiRstone site.

In addition the staff also contacted U.S. Fish and WildUle Service (FWS) by letter dated

March 18, 2004, requesting a flst of Federally threatened or endangered terrestrial specles that

may be in the vicinity o( MPS. In a letter dated April 15. 2004, FWS Identified the foblowing

terrestrial species: the endangered roseate tem (Stema dLgai dougaNih); the threatened

piping plvr (Chracdkus mefodkis), puritan tiger beetle (Ckindela purfana). small whorled

pogonla (Jsotnla medaoldoes), and bald eagle (Harlateus heucophalus); and one caoddate

species the New England cottontai (Sy'Msgw transfitons).

The staff has determined that license renewal for MlIstone would have no effect on the puritan

tiger beetle. shortnoss sturgeon, loggerhead sea turtle, green sea turtle leatherback sea turtle,

Kemp's ridley sea turtle. piping plover, right whale, finback whale, and humpback whale.

License renewal may affect, but Is not likely to adversely affect, the bald eagle, roseate tem,

New England cottontail, and small whorted pogonla.

NUREG-1437, Supplement 22 E-38 July 2005

I
Appendix E

P. Kurkul -2-

We are requesting your concurrence with our determilnationr In reaching our conclusion, the

NRC staff relied on information provided by the licensee, on literature research and Interviews

with experts performed by NRC staff, and on Information provided by FWS (i.e.. Including

current listings of species provided by the FWS. Concord, New Hampshire, New England Field

Office) and NOAA Fisheries (Northeast Regional Office).

If you have any questions regarding this BA or the staffs request, please contact

Mr. Richard L Emch, Jr., Senior Environmental Project Manager, at 301.415-1590 or via e-mall

at reoOnrc.gov.

Sincerely.

*cense Renewal and Environmental Impacts Program

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-336 and 50-423

Enclosures: As stated

cc wlenctL: See next page I . i .

July 2005 E-39- NUREG-1437, Supplement 22
Appendix E

UNITED STATES

NUCLEAR REGULATORY COMMISSION

W WAStTOK : DC. 20585.0W1

November 9, 2004

Mr. Marvin Moriarty. Regional Director

Northeast Regional Offlce

U.S. Fish and Wildlife Service

300 Westgate Center Drive

Hadley. MA 01 035.9589

SUBJECT: REQUEST FOR CONCURRENCE- BIOLOGICAL ASSESSMENT FOR

MILLSTONE POWER STATION, UNITS 2 AND 3 LICENSE RENEWAL

Dear Mr. Moriarty.

The U.S. Nuclear Regulatory Commission (NRC) has prepared the enclosed biologIcal

assessment (BA) to evaluate whether the proposed renewal of the Millstone Power Station,

Units 2 and 3 (MPS) operating flcenses for a period of an additional 20 years would have

adverse effects on listed species. The proposed action (license renewal) Is not a major

construction activity. MPS Is located on the north shore of Long Island Sound In Waterford,

Connecticut, approximately 40 miles southeast of Hartford, Connecticut.

By letter dated March 18, 2004, to the U.S. Fish and Wildlife Service (FWS). the NRC

requested a l1st of Federally threatened or endangered terrestrial species that may be in the

vicinity of MPS and its associated transmission lines. In a letter dated April 15. 2004, the FWS

provided a list of Federally threatened or endangered species. The FWS Identified the

following terrestrial species: the endangered roseate tern (Stoma dougalfi dougaillo; the

threatened piping plover (Charadrus melodus), puritan tiger beetle (Cicindela purilana), small

whorled pogonia (Isotrla medoololdes), and bald eagle (Harlaeatus Ieucophalus); and one

candidate species, the New England cottontail (Syhlagus transitlonalls).

In addition the staff also contacted the National Oceanic and Atmospheric Administration -

Fisheries (NOAA Fisheries) by latter dated March 17,2004, requesting a list of Federally

threatened or endangered aquatic species that may be In the vicinity of MPS. In a letter dated

Septenter 21, 2004, NOAA Fisheries identified one threatened and three endangered species

of sea turtles that may be seasonally found In the waters of Long Island. These are the

loggerhead (Caretta caretta), Kemp's ridley (Lepidochelys kemp4, green turtles (Chelonia mydas) and leatherback turtles (Dermochelys corlacea). The letter also Identified three other

endangered species known to occur seasonally In Northeast waters, North Atlantic right whales

(Eubalaena glacialls), humpback whales (Magaptera novaoangllae), and fin whales

(Balaenopteraphysalus). The NRC has also included In Its evaluatin the endangered

shortness sturgeon (Aciponserbrevirostrum); this species is known to occur in the Connecticut

River, which fiows into Long Island Sound approximately 10 miles east of the Millstone site.

The staff has determined that license renewal for Millstone would have no effect on the puritan

tiger beetle, shortnose sturgeon, loggerhead sea turtle, green sea turtle, leatherback sea turtle.

Kemp's ridley sea turtle, piping plover, right whale, finback whale, and humpback whale.

License renewal may affect, but is not likely to adversely affect, the bald eagle, roseate tern,

New England cottontail, and small whorled pogonia.

NUREG-1 437, Supplement 22 E-40 July 2005
Appendix E

M. Moriarty -2-

We are requesting your concurrence with our determination. In reaching our conclusion. theNRC staff relied on Information provided by the licensee, on literature research and Interviews

with experts performed by NRC staff, and on Information provided by FWS (i.e., Including

current listings of species provided by the FWS, Concord, New Hampshire, New England Field

Office) and NOAA Fisheries (Northeast Regional Office).

If you have any questions regarding this BA or the staff's request, please contact

Mr. Richard L Emch, Jr:, Senior Environmental Project Manager, at 301-415-1590 or via e-mail

at rdefnrc.gov.

Sincerely,

P Ku&, Program Director

Lense Renewal and Environmental Impacts Program

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-336 and 50-423

Enclosures: As stated

cc w/encl.: See next page

July 2005 !,,.. E-41 NUREG-1437, Supplement 22
Appendix E

ENCLOSURE 1

BIOLOGICAL ASSESSMENT

NUREG-1 437, Supplement 22 E-42 July 2005
Appendix E

Biological Assessment .

Millstone Power Station'-

License Renewal Review

USNlr er Commissio

'-'' 'October 2004 '''-','

Docket Numbers

- 50-336

:50423: . I . . .

U.S.,,Nuclear Regulatory. Commission- ,-

,-'- Rockville, Maryland,._q,_. -''

July 2005 E-43 NUREG-1 437, Supplement 22-
Appendix E

1.0 Introduction

The U.S. Nuclear Regulatory. Cominission (NRC) issues operating licenses for domestic

nuclear power plants in accordance with the provisions of the Atomic Energy Act of 1954, as

amended, and NRC Implementing regulations. The purpose and need for the proposed action

(that is, renewal of an operating license) is to provide an option that allows electric power

generation to continue beyond the term of the current nuclear power plant operating license, so

future generating needs can be met if the operator and State regulatory agencies pursue that

option.

Dominion Nuclear Connecticut. Inc. (Dominion) has prepared an environmental report In

conjunction with its application for renewal of the Millstone Nuclear Plant. Units 2 and 3

(Millstone) operating licenses, as provided for by the following NRC regulations:

* Title 10, Energy, Code of Federal Regulations (CFR) Part 54, Requirements for

Renewal of Operating Ucenses for Nuclear Power Plants," Section 54.23, Contents of

application - environmental information (10 CFR 54.23).

* Title 10, Energy. CFR Part 51, Environmental Protection Regulations for Domestic

Licensing and Related Regulatory Functions," Section 51.53, Postconstnrction

environmental reports, Subsection 51.53(c), Operating license renewal stage

110 CFR 51.53(c)].

The NRC Is reviewing an application submitted by Dominion (the applicant) for the renewal of

the operating licenses for Millstone for a period of an additional 20 years. There will be no

major construction, refurbishment, or replacement activities associated with this action. This

biological assessment examines the potential effects of the continued operation of Millstone on

14 Federally listed species and one species proposed for candidate listing that could occur

within the Millstone site, near the site, or along is associated transmission line rights-of-way

(ROWs). This consultation is pursuant to Section 7(a)(2) of the Endangered Species Act.

In letters dated March 17 and 18. 2004, the NRC requested that the National Oceanographic

and Atmospheric Administration (NOAA) - Fisheries (also known as the National Marine

Fisheries Service or NMFS) and the U.S. Fish and Wildlife Service (FWS), respectively to

provide lists of Federally listed endangered or threatened species and infornation on protected, proposed, and candidate species, as well as any designated critical habitat, that may be In the

vicinity of Millstone and its associated transmission line ROWs (NRC 2004a, 2004b). The

project area is defined as the Millstone site, its sssociated transmission line ROWs, and

adjacent areas of Long Island Sound. In letters from the FWS (FWS 2004a) and the NMFS

(NMFS 2004a), the NRC was provided a list of Federally protected species In the project area.

A total of eight aquatic and six terrestrial species afforded protection under the Endangered

Species Act of 1973 or candidates for such protection were identified that could potentially

inhabit the project area.

.2-

NUREG-1437, Supplement 22 E-44 July 2005
Appendix E .

2.0 Proposed Action

The proposed action Is the renewal of the operating licenses for Millstone. The current

operating license for Unit 2 expires on July 31, 2015, and for Unit 3 on November 25, 2025.

Dominion has submitted an application to the NRC to renew these operating licenses for an

additional 20 years of operation (.e.. until July 31, 2035. for Unit 2 and November 25, 2045, for

Unit 3). The renewed licenses, If Issued, will be effective from their date of issuance until

20 years after the expiration date of the current operating licenses.

Millstone Is located on Millstone Point In Niantic Bay, between the Nantic and Thames Rivers

on Long Island Sound, near Waterford In New London County, Connecticut (Figure 1). The

nearest large cties are New Haven. approximately 64 km (40 ml) to the west, and Hartford,

approximately 64 km (40 ml) to the northwest The site Is situated on the edge of Long Island

Sound and Niantic Bay and Is approximately 32 km (20 ml) west of Rhode Island. At one time,

there were three operating nuclear power plants at the Millstone site. Construction on Unit 1

began In 1966. on Unit 2 In 1970, and on Unit 3 hI 1974. Unit I was a boiling-water reactor that

was permanently shut down In 1995. The facility Is In long-term storage awaIting

decontamination and dismantlement as part of station decommissioning. Unit I Is not part of

this license renewal application. Millstone Unit 2 is a two-loop, dosed-cycle, pressurized-water

nudear reactor with a calculated electrical output of approximately 870 megawatts electric

(MW[eJ): while Millstone Unit 3 Is a four4oop, dosed-cycle, pressurized-water nuclear reactor

with a calculated electrical output of approximately 1.154 MW(e) (Dominion 2004a).

Long Island Sound Is the source of water for the once-through turbine condenser cooling

systems at Milistone. The system withdraws salt water from Long Island Sound though Intakes,

pumps the water through the condenser for cooling, and surface discharges heated water to

Long Island Sound approximately 610 m (2000 if) southeast of the withdrawal points

(Dominion 2004a).-

Intake structures for Units 2 and 3 are located on the eastern shore of Niantic Bay. which Is fed

by Long Island Sound (Figure 2). The structures consist of four reinforced-concrete bays for

Unit 2 and six bays for Unit 3. When both Units 2 and 3 are operating at full power, the

10 pumps (one for each bay) pump a total of 92 mrIs (1.46 million gpm) Into 2-m (7-fn) diameter

conveyance pipes. Cooling water then moves through the condensers. After passing through

each unit's condensers, cooling water Is discharged to the former granite quarry. The heated

discharge water then flows through two cuts excavated from the bedrock at the eastern end of

the quarry Into Long Island Sound. Figure 2 shows the Intake structures. quarry, and discharge

points for the Millstone drculating water system. ;

The Intake structures are designed to minimize the possibility of dogging or Impingement of

aquatic organisms. Before the Intake water reaches the circulating water pumps, the water

passes through trash racks consisting of 1-cm (3/8-1n. thick) metal bars spaced horizontally on

5-cm (24n.) centers. The water then flows through vertical traveling screens with 1-cm (3/84n.)

mesh that prevent debris and large organisms from entering the cooling system. A cutoff wall

In front of the Intake extends 2.7 in (9 ft) below the surface to prevent surface water debris and

organisms from entering the Intake. Individual trash and fish return troughs collect and sluice

debris and fish from the screens. Unit 3 was originally constructed with a fish return trough;

-3-

July 2005 :- E-45 - NUREG-1437, Supplement 22
Appendix E

Figure 1. Location of Millstone. 80-km (50-mi) Region

-4-

NUREG-1437, Supplement 22 E-46 July 2005
Appendix E

k

Uni:.

*/'

- I

.7- '\ 1'

S7

-,O IDW ft FIGURE 2

Millstone Po6it Location of 500 ft Millstone Cooling Water Scale 15 approx1mate. Intakes and Discharges

Figure 2. Millstorie Point Location of Millstone Cooling Wator Inlakeland Discharges

-5-

July.2005 E-47 NUREG-1 437, Supplement 22 -
Appendix E

a fish return trough was added to Unit 2 in 2000. Water velocity in front of the Unit 2 structure

is estimated to be about 0.2 mis (0.6 ftWs) (Dominion 2004a).

Biocides are added to the Intake water to prevent biofouling. Sodium hypochlorite is injected on

a periodic basis, and the system Is designed to maintain a 0.2 parts per million (ppm) chlorine

concentration (Dominion 2004a). Residual chlorine is monitored in the effluent water. Thermal

backwashlng is also performed to prevent mussels from fouling the Intake structure pump bays.

3.0 Environmental Setting

3.1 Terrestrial Resources

The Millstone silo Is located In the Southern New England Coastal Plains and Hills of the

Northeastern Coastal Zone ecoreglon (U.S. Environmental Prolection Agency [EPA) 2004a).

Pre-settlement vegetation would have consisted primarily of winter deciduous hardwood forests

with some salt marsh and beach habitat types. Out of approxrmately 212 ha (525 ar) that

comprise the Millstone site, current land use Includes approximately 89 ha (220 ac) of

developed area, a 20-ha (50-ac) natural area, and a 12-ha (30-ac) ballpark licensed to the town

of Waterford. Until 1960, the site was used as a granite quarry. which operated for 200 years

(Dominion 2004a).

The current terrestrial environment Indudes old field habitats dorinated by eastern red cedar

(Juniperus virgWana), scarlet oak (Quercus coccines), black cherry (Prunus serotlna), and.

blackberry (Rubus spp;) (Dominion 2004a). Comrnmon invasIve exotics In this habitat Include

multflora rose (Rosa multPflors) and Japanese honeysuckle (Lonicerajaponica). Winter

deciduous hardwood forest dominated by various species of oak (Quarcus spp.), pignut hickory

(Carya glabra), black birch (Befula fenta). red maple (Acerrubrum), and American beech

(Fagus grandifoia) Is the most common undisturbed habitat type. Along the coast, beach and

coastal marsh habitats are dominated by beach grass (Ammopla brevgulata), toadflax

(Linaria vwugads), evening primrose (Oanothera blennis), seaside goldenrod (Soiidago

semperviens), salt meadow grass (Spartina patens), salt grass (DistichIs spicata), B8gelows

gtasswort (Salcomfa b~gelovii), and smooth cordgrass (Sparline alfemfflora). Ponds and

wetlands in the eastern portion of the site are managed as a wildlife refuge.

Terrestrial habitats on the Millstone silo support common wildlife species sudi as white-tailed

deer (Odocofleus vk'glnlanus), gray squirrel (Scmurus carolinensls), cottontail rabbits (Sytv71agus

spp.), red fox (Vulpes vuipes), woodchucks (Mammota monax), and wild turkey (Mefeagrds

gagopevo). Coastal marshes and the wildlfe refuge on the site contain habitat that supports

waterfowl such as mallard ducks (Anss platyrnynchos), wood ducks (Aix sponsa), Canada

geese (Bmnta canadensis), common mergansers (Mergus merganser,) black ducks Onas

rubrfpes), herons, and egrets. Osprey (Pandlon hallaetus) nest platforms have been

maintained at Millstone for over 35 years and 173 fledglings have been produced over that time

period (Dominion 2004a).

Four 345-KV transmission lines connect Millstone to the power grid (Table 1) (Dominion 2004a).

The ROWs traverse New London, Middlesex, Hartford, Tolland, and the northeast comer of

New Haven counties. The four lines share a common ROW for 14.5 km (9 ml) north to Hunts

-8-

NUREG-1437, Supplement 22 E-48 July 2005

I
Appendix E

Brook Junction (Figure 3). At Hunts Brook Junction two lnes run north In the same ROW to the

Card Street Substation where one line continues on to the Manchester Substation, one line runs

east to the Montville Station and one line runs west to the Southington Substation. All Millstone

lines share'ROWs with lines from other sources and would be maintained If Millstone ceased

operating. Transmission lines traverse abandoned fields, pasture, cultivated fields, forests, and

wetlands as well as a number of conservation areas (Dominion 2004a). The Card

Street/Manchester line crosses the Pease Brook Wildlife Management Area. The Southington

line crosses the Nehantic State Forest, Cockaponset State Forest, and Hartman Park, a

municipal park owned by the town of Lyme, Connocticut.

Table 1. Mfllstone Transmission Une Corridors.

- Length Width Max Areaa

Substation kV km (ml) m (t) ha (ac)

HuntsBrookJunction 345 14 (9) 152 (500) .220 (545)

Montville 345 6 - (4) 99 (325) 64 (158)

Card Street 345/ 32 (20) 91 (300) '294 (727)

Manchester 345 61 (38) 91 (300) 559 (1382)

Southington 345 71 (44) 76 (250) 539 (1333)

'4 Max area calculations use marimum right-ol-way width estimates (Dominion 2004a).

Connecticut Ught and Power (CL&P), a subsidiary of Northeast Utilities rconducts maintenance

activities on these transmission lines and ROWs. These activities Include, but are not restricted

to, maintenance of vegetation In each ROW, replacement of poles ortowers, Installaton of

lightning arresters and counterpoise, and upgrading of existing equipment.

CL&P manages vegetation within the ROWs with an approach It cals two-zone maintenance'

(NU 2004). The area directly beneath the transmission lines and extending out 4.5 m (1 5 ft) on

either direction Is called the 'wire zone.' Most vegetation In the wire zone Is kept short except

for the occasional clusters of eastern red cedar that are maintained for nesting habitat. The

area from the edge of the wire zone to the outside edge of the ROWe Is called the 'aide zone'

The side zone acts as a transition between the towers and conductors of the wire zone and the

forest. The side zone Is maintained as a multi-layered habitat with low growing trees and

shrubs. ;

Vegetation Is managed through a combination of mowing, trimming, and herbicide treatments.

An personnel applying herbicides are required to possess a valid applicator's lic6nse (NU 2004).

Wetlands and other water bodies are protected from herbicides by a 3-m (1 0-ft) vegetative

border (NU 2004). Mowing Is conducted only between the months of November and April to

minimize Impacts to wet soils, nesting birds, and widlife forage. The Connecticut Department

of Environmental Protection (CTDEP) reviews all ROW management plans to assure protection

-7-

July 2005:, E-49 NUREG-1 437, Supplement 22
Appendix E

Figure 3. Millstone Site and Associated Transmission Lines

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NUREG-1437, Supplement 22 E-50 July 2005
Appendix E

of threatened and endangered species. CL&P personnel work closely with maintenance crews

to ensure that treatments are implemented properly.

CL&P encourages collaboration with conservation groups to use the ROWs for wildlife habitat

Improvement. It has also developed a list of plant species and wildlife habitat types that It

attempts to promote through Its vegetation management actions. Contractors are required to

Identify and target non-native, InVasive plant species (NU 2004). -.

3.2 Aquatic Resources '

Aquatic resources In the vIcinity of Millstone are primarily associated with marine and estuarine

environments that are part of Long Island Sound. Millstone Is bordered on the west by Niantic

Bay, to the east by Jordan Cove. and to the south by the Twotree Island Channel (Dominion

2004b). The plant Is located approximately 1.6 km (1 ml) southeast of the mouth of the Niantic

River, and approximately 6.5 km (3.5 mi) west of the Thames River. 'Cooling water Intakes are

located In Niantic Bay on the western shoreline of Millstone Point and are situated

approximately 4.6 to 7.6 m (15 to 25 A) below mean sea level. Once-through' cooling water Is

discharged Into an abandoned granite quarry located In approximately the center of Millstone

Point Water then flows from the quarry over a weir Into Long Island Sound near the Twotree

Island Channel (Figure 2). Rated flows for Millstone Units 2 and 3 are 36 and 59 m1 s'

(1275 and 2097 ftle s1) respectively. -

Long Island Sound Is a large water bbdy. with a surface area of 3420 km2 (1320 mi)). and

965 km (600 ml) of coastline. The drainage area associated with the water body is

approximately 27,070 kn9 (18,820 riP). The average depth of the sound Is 19 m (63 ft); and

the approximate volume Is 68 trillion L (18 trillon gallons). Milstone Point Des on the western

shore of Long Island Sound, near the mouth of the sound. This area of Long Island Sound

experiences a salinity of approximately 23 parts perthousand due to the Influence of three

major rivers: the Thames. the Housatonic, and the Connecticut Rivers. Ambient water

temperature near the Millstone cooling water Intakes can range from VIC to 22*C (34*F to

72'F) over the course of a year. Unear regression performed on daily and annual seawater

temperatures near Millstone over a 25-year period revealed a significant long-term Increase In

watertemperature of 1.55*C (2.8'F) based on daily means and 1.01 C (1.8F) based on annual

means (Keser et al. 2003).

Millstone Point Is situated approximately 5.6 km (3.5 ml) west of the Thames River,'In an area

that experiences strong tidal currents that Influence the nearshore ecosystem,rwhich Include

rocky coastlines and boulder and gravel substrate beaches that support a variety of fish.

Invertebrate, and marine plant life . The average tidal fow through Twotree Island Channel Is

approximately 3400 m' s (1.2 x j08 ft3 W t ) with a maximum flow of about 8500 mn's'

(3.0 ix 10 ft' s'). This translates Into current velocities of about 1.8 to 3.30 km hr'

(1 to 1.8 knots), with slightly lower velocities near the plant Weak currents predominate In both'

the Niantic River and Jordan Cove. Tidal fluctuation In this -area Is not severe, with mean and

maximum ranges of 0.8 and 1.0 m (2.8 to 3.3 ft). respectively (Dominion 2004b).

- . -- - **.-..--

J uly 2005 - E-51 NUREG-1437, Supplement 22
Appendix E

EPA Region 1 has identified Long Island Sound as an estuary of national signiflcances and

listed six problem areas of concern associated with water quality (EPA 2004b):

1. Low dissolved oxygen (hypoxia)

2. Toxic contamination

3. Pathogen contamination

4. Floatable debris

5. Habitat degradation and loss, and living resource health associated with Items 1-4

6. Land use and development resulting In habitat loss and degradation of water quality

These problem areas have resulted in a variety of long-term. Integrated studies of Long Island

Sound by both state and Federal agendas.

* Chemical Contarninants Near Millstone

Specifc chemical data associated with sediment, water, or blota near the Millstone study area

were not available for review; but in general. surficlal sediment associated with the eastern

portion of Long Island Sound exhibits lower levels of common contaminants (heavy metals,

polycydlic aromatie hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), pesticides) than

the western portion. United States Geological Survey (USGS) data (Mecray et al. 2004)

showed regional patterns of high metals concentrations In the western sound, with relatively low

concentrations associated with the eastern sound in the vidnity of Millstone. Draft data

(Battelle 1999) associated with surfidal samples from the Thames River Indicated most metals

were below NOAA effectserange-median (Long et al. 1998). and organic constituents were at or

near detection limits with the exception of the PAH, perylene. which was detected at

concentrations ranging from approximately 20 to 1200 pg/kg dry weight. Ills suspected the

source of this compound Is blogenic rather than anthropogenic.

A citzens' group conducted limited chemical and radiological monitoring of bottom sediments in

the vicinity of Millstone and reported possible elevated levels of hydrazine and uranium In the

bottom sediments of Jordon Cove (CTDEP 2002). The chemical compound

1,1-dimethylhydrazlne (UMDH) was reported as detected In two sediment samples at low levels.

It was postulated that the UMDH might be due to hydrazine used at Millstone for corrosion

control. CTDEP reviewed available Informatlon and concluded that the detections likely were

false positives because of questionable quality of the analytical procedures, and It was unlikely

that hydrazine could accumulate In bottom sediments because It degrades rapidly Into water

and nitrogen. In addition, the particular chemical form of hydrazine used at Millstone Is different

than UMDH. There are also industrial facilities In the area that commonly use hydrazine.

CTDEP also concluded that the types and levels of uranium measured In sediments near

Millstone reflected naturally occurring background levels (CTDEP 2002). Neither concern was

Judged by CTDEP to be sufficlenty credible to warrant further Investigation.

a Important Fish and Shellfish Communities Near Millstone

A variety of commercially, recreatlonally. or environmentally Important fish and shellfish live or

spend a portion of their life cycle In the vicinity of Millstone, and also commonly occur In Long

-10 

NUREG-1437, Supplement 22 E-52 July 2005

I
Appendix E

Island Sound (Table 2). Many of these species live In the waters near Millstone, travel through

the area during their seasonal migrations in and out of Long Island Sound, or pass close'to the

plant as they enter rivers adjacent to Millstone during their spawning seasons. Because of their

proximity to Millstone, they may be susceptible to entrainment. Impingement, or to lethal or

sublethal effects associated with Olant operations. In order to assess relative species

abundance near Millstone operations, a variety of collection and enumeration methods have

been employed, Including sampling cooling water discharge using plankton nets to determine

Ichthyoplankton (fish eggs and larvae) abundance, shore-zone seines to capture small fish, and

bottom trawls to capture larger, demersal fish (Dominion 2004b). In general, assessments of

fish and shellfish have Included sampling stations in direct proximity to the plant (e.g., within a

radius of approximately 3 km 12 mi). Sampling stations have Included a station located near

the Unit 2 and 3 cooling water discharge, stations in the Niantic River and Bay, and stations In

Jordan Cove.' Far-field reference sites were not Included In the fish and shellfish monitoring

programs, nor were sampling grids located al varying distances from the area of interest to

Identify environmental gradient effects. Plume dynamic studies and assessments of Intertidal

ecosystems, however did use far-field reference or control sites. - ' -

Table 2. Important Fish and Shellfish Species.

Common Name Scientific Name

winter founder Pseudopleuronocies ainuricanus

lobster Homards emericanus -

'American sandlance Ammodytes amerkcanus

anchovy - Anchoe spp. - -.

sflversldes Menidlaspp. ' :

grubby Myoxocephalusaenaeus -

cunner : .utogolebrus adspersus-.

tautog Tautogs on'

Eelgrass Community

Eelgrass (Zosfera marina) Is one of the dominant seagrasses In coastal regions of the northern

hemisphere, and common in eastern Long Island Sound near the Millstone facility. This

seagrass Is Important because of its significant Influence on the nearshore environment.

Eelgrass beds provide habitat and cover for many larval and juvenile forms of fish and

Invertebrates, support significant primary and secondary production, and serve as a food

source for numerous waterfowl or planktonic grazers (Kesar et al., 2003). Eelgrass beds In the

vicinity of Millstone have been monitored for many years to evaluate population dynamics and

document change over time. -Sampling locations Included areas associated with thermal plume

discharge (Jordan Cove. White Point). and reference locations associated with the Niantic River

(Dominion 2004b). ' Studies near Millstone and In Long Island Sound have shown considerable

variation In the extent of eelgrass beds at all locations, probably due to water body temperature

-1 1- *'-

iuly'200: E-53 NUREG-1437, Supplement 22
Appendix E

fluctuations, eutrophicatlon. sedimentation, turbidity, the presence of nuisance organisms

(mussels and green algae blooms) and possible changes associated with nearshore

hydrodynamics. Studies conducted at Millstone have suggested that eelgrass abundance and

distribution at Jordan Cove and White Point has been affected by the thermal plume discharge.

but have observed relative stable biomass and distribution over the past 16 years at other

locations adjacent to the facility (Dominion 2004b). Studies have also noted dramatic changes

in eelgrass populations In the Nlantic River, resulting In multiple relocations of reference sites

over the past 20 years due to die-off that Is attributable to poor water quality and potential

biological disturbances (Dominion 2004b).

Rocky Intertidal Communities

A rich and varied rocky intertidal habitat exists in the region surrounding Millstone, and indudes

marina alga. polychaeteous annelids, crustaceans, and molluscs. All of these organisms are

Important contributors to the structure and function of nearshore ecosystems. Environmental

studies conducted by Dominion have included sites at Fox Island, Millstone Point, White Point,

and a reference location near Giants Neck (Figure 2). Cooling water discharge stations have

Included a location dose to the quarry cuts and one location approximately 200 m (660 ft)

southeast of the quarry cut. Millstone monitoring programs have been In effect since 1979 and

are intended to provide 1) an environmental baseline of abundance of Important species, and

2) a means to detect change In community structure and function near the Millstone facility.

Algal studies have been conducted since 1979, and have identified over 140 species that occur

or have occurred in the area during the study duration. Dominion scientists have data on

organisms that represent the more common marine flora or fauna, including barnacles, the

algae Fucus spp., the red alga Chondius spp.. and the marine mussel ytus edulfs.

Community analyses using clustering techniques suggest that plant Impacts are generally

limited to approximately 150 m (490 ft) of shoreline on the east side of the discharge to Long

Island Sound (Dominon 2004b). Detectable changes at the comrnunity level have been

observed In the study area, as have ecosystem-level changes (e.g. water temperature

fluctuations, nutrient concentrations, light Intensity). Of particular note Is the presence of the

red alga AntUthamnkin pecUnatum, an exotic species native to the Pacific Ocean that was not

previously reported In the Atlantic.

Benthic Infauna

Benthic infaunal communities near Millstone are consistent with soft-bottom. nearshore

environments associated with New England. These communities typically contain a diverse

assemblage of species that collectively contribute to the stability of the nearshore food web.

Subtidal communities In the vicinity of Millstone and at a reference sie located near Giants

Neck have been sampled and studied since 1980. During the 2003 sampling, marine

polychaetes were the most abundant taxa, followed by oligochaetes, arthropods, and molluscs

(DomInion 2004b). The following lnfaunal taxa were selected as representative of sites affected

by Millstone: oligochaetes. the polychaetes ArkIdea catherinae, Medlomastus ambisets,

Thayry spp., Polycikrus exdmius, Protodorvilea gaspeensIs, Parmpionosylls longkirrata, and the

bivalve mollusc Nuculana annulata (Dorminion 2004b). Monitoring studies have been helpful In

detecting changes In benthic infauna community structure and linking the observed changes to

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NUREG-1437, Supplement 22 E-54 July2005

I
Appendix E

both natural and anthropogenic disturbances.' Milstone activities relating to cooling water

discharge and required maintenance dredging have produced observable effects to the

structure of benthic communities In the Immediate vicinity of the plant. 'This was clearly evident

by the response of the benthic community during extended shutdowns during 1996-1998.

4.0 Assessment of Federally Usted Species

Several Federally Iistid spacies are known to occur in the vicinity of the Millstone site or

associated transmission line ROWs. No FWS-designated critical habitat Is found within the site

or associated ROWs. '- -

4.1 Aquatic Species

Eight Federally listed marine species could occur In Long Island Sound in the vicinity of

Millstone. These Indude three species of whales and four species of turtle (NMFS 2004a.

FWS 2004b) (Table 3). The staff has also evaluated the potential Impacts of continued

Millstone operation on the shortnose sturgeon (Acipenserbrvirorstrum). The shortnose

sturgeon is a Federally listed endangered species that Is found In the Connecticut River, which

flows Into Long Island Sound approximately 10 miles east of the Millstone site.

Table 3. - Aquatic Endangered and Threatened AquaticSpecles'

Scientific Name Common Name Federal Statue

. . - . - -FUH - -::

Aclpenserbevirostrum - shortnose sturgeon Endangered

TuRTLEs

Caretta cwrefta - loggerhead - = '-Endangered

Chelonla mydas * green turtle -Threatened

Denmochelys corfacea leatherback turtle - Endangered

Lepldochefys kempfl Kemp's Ridley - ' Endangered

WHALU . -

Baleena glaciais right whale - - Endangered

Balaenoptere physsas ' f' back whale _-Endangered

Megaptera novaengnae ''humpback whale Endangered

(a) FWS 2004b, NMFS 2004a.

Shortnose Sturgeon (Acipenser brevirostrum)

The shortnose sturgeon Is Federally listed as endangered In the entire range (FWS 2004b).

Two populations of shortnose sturgeon are present In the Connecticut River. One of these Is

landlocked In the upper part of the river between the Holyoke dam and Turners Faas dam In

Massachusetts, and the other population Is located In the lower Connecticut River from the

Holyoke Dam to Long Island Sound. An estimated 1200 to 1500 shorlnose sturgeon are found

In freshwater and estuarine portions of the Connecticut River and are presumed to occasionally

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July 2005 E-55 NUREG-1437, Supplement .. 22
Appendix E

range Into adjacent areas of Long Island Sound (FWS. 2001). No shortnose sturgeon have

been impinged or captured In more than 30 years of sampling at Millstone (Dominion 2004a).

The primary threats to this species are dam building, water pollution, and dredging

(NatureServe 2004).

Although this species has not been recorded for the area and It Is highly unlikely that Individuals

could even occasionally be present. The Intake structures at Dorninion have been fitted with

fish sluiceways that return fish and other organisms that become Impinged during cooling water

Intake. It is unknown how impingement and returns affect mortality of shortnose sturgeon but It

Is expected that the mortality rate would be low. The species has a bottom orientation, It Is a

strong swimmer and its robustness would likely minimize the potential for impingement.

The staff reviewed the design, operation, and location of the intake and discharge structures at

Millstone and the Impingement and entrainment data collected during plant operation. The staff

also visited the she and reviewed the life history information about the shortnose sturgeon. On

the basis of this information, the staff has determined that the continued operation of Millstone

over the 20-year renewal period will have no effect on the shortnose sturgeon.

Loggerhead (Caretta caretta)

The loggerhead sea turtle Is Federally fisted as threatened throughout Its range (FWS 2004b).

There are currently no critical habitats designated for this species, although the NMFS Is

currently working on a status review based on a 2002 petition to redassify the Northern and

Florida Panhandle subpopulations with endangered status and to designate critical habitat for

both subpopulations (NMFS 2004b). The range for the Atlantic population of loggerheads

extends from Newfoundland to Argentina, with primary nesting areas located In florida,

Georgia, and the Carolinas.

The NMFS (2004b) has noted that loggerheads can become impinged on Intake structures of

coastal power plants and estimates the mortality rate for impingement Is 2 percent

(NMFS 2004b). The applicant has not reported any incidences of Impingement of loggerheads

or Incidental takes during trawling studies In over 30 years of sampling operations.

The staff reviewed the design, operation, and location of the Intake and discharge structures at

Millstone and the impingement and entrainment data collected during plant operation. On the

basis of this information, and that previously provided for the aquatic resources in the vicinity of

the plant, the staff has determined that continued operation of Millstone over the 20-year

renewal period will have no effect on the loggerhead sea turtle.

Green Turtle (Chelonla mydas)

The green sea turtle Is Federally listed as endangered in the breeding colony populations In

Florida and on the Pacific coast of Mexico and threatened for all other areas (FWS 2004b).

The western Atlantic population of green turtles ranges from Massachusetts south to the U.S.

Virgin Islands and Puerto Rico. with important feeding grounds In Florida, and primary nesting

sites on the east coast of Florida. the U.S. Virgin Islands and Puerto Rico (NMFS 2004c).

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NUREG-1437, Supplement 22 E-56 July 2005

I
Appendix E

NMFS (2004c) has noted that green sea turtles can become impinged on Intake structures of

coastal power plants and estimates the Impingement mortality for green sea turtles at 7 percent (NMFS 2004c). The applicant has not reported any Incldences of Impingement of green turtles

or Incidental takes during trawling studies In over 30 years of sampling operations.

The staff reviewed the design, operation. and location of the Intake and discharge structures at

Millstone and the Impingement and entrainment data collected during plant operation. On the -.

basis of this information, and that previously provided for the aquatic resources In the vicinity of

the plant, the staff has determined that continued operation of Millstone over the 20-year renewal period WUf have no effect on the green turtle:

Leatherback Turtle (Dermochelys corlacea)

The leatherback sea turtle Is Federally listed as endangered throughout Its range (FWS 2004b). The western Atlantic population of leatherback sea turtles ranges from Nova Scotia to Puerto

Rico and the U.S. Virgin Islands. During the summer. leatherbacks are typically found along the east coast of the U.S. from the Gulf of Maine to central Florida. Critical habitat designated in the area around the U.S. Virgin Islands, with nesting sites located from Georgia to the U.S.

Virgin Islands (NMFS 2004d).

The primary threats to the survival of leatherback sea turtles Include habitat destruction,

Incidental catch in commercial fisheries, and harvest of eggs and meat (NMFS 2004d). Impingement of leatherback sea turtles is not listed by NMFS as one of the human Impacts on

this species (NMFS 2004d). The applicant has not reported any Incidences of Impingement of

leatherback turtles or incidental takes during trawling studies In over 30 years of sampling operations.

The staff reviewed the design, operation, and location of the Intake and discharge structures at.

Millstone and the impingement and entrainment data collected during plant operation. On the'

basis of this Information, and that previously provided for the aquatic resources in the vicinity of

the plant, the staff has determined that continued operation of Millstone over the 20-year renewal period will have no effect on the leatherback turtle.'

Kemp's Ridley (Lepldochelys kempl) -

The Kemp's rldley sea turtle Is Federally listed as endangered throughout its range (FWS 2004b). This species is found primarDy in coastal areas of the Gulf of Mexico and the

northwestern Atlantic, wlth-a major nesting beach on the northeastern coast of Mexdco

(NMFS 2004e).

Habitat degradation, pollution, and Ingestion of floating debris are among the most significant threats to Kemp's rMdlay sea turtles (NMFS 20040). Impingement of Kemp's ridley was not

listed In NMFS (2004e) as one of the human irnpacts on this species. The applicant did not

report any Incidences of Impingement of Kemp's ridley or incidental takes during trawling' studies in over 30 years of sampling operations. ; -

July 2005 E-57 NUREG-1437, Supplement 22
Appendix E

The staff reviewed the design. operation, and location of the Intake and discharge structures at

Millstone and the Impingement and entrainment data collected during plant operation. On the

basis of this Information, and that previously provided for the aquatic resources In the vicinity of

the plant, the NRC concludes that continued operation of Millstone over the 20-year renewal

period will have no effect on the Kemp's ridley.

Right Whale (Eubalaena gladalls)

The right whale Is Federally listed as endangered throughout its range (FWS 2004b). With a

population estimated at 291 Individuals In 1998, the North Atlantic right whale Is considered to

be one of the most critically endangered populations of large whales In the world (NMFS 2002).

This population ranges from wintering and calving grounds In the coastal waters of the

southeastern United States to summer feeding and nursery grounds In New England waters

and Northward (NMFS 2002). In 1994. the NMFS designated three critical habitats for the North

Atlantic right whale: Cape Cod BaylMassachusetts Bay. Great South Channel, and the

Southeastern USA. At the present time, Injuries and mortality caused by ship strikes are the

primary source of human impacts to right whales, with some additional impacts from fishery

entanglements. Right whales have been sighted near Long Island Sound (NMFS 2004ay, but

are not known to move Into the shallow waters Immediately offshore of the Millstone site

(Dominion 2004b).

On the basis of this Information, and that previously provided for the aquatic resources In the

vicinity of the plant, the staff has determined that continued operation of Millstone over the

20-year renewal period will have no effect on the Tight whale.

Flnback Whale (Balaenoptera physalus)

The finback (fin) wthale Is Federally listed as endangered throughout its range (FWS 2004b).

The current minimum population estimate from a 1999 survey for the western North Atatic fin

whale was 2382 (NMFS 2002). Fin whales are found principally In waters from North Carolina

north to Nova Scotia. New England waters provide an Important feeding ground for this

spedes. There are no critical habitats designated for the fin whale, although a recovery plan

has been drafted. At the present time, Injuries and mortality caused by ship strikes are the

primary source of human Impacts to fin whales. It Is possible that fin whales could enter Long

Island Sound, but they are not known to move Into the shallow waters Immediately offshore of

the Millstone site (Dominion 2004b).

On the basis of this information, and that previously provided for the aquatic resources In the

vicinity of the plant, the staff has determined that continued operation of Millstone over the

20-year renewal period will have no effect on the fin whale.

Humpback Whale (Megaptera novaengllae)

The humpback whale Is Federally Usted as endangered throughout Its range (FWS 2004b).

The overall abundance for the North Atlantic humpback whale population was estimated in

199211993 at 11,570 Individuals (NMFS 2002). North Atlantic humpback whales are found

during the spring, summer, and fall over a range covering the eastern coast of the United

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NUREG-1 437, Supplement 22 E-58 July 2005

I
Appendix E

States. New England waters are an Important feeding ground for this species. A recovery plan. for humpback whales has been developed and Implemented.' Injuries and mortality from fishery entanglements and ship strikes are the primary human Impacts on humpback whales.

Disturbance from whale watching traffic Is also of concern, particularly In coastal New England waters. It Is possible that humpback whales could enter Long Island Sound, but they are not

known to move Into the shallow waters Immediately offshore of the Millstone site (Dominion

2004b).

On the basis of this Information, and that previously provided for the aquatic resources In the

vicinity of the plant, the staff has determined that continued operation of Millstone over the 20-

year renewal period will have no effect on the humpback whale. ,

4.2 TerrestrIal Species -

A total of five Federally fisted and one potential candidate terrestrial species was Identified

(FWS 2004a) as having the potential to occur In New London county or counties traversed by transmission line ROWs (Middlesex, Hartford, Tolland. and the northeast corner of New Haven):

(Table 4).

Table 4. -. Terrestrial Endangered and Threatened Species: -; - i

Scientific Name Common Name Federal Status"

INSECTS

ClcIndela purftana Puritan Uger beetle -- -- e Threatened

BIRDS

Charaddus nelodus piping plover Threatened

Hafiaeets JeucocephaA's bald eagle ; Endangered

Sterna dougaIN doug& roseate tern Endangered

MAMMALS1

S/megus transitknvls New England cottontail Proposed for Candidacy

* - PWL S .

isobra mnedelokas small whorled pogonla* - Threatened

(a) FWS 2004a, 2004b. - . .-. ---- . . -- .

Puritan Tiger Beetle (Cicindela purltana)

The Puritan tiger beetle Is Federally listed as threatened. This species Is krnown from two

disjunct populations, one along Chesapeake Bay In Maryland and one along the Connecticut

River, In northern Connecticut (CTDEP 2004). Although this species Is reported to occur In'-

Middlesex County (FWS 2004b), CTDEP distribution maps clearly show the Connecticut

population to be centered primarily along the Connecticut River In Hartford County (CTDEP 2004). tThe Millstone ROW for the Manchester transmission line does not cross the

Connecticut River In Hartford County. The Puritan tiger beetle is restricted to sandy habitats

typically found along river banks. Habitat has been depleted through riverbank stabilization and

-17-

July 2005 E-59r NUREG-1437, Supplement 22
Appendix E

flood control practices. There is no known habitat for this species near the Millstone site or

within associated transmission line ROWs.

The staff has determined that continued operation of Millstone over the 20-year license renewal

term will have no effect on the Puritan tiger beetle.

Piping Plover (Charadrifus melodus)

The piping plover Is Federally listed as threatened. This species Is a shorebird that Is found

nesting in sandy beach habitats along seacoasts (CTDEP 2004). Piping plovers nest from

North Carolina north to Nova Scotia. Nesting generally occurs from March through July.

Historically, these birds were killed for consumption and the feathers used for adomment.

Current threats Include development and beach stabilization.

CTDEP range maps (CTDEP 2004) show piping plover habitat extending no further east than

the east side of the mouth of the Connecticut River. There have been no reported sitings of

piping plovers at the site. It is not likely that the necessary beach habitat for nesting Is present

In the vicinity of the site.

For these reasons. the staff has determined that continued operation of Millstone over the

20-year license renewal term will have no effect on the piping plover.

Bald Eagle (Hallaeetus leucocephalus)

The bald eagle Is Federally listed as threatened. This species Is a large raptor that is found

along the coastline and around lakes and rivers. Eagles generally nest In tall trees or on cliff

faces near water and away from human disturbance. Eagle populations have declined In the

Connecticut due to loss of habitat. human disturbance, and pesticide contamination. There are

reported to be up to 100 eagles wintering along major rivers and reservoirs In Connecticut

(CTDEP 2004). There are no known nesting pairs near the Mi~lstone site or along transmission

corridors. However, indviduals have been seen foraging In the area.

Although no bald eagles are known to nest at the Millstone site, Dominion does maintain a

raptor reporting program and will follow CTDEP recommendations should bald eagles nest on

the Millstone site. For these reasons, the staff has determined that continued operation of

Millstone over the 20-year license renewal term may affect, but Is not likely to adversely affect,

the bald eagle.

Roseate Tern (Sterna dougatill dougallll)

The roseate tern Is Federally listed as endangered. This species Is a seabird that Is found

almost exclusively on saltwater coastlines. Roseate terns nest In colonies on coastal beaches

and offshore Islands. Historically, tern populations in Connecticut have been Impacted by

unrestricted market hunting and more recently by the expansion of predatory great blackbacked and herring gull populations throughout their range In the state (CTDEP 2004).

-18-

NUREG-1437, Supplement 22 E-60 July 2005
Appendix E

Fox Island (Figure 2) Is a small promontory extending off the Millstone site and Into Long Island

Sound. This site Is used by multiple'species of seabirds and It Is known to be used by roseate

tems during the fall migration period. Roseate tems are not known to nest In the vicinity of the

Millstone site (Dominion 2004a). Fox Island Is managed as a tern sanctuary In the fall and

access is strictly controlled. For these reasons, the staff has determined that continued

operation of Millstone over the 20-year license renewal term may affect, but Is not likely to

adversely affect the roseate tern.

New England Cottontail Rabbit (Sylvilagus translitonalis)

The FWS Is In the process of determining It the New England cottontail rabbit will be proposed

for listing as a candidate species. Populations In Connecticut were considered abundant

through the mid 1 930s, but competition from Introduced Eastern cottontails (SyMlagus

t7ofidanus) and loss of agriculture-related habitat has led to a decline Is numbers

(CTDEP 2004). This species Is found In brushy habitats associated wIth fencelines and edges

of fields and forests. Transmission line corridors are not considered high quality habitat due to

the abundance of perching raptors and other predators that use the corridors. However, the ' species may use corridors for dispersal from one site to another. Surveys of eastern and New

England cottontail rabbits have found New England cottontail rabbits near the Millstone site and ' In areas crossed by transmission lines (Goodie et al. 2004). Considering the population trends

of this species It Is likely to be listed before or during the period of license renewal.

Vegetation management techniques used on the Millstone site and associated transmission line

corridors maintain the early successional habitat types that the New England cottontail requires.

The CTDEP reviews aN ROW management plans to assure protection of threatened and

endangered species. CL&P personnel work closely with maintenance crews to ensure that

treatments are Implemented properly. The staff has determined that with Implementatlon of

current management procedures and safeguards, continued operation of Millstone over the

20-year license renewal term may affect, but Is not likely to adversely affect, the New England

cottontaiLSmall Whorled Pogonla (Isoida medeololdes) -

The small whorled pogonla Is Federafly listed as threatened. This species occurs In Isolated

populations throughout the eastern United States. In Connecticut t is reported to occur in New

London, Middlesex. Tolland, Hartford, and New Haven counties. New England populations of

this orchid are found almost exclusively on acidic, well drained, fragipan (a subsurface

Impermiable layer) soils (NatureServe 2004). Common plant associates Include red maple,

eastern hemlock (Tsuga canadensis), paper birch (Betula papyritera). northern red oak

(Quercus rubra), eastern white pine (Pinus strobus), and American beech (Fagus grandifolia).

Isotria populations are found In second growth and mature forests. The major threats to this

species are habitat destruction through development and forestry. ' -- ''

Habitat for the small whorled pogonia may exist at the Millstone site or along associaled

transmission line ROWs. The Millstone she is covered by glacial soils (Dominion 2004a) which '

can have subsurface fragipan layers. Some of the common plant associates'are found on the

site (red maple. American beech). This plant has been recorded In the towns of Lyme and -

July 2005 EE-61 -- NUREG-1437, Supplement 22
Appendix E

Glastonbury, Connecticut but Is not known to currently occur at these sites (NRC 1984). ROW

maintenance activities should not greatly impact the small whorled pogonia as long as soil

disturbance is minimized. Mowing of some portions of the transmission line ROWs Is only

conducted between the months of November and April to minimize Impacts to wet soils

(NU 2004).

The CTDEP reviews all ROW management plans to assure protection of threatened and

endangered species. CL&P personnel work closely with maintenance crews to ensure that

treatments are implemented properly. The staff has determined that with Implementation of

current management procedures and safeguards, continued operation of Millstone over the

20-year license renewal term may affect, but is not likely to adversely affect, the small whorled

pogonia.

5.0 Conclusions

The staff Identified six terrestrial and eight aquatic species listed as threatened, endangered, or

proposed for candidate under the Endangered Species Act that have a reasonable potential to

occur In the vicinity of Millstone, along associated transmission line ROWs, or In adjacent areas

of Long Island Sound. The Millstone site and the transmission line ROWs may cross or contain

suitable habitat for some of these species. Glven this possibility. Northeast Utilities has

designed and Implemented maintenance procedures for Its transmission line rIghts-of-way that

protect listed species and their habitats.

The staff has determined that license renewal for Millstone would have no effect on the Puritan

tiger beetle, shortness sturgeon, loggerhead, green turtle, leatherback turtle. Kemp's ridley,

piping plover, right whale, finbackc whale, and the humpback whale. Lcense renewal may

affect, but is not likely to adversely affect, the bald eagle, the roseate tem, the New England

cottontail, and the small whorled pogonia.

6.0 References

Atomic Energy Act of 1954, 42 United States Code (USC) 2011, et seq.

Battelle Duxbury Operations (Battelle). 1999. Draft Final Data Report for Thames River

Vibratoly Core Samplfg at Uncesviyle, CT. Duxbury. Maryland.

Connecticut Department of Environimental Protection (CTDEP). 2002. Letter from

Water Management Bureau, Robert L Smith, Chief, to Scott Mb Cullen, STAR Foundation.

Connecticut Department of Environmental Protection (CTDEP). 2004. Whilff In Connecticut

Endangered and Threatened Species Sedes. Accessed at

httplJIdep.state.ct.us/bumatrhAvikidfe/factshts on April 27 through Sept 21, 2004.

Dominion Nudear Connecticut (Dominion). 2004a. Applicants Environmental ReportOperating Ucense Renewal Stage, Millstone Power Station Units 2 and 3, Dominion Nuclear.

Connecticut. Docket No. 50.338, License No. DPR-65; Docket No. 50-423, License No.

NPF-49. January 2004.

-20-

NUREG-1437, Supplement 22 E-62 July 2005
Appendix E

Dominion Nudear Connectcut (Dominion). 2004b. Annual Report 2003. Monitoring the

Marine Environment of Long Island Sound at Millstone Power Station, Waterford, Connecticut.

Millstone Environmental Laboratory, Dominion Nudear Connecticut April 2004.

Goodie. TJ.. MA Gregonis. and H.J. Kllpatrick. 2004. Preliminary assessnnent of New

England cottontail (Sytvilagus fransltlonalis) and eastern cotiontail (Sytlvtagus floddanus) distribution In Connecticut, October 2000-March 2004. Connecticut Department of

Environmental Protection. '

Keser. M., J.T. Svwenaarton. J.M. Vozarik ,and J.F. Foertch. 2003. 'Decline In eelgrass (Zostera marina L) In Long Island Sound near Millstone Point, Connecticut (USA) unrelated to thremal

Input. Journal of Sea Research 49, 11-26. - . -. -

Long, E.R.. L.S. Field. D.P. MacDonald. 1998. Predicting toxrdy In marine sediments w1th

numerical sediment quality guidelines. Environmental Toxicology and.

Chemistry 17(4):714-727.

Mecray, E.L., M.R. Buchholtz ten Brink, and S. Shah. 2004. Metal Distributions In the surface

sediments of Long Island Sound. U.S. Geological Survey (USGS), USGS OFR 00-304:

Chapler 6. http 1/pubs.usgs.govlof/ofo30034/htmldocs/chap06/indexbhrnNRESULTS

National Marine Fisheries Service (NMFS). 2002. U.S. Atlantic and Gulf of Mexico Marine

Mammal Stock Assessments - 2002. Accessed ate . -

http:/lwww.nmfs.noaa.gov/proLres/PR2/StockAssessmentProgramrisars.html#Overvlew. on

June 24,2004.-.

National Marine Fisheries Service (NMFS). 2004a. Letter from National Marine Fisheries

Service, providing a response to the March 17,2004 NRC staff letter requesUing Inforrnation

regarding threatened and endangered species In the vicnity of the MPS. UnIts 2 and 3.

(Accession No. ML042810294)

National Marine Fisheries Service (NMFS). 2004b. Loggerhead Sea Turtles (Caretta caretta). Accessed at: httplAvw.nrnfs.noaa.gov/protreslspeleslturtleslloggerhead.html on June 24,

2004.

National Marine Fisheries Service (NMFS). 2004c. Green Sea Turtle (Chelonia mydas) Accessed at; http:/lwww.nrrifsnoaa gov/proLres/specles/lurtres/green.htrnl. on June 24. 2004.

National Marine Fisheries Service (NMFS). 2004d. Hawksbtll Sea Turtle (Eretmochelys Imbricasta). Accessed at http:/lw'w.rirfs.noaa.gov/prot res/specdesturtles/hawksbil.htmL. on

June 24. 2004. - - ;, -

National Marine Fisheries Service (NMFS). 2004e. Kemp's Ridlay Turtle (Lepidochelys kempl) Accessed at: http:/iww.nrnfs.noaa.gov/Lprotes/specleslturtiesikenps.htmnl. on June 24,

2004.

-21-

July 2005 E-63 NUREG-1437, Supplement 22
Appendix E

NatureServe 2004. NatureServe Explorer an Online Encyclopedia of Life. Version 3.1.

NatureServe, Arlington. Virginia. Accessed at http twww.natureserve.org. on September 17-

21,2004

Northeast Utilities (NU). 2004. Section 111, Technical Requirements. Specificatlon forRights-ofWay Vegetation Management

U.S. Environmental Protection Agency (EPA). 2004a. Ecoregiens of Massachusetts,

Connecticut, and Rhode Island. Accessed at

http:/jvww.epagovtwedlpageslecoreglonslrnactrLeco.htm on September 21. 2004.

U.S. Environmental Protection Agency (EPA). 2004b. Long island Sounrd An Estuary of

Natonal Significance. U.S. Environmental Protection Agency, Region 1: New England

Access at: httpwiwww.epa.govkregionOl/econlslccrnp.intro.html. on June 24. 2004.

U.S. Fish and Wildlife Service (FWS). 1999. Title 50- Wildlife and Fisheries, Part 17-

Endangered and Threatened Wildlife and Plants, Subpart i3- Lists. U.S. Fish and Wildlife

Service, December 21. 1999.

U.S. Fish and Wildlife Service (FWS). 2001. Fish Facts - Shorinose Sturgeon. Connecticut

River Coordinator's Office website. Accessed at httpJiwvw.fws.govrScTtishIzf acbr.htrmL

on June 24, 2004.

U.S. Fish and Wildlife Service (FWS). 2004a. Letter from U.S. Fish and Wildlife Service.

providing a response to the March 1 8, 2004 NRC staff letter requesting information regarding

threatened and endangered species In the vicinity of the MPS. Units 2 and 3. (Accession No.

ML0411190230)

U.S. Fish and Wildlife Service (FWS). 2004b. Species Information, Threatened and

EndangeredAnimals and Plnts website. Accessed at httpl/endangered.iws.govlwildflfe.html.

Accessed August 2. 2004 through September 23, 2004.

U.S. Nuclear Regulatory Commission (NRC). 1984. Final Environmental Statement related to

operation of Millstone NuclearPower Station. Unit No. 3. Docket No. 50-423. NUREG.1064.

Washington, D.C.

U.S. Nuclear Regulalory Commission (NRC). 2004a. NRC staff letter to Ms. Patricia A. Kurkul.

Regional Administrator, National Marine Fisheries Service (NOAA Fisheries). Request for Ust

of Protected Species Within the Area Under Evaluation for the MPS. Units 2 and 3, Ucense

RenewaL (Accession No. ML040780653)

U.S. Nuclear Regulatory Commission (NRC). 2004b. NRC staff letter to Mr. Marvin Moriarty,

Regional Administrator. National Marine Fisheries Service (NOAA Fisheries). Request for List

of Protected Species Within the Area Under Evaluation for the MPS, Units 2 and 3, Ucense

Renewal. (Accession No. ML040770760)

-22-

NUREG-1 437, Supplement 22 E-64 July 2005

I
Appendix E

Millstone Power Station, Units 2 and 3

cc:

Lillian M. Cuoco, Esquire -

Senior Counsel

Dominion Resources Services. Inc.

Rope Ferry Road

Waterford, CT 06385

Edward L Wilds, Jr., Ph.D...

Director, Division of Radiation

Department of Environmental Protection

79 Elm Street

Hartford. CT 061 6-5127

Regional Administrator, Region I

U.S. Nuclear Regulatory Commission

475 Allendale Road

King of Prussia. PA 19406

Paul Eccard -

First Selectman

Town of Waterford

15 Rope Ferry Road

Waterford, CT 06385-2886

Mr. P. J. Parulls

Manager - Nuclear Oversight

Dorrinion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford. CT 06385

Mr. W. R. Matthews - Senior Vice President - Nuclear Operation

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road -- *Waterford,-CT 06385

Mr. John Markowicz

Co-Chair

Nuclear Energy Advisory Council

9 Susan Terrace

Waterford, CT 06385

Mr. Evan W. Woollacott

Co-Chair

Nuclear Energy Advisory Council

128 Terrys Plain Road

Slmsbury, CT 06070

Senior Resident Inspector

Millstone Power Station

clo U.S. Nuclear Regulatory Commission

P. 0. Box 513

Niantic, CT 06357

Mr. G. D. Hicks

Director - Nuclear Station Safety

and Licensing

Dominion Nuclear Connecticut. Inc.

Rope Ferry Road

Waterford, CT 06385

Ms. Nancy Burton

147 Cross Highway.-

Redding Ridge, CT 00870

Mr. William D. Meinert

Nuclear Engineer

Massachusetts Municlial Wholesale

Electric Company

Moody Street

P.O. Box 426

Ludlow, MA 01056

Mr. J. Alan Price a,

Site Vice President

Dominion Nuclear Connecticut, Inc.

Rope FerryRoad -Waterford, CT 06385 s

Mr. Chris L. Funderburk

Director. Nuclear Licensing and

Operations Support Dominion Resources Services. Inc.

Innsbrook Technical Center

'5000 Dominion Boulevard

Glen Agen. VA 23060-6711

Mr. David W. Dodson

Licensing Supervisor, Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

July 2005E E-65 NUREG-11437. Supplement 22 -
Appendix E

Millstone Power Station, Units 2 and 3

Mr. S. E. Scace

Assistant to the Site Vice President

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

Mr. M. J. Wilson

Manager - Nudear Training

DominIon Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

Mr. A. J. Jordan, Jr.

Director - Nuclear Engineering Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

Mr. S. P. Saiver

Director - Nuclear Station Operations

and Maintenance

Dominion Nuclear Connecticut, Inc.

Rope Ferry Road

Waterford, CT 06385

Mr. Charles Brinkman. Director

Washington Operations Nuclear Services

Westinghouse Electric Company

12300 TwInbrook Pkwy. Suite 330

Rockville, MD 20852

Mr. David A. Christian

Sr. Vice President and Chief Nuclear Officer

Dominion Nuclear Connecticut, Inc.

Innsbrook Technical Center

5000 Dorninlon Boulevard

Glen Allen. VA 23080-B711

Mr. Fred Emerson

Nuclear Energy Institute

1776 1 Street, NW, Suite 400

Washington, DC 20008-3708

NUREG-1437, Supplement 22

Ms. Roslyn Rubenstein, Director

Waterford Public Library

49 Rope Ferry Road

Waterford, CT 06385-2899

Mildred Hodge, Director

Three Rivers Community College

Thames River Campus Ubrary

574 New London Turnpike

Norwich, CT 06360

Ralph Bunge NRC Proceedings Representative

for Waterford, CT

510 Carr Ave

Rockville, MD 20850-

Thomas V. Wagner, AICP

Planning Director

Town of Waterford

15 Rope Ferry Road

Waterford, CT 06385

David R. Lewis

Shaw Pittman, LLC

2300 N Street. NW

Washington. DC 20037

Mr. William D. Corbin

Director - Nuclear Projects Department

Innsbrook Technical Center

5000 Dominion Boulevard

Glen Allen, VA 23060-6711

Mr. William R. Watson. Jr.

Supervisor - Ucense Renewal Project

Building 47515

Millstone Power Station

Rope Ferry Road

Waterford, CT 06385

E-66 July 2005

I
Appendix E

Millstone Power Station. Units 2 and 3

cc:

Robert A. Avena

Town Attorney for Waterford. CT

Kepple. Morgan & Avena, P.C.

Box 3A Anguilla Park

20 South Anguilla Road

Pawcatuck, CT 06379

Michael J. Amaral

U.S. Fish and Wildlife Service

New England Field Office

70 Commercial Street. Suite 300

Concord, NH 03301-5087

I . . . .

* * - s---

July 2005. E-67 - NUREG-1 437, Supplement 22
Appendix E

United States Department of the Interior

FISH AND WILDLI SERVICE

New Enland Field Olfioe

70 Commercial Stt, Sufte 300

Concord. New Hampshins 03301-5087

Januay 5. 2005

Pbo-Tsan Kuo

Office of Nuclar Reaco Reuastion

U.S. Nudear Regulosy Comnniizon

Wasnton, D.C 205SS-0001

Der Mr. Kuo.

We are in rectipt of your biological assessment and requlst ror conacrrence for the proposed

re iwal of the is61hne Power Stao, Urds 2 and 3. Waterford. Connecticu. The following

comments are provided in acrdance with Section 7 of the Etdingered Spcies Act (ESA) of

1973. as amended (Q6 U.S.C I 531-1543).

Based on inbnnation currently mailable to us, and the hfonmation contained widin the biological

assessmesm, the U.S. Fish and Wildirei Service coats that the proposed acoc wil hav no e~va

on threae pi tigertbeesad i plove. We also ncur thathe prposed icense

is not likely to advasey er the bald asle, roseate ten and smal w red pogoa.

Further constation with us under Section 7 oftbe Endangered Species Act is not required. Ths

owArOes our review of Usted species and critical habitat in the project location and aevirons

referenced above. No fRther E idangered Species Act ecordiraion ofrhis type is necesy fora

period ofone year from the dae of h leter, unes ao tional information on liaed or proposed

species becomes awvfaible

Thank you for your coordlstion Please contact us at 60-223-2541 if we can be of & aher

tn fhe tutnre, h erder Is expedite your re*, please direct any Inqures of this

nature to this eflice at the above addres.

Sincereyyours,

Michad J. Amand

Endangered Species Specialist

New Englad Field Office

NUREG-1437, Supplement 22 E-68 July 2005
Appendix E

I

UNITED STATES DEPARTMENT OF COMMERCE

JAN 12 200

PnoTsln Kuo

Prorm Director

License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs:

Office of Nuclear Reactor Regulation

US NuclearRegulatory ComZiission -'

MST1ll P1

Washington, DC 20555

Re: Millstone Power Station Units 2 and 3 license renewal

.DenrMr.K 3 o, -

Thisiss in rsponse to your lette daed November 9. 2004 regaing the pposed

r iewal ofthe opeting licenses for Units 2 and 3 of theMillstonePower Station for

a period of 20 years. Mhr Millstone Power Station is located on tbe wrth shore of

Loninsld Sond In the twa of Waterford, Cl. Included with your letter was a

Biological Assessment (BA) which evluates whedther the propoied license renewal of

the Millstonc Power Station would have an adverse affect on listed species in Long

Island Sound. The US. Nuclear Regulatory Conmission (NRC) has made a

preliminarydetemnination that the prposed action wiU have no efoct on llsted

species under the jurisdico r te National Mine Fisheries Service (NOAA ;

FiShed:es.

In akttcr datd September21.2004.NOAAFisheries provlded te NRC with a list

of federally thratened and endangered species that ase known tobe seasonally

present in th watersa of Long Island Sound. Four species of federally threatened or

endangerod sea turtles may be found seasonaly In the witers of Long Islad Sound.'

Sea turtles are expected to be In the vicinity of the project Wra In vrnner months.

typically fron May ! to November 15. The sea turtles in Long land waters are

typically small juveniles with the most abundant being the fedally threatened

loggerhead (Carefa coarei) followed by the federally endazrierd Kemp's sidley

(Lrpldcedks AepO. The waters of Long lIsland Sound have also heen founed to be :

warm enough to support federlly endanged i sa cn turts(Cheonla mda)

from June through October. The three species of chelonid turtles found In thc

Northeast remain very briefly in open ocean waters, spending most of their tI]e

during the summer months in hanbors and estuarine wateri, such as those found in .0

July 2005 E-69 NUREG-1437, Supplement 22
Appendix E

Long Island Sound. Federally endangered kathebaock sea twtles (Dennochalys

coriacca) mny be found in the waters of Long Island Sound during die wanmer months as well.

Ibree species of federally endangered whales, North Atlantic right whales

(EubaalagalacaWLs). humpback whales (Bfcgaptera noawt8gliac). and fin whales

(Bdaenopterrphysalhts). may also be found seasonally in Northeast waterS, although

it rarn that these species will travel Into Long Island Sound. Pederally endangered shortnose sturgeon (Acnsr brevirstrum) ae bnow to occur in the Connecticut

River which flows Into Long Island Sound approximately 10 miles cast of the

Millstone site; however. shortnose sturgeon are not known to parti;ipzte in coastal

migratIons and no shonaose sturgeon arm likely to occur near the project ste.

The entrainment and impingement of sen turtles has been documented at several

nuclear power plants on the East Coast The Milstone system withdraws water freom

Long Island Sound through intakes. Wer withdrawn from Lag Istand Sound is

filtered through trash and debris screens at a rate of 0.2 mWs. The debris screens ame an effectiv mechanism to reduce the likelihood that aquatic orpnism;, including

turtles, win be Impinged or entrained on the intakes. The MilstoW e operalors hve

been monitoring the intakes for over 20 years and no sea turtles have been

documented to be impinged or entrained during that time. Based on the size of the screens. the rawe of intake and the lack of sea turtle Impingements or entrainments in

the past, it is unikelythat sea trties will be affected by th inakes through the term

otthe new licenseWater taken into the plant Is pumped thmough a turbinc condensercooling system which causes the water temperature to Increase The heated wotw then surfacec

discharges through a former granite qumny and flows out two cuts excavated form the

bedrock into Long Island Sound. At full discharg flow the wwer temperature will

have Increased 9 to 140C from Its intake tempenkc. The National Pollutant

Discharge Ellminktion System (NPDES) permit for the Millstone PowerStation

limits the discharge temperature to 40C and limits the maxinum increase in water

temperature from intakl to discharge to 18°'C. Based an the volumna of waler in the

discharp area. Lhe ability for sea turtles to avoid the ara of healed water. and the

known tolerance of sa tuntes to tropical water tmperstures, It is unlikely that sea * turtles -ill be affected by the discharge of hcated water into Long Island SoundL'

Based on the analysis abov4 NOAA Fisherfes is able to concur with the NRC's

determination dint this prject will have no effect on shortnose sturgeon, fin whales,

humpback whales. or right Odties. NOMA Fisheries Is not able to concur with a no effect determination for the fourspecies of sea tutles; how1va based on the . * asscssment above, it has been determined that the proposed action Is not likely to

ndversely alfect sea turtles. Therefore, no fixther consultation pursuant to section 7

of the ESA is required. Should pmject plans change or new laformatdon become

NUREG-1437, Supplement 22 E-70 July 2005
Appendix E

I

availabl tha changes the basis for this determination, consultation should be

reinitiated. Should you have any questions about these comments, please contact

Sara McNulty st.(978) 281-9328 CXL 6520.

sicaccely.

ti* ionPatrici Adiiirlo

KRegionul Adminisuvaor

Cr:Sdd2.FftNER3

wVilliaMs, OWNE

Rusnowvsky, F7NER4

July 2005 E-71 NUREG-1437, Supplement 22
Appendix F

GEIS Environmental Issues Not Applicable

to Millstone Power Station, Units 2 and 3
Appendix F

GEIS Environmental Issues Not Applicable

to Millstone Power Station, Units 2 and 3

Table F-1 lists those environmental issues listed in the Generic Environmental Impact

Statemient for License Renewal of Nuclear Plants (GEIS) (NRC 1996; 1 999)(a) and 10 Code of

Federal Regulations (CFR) Part 51, Subpart A; Appendix B, Table B-i, that are not applicable--

to Millstone Power Station,' Units 2 and 3, because of plant or site characteristics.

-Table F-1k -- GEIS Environmental Issues Not Applicable to Millstone Power Station,

- Units 2 and3 3

ISSUE-10 CFR Part 51, Subpart A, GEIS

Appendix B, Table B-1 Category Sections Comment

-SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered thermal stratification of lakes 1 4.2.1.2.3 Millstone does not discharge

4.4.2.2 into a lake.

Temperature effects on sediment 1 4.2.1.2.3 Millstone does not discharge

transport capacity ' : 4.4.2.2 into a small river.

Eutrophication 1 4.2.1.2.3 Millstone does not discharge

4.4.2.2 into a lake.,

Water-use conflicts (plants with cooling 2 4.3.2.1 The Millstone cooling' system -

ponds or cooling towers using makeup 4.4.2.1 does not use make-up' water' -

water from a small river with low flow) from a small river with low flow.

AQUATIC ECOLOGY (FOR ALL PLANTS)

Premature emergence of aquatic insects 1 4.2.2.1.7 'Aquatic insects are only present

*- - .4.4.3 in freshwater environments.

AoUATIC ECOLOGY (FOR PLANTS WITH COOLING TOWER BASED HEAT DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early 1 4.3.3 This issue is related to

life stages' . heat-dissipation systems that

are not installed at Millstone.

Impingement of fish and shellfish 1 4.3.3 This issue is related to

heat-dissipation systems that

are not installed at Millstone.

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the "GEIS" include the GEIS and its Addendum 1.

I

July 2005, F-1 NUREG-1 437, Supplement 22
Appendix F

Table F-1. (contd)

ISSUE-10 CFR Part 51, Subpart A, GEIS

Appendix B, Table B-1 Category Sections Comment

AoUATc ECOLOGY (FOR PLANTS WITH COOLING TOWER BASED HEAT DISSIPATION SYSTEMS)

Heat shock 1 4.3.3 This issue is related to

heat-dissipation systems that

are not installed at Millstone.

GROUND-WATER USE AND QUALITY

Ground-water use conflicts (potable and 2 4.8.1.1 Millstone uses <100 gpm of

service water, and dewatering; plants 4.8.2.1 groundwater.

that use >100 gpm)

Ground-water use conflicts (plants using 2 4.8.1.3 This issue is related to

cooling towers withdrawing makeup 4.4.2.1 heat-dissipation systems that

water from a small river) are not installed at Millstone.

Ground-water use conflicts (Ranney 2 4.8.1.4 Millstone does not have or use

wells) Ranney wells.

Ground-water quality degradation 1 4.8.2.2 Millstone does not have or use

(Ranney wells) Ranney wells.

Ground-water quality degradation 1 4.8.3 Millstone does not use cooling

(cooling ponds in salt marshes) ponds.

Ground-water quality degradation 2 4.8.3 Millstone is not located at an

(cooling ponds at inland sites) inland site.

TERRESTRIAL RESOURCES

Cooling tower impacts on crops and

ornamental vegetation

1 4.3.4

Cooling tower impacts on native plants

Bird collisions with cooling towers

Cooling pond impacts on terrestrial

resources

1 4.3.5.1

1 4.3.5.2

1 4.4.4

This issue is related to a

heat-dissipation system that is

not installed at Millstone.

This issue is related to a

heat-dissipation system that is

not installed at Millstone.

This issue is related to a

heat-dissipation system that is

not installed at Millstone.

This issue is related to a

heat-dissipation system that is

not installed at Millstone.

NUREG-1437, Supplement 22 F-2 July 2005
Appendix F

Table F-1. (contd)

ISSUE-10 CFR Part 51, Subpart A, GEIS

Appendix B, Table B-1 Category Sections Comment

HUMAN HEALTH

Microbial organisms (occupational 1 4.3.6 This issue is related to a

health)(plants with cooling towers) heat-dissipation system that is

not installed at Millstone.

Microbial organisms (public health) 2 4.3.6 This issue is related to a

(plants using lakes or canals, or cooling heat-dissipation system that is

towers or cooling ponds that discharge to not installed at Millstone.

a small river).

F.1 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants: Main Report, Section 6.3, Transportation, Table 9.1,

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

July 2005 G-3 NUREG-1437, Supplement 22
Appendix G

Connecticut State-Listed Terrestrial Species for Hartford,

Middlesex, New London, and Tolland Counties with the

Potential to Occur at the Millstone Site or Along Associated

Transmission Line Rights-of-Way
Appendix G

--Connecticut State-Listed Terrestrial Species for-Hartford,

Middlesex, New London, and Tolland Counties with the

-------Potential to Occur at the Millstone Site or Along Associated---

-Transmission Line Rights-of-Way -

Table G-1. Connecticut State-Listed Terrestrial Species for Hartford, Middlesex, New

London, and Tolland Counties with the Potential to Occur at the Millstone

Site or Along Associated Transmission Line Rights-of-Way

- -State

Scientific Name - Common Name Status(a)

-:AMPHIBIANS

Ambystoma jeffersonianum -Jefferson salamander SC

Ambystoma laterale - blue-spotted salamander -- TGyrinophilus porphyriticus northern spring salamander T

Rana pipiens northern leopard frog SC

Scaphiopus holbrookii <- . eastern spadefoot -E

I

Aegolius acadius

Ammodramus caudacutu

Ammodramus henslowii

Ammodramus maritimus

Ammodramus savannaru

Anas discors

Asio flammeus

Asio otus

Bartramia longicauda

Botaurus lentiginosus

Caprimulgus vociferus

Cistothorus platensis

Corvus corax

.-BIRDS ----

northern saw-whet owl SC

s ---saltmarsh sharp-tailed sparrow SC

Henslow's sparrow - SC

seaside sparrow SC

m grasshopper sparrow E

* blue-winged teal T

short-eared owl T

long-eared owl E

upland sandpiper E

- American bittern E

whip-poor-will -SC

sedge wren -E

-common raven SC

I- I

I

I .

II

July 2005;- G-1 NUREG-1 437, Supplement 22
Appendix G

Table G-1. (contd)

State

Scientific Name Common Name Status(a)

BIRDS

Egretta caerulea little blue heron SC

Empidonax alnorum alder flycatcher SC

Eremophila alpestris horned lark E

Falco peregrinus peregrine falcon E

Falco sparverius American kestrel T

Galinula chloropus common moorhen E

Gavia immer common loon SC

Haematopus palliatus American oystercatcher SC

Ixobrychus exilis least bittern T

Laterallus jamaicensis black rail E

Melanerpes erythrocephalus red-headed woodpecker E

Parula americana northern parula SC

Passerculus sandwichensis savannah sparrow SC

Passerculus sandwichensis ssp. princeps Ipswich sparrow SC

Plegadis falcinellus glossy ibis SC

Pooecetes gramineus vesper sparrow E

Progne subis purple martin T

Rallus elegans king rail E

Sterna hirundo common tem SC

Stumella magna eastern meadowlark SC

Toxostoma nufum brown thrasher SC

Tyto alba barn owl E

Vermivora chrysoptera golden-winged warbler E

INVERTEBRATES

Acronicta lanceolaria a noctuid moth SC*

Apamea burgessi a noctuid moth SC

Apodrepanulatrix liberiaria New Jersey tea inchworm SC

NUREG-1 437, Supplement 22 G-2 July 2005

I
Appendix G

Table G-1. (contd)

State

-Scientific Name -''- " : Cornirnon 'Name Status(a)

----- .-- - :INVERTEBRATES

Callophrys henrici

Callophrys irus

Calopteryx dimidiata

Catocala pretiosa

Chaetaglaea cerata

Cicindela formosa ssp. generos

Cicindela hirticollis

Cicindela lepida

Cicindela purpurea

Cicindela tranquebarica

Citheronia regalis

Cordulegaster erronea

Cucullia speyeri

Eacles imperialis ssp. imperialis

Enallagma doubidayi

Enallagma minusculum

Enallagma pictum;

Erynnis brizo

Erynnis lucilius

Erynnis martialis

Etynnis persius ssp. persius

Eucoptocnemis fimbriaris

Euphyes bimacula

Exyra rolandiana

Geopinus incrassatus

Gomphus adelphus

Henry's elfin

frosted elfin

sparkling jewelwing

.precious underwing moth

a noctuid moth

wa pine barrens tiger beetle

beach-dune tiger beetle

dune ghost tiger beetle

tiger beetle

dark-bellied tiger beetle

regal moth

tiger spiketail

a noctuid moth

imperial moth

Atlantic bluet

little bluet

scarlet bluet

sleepy duskywing

columbine duskywing

mottled duskywing

persius duskywing

a noctuid moth

two-spotted skipper

pitcher plant moth

a ground beetle

mustached clubtail dragonfly

SC

SC

50*.

Sc SCE

SC*

SC.

SC

E -

SC*

SC

~Sc_

SC

T.

E

,. , ,SC*,

E

, SC

T

SC

SC

.. . T; C .

July 2005. t. G-3 NUREG-1 437, Supplement 22.'
Appendix G

Table G-1. (contd)

State

Scientific Name Common Name Statusca)

Gomphus descriptus

Gomphus fraternus

Gomphus vastus

Gomphus ventricosus

Grammia phyllira

Hetaerina americana

Hemileuca maia maia

Hybomitra frosti

Hybomitra typhus

Ladona deplanata

Lepipolys perscripta

Leptophlebia bradleyi

Leucorrhinia glacialis

Lycaena epixanthe

Lycaena hyllus

Merycomyia whitneyi

Mitoura hesseli

Papaipema duovata

Paraleptophlebia assimilis

Pomatiopsis lapidaria

Psectraglaea camosa

Schinia spinosae

Speyeria idalia

Sphodros niger

Stylurus amnicola

Tabanus fulvicallus

Williamsonia lintneri

INVERTEBRATES

harpoon clubtail dragonfly

midland clubtail dragonfly

cobra clubtail dragonfly

skillet clubtail dragonfly

phyllira tiger moth

American rubyspot

buckmoth

a horse fly

a horse fly

blue corporal dragonfly

scribbled sallow

a mayfly

crimson-winged whiteface dragonfly

bog copper

bronze copper

tabanid fly

Hessel's hairstreak

seaside goldenrod stem borer

a mayfly

slender walker

pink sallow

a noctuid moth

regal fritillary

purse-web spider

riverine clubtail dragonfly

horse fly

banded bog skimmer

T

T

SC

SC

SC*

SC

E

T

SC

SC

SC

SC

T

SC

SC

SC

E

SC

SC

SC

T

SC

SC*

SC

T

SC

E

NUREG-1437, Supplement 22 G-4 July 2005-

I
Appendix G

Table G-1. (contd)

~- - Scientific Name

Zale curema

Zale obliqua

Zale submedia

Cryptotis parva

Lasiurus borealis

Lasiurus cinereus

Puma concolorssp. couguar

Synaptomys cooped

Acalypha virginica

Agalinis acuta

Agastache nepetoides

Agastache scrophularifolia

Alopecurus aequalis

Amelanchier sanguinea

Andromeda glaucophylla

Angelica lucida

Angelica venenosa

Aplectrum hyemale

Arenaria glabra

Arenaria macrophylla

Arethusa bulbosa

Aristida longespica

Aristida purpurascens

Aristolochia serpentaria

i- bommon Name

INVERTEBRATES

a noctuid moth

a noctuid moth

a noctuid moth

MAMMALS

least shrew

eastern red bat

hoary bat

eastern cougar

southern bog lemming

PLANTS

Virginia copperleaf

sandplain gerardia

yellow giant hyssop

purple giant hyssop

orange foxtail

roundleaf shadbush

bog rosemary

sea-coast angelica

.-. .. hairy angelica

, puttyroot

.smooth mountain sandwort

large-leaved sandwort

arethusa

needlegrass

.... arrowfeather

Virginia snakeroot

SC

SC

-SC*

SC.

SC

E

SC*

E

E . -

T - .

E

SC*

T

S*sc

SC.

SC

- : State

Status°

SC

. I . SC -

I . - T ..-

July 2005 G-5 NUREG-1437, Supplement 22
Appendix G

Table G-1. (contd)

State

Scientific Name Common Name Status(3)

Asclepias purpurascens

Asclepias variegata

Asplenium montanum

Asplenium ruta-muraria

Aster nemoralis

Aster prenanthoides

Aster radula

Aster spectabilis

Aster X blakei

Aster X herveyi

Bidens eatonji

Blephilia ciliata

Blephilia hirsuta

Calystegia spithamaea

Cardamine longYi

Carex aestivalis

Carex alata

Carex barrattil

Carex bushii

Carex buxbaumii

Carex collinsti

Carex crawfordii

Carex cumulata

Carex davisdi

Cares exilis

Carex hitchcockiana

Carex limosa

PLANTS

purple milkweed

white milkweed

mountain spleenwort

wallrue spleenwort

bog aster

crooked-stem aster

rough-leaved aster

showy aster

Blake's aster

Hervey's aster

Eaton's beggar-ticks

downy woodmint

hairy woodmint

low bindweed

Long's bitter-cress

summer sedge

broadwing sedge

Barratt's sedge

sedge

brown bog sedge

Coilins' sedge

Crawford sedge

clustered sedge

Davis' sedge

sedge

Hitchcock's sedge

sedge

SC

SC*

T

T

E

SC*

E

T

E

SC

T

SC*

SC*

SC*

SC*

SC

E

E

SC

E

SC*'

SC*

T

E

E

SC

E

NUREG-1437, Supplement 22 G-6 July 2005
Appendix G

Table G-1. (contd)

Scientific N

Carex lupuliformis

Carex nigromarginata

Carex oligocarpa

Carex oligosperma

Carex polymorpha

Carex pseudocyperus

Carex squarrosa

Carex sterilis

Carex tuckermanfi

Carex typhina

Castilleja coccinea

Cercis canadensis

Chamaelirium luteum

Chenopodium rubrum

Chrysopsis falcata

Cirsium horridulum

Coeloglossum viride var.

Corollorhiza trifida

Corydalis flavula

Crassula aquatica

Cuphea viscosissima

Cuscuta coryli

Cypripedium parviflorum

Cypripedium reginae

Deschampsia caespitosa

Desmodium glabellum

a e Comnmon Name

false hop sedge

black-edge sedge

eastern few-fruit sedge

few-seeded sedge

variable sedge

cyperus-like sedge

sedge

dioecious sedge

Tuckerman sedge

sedge

indian paintbrush

eastern redbud

devil's-bit

coast blite

sickle-leaf golden-aster

yellow thistle

virescens, long-bracted green orchid

early coralroot

yellow corydalis

,pygmyweed

blue waxweed

hazel dodder

yellow lady's-slipper

showy lady's slipper

tufted hairygrass

Dillen tick-trefoil

I- -. _ state

Status(s)

. . -.

SC

SC*

-SC

Sc*

E

;E

SC

SC

SC

SC

E

SC*. .-

E

sC*

E

E

SC,

SC

T

E.

-. .SC*.- .

SC*

Sc

ESC

SC

July 2005_ NUREG-1437, Supplement 22
Appendix G

Table G-1. (contd)

State

Scientific Name Common Name Status~a)

Desmodium humifusum

Desmodium sessilifolium

Dicentra canadensis

Diplachne maritima

Diplazium pycnocarpon

Draba reptans

Dryopteris goldiana

Echinodorus tenellus var. parvulus

Eleocharis equisetoides

Eleocharis microcarpa var. filiculmis

Eleocharis quadrangulata var. crassior

Elymus trachycaulus var. subsecundus

Elymus wiegandii

Equisetum palustre

Equisetum pratense

Eriocarpon parken

Eriophorum vaginatum var. spissum

Eupatorium album

Eupatorium aromaticum

Gaultheria hispidula

Gaylussacia dumosa var. bigeloviana

Geranium bicknellfi

Gnaphalium purpureum

Goodyera repens var. ophioides

Helianthemum propinquum

Hemicarpha micrantha

Hottonia inflata

PLANTS

trailing tick-trefoil

sessile-leaf tick-trefoil

squirrel-corn

saltpond grass

narrow-leaved glade fern

whitlow-grass

Goldie's fern

bur-head

horse-tail spikerush

spike-rush

spike-rush

slender wheatgrass

Wiegand's wild rice

marsh horsetail

meadow horsetail

Parker's pipewort

hare's tail

white thoroughwort

small white snakeroot

creeping snowberry

dwarf hucklberry

Bicknell northern crane's-bill

purple cudweed

dwarf rattlesnake plantain

low frostweed

dwarf bulrush

featherfoil

SC

SC*

T

E

E

SC

SC

E

E

SC*

E

SC

SC

SC*

E

E

T

E

E

T

T

SC*

SC*

SC*

T

E

SC

NUREG-1437, Supplement 22 G-8 July 2005
Appendix G

Table G-1. (contd)_

Scientific Name

Houstonia longifolia

Hudsonia ericoides

Hudsonia tomentosa

Hydrastis canadensis

Hydrocotyle umbellata

Hydrocotyle verticillata

Hydrophyllum virginianum

Hypericum adpressum

Hypericum pyramidatum

llex glabra

Isanthus brachiatus

Juncus debilis

Lachnanthes caroliana

Ledum groenlandica

Liatris scariosa var. novae-anglica

Ligusticum scothicum

Lilaeopsis chinensis

Limosella subulata

Linnaea borealis var. americana

Linum intercursum

Linum sulcatum

Liparis liliifolia

Liquidambar styraciflua

Ludwigia polycarpa

Ludwigia sphaerocarpa

Lycopus amplectens

July 2005

-- State

Common Name Statusca)

PLANTS

longleaf bluet E

golden-heather E

false beach-heather SC

golden-seal E

water pennywort -E

whorled pennywort E

Virginia waterleaf SC

creeping St. John's wort - SC*,

great St. John's wort - SC

ink-berry T

false pennyroyal E

weak rush SC*

Carolina redroot E

,Labrador tea -T

blazing star SC

scotch lovage E

lilaeopsis SC

mudwort SC

twinflower E

sandplain flax :SC*

yellow flax -SC

lily-leaved twayblade E

sweet gum - -SC---

many-fruit false-loosestrife -- SC*

globe-fruited false-loosestrife E

clasping-leaved water-horehound - , SC

G-9- NUREG-1437, Supplement 22
Appendix G

Table G-1. (contd)

State

Scientific Name Common Name Status(a)

Lygodium palmatum

Malaxis unifolia

Megalodonta beckii

Milium effusum

Mimulus alatus

Moneses uniflora

Myriophyllum pinnaturn

Nuphar advena

Nuphar microphylla

Nymphaea odorata var. tuberosa

Onosmodium viginianum

Ophioglossum pusillum

Opuntia humifusa

Orontium aquaticum

Oryzopsis pungens

Oxalis violacea

Panax quinquefolius

Panicum amarum

Panicum commonsianum

Panicum rigidulum var. elongatum

Panicum scabriusculum

Panicum xanthophysum

Paronychia fastigiata

Paspalum laeve

Paspalum setaceum var. psammophilum

Pedicularis lanceolata

Phaseolus polystachios var. aquilonius

PLANTS

climbing fern

green adder's-mouth

water-marigold

tall millet-grass

winged monkey-flower

one-flower wintergreen

cutleaf water-milfoil

large yellow pond lily

small yellow pond lily

water lily

gravel-weed

adder's tongue

eastern prickly-pear

golden club

slender mountain-ricegrass

violet wood-sorrel

American ginseng

panic grass

panic grass

tall flat panic grass

panic grass

panic grass

hairy forked chickweed

field paspalum

bead grass

swamp lousewort

wild kidney bean

SC

E

T

SC*

SC

E

E

SC*

SC

SC*

E

T

SCSC

SC

SC

SC

T

SC

SC*

E

SC*

SC*

E

SC*

T

SC*

NUREG-1437, Supplement 22 G-10 July 2005
Appendix G

Table G-1. (contd),,. _ _. _

Scientific Name

Pinus resinosa

Plantago virginica

Platanthera blephariglottis

Platanthera ciliaris

Platanthera dilatata

Platanthera flava

Platanthera hookeri

Platanthera orbiculata

Podostemum ceratophyllum

Polygala cruciata

Polygala nuttalij

Polymnia canadensis

Populus heterophylla

Potamogeton confervoides

Potemogeton pusillus var. gemmiparus

Potamogeton vaseyi

Potentilla arguta

Prunus alleghaniensis

Puccinellia langeana ssp. alaskana

Pycnanthemum clinopodioides

Pyrola secunda

Ranunculus ambigens

Ranunculus cymbalaria

Ranunculus pensylvanicus

Ranunculus sceleratus

Rhynchospora macrostachya

Common Name

PLANTS

:red pine

hoary plantain

white-fringed orchid

yellow-fringed orchid

tall white bog orchid

pale green orchid

Hooker orchid

large roundleaf orchid

threadfoot

field milkwort

Nuttall's milkwort

small-flowered leafcup

swamp cottonwood

pondweed

capillary pondweed -

Vasey's pondweed

.tall cinquefoil

Alleghany plum

'goose grass

basil mountain-mint

one-sided pyrola .,:

water-plantain spearwort

seaside crowfoot -

bristly buttercup

cursed crowfoot

beaked rush

State

Status(a)

E

SC

T

SC*

-- S C _rSC*

SC*

SC

'SC

E

E

SC*-.

E

SC ..,

SC* .

SC*

SC*

SC

- .. -T. . -.

July 2005, G-11 - NUREG-1437,'Supplement 22
Appendix G

Table G-1. (contd)

State

Scientific Name Common Name Status~a)

Rhynchospora scirpoides

Ribes glandulosum

Ribes rotundifolium

Ribes triste

Rosa nitida

Rotala ramosior

Rubus cuneifolius

Rumex maritimus var. fueginus

Sabatia stellaris

Sagittaria cuneata

Sagittaria subulata

Salix exigua

Salix pedicellaris

Salix petiolaris

Saururus cemuus

Scheuchzeria palustris

Schizachne purpurascens

Schwalbea americana

Scirpus cylindricus

Scirpus hudsonianus

Scirpus longii

Scirpus paludosus var. atlanticus

Scirpus torreyi

Scleria pauciflora var. caroliniana

Scleria reticularis

Scleria triglomerata

Scutellaria integrifolia

PLANTS

long-beaked baldrush

skunk currant

wild currant

swamp red currant

shining rose

toothcup

sand bramble

sea-side dock

marsh pink

waputo

arrowleaf

sandbar willow

bog willow

slender willow

lizard's tail

pod grass

purple oat

chaffseed

salt-marsh bulrush

cotton bulrush

Long's bulrush

bayonet grass

Torrey's bulrush

few-flowered nutrush

reticulated nutrush

nutrush

hyssop skullcap

.

E

T

SC*

E

SC

T

SC

SC*

E

SC*

SC

T

E

SC*

E

E

SC

SC*

SC

SC*

SC*

SC

T

E

E

E

E

NUREG-1437, Supplement 22 G-12 July 2005
I

Appendix G

Table G-1. (contd)

-

Scientific Name Common Name

PLANTS

Senecio pauperculus ragwort

Senna hebecarpa .- wild senna

Silene stellata starry campion

Smilacina trifolia -,three-leaved false Solomon's-seal

Solidago elliottii Elliott goldenrod

Solidago rugosa var. sphagnophila early wrinkle-leaved goldenrod

Spergularia canadensis -Canada sand-spurry

Spiranthes tuberosa var. grayi little ladies'-tresses

Sporobolus clandestinus rough dropseed

Sporobolus neglectus small dropseed

Stachys hyssopifolia hyssop-leaf hedge-nettle

Stachys tenuifolia smooth hedge-nettle

Stellaria borealis northern stitchwort

Streptopus amplexifolius var. americanus .,white mandarin

Thuja occidentalis > - : - . northern white cedar

Trichomanes intricatum Appalachian gametophyte

Triosteum angustifolium narrow-leaved horse gentian

Triphora trianthophora nodding pogonia

Trisetum spicatum var. molle spiked false oats

Utricularia fibrosa fibrous bladderwort

Utricularia resupinata bladderwort

Uvularia grandiflora large-flowered bellwort

Vaccinium myrtilloides velvetleaf blueberry

Vaccinium vitis-idea var. minus mountain cranberry

Valerianella radiata var. femaldii beaked corn-salad

Verbena simplex narrow-leaved vervain

State

Status(a)

*E

SC

S.c

SC

* SC*

T,

SC*

E

E

:":._ _S.

SC

---

T.

SC

SC*

SC*

SC*

SC*

E

E

: SC*

SC*

SC*

SC*

SC*

July 2005, G-13 NUREG-1437,-Supplement 22
Appendix G

Table G-1. (contd)

State

Scientific Name Common Name Status(a)

PLANTS

Vibemum nudum possum haw SC*

Viola canadensis Canada violet SC

Viola selkirkii great-spurred violet SC

Vitis novae-angliae New England grape SC

Waldsteinia fragarioides barren strawberry SC

Xyris montana northern yellow-eyed grass T

Xyris smalliana Small's yellow-eyed grass E

Zizia aptera golden alexanders E

REPTILES

Clemmys insculpta wood turtle SC

Crotalus horridus timber rattlesnake E

Eumeces fasciatus five-lined skink T

Heterodon platirhinus eastern hognose snake SC

Terrapene carolina eastern box turtle SC

Thamnophis sauritus eastern ribbon snake SC

(a) E=endangered, T = threatened, SC = species of concern, (^) = believed extirpated (CTDEP 2004)

NUREG-1437, Supplement 22 G-14 July 2005
Appendix H

NRC Staff Evaluation of Severe Accident Mitigation Alternatives

(SAMAs) for Millstone Power Station, Unit 2, in Support of the License

Renewal Application Review
Appendix H

NRC Staff Evaluation of Severe Accident Mitigation

Alternatives (SAMAs) for Millstone Power Station, Unit 2, in

Support of the License Renewal App!ication ReviewH.1 Introduction -.

Dominion Nuclear Connecticut, Inc. (Dominion) submitted an assessment of SAMAs for

Millstone Power Station, Unit 2 (MPS2) as part of the Environmental Report (ER) (Dominion'-'

2004a). This assessment was based on the most recent MPS2 Probabilistic Risk Assessment

(PRA) available at that time, a plant-specific off-site consequence analysis performed using the

* MELCOR Accident Consequence Code System 2 (MACCS2) computer program, and insights

from the MPS2 Individual Plant Examination (IPE) (NNECO 1993) and Individual Plant '

Examination of External Events (IPEEE) (NNECO 1995). In identifying and evaluating potential

SAMAs, Dominion considered SAMA analyses performed for other operating plants, as well as

industry and NRC documents that discuss potential plant improvements, such as NUREG-1 560

(NRC 1997a). Dominion identified 196 potential SAMA candidates. This list was reduced to

44 unique SAMA candidates by eliminating SAMAs that were not applicable to MPS2 due to -

design differences, had already been implemented, or were related to a reactor coolant pump

(RCP) seal dependency on charging pumps. Dominion assessed the costs and benefits

associated with each of the remaining SAMAs and concluded in the ER that one of the

candidate SAMAs evaluated would be cost-beneficial for MPS2.

Based on a review of the SAMA assessment, the NRC issued a request for additional

information (RAI) to Dominion by letter dated June 22, 2004 (NRC 2004). Key questions

concerned the following areas: peer reviews of the PRA, dominant risk contributors at MPS2

and the SAMAs that address these contributors,-the mapping of Level 1 PRA results into the -

Level 2 analysis, the potential impact of external event initiators and uncertainties on the

assessment results,-detailed information on some specific candidate SAMAs, and consideration

of additional SAMAs. Dominion submitted additional information by letter dated -

August 13, 2004 (Dominion 2004b) including, summaries of peer review comments and their - -

impact on the SAMA analysis; importance measures and corresponding SAMA candidates;

information regarding the Level 2 analysis; information related to the resolution of IPEEE

outliers and the impact of external events in the risk analysis; an assessment of the impact of

uncertainties; and additional information regarding specific SAMAs.^ Dominion's responses,-.-

addressed the staff's concerns. -As a result, Dominion identified one SAMA that is costbeneficial, and a second SAMA that would be cost-beneficial if it can be accomplished via a

severe accident management guideline, without a hardware modification. -

An assessment of SAMAs for MPS2 is presented below.

July 2005;, H-1 NUREG-1437, Supplement 22 -'
Appendix H

H.2 Estimate of Risk for MPS2

Dominion's estimates of offsite risk at MPS2 are summarized in Section H.2.1. The summary is

followed by the staff's review of Dominion's risk estimates in Section H.2.2.

H.2.1 Dominion's Risk Estimates

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA

analysis: (1) the MPS2 Level 1 and 2 PRA model, which is an updated version of the IPE

(NNECO 1993), and (2) a supplemental analysis of offsite consequences and economic

impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The

identification of candidate SAMAs was based on Revision 2 of the PRA model, dated April

2001; the quantification of SAMA benefits was based on Revision 3, dated October 2002

(Dominion 2004b). The scope of the MPS2 PRA does not include external events.

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is

approximately 7.17x10-5 per year. The CDF is based on the risk assessment for internally

initiated events. Dominion did not include the contribution to risk from external events or

internal flooding within the MPS2 risk estimates; however, it did account for the potential risk

reduction benefits associated with external events by increasing the estimated benefits for

internal events by 30 percent. This is discussed further in Sections H.4 and H.6.2.

The breakdown of CDF by initiating event is provided in Table H-1. As shown in this table, loss

of coolant accidents (LOCAs), loss of cooling water to the primary side components (COOL)

including service water (SW) and reactor building closed cooling water (RBCCW), loss of DC

power, and transients including anticipated transients without scram (ATWS) are dominant

contributors to the CDF. LOCAs are dominated by small-break LOCAs which make up about

36 percent of the total CDF. Bypass events [i.e., steam generator tube rupture (SGTR) and

interfacing systems loss of coolant accident (ISLOCA)] contribute less than 4 percent to the

total internal events CDF. In response to an RAI, Dominion estimated the contribution to CDF

from internal floods to be approximately 2x1 0 7 per year (Dominion 2004b).

The Level 2 PRA model is based on the original Level 2 model of the IPE (NNECO 1993). The

model has been revised to reflect modified plant damage states and new release categories.

These revisions were made to make the plant damage states (PDSs) and release categories

consistent with those used for Millstone Power Station, Unit 3 (MPS3). The result of this

analysis is a matrix that transforms the PDS frequencies to the release category frequencies.

The source terms for each release category (also termed the source term category) were

obtained from the results of MAAP 3.0B analyses of the dominant core damage sequences in

the IPE.

NUREG-1437, Supplement 22 H-2 July 2005

I
Table H-1. MPS2 Core Damage Frequency

- Initiating Event or

. - .__ Accident Class .

-CDF % Contribution to

(Per.Year) .-- .- ... -. CDF. -a -- -

LOCA

COOL-(SW+Seal LOCA+ RBCCW)(a) -

Loss of DC power

ATWS

Transients

2.66 x1 04

-1.44 x 1 -

1.03 x 1 F-5

8.68 x 10o6

4.66 x 106

2.22 x 106

2.15 x 106

1.72 x 10-6

37.1

20.1 --- - - - I

14.4

12.1

6.5

3.1

3.0

2.4

SGTR

Station blackout (SBO)

Steamline and main feed line breaks

Loss of offsite power (LOOP)

ISLOCA - -

- - -- 8.60 x 10 7 ---- - 1.2 - -

- -- 1.43x10-7 0.2 - - -- - -

Total CDF 7.17x104 100

(a) COOL represents the loss of cooling water to the primary side components, leading to an

eventual degradation of the reactor coolant pump seal integrity. . I

The offsite consequences and economic impact analyses-use the MACCS2 code to determine

the offsite risk impacts on the surrounding environment and public. Inputs for this analysis

include plant-specific and site-specific input values for core radionuclide inventory, .source term

and release characteristics, site meteorological data, projected population distribution within a

80 kilometer (km) (50-mile [mui) radius for the year 2030, emergency response evacuation

modeling, and economic data. The core radionuclide inventory is based on the generic

pressurized water reactor (PWR) inventory provided in the MACCS2 manual, adjusted to',

represent the MPS2 power level of 2700 megawatts thermal (MW[t]). The magnitude of the

onsite impacts (in terms of clean-up and decontamination costs and occupational dose) is

based on information provided in NUREG/BR-0184 (NRC 1997b). l

In the ER, Dominion estimated the dose to the population within 80 km (50 mi) of the MPS2 site,

to be approximately 0.174 person-sieverts (person-Sv) (17.46perso'-roentgen'equivalents main

[person-rem]) per year. The breakdown of the total population dose by containment release

mode is summarized in Table H-2. Intermediate containment failures dominate the population

dose risk at MPS2, followed by SGTR and late-containment faiiures. 'Early-containment failures

and ISLOCAs make 'relatively small contributions, each being less than 3 percent of the total.

Containment'isolation and basemat failures 'are'each indicated to be zero contributors to risk.

As indicated in the response to anrRAI,' these release modes are incorporated into other

release modes with similar characteristics (Dominion 2004b).

July 2005 H-3' NUREG-1 437, Supplement 22
Appendix H

Table H-2. Breakdown of Population Dose by Containment Release Mode (Unit 2)

Population Dose

Containment Release Mode (Person-rem(') Per Year) % Contribution

Intermediate failure 12.4 71

SGTR 2.5 14.4

Late failure 1.63 9.4

Early failure 0.48 3

ISLOCA 0.42 2.4

Containment isolation failure 0 0

Basemat failure 0 0

Total Population Dose 17.4 100

(a) One person-rem = 0.01 person-Sv

H.2.2 Review of Dominion's Risk Estimates

Dominion's determination of offsite risk at MPS2 is based on the following three major elements

of analysis:

* the Level 1 and 2 risk models that form the bases for the 1993 IPE submittal (NNECO 1993)

and the 1995 IPEEE submittal (NNECO 1995),

* the major modifications to the IPE models that have been incorporated in the MPS2 PRA,

and

* the MACCS2 analyses performed to translate fission product source terms and release

frequencies from the Level 2 PRA model into offsite consequence measures.

Each of these analyses was reviewed to determine the acceptability of Dominion's risk

estimates for the SAMA analysis, as summarized below.

The staff's review of the MPS2 IPE is described in an NRC report dated May 21, 1996

(NRC 1996). Based on a review of the original IPE submittal, the staff concluded that IPE

submittal met the intent of Generic Letter 88-20 (NRC 1988); that is, the IPE was of adequate

quality to be used to look for design or operational vulnerabilities. The staff did, however,

NUREG-1437, Supplement 22 H-4 July 2005

I
identify a number of weaknesses in the IPE analysis. In response to an RAI, Dominion

indicated that all of th6se' weaknesses have been addressed in the PRA used for the SAMA

analysis (Dominion 2004b).- -

A comparison of internal events risk profiles between the IPE and the PRA used in' the SAMA

analysis indi6ates an increase of approximately 3.8x105 per year in the total CDE.(from 3.4x10 5

per year to 7.1 7x1 05 per year).' The change is a net result of m6deling changes 'and some

minor plant design changes that have'been implemented at MPS2 since the IPE. A summary

listing of those changes that resulted in'the greatest impact on the total CDF was provided in

the ER and in" response t6'RAls (Dominion 2004a, 2004b), ard include the following: '

added credit for passive ventilation in the intake structure i-

* updated'the loss of normal power event frequency '-

* added new cross-tie to Unit 3 AC power sources to mitigate SBO conditions at Unit 2

* modified the total loss'of coolirig event tree by updating nodes for failure of the operator to

; trip the reactor coolant pumps' and reactor coolant pump seal LOCA

* modified the AC power distribution logic by adding the MPS2 normal station service

transformer as the power source (not previously modeled)

* modified the DC logic to (1) transfer to the loss of DC when emergency diesel generators

and DC buses are not available, and (2) add a loss of DC bus A and B event as first event

to be considered in'the'SBO event tree. ' ' '-

An additional change that has a significant impact on the CDF value is the truncation value

used in the PRA model.- For the PRA version used for the'SAMA analysis, Do'miniorn'used a

: truncation value of 1.0 x 10-11. In contrast, use of a trurictiornvalue of 2.0 x 109 (as used in

previous versions of the PRA) would result in a ODE of aboit 5'x iO per year. Thisaalone '

' would account for approxirnately'half of the noted increase in CDF since the IPE.

The IPE CDF value for MPS2 is comparable to the CDF values reported in the IPEs for other

Combustion En'gineering (CE) PWR plants. Figure 11.6 of NUREG-1 560 shows that the"

IPE-based total internal events CDF for CE PWRs' ranges fror'm1 x 1 0-5 to 3 x 104 per year

(NRC 1997a). It is recognized that'other plants have reduced their' values' for CDF after the IPE '

submittals due to inodeling and hardware changes. The currert internal events CDF results for

MPS2 remain'comparable to'the' resuIts for other plants of sin'ilai Vintage -and characteristics

The staff considered the' peer review performed for the MPS2 PRA, and the&potential impact of

the' review findings on the SAMA evaluation.' In r'espronse to arnRAI, Dominion described the

July 2005 H-5 NUREG-1437, Supplement 22
Appendix H

external peer review, which was the Combustion Engineering Owners Group (CEOG) Peer

Review of PRA Revision 0 performed in 1999 (Dominion 2004b). The review resulted in 25

Level A facts and observations (extremely important and necessary to address to ensure

technical adequacy) and 59 Level B facts and observations (important and necessary to

address but may be deferred until next PRA update). The majority of the recommendations

from this review were addressed or reflected in Revision 3 of the MPS2 PRA. Seven of the

Level A recommendations are yet to be resolved, while 25 of the Level B recommendations are

yet to be resolved. Those Level A recommendations not yet incorporated are in the areas of

accident sequence analysis, human reliability analysis, dependency analysis, and quantification.

The Level B recommendations not yet incorporated affect all PRA elements. Dominion has

reviewed all of the unresolved facts and observations and concluded that they have negligible

impact on the SAMA analysis (Dominion 2004b). The staff has also reviewed Dominion's

assessment of the impacts of the outstanding peer review comments and has come to the

same conclusion.

Given that (1) the MPS2 PRA has been peer reviewed and the potential impact of the peer

review findings on the SAMA evaluation has been assessed, (2) Dominion satisfactorily

addressed staff questions regarding the PRA (Dominion 2004b), and (3) the CDF falls within

the range of contemporary CDFs for CE plants, the staff concludes that the Level 1 PRA model

is of sufficient quality to support the SAMA evaluation.

The licensee submitted an IPEEE in December 1995 (NNECO 1995), in response to

Supplement 4 of Generic Letter 88-20. While the IPEEE submittal did not specifically state a

criterion for identifying a vulnerability to severe accident risk in regard to the external events

related to seismic, fire, or other external events, a number of outliers or 'opportunities for safety

enhancements" were identified. The current status of these outliers was provided by Dominion

in response to a staff RAI. In the response, Dominion stated that of a total of 29 items, 21 were

resolved prior to 2003. The remaining eight items were closed in August 2003 (Dominion

2004b). In a letter dated January 12, 2001, the staff concluded that the IPEEE submittal met

the intent of Supplement 4 to Generic Letter 88-20, and that the licensee's IPEEE process is

capable of identifying the most likely severe accidents and severe accident vulnerabilities

(NRC 2001).

The seismic portion of the IPEEE consisted of a 0.3g (the acceleration due to the gravitation

force [g]) focused-scope seismic evaluation using the Electric Power Research Institute (EPRI)

methodology for Seismic Margins Assessment (SMA). A total of 16 components were initially

estimated to have high-confidence low-probability of failure (HCLPF) capacities less than the

review level earthquake peak ground acceleration of 0.3g. The lowest of these were included in

the list of outliers to be resolved. The actions taken by the licensee to resolve seismic outliers

included modification of the RBCCW and chilled water surge tanks supports, and modification.

to anchorage of battery racks. Other items were resolved by verifying component adequacy by

NUREG-1437, Supplement 22 H-6 July 2005
calculation or by correcting housekeeping problems. After resolution of these outliers, three

components remained with HCLPF values less than the 0.3g review level earthquake: the

turbine building housing the auxiliary feedwater (AFW) pumps (0.25g), the 125 VDC vital bus

201 B (0.26g), and the RBCCW heat exchangers'(0.29g). Dominion 'concluded that because of

adequate seismic margins and the complexity associated with increasing the seismic capacity

of a structure, no cost-effective SAMAs related to seismic events could be identified

(Dominion 2004b). The staff agrees that it is unlikely that cost-effective SAMAs that address

seismic vulnerabilities will exist. This is due to high cost of structural modifications compared to

* the benefits expected. --

The MPS2 IPEEE does not provide numerical estimates of the CDF contributions from seismic

initiators. Section F.2.4 of the ER indicates that the seismic CDF is 9.1 x106 per year. Since

the SMA does not result in a numerical value, the staff asked Dominion to provide'the basis for

the seismic CDF value given in the ER (NRC 2004). In response, Dominion indicated that the

value 'used is the seismic CDF for Millstone Power Station, Unit 3 (MPS3) obtained from the

MPS3 seismic PRA. The staff notes that for MPS3 all of the plant components or structures

whose failure would significantly impact CDF have HCLPF values equal to or greater than the

review level earthquake acceleration of 0.3g, whereas MPS2 has three components/structures

with HCLPF values that are below 0.3g. This'would indicate that the seismic CDF for MPS2

may be greater than that for.MPS3. -

Even though the MPS2 seismic CDF may be larger than that used to estimate the added

benefit of SAMA candidates due to their impact on seismic risk,'the staff believes that the!

seismic CDF would remain a relatively small contributor to the'total CDF. This'is'due to the

small contribution that low-magnitude earthquakes make to the'CDF. The impact of lowmagnitude earthquakes (in the range of 0.1 to 0.3 g) is principally in causing initiating events

and for a LOOP reducing the likelihood of offsite power recovery. The frequency of these

seismic initiating events is several orders of magnitude less than that due to random failures'

Even a station blackout following a seismic LOOP has a frequency considerably less than that

due to internal events. For higher-magnitude earthquakes, the impact of structural failures '

starts to become more important. However, as indicated above, SAMAs to mitigate these'risk''

contributors are not expected to be cost effective.-

The licensee's IPEEE fire analysis was based on EPRI's Fire Induced Vulnerability Evaluation

methodology. This methodology employs a graduated focus on the most important fire zones

using qualitative and quantitative screening criteria: The fire zones or compartments were -

subjected to at least two screening phases. In the first phase, a zone was screened out if a fire'-'

could not cause an initiating event and if the zone contained no'equipment or cables needed to

mitigate an initiating event. In the second-phase screening, three quantitative'criteria were':

used: (1) a zone is screened out if the CDF is less than 1 x 1 0- per year from evaluating the

plant model assuming all equipment in the zone is lost, (2) a zone is screened out if contains a

single train of safety equipment and the fire induced unavailability is small compared to that due

July 2005 .- H-7 NUREG-1 437, Supplement 22
Appendix H

to internal events, and (3) a zone is screened out if the effect of a fire is similar to but less

severe than that in another analyzed zone. Of a total of 87 fire zones, 13 zones comprising five

fire areas were not screened out and were subjected to a more detailed quantitative analysis.

These areas are as follows:

Fire Area Description CDF (per year)

AUXB-1 auxiliary building 2.76 x 10-

A-24 cable vault 2.83 x 10-

A-25 main control room 6.57 x 10-7

I-1A intake structure pump room 9.66 x 1-

TB turbine building general areas 1.63 x 1V0!

The fire CDF for MPS2 is approximately 6.3 x 10- per year or about nine percent of the MPS2

internal events CDF.

In an RAI, the staff asked Dominion to explain, for each important fire area, what measures

were taken to further reduce risk, and explain why these CDFs cannot be further reduced in a

cost-effective manner (NRC 2004). For each area, Dominion provided a discussion of the

major fire contributors assumed in the analysis and the existing plant features to address fire

events. Dominion identified several improvements that have been implemented to address

fire-related issues and confirmed that all fire-related plant outliers identified in IPEEE were

implemented prior to the SAMA analysis. Dominion also discussed the potential for further

cost-effective hardware changes to address the fire-related matters listed above, including

improvements to detection systems, enhancements to suppression capabilities, and changes

that would improve cable separation and train separation (Dominion 2004b). Dominion

concluded that no further modifications would be cost-effective for any of the fire areas.

The staff notes that although additional SAMAs to reduce the fire risk contributors might be

viable, given the low level of risk from fires and the improvements that have already been

implemented, it is unlikely that further modifications would both substantially reduce risk and

remain cost-beneficial.

The risk associated with other external events at MPS2 is small. While the CDFs due to high

winds, floods and other events were not estimated since they were screened out using the

NUREG-1407 approach (NRC 1991), a number of possible enhancements were identified in the

IPEEE. These enhancements, primarily related to high winds and external flooding, have all

been resolved (NRC 2001).

NUREG-1437, Supplement 22 H-8 July 2005
In the SAMA analysis, Dominion accounted for the additional risk contribution due to external

events by increasing the benefit derived from the internal events model by 30 percent. This

was determined by summing the following CDF contributions:'-'

* Fire 6.3 x 10- peryear.

Internal flooding '0.2 x 10- per year.

^ Seismic - ' 9.1 x 106peryear -

The fire contribution is discussed above. The internal flood contribution is based on the IPE

analysis, but has subsequently been dropped from' the internal events model. The total external

events CDF from the above is 1.6 x 1 O per year, or approximately 22 percent of the CDF due

to internal events. 'This was rounded up to 30 percent for the.SAMA analysis. -

The MPS2 Level 2 PRA analysis is based on the IPE. The IPE results were transformed to

reflect new plant damage state and release category definitions. This process is described in

Section F.2.3 of the ER (Dominion 2004a), and further clarified in response to RAIs

(Dominion 2004b, 2004c). The resulting plant damage state'torelease category transformation

matrixand release category-frequencies are provided in Tables F.2-4 and F.2-6 of the ER,

respectively (Dominion 2004a). The release fractions for each release category were obtained'.

i from MAAP 3.OB analysis for the dominant sequences in the IPE and are provided in

Table F.1 -2 of the ER (Dominion 2004a). In response to an RAI concerning the use of !PE

dominant sequences to determine the release fractions used in the SAMA analysis, Dominion

provided a discussion and a comparison of the plant damage states and release categories for

the IPE and SAMA analyses (Dominion 2004b). The staff reviewed Dominion's source term

estimates for the major release-categories and found the release fractions to be within the

range of the release fractions for similar plants. Dominion also provided the results of several

sensitivity studies relative to the source term and release characteristics including doubling the

plume release height, doubling the duration of source term release time,' setting source terrr for

M9 and MI 1 (late and baseemat failures with sprays) equal to Ml 0 (basemat failure without -

sprays), and using the MPS3 data for release category MiA (ISLOCA sequence). The results

showed that these parameter variations had only a minor imnpact (less than 10 percent) on the

estimated dollar benefits for the candidate SAMAs.- The'staff cbncludes that the process used

for determining'the release category frequenciesand source terms is reasonable and

: appropriate for the purposes of the SAMA analysis.

As discussed previously, the fissi6n'product inventory used in the consequence analysis is'

based on a fission pr~6duct inventory scaled from generic information. In response to an RAI

concerning the impact of current and future fuel managerndnt practices, Dominion described a,

conservative bounding analysis of core fission produ-ct inventory 'onsidering a range of

enrichments and burnups (Dominion 2004b). Using this inventory would result in a 22-percent

increase in total benefit from eliminating all risk; Using realistic mid-life or average-conditions

July 2005 H-9 -: NUREG-1437, Supplement 22
Appendix H

would result in a smaller increase in the maximum benefit. The staff concludes that the scaling

based on the plant-specific power level yields sufficiently accurate and reasonable results for

the dose assessment.

The staff reviewed the process used by Dominion to extend the containment performance

(Level 2) portion of the PRA to an assessment of offsite consequences (essentially a

Level 3 PRA). This included consideration of the major input assumptions used in the offsite

consequence analyses. The MACCS2 code was utilized to estimate offsite, consequences.

Plant-specific input to the code includes the source terms for each release category and the

MPS2 reactor core radionuclide inventory (both discussed above), site-specific meteorological

data, projected population distribution within a 80 km (50 mile) radius for the year 2030, and

emergency evacuation modeling. This information is provided in Appendix F to the ER

(Dominion, 2004a).

Dominion used site-specific meteorological data processed from hourly measurements for the

2000 calendar year as input to the MACCS2 code. The hourly data (wind direction, wind speed,

and stability class) were collected from the onsite meteorological tower. Precipitation data were

recorded at the Green Airport near Providence, Rhode Island, the closest weather station to

Millstone. Morning and afternoon mixing height values were obtained from the National

Climatic Data Center. The applicant also considered the impact on SAMA benefits of using

meteorological data for 1998 and 1999. The results of these sensitivity cases showed that the

benefits increased by an average of about five percent. The staff considers the use of the 2000

data in the base case to be reasonable.

The population distribution the applicant used as input to the MACCS2 analysis was estimated

for the year 2030, based primarily on SECPOP90 (NRC 1997c). U.S. Census Bureau Year

2000 population data, projected to year 2030, was then used to update the SECPOP90

population data (Dominion 2004a). The staff questioned the difference between the use of

SECPOP90 and SECPOP2000, and what the impact would be if the latter was used. In

response, Dominion noted that the expected impact of using SECPOP2000 would be negligible

since census data from 2000 were used to update the SECPOP90 file. The staff considers the

methods and assumptions for estimating population reasonable and acceptable for purposes of

the SAMA evaluation.

The emergency evacuation model was modeled as a single evacuation zone extending out 16

km (10 mi) from the plant. It was assumed that 100 percent of the population would move at an

average speed of approximately 1.49 meters per second with a delayed start time of

7200 seconds from the offsite alarm reference time point (Dominion 2004a). Dominion

performed sensitivity studies exploring the impact of the fraction of population that evacuates

and the evacuation speed. The results demonstrated that the total dose and economic cost

NUREG-1437, Supplement 22 H-10 July 2005

I
results are insensitive to these parameters (Dominion 2004a). The staff concludes that the

evacuation assumptions'and analysis are reasonable and acceptable for the purposes of the

SAMA evaluation. ' ' 

Much of the site-specific economic data was provided from SECPOP90 (NRC 1 997c) by

specifying the data for counties surrounding the plant to a distance of 50 miles. The

SECPOP90 input file was updated to 2001 using cost of living and other data from the Bureau

of the Census and the Department'of Agriculture '(Dominion 2004a). The agricultural economic

data were updated using available data from the 1997 Census of Agriculture (USDA 1998).

The staff coricludes that the 'imethodology used by Dominion to estimate the offsite

: consequences f6r'MPS2 provides an acceptable basis'from'which to proceed with an

assessment of risk reduction potential for candidate SAMAs. Accordingly, the'staff based its

assessment of offsite risk on the CDF and offsite doses reported by Dominion.

Potential Plant Improvements

The process for identifying potential plant improvements, an evaluation of that process, and the

improvements evaluated in detail by Dominion are discussed in this section.

H.3.1 Process for Identifying Potential Plant Improvements

- 4. ,.J* -

Dominion's process for identifying potential plant improvements (SAMAs) consisted of the

following elements: ;

* review-of the most significant basic events fr6m the MPS2 PRA Model, Rev. 2 (April 200i),

* 'review of items not already evaluated and/or implemented during the IPE and IFEEE,

* review of SAMA analyses' submitted in support of originral licensing arid license renewal

activities'f6r other operating nuclear p6wer plants, a1nd

* review of other NRC and industry documentation discussing potential plant improvements. - i ! -. I

-x -* * e' 1 _ i h,. In Pase the

Based on this process, an initial set of 196 'carididate SAMAs ws identified. In Phase 1 of the

eva!uation,'Dominion performed a' qualitative screening of thehinitial list of SAMAs and

eliminated SAMAs fromrfurther consideration using the followingjbriteria:

* 'the SAMA is not applicable at MPS2, :

* the SAMA has already been'implemented at MPS2, or the MPS2 design meets the intent of

the SAMA, or

July 2005 H-1 1 NUREG-1437, Supplement 22
Appendix H

* the SAMA is related to a RCP seal vulnerability stemming from charging pump dependency

on component cooling water (CCW). (MPS2 does not have this vulnerability because it

relies on the RBCCW system rather than CCW for RCP seal cooling.)

Based on this screening, 152 SAMAs were eliminated leaving 44 for further evaluation. Of the

SAMAs eliminated, 53 were eliminated because they were not applicable, 91 were eliminated

because they already had been implemented, five were eliminated because they were related

to RCP seal vulnerability, and three were similar to and combined with other SAMAs. A cost

estimate was prepared for each of the 44 remaining candidates to focus on those that had a

possibility of having a net positive benefit. To account for the potential impact of external

events, the estimated benefits based on internal events were multiplied by a factor of 1.3 for all

SAMAs except those related to ISLOCA and SGTR-initiated events.

Of the 44 SAMAs evaluated, one was identified as potentially cost-beneficial. Other SAMAs

were evaluated and subsequently eliminated, as described in Sections H.4 and H.6.1 below.

H.3.2 Review of Dominion's Process

Dominion's efforts to identify potential SAMAs focused primarily on areas associated with

internal initiating events. The initial list of SAMAs generally addressed the accident categories

that are dominant CDF contributors or issues that tend to have a large impact on a number of

accident sequences at MPS2.

The preliminary review of Dominion's SAMA identification process raised some concerns

regarding the completeness of the set of SAMAs identified and the inclusion of plant-specific

risk contributors. The' staff requested additional information 'regarding the top 30 cut sets and

certain sequences (NRC 2004). In response to the RAI, Dominion provided a listing of the top

contributors to risk, the associated plant damage state, and a cross-reference between the top

contributors to risk from a later version of the PRA and the SAMAs that addressed those risk

contributors (Dominion 2004b).

The staff noted that Dominion based the SAMA identification process on PRA Revision 2

(dated April 2001) and the SAMA quantification on Revision 3 (dated October 2002). The staff

questioned Dominion regarding the impact on the SAMA identification process if the later

version of the PRA was used to identify potential SAMAs (NRC'2004). In response, Dominion

reassessed the SAMA identification process considering the later PRA revision. The basic

events not included in the initial Unit 2 PRA importance list were identified. Those events with a

risk reduction worth greater than or equal to 1.005 from the more recent PRA model were

specifically evaluated. These events were compared to the SAMA list to determine which

events were already addressed by a SAMA. Dominion determined that all of the additional

basic events map to previously identified SAMAs. As a result, no new SAMAs were created

NUREG-1437, Supplement 22 H-1 2 July 2005
(Dominion 2004c). Based on these additional assessments, Dominion concluded that the set of

196 SAMAs evaluated in the ER addresses the major contributors to CDF and offsite dose, and

' that the review of the top risk contributors does not reveal any new SAMAs.

The staff questioned Dominion regarding use of the second screening criterion (i.e., screening

out a SAMA on the basis that it has already been implemented at MPS2) to eliminate SAMAs

that were identified based onreview of the PRA (NRC 2004). In response, Dominion provided

qualitative or quantitative details on the plant-specific SAMAs that were screened using this

criterion (SAMAs 161,162,-163,-164, 167, 168,169,171,:177,178,180,181, 188, and 196).

None of these SAMAs were determined to be cost-beneficial based on this further evaluation.

The staff questioned Dominion about lower-cost alternative'stb some of the SAMAs evaluated,:

including the use of portable'battery chargers and a direct-dr e diesel AFW pump' (NRC 2004).

In response, Dominion identified several lower-cost alternatives,rall of which are covered by an

existing procedure or severe accident management guideline (SAMG), or could be instituted'-.'

following evaluation and guidance by the Technical Support Center (Dominion 2004b). -This is

discussed further. in Section H.6.2. - -

The staff also questioned Dominion about several other candidate SAMAs that were found to

be potentially cost-beneficial at another CE plant but not addressed by MPS2 (NRC 2004). In

response, Dominion provided an evaluation of the applicability and/or costs and benefits for

these SAMAs at MPS2.- Based on this assessment,'all of the SAMAs were dismissed except -

one involving adding a capability to flash the field on the emergency diesel generator to -

enhance SBO event recovery (Dominion 2004b). This is discussed further in Section H.6.2.

The staff notes that the set of SAMAs submitted is not 'all inclusive, since additional, possibly

even less expensive,'design alternatives can always be postulated. However, the staff',-

concludes that the benefits of any additional modifications are unlikely to exceed the benefits of

the modifications evaluated and that the alternative improvements would not likely cost less

than the least-expensive alternatives evaluated, when the subsidiary costs associated with

maintenance, procedures, and training are considered.

t; ;- -' - ' . -. . .'. -; ,- ..... '-7.-.. ..- ': ................. _ ' .: .; .

The staff concludes that Dominion used a systematic and comprehensive process for -

identifying potential plant improvements forMPS2, and that the set of potential plant. -.

improvements identified by Dominion is reasonably comprehensive and, therefore, acceptable.

This search included reviewing insights from the IPE and IPEEE and other plant-specific

studies, reviewing plant improvements considered in previous SAMA analyses, and using the,

knowledge and experience of its PRA personnel.. While explicit treatment of external events in

the SAMA identification process was limited, it is recognized that the prior implementation of

plant modifications for seismic events and the absence of external event vulnerabilities

reasonably justifies examining primarily the internal events risk results for this purpose.

July 2005' H-13 NUREG-1 437, Supplement 22
Appendix H

H.4 Risk Reduction Potential of Plant Improvements

Dominion evaluated the risk-reduction potential of the 44 remaining SAMAs that were

applicable to MPS2. A majority of the SAMA evaluations were performed in a bounding fashion

in that the SAMA was assumed to completely eliminate the risk associated with the proposed

enhancement. Such bounding calculations overestimate the benefit and are conservative.

Dominion estimated the potential benefits for each SAMA by generating a revised set of plant

damage state frequencies. Using these revised frequencies, a revised Level 3 (dollars averted)

calculation was performed. The benefit was calculated using the fault trees, event trees, and

databases from Revision 3 of the MPS2 PRA. The assumptions made to evaluate the benefit

were provided in response to an RAI (Dominion 2004b, 2004c). Table H-3 lists the

assumptions considered to estimate the risk reduction for each of the evaluated SAMAs, the

estimated risk reduction in terms of percent reduction in CDF and population dose, and the

estimated total benefit (present value) of the averted risk (including the 1.3 multiplier to account

for benefits in external events). The determination of the benefits for the various SAMAs is

further discussed in Section H.6.

The staff has reviewed Dominion's bases for calculating the risk reduction for the various plant

improvements and concludes that the rationale and assumptions for estimating risk reduction

are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what

would actually be realized). Accordingly, the staff based its estimates of averted risk for the

various SAMAs on Dominion's risk reduction estimates. The estimated risk reduction for

several of the SAMAs was negligible or zero. In these instances, the SAMA either affects

sequences or phenomena that do not contribute to risk at MPS2, or represents an ineffective

plant improvement. As such, a minimal impact on risk is not unreasonable in those cases.

H.5 Cost Impacts of Candidate Plant Improvements

Dominion personnel experienced in estimating the cost of performing work at a nuclear plant

estimated the costs of implementing the 44 candidate SAMAs. For some of the SAMAs

considered, the cost estimates were sufficiently greater than the benefits calculated such that it

was not necessary to perform a detailed cost estimate. Cost estimates typically included

procedures, engineering analysis, training, and documentation, in addition to any hardware.

The staff reviewed the bases for the applicant's cost estimates (presented in Section F.3 of

Appendix F to the ER). For certain improvements, the staff also compared the cost estimates

to estimates developed elsewhere for similar improvements, including estimates developed as

NUREG-1437, Supplement 22 H-14 July 2005
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Table H-3. SAMA Cost-Benefit Screenina Analvsis for Millstone Power Station, Unit 2

'C

- - - -% Risk Reduction

SAMA Assumptions Po uain T tlB nft() Cost()

--- ,,--- -CDF Dose

3 - Enhance loss of RBCCW Set RCP seal failiure and loss of the 7.8 4.9 173,300 100,000 procdedure to ensure cool down of -RBCCW system to zero ---

reactor coolant system (RCS) prior to (This SAMA Is bolded because It was

seal LOCA, determined to be cost-beneficial)

8 - Eliminate R'C-P thermal barrier Set ioss of the RBCCW system to zero 6.9 4.6 155,500 5,000,000 dependence on RBCCW such that loss

of RBCCW does not result directly In -

core damage

10 - Create an Independent RCP seal Eliminate the need for RCP cooling, 6 3.9 135,400 6,000,000 coolin6 syst~n, with dedliated diesel from the fault tree - --- ----

1 1 - Create an Independent RCP seal Same as SAMA #10: -- - 6 3.9 135,400 5,000,000 cooling system, without dedicated diesel -.

22-a6elbi~heat Set RI3CCW heat exchanger failures to 0.3 0.3 7,300 2,500,000

removal heat exchangers zero

34 - Inistalle co6ntainiment v'ent.lar-g'e Set the electrical and mechanical 9.9 4.0 204,300 10,000,000

enough to remove ATWS decay heat reactor trip probabilities to zero

35 - Install a filtered containment vent to Set the containment spray component 16.2 16.0 414,300 12,000,000

remnove decay heat - failures to zero,

36 - Install an unfiltered hardened - Same as SAMA #35 -16.2 160414,300 10,000,000

containment ventf

I

N) I I - -- - - . .
Table H-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 2 (Cont.)

0

a % Risk Reduction

en SAMA Assumptions P Total Benefit (S) Cost ($)

CDF Dose

43 - Create a reactor cavity flooding Re-bin Intermediate and late 0 16.4 84,700 18,000.000 system containment failures without sprays Into

corresponding release categories with

sprays

44 - Create other options for reactor Same as SAMA #43 0 16.4 84,700 18,000,000 cavity flooding

75 - Create a water backup for diesel Set loss of emergency diesel generator 1.5 2.8 44,600 10,000,000 cooling (EDG) 'A' and 'B' and common cause

failure (CCF) of EDG 'A' and 'B' to zero

I 77 - Provide a connection to alternate Remove cutsets containing loss of the 8.3 13.9 234,900 6,000,000 a) offsite power source (the nearby dam) Unit 3 cross-tie and grid and weather

related losses of normal power from the

base case. Set Unit 3 cross-tie and

grid and weather related initiators to

zero

81 - Install a fast acting motor generator Set 125 VDC Buses 201A and 201 B 1.0 1.7 29,200 3,000,000 output breaker Initiators to zero

z

C 87 - Replace steam generators with new Set steam generator tube rupture 3 12.7 126,900 200,000,000 m design Initiating event frequency to zero

v 93 - Install additional instrumentation Set the ISLOCA containment release 0.2 2.4 22,100 12,000,000 W and inspection to prevent ISLOCA category frequency to zero

Cn sequences InC

' 94 - Increase frequency of valve leakage Same as SAMA #93 0.2 2.4 22,100 2,000,000 m testing >

n 99 - Ensure all ISLOCA releases are Same as SAMA #93 0.2 2.4 22,100 4,000,000 (D W scrubbed 

C

-- -... -...-
Table H-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 2 (Cont.) rn 

C

SAMA -Assumptions.CF Pplto ~a eei $ Cost($

I 100 -Add redundant and''diverse limit Same as SAMA #93 0.2 2.4 28,700 18,000,000

CD switch to'ea'ch containment isolation,

(D valve'

123 -, Provide capability for diesel-driven, Set failure of the low pressure safety 0 0 0 7,500,000 low pressiure vessel makeup.*-. Injection (LPSI) pumps and CCF of the

LPSI pumps to zero

124/125 -Pirovide ani addition~al high Set failure ~ of the high pressuresafeity 10.5 13.0 286,100 10,000,000

pressure injection pump withIneto HS)pmsadCFfth Independent diesel_ njectionu(pstopupsaner f h

17 127 - Implement a reactor water storage Set probability of RWST rupture and 0.2 0.5 7,400 50,000 .. ~tank (RWST) makeup procedure RWST unavailability to zero

150 -~Prov'Ide an additional Set electrical reactor trip and turbine 8.7 3.5 177,900 600,000 instrumentatlo'n&c66ntrol syifem-(:e~g. trip to z'ero,*,

ATWS Mitigati6~f Syste'm ActuationCircuitry) - .:-,: i4

159 lintill 6idr& iwpu~m'p' Set failure 'of the' tu'rb'n~e'driven&AF 8.0 5.1 178,100 12,000,000

pumps to zero

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Table H-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 2 (Cont.)

% Risk Reduction

SAMA Assumptions Populaton Total Benefit Cost (5)

CDF Dose

165 - Install independent air-operated Set failure of RBCCW/ESFRS AOV 2- 0.2 0.3 4,900 4,000,000 valve (AOV) around existing RB-68.1A to open to zero

RBCCW/engineered safeguards feature

room service (ESFRS) AOV in 'A' train

to improve reliability of engineered safety

feature room cooler

166 - Install additional motor-driven AFW Set failure of the motor driven AFW 2.2 1.1 47,400 12,000,000 pump pumps A' and 'B to zero

170 - Install redundant parallel Set failure of MOV 2-CS-1 6.1A to open 6.0 5.3 146,900 2,000,000 containment sump motor-operated valve to zero

(MOV) to provide additional flow path

during containment swapover in

recirculation

172 - Add a redundant 125 VDC bus Set loss of 125 VDC buses 201A and 0.1 0.3 4,100 5,000,000

201 B initiators and bus faults to zero

173 - Install diverse valve around Set failure of AOVs 2-SW-8.1A/B/C to 8.0 4.6 175,000 1,000,000 existing service water AOV in each train open and CCF to open to zero

to improve reliability of cooling water

supply to RBCCW heat exchangers

174 - Install additional AOV in series with Set failure of AOV 2-RB-8.1A to close 3.4 2.1 748900 2,000,000 existing AOV in each train to Improve to zero

isolation of RBCCW supply to nonessential Spent Fuel Pool heat

exchanger

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Table H-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 2 (Cont.)

% Risk Reduction

SAMA Assumptions Total Benefit ( Cost (S) Population

CDF Dose

176 - Install additional AOV around Set failure of AOV 2-SW-8.1A to open 2.2 1.3 48,600 3,000,000 existing service water AOV In 'A' train to to zero

improve reliability of cooling water supply

to RBCCW heat exchanger

179 -Automate RCP trip circuitry on loss Set failure of operator to trip RCPs on 6.0 3.9 135,400 3,000,000 of seal cooling loss of thermal barrier cooling to zero

182 - Automate the start and alignment Set failure of operator to align stand-by 0 0 0 1,000,000 of the RBCCW pump RBCCW pump to zero . .... -

183 - Automate isolation feature of Set failure of operator to Isolate faulted 1.3 0.6 27,400 5,000,000 faulted steam generator' steam generator to zero

184 - Install redundant AFW regulating Set failure of operator to open AFW 0.7 0.4 15,900 2,000,000 valve following regulating valve fail to regulating bypass valve on failure of

open -. AFW regulating valve to open to zero

185 - Install redundant ESFRS fan *' - ElmiInate the need for ESFRS fin F- 0.2 0.3 4,900 450,000 S.,,.;. r..'. * i';+ -'X L M 3 15B frfithe fa'ulttree'andsetthe" -

i . . .unavailability of ESFRS fans F- I5A and

F-15B as well as their CCF to zero

186 - Install diverse strainers L-1A, B, C Set failure'of CCF of all 3 SW pump 0.5 0.7 13,200 2,000,000 to all three SW pump discharge lines to strainer initiator asiw6ll as CCF of

prevent CCF strainers to operate to zero- .-: I ',. ! |,

187 - Automate start capability of Terry Set failure of operator to start the Terry 0.2 0.3 4,500 1,500,000 turbine .. ...- - turbine to zero•

189 - Automate emergency boration of Set the electrical and mechanical 0.9 0.5 18,700 2,000,000 RCS reactor trip probabilities to zero

-a

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a.

Ir
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Table H-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 2 (Cont.)

0

o % Risk Reduction LA SAMA Assumptions Total Benefit(S) Cost(S)

CDF Dose

190 - Install redundant parallel valve in Set failure of the RWST isolation valve 1.0 0.5 22,100 1,000,000 charging pump suction line to RWST AOV 2-CH-192 to open to zero

192 - install additional MOV on volume Set all failures relating to MOV 2-CH- 0.7 0.4 15,500 2,000,000 control tank outlet line similar to MOV- 501 to close to zero

CH-501 for closure to assure boric acid

flow to charging pump

193 - Install additional AFW bypass line Set failure of the AOVs 2-FW-43A/B to 1.0 0.5 21,700 1,000,000 with diverse check valves and regulating open, their CCF to open, their air

valves similar to check valves 2-FW-1 2A accumulators to operate, as well as

and 12B and regulating valves 2-FW- CCF of CVs 2-FW-12A/B to open to

43A and 43B to steam generators zero

o 195 - Install an MOV around existing Set failures of AOVs 2-RB-68.1A/B to 0.4 0.7 11,600 500,000 RBCCW/ESFRS AOV in each train to open and CCF to open to zero

improve reliability of ESF room coolers

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part of other licensees' analyses of SAMAs for operating reactors and advanced light-water

reactors. The cost estimates provided were in the form of rariges.; For purposes of evaluating

specific SAMAs, the staff selected the low end values from the range to represent the costs.

For some SAMAs, the costs appeared to be overestimated.' Therefore, the staff asked the'

applicant to justify the costs for those SAMAs that had significant benefits (NRC 2004). In

response to the staff's request, Dominion provided a discussion of the components and

activities that were considered in estimating the costs of those SAMAs for which the benefit was

determined to be $50,000 or more. The discussion included a description of the modification, if

any procedure changes and training would be required, and if any new instrumentation and

maintenance would be required (Dominion 2004b). The staff reviewed the costs and

subsequent explanations and found them to be reasonable and generally consistent with

estimates provided in support of other plants' analyses. -

The staff concludes that the' cost estimates provided by Dominion are sufficient 'and adequate

for use in the SAMA'evaluation. ' ' - . -

H.6 Cost-Benefit Comparison.

Dominion's cost-benefit analysis and the staff's review are described in the following sections.

H.6.1 Dominion Evaluation

The methodology used by Dominion was based primarily on NRC's guidance for performing

cost-benefit analysis, i.e., NUREG/BR-01 84, Regulatory Analysis 'Technical Evaluation

Handbook (NRC 1 997b). The guidance involves determining the net value for each SAMA

according to the following formula:

NetValue=(APE+-AOC+AOE+AOSC)-COE; ; - : --

; ., . . . ........... ~~~~~~.. * .-*..- -. ,...................., -. -,

where, - - -I .a .. '

APE = present value of averted public exposure ($)

AOC = present value of averted offsite property damage costs ($) ' :

AOE = present value of averted occupational exposure costs ($)

AOSC = present value of averted onsite costs ($) - -: .

COE = cost of enhancement ($).

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the

benefit associated with the SAMA and it is not considered cost-beneficial. Dominion's

derivation of each of the associated costs is summarized below. , -

- , ,Jo j{ * x-.

July 2005 -'- H-21 NUREG-1437, Supplement 22
Appendix H

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (Aperson-rem/year)

x monetary equivalent of unit dose ($2,000 per person-rem)

x present value conversion factor (10.76 based on a 20-year period with a

7-percent discount rate).

As stated in NUREG/BR-01 84 (NRC 1997b), it is important to note that the monetary value of

the public health risk after discounting does not represent the expected reduction in public

health risk due to a single accident. Rather, it is the present value of a stream of potential

losses extending over the remaining lifetime (in this case, the renewal period) of the facility.

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an

accident could occur at any time over the renewal period, and the effect of discounting these

potential future losses to present value. For the purposes of initial screening, Dominion

calculated an APE of approximately $375,000 for the 20-year license renewal period, which

assumes elimination of all severe accidents.

Averted Offsite Property Damage Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction

x offsite economic costs associated with a severe accident (on a per-event basis)

x present value conversion factor.

For the purposes of initial screening, which assumes all severe accidents are eliminated,

Dominion calculated an annual offsite economic risk of about $13,700 based on the Level 3 risk

analysis. This results in a discounted value of approximately $147,500 for the 20-year licenserenewal period.

Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction

x occupational exposure per core damage event

x monetary equivalent of unit dose

x present value conversion factor.

Dominion derived the values for averted occupational exposure from information provided in

Section 5.7.3 of the regulatory analysis handbook (NRC 1997b). Best estimate values provided

NUREG-1437, Supplement 22 H-22 July 2005
Appendix H

for immediate occupational dose (3300 person-rem) and long-term occupational dose -

(20,000 person-rem over a 10-year cleanup period) wereiused.-;'The present value of these

doses was calculated using the equations provided in the handbook in conjunction with a

monetary equivalent of unit dose of $2,000 per person-rem, a real discount rate of 7 percent,

and a time period of 20 years to represent the license renewal period.\ For the purposes'of

initial screening, which assumes all severe accidents are eliminated, Dominion calculated an

AOE of approximately $27,300 for the 20-year license renewal period.

Averted Onsite Costs (AOSC) -

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted

power replacement costs. Repair and refurbishment costs are considered for-recoverable

accidents only and not for severe accidents.' Dominion derived the values for AOSC based on

information provided in Section 5.7.6 of the regulatory analysis handbook (NRC 1997b).

Dominion divided this cost element into two parts - the Onsite'Cleanup and DecontaminationCost, also commonly referred to as averted cleanup and decontamination costs, and the

replacement power cost. -

Averted cleanup and decontamination costs (ACC) were calculated using the following formula:

ACC= Annual CDF reduction - -'

x present value of cleanup costs per core damage event -'.

x present value conversion factor. - - '-.. ' -

The total cost of cleanup and decontamination subsequent to a severe accident'is estimated in

the regulatory analysis handbook to be $1.5 billion (undiscounted). This value was converted to

present costs over a 10-year cleanup period and integrated over the term of the proposed:

license extension.' For the purposes of initial screening, which assumes-all severe accidents

are eliminated, Dominion calculated an ACC of approximately $831,700 for the 20-year license;

renewal period. : , - ,

Long-term replacement power costs (RPC) were calculated using the following formula:

RPC = Annual CDF reduction - . - - - -

x present value of replacement power-for a single event -

x factor to account for remaining service years for which replacement power is

required * . -

x reactor power scaling factor

Dominion based its calculatio'ns on the value of 870 megawatts .electric (MW[e]).. Therefore, - ,

Dominion applied a power scaling factor of 870 MW(e)/910 MW(e) to determine the

July 2005- H-23 i NUREG-1437, Supplement 22 -
Appendix H

replacement power cost. For the purposes of initial screening, which assumes all severe

accidents are eliminated, Dominion calculated the RPC to be approximately $540,300.

Using the above equations, Dominion estimated the total present dollar value equivalent

associated with completely eliminating severe accidents at MPS2 to be about $1,920,000.

Dominion's Results

The total benefit associated with each of the 44 SAMAs evaluated by Dominion is provided in

Table H-3. These values were determined based on the above equations for the various

averted costs together with the estimated annual reductions in CDF and population dose, and

then increased by a multiplier of 1.3 to account for additional risk reduction in external events.

The values for total benefit reported in Table H-3 include this multiplier. As a result, one of the

44 SAMAs was considered to be cost beneficial:

SAMA 3: Enhance loss of RBCCW procedure to ensure cool down of RCS prior to seal

LOCA. The resolution of this issue is expected to be either a new procedure or a

procedure modification that will require actions to prevent/mitigate a seal LOCA

upon loss of RBCCW.

As stated in the ER, Dominion is addressing SAMA 3 as part of a comprehensive industry

initiative in response to Generic Safety Issue 23, "Reactor Coolant Pump Seal Failure.'

Additionally, the CEOG is addressing this issue in CEOG Task 1136, 'Model for Failure of RCP

Seals Given Loss of Seal Cooling.' The SAMA is anticipated to be implemented before the

period of extended operation, and is being addressed under the current license

(Dominion 2004b).

In response to an RAI, Dominion assessed the applicability and feasibility of several SAMAs_

considered by another CE plant. As a result, Dominion eliminated all of the SAMAs questioned

except one - adding a capability to flash the field on the EDG (using a portable generator) to

enhance SBO event recovery. Dominion stated that this SAMA is not expected to be costbeneficial because it would likely require a plant modification to install a disconnect to allow the

connection of a portable (temporary) generator, as well as development of a new SAMG.

However, Dominion stated that if this SAMA can be accomplished via a SAMG without a

hardware modification, the SAMA would be cost-beneficial and will be implemented prior to the

period of extended operation (Dominion 2004b).

H.6.2 Review of Dominion's Cost-Benefit Evaluation

The cost-benefit analysis performed by Dominion was based primarily on NUREG/BR-01 84

(NRC 1997b) and was conducted in a manner consistent with this guidance.

NUREG-1437, Supplement 22 H-24 July 2005
Appendix H

In order to account for uncertainties in the cost estimates, Dominion applied a factor of two

margin in assessing whether SAMAs were cost-beneficial, i.e.,; a'SAMA was considered to be

cost-beneficial if the total benefit is within a factor of two of the estimated cost. The staff asked

the applicant to consider the impact of uncertainty in the CDF (NRC 2004). In response,

Dominion stated that CDF uncertainty calculations are not available in the current version of the

Millstone PRA model. However, based on a review of recent SAMA analyses in support of

license renewal, the 95" percentile CDF ranged from a factor of 2.0 to a factor of 6.4 greater

than the mean CDF. Dominion stated that, in order to provide conservatism, it compared the

costs to twice the calculated benefit.- Dominion further indicated that most of the benefit

calculations were performed in a bounding fashion, i.e., the SAMA is completely effective, and

that such estimates would be substantially less if a more realistic analysis were performed for

each SAMA (Dominion 2004b).

The staff questioned the approach of increasing the benefit (based on internal events) by

30 percent to account for external events (NRC 2004). In response to the RAI,-Dominion stated

that a multiplier of 1.3 was used because the external events analyses are not readily'

quantifiable (Dominion 2004b). The use of a multiplier on the benefits obtained from the

internal events PRA to incorporate the impact of external events makes the implicit assumption

that the consequences from external events sequences are the same as the consequences

; from internal events sequences. To demonstrate the robustness of the analysis, Dominion -

performed a sensitivity study that increased the assumed contribution from external events from

30 percent to 60 percent of the internal event benefits; The result was that the increased

benefit exceeded the lower bound of the cost estimate range for only SAMA 3, which was

already determined to be cost-beneficial. Therefore, Dominion concluded that the use of the

1.3 multiplier is acceptable. -

Dominion assessed the impact of other factors on the analysis results, such as the contribution

of external event initiators that were not explicitly included in the MPS2 risk profile,-the use of a

3 percent discount rate as compared to the 7 percent discount rate used in the baseline

calculations, as well as a 15-percent real discount rate (Dominion 2004a). These sensitivity'

cases resulted in an increase in the benefit calculation of about 30 percent or less. These

analyses did not change Dominion's conclusion that none of the candidate SAMAs would be

cost-beneficial except as noted above. In addition, Dominion performed sensitivity analyses

that addressed assumptions made in other parts of.the cost-benefit analysis, including

meteorological data,-source term, and evacuation., Dominion also considered the sensitivity to

the impact of current and future fuel management practices. These sensitivity cases are:

bounded by the 3-percent discount rate sensitivity study.

The staff notes that accounting for each of these factors would tend to increase the benefit as

compared to the baseline case analysis. However, the calculated benefits used in the baseline

analysis are generally over estimated and, therefore, conservative. -,The staff concludes that the

July2OO5..;,. H-25- NUREG-1437, Supplement 22
Appendix H

use of the factor of two to account for uncertainties, coupled with the fact that the calculated

benefits are generally conservative, provides a reasonable treatment of uncertainties and is

adequate for the SAMA evaluation.

The staff questioned Dominion about lower cost alternatives to some of the SAMAs evaluated,

including the use of a direct-drive diesel AFW pump (NRC 2004). In response, Dominion

identified and evaluated several lower-cost alternatives to those considered in the ER. These

alternatives included 1) installing a RBCCW header cross-tie, 2) using the hydrogen purge

system as an unfiltered hardened containment vent, 3) using the existing systems to flood the

reactor cavity, 4) providing reactor water storage tank makeup, and 5) using the diesel fire

pump as a backup to the turbine-driven AFW pump. Dominion concluded that all of the

alternatives considered are either covered by an existing procedure or SAMG, or could be

instituted following evaluation and guidance by the Technical Support Center. With regard to

the specific lower cost alternative involving a direct-drive diesel AFW pump, Dominion stated

that the alternative would not be viable at MPS2 due to room and ventilation constraints as well

as costs. Dominion further stated that MPS2 has a SAMG for using the diesel fire pump to

provide water to the AFW system (Dominion 2004b).

The staff also questioned Dominion about several other candidate SAMAs that were found to

be potentially cost-beneficial at another CE plant but not addressed by MPS2 analysis

(NRC 2004). In response, Dominion provided an evaluation of the applicability and/or costs and

benefits for these SAMAs at MPS2. Based on this assessment, all of the SAMAs were - -

dismissed except one involving adding a capability to flash the field on the emergency diesel

generator to enhance SBO event recovery. Dominion stated that the ability to flash the field on

the EDG (using a portable generator) to enhance SBO event recovery would likely require a

plant modification to install a disconnect to allow the connection of a portable (temporary)

generator, as well as a new SAMG. However, If a hardware modification is not required, then

the SAMA would be cost-beneficial. Dominion committed to complete its evaluation of this

SAMA and develop a SAMG prior to the period of extended operation if it found to be costbeneficial (Dominion 2004b).

The staff concludes that, with the exception of the two potentially cost-beneficial SAMAs

discussed above, the costs of the SAMAs would be higher than the associated benefits. This

conclusion is supported by uncertainty assessment and sensitivity analysis and upheld despite

a number of additional uncertainties and nonquantifiable factors in the calculations, summarized

as follows:

A factor of two was used to account for uncertainties. Even if a higher factor were

considered to reflect a larger uncertainty in CDF, e.g., a factor of five, only two additional

SAMAs would be close to becoming cost-beneficial - SAMAs 150 and 175. However,

these SAMAs involve hardware modifications that are not expected to be cost-beneficial

under more realistic assumptions regarding risk reduction.

NUREG-1437, Supplement 22 H-26 July 2005
Appendix H

*- ,Sensitivity calculations were performed with respect to the discount rate (3 percent anid

.15 percent) and various MACCS2 parameters, including meteorological data, evacuation

I speed, evacuation delay time, and source terms. The results of these sensitivity studies

showed that none of the risk benefits were increased by more than 30 percent. Since this is

less than the margin between cost and benefit for the SAMAs considered, the uncertainties

in these parameters would not alter the conclusions.

H.7 Conclusions

Dominion compiled a list of 196 SAMA candidates using the SAMA'analyses'as submitted in

support of licensing activities for other nuclear power plants, NRC and industry documents

discussing potential plant improvements, plant-specific insights from the MPS2 PRA model. A

qualitative screening removed SAMA candidates that (1) were not applicable at MPS2 due to

design differences, (2) had already been implemented at MPS2, or (3) were related to RCP seal

vulnerability. A total of 152 SAMAs were eliminated, leaving 44 for further evaluation:' '

For the remaining SAMA candidates, a more detailed design and cost estimate were developed

as shown in Table H-3. The cost-benefit analyses showed that one of the SAMA candidates

was cost-beneficial.' Upon completion of a 3-percent discount rate sensitivity study, as well as

other sensitivity studies, no additional SAMA candidates were determined to be cost-beneficial.,

To account for uncertainties, Dominion compared the costs of the SAMA with twice the

calculated benefit. As a result, no additional SAMAs were cost-beneficial.

The staff reviewed the Dominion analysis and concluded that the methods used and the

implementation of those methods were sound. -The treatment of SAMA benefits and costs, the

generally large negative net benefits, and the inherently small baseline risks support the

general conclusion that the SAMA evaluations performed by Dominion are reasonable and

sufficient for the license renewal submittal. The unavailability of an external event PRA model

precluded a quantitative evaluation of SAMAs specifically aimed at reducing risk of external

event initiators; however,-improvements that have been realized as'a result of the IPEEE

process and the inclusion of a multiplier to account for external events would minimize the

likelihood of there being cost-beneficial enhancements in this area.

Based on its review of the Dominion SAMA analysis, the staff concurs that none of the -

candidate SAMAs are cost-beneficial, except for SAMA 3 and possibly an additional SAMA

involving adding a capability to flash the field on the EDG (using a portable generator) to

enhance SBO event recovery. This is based on conservative treatment of costs and benefits.-

This conclusion is consistent with the low residual level of risk indicated in the MPS2 PRA and

the fact that MPS2 has already implemented many of plant improvements identified from the

IPE and IPEEE processes. Although the one SAMA candidate is cost-beneficial and a second

SAMA may be cost-beneficial if it can be implemented via procedural enhancements, neither of';

July 2005 H-27 - NUREG-1437, Supplement 22
Appendix H

these SAMAs relates to adequately managing the effects of aging during the period of extended

operation. Therefore, they need not be implemented as part of the license renewal pursuant to

10 CFR Part 54.

H.8 References

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for

Renewal of Operating Licenses for Nuclear Power Plants."

Dominion Nuclear Connecticut, Inc. (Dominion). 2004a. Applicant's Environmental

Report-Operating License Renewal Stage, Millstone Power Station, Units 2 and 3. Dominion

Nuclear Connecticut, Inc., Richmond, Virginia. January 2004.

Dominion Nuclear Connecticut, Inc. (Dominion). 2004b. Letter from Leslie N. Hartz, Dominion,

to United States Nuclear Regulatory Commission Document Control Desk. Subject: Dominion

Nuclear Connecticut, Inc., Millstone Power Station, Units 2 and 3, Response to Request for

Additional Information, License Renewal Applications. (August 13, 2004).

Dominion Nuclear Connecticut, Inc. (Dominion). 2004c. Email from Richard J. Gallagher,

Dominion, to Richard Emch, NRC. Subject: Clarification of RAI Responses. (September 16,

2004).

Northeast Nuclear Energy Company (NNECO). 1993. Letter from S. E. Scace, NNECO, to

U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Millstone Nuclear

Power Station, Unit 2, Response' to Generic Letter 88-20 Individual Plant Examination for

Severe Accident Vulnerabilities Summary Report. (December 30, 1993).

Northeast Nuclear Energy Company (NNECO). 1995. Letter from D. B. Miller, NNECO, to U.S.

Nuclear Regulatory Commission Document Control Desk. Subject: Millstone Nuclear Power -

Station, Unit 2, Response to Generic Letter 88-20, Supplements 4 and 5 Individual Plant

Examination for External Events Summary Report. (December 29, 1995).

U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, "Individual Plant

Examination for Severe Accident Vulnerabilities." (November 23,1988).

U.S. Nuclear Regulatory Commission (NRC). 1990. NUREG-1 150, Severe Accident Risks: An

Assessment for Five U.S. Nuclear Power Plants, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1991. NUREG-1407, ProceduralandSubmittal

Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident

Vulnerabilities, Washington, D.C.

NUREG-1437, Supplement 22 H-28 July 2005
Appendix H

U.S. Nuclear Regulatory Commission (NRC). 1996. Letter from Daniel G. McDonald, U.S.

NRC, to Ted C. Feigenbaum, Northeast Utilities Service Company. Subject: NRC Staff's

Evaluation of the Individual Plant Examination (IPE) Submittal for Millstone Nuclear Power

Station, Unit No. 2 (B1 4702), (TAC NO. M74433). (May 21, 1996).

U.S. Nuclear Regulatory Commission (NRC). 1997a. NUREG-1560, Individual Plant

Examination Program: Perspectives on Reactor Safety and Plant Performance, Washington,

D.C. rie.. - -

U.S. Nuclear Regulatory Commission (NRC). 1997b. NUREG/BR-0184, Regulatory Analysis

Technical Evaluation Handbook, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997c. NUREG/CR-6525, SECPOP90: Sector

Population, Land Fraction, and Economic Estimation Program, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2001. Letter from Jacob I. Zimmerman, U.S.

NRC, to R. G. Lizotte, Northeast Nuclear Energy Company. Subject: Millstone Nuclear Power

Station, Unit No. 2- Individual Plant Examination of External Events (IPEEE) (TAC NO.

M83642). (January 12,2001).

U.S. Nuclear Regulatory Commission (NRC). 2004. Letter from Richard L. Emch, Jr., NRC, to

David A. Christian, Dominion. Subject: Request for Additional Information (RAI) Regarding

Severe Accident Mitigation Alternatives for the Millstone Power Station, Units 2 and 3 (TAC

NOS. MC1 827 and MC1828). (June 22, 2004).

U.S. Department of Agriculture (USDA). 1998. 1997 Census of Agriculture, National

Agriculture Statistics Service, 1998.

July 2005 H-29 NUREG-1 437, Supplement 22
Appendix I

NRC Staff Evaluation of Severe Accident Mitigation Alternatives

(SAMAs) for Millstone Power Station, Unit 3, in Support of the License

Renewal Application Review
Appendix I

NRC Staff Evaluation of Severe Accident Mitigation

Alternatives (SAMAs) for Millstone Power-Station, Unit 3, in

Support of the License Renewal Application Review

1.1 Introduction

Dominion Nuclear Connecticut, Inc. (Dominion) submitted an'assessment of SAMAs for '

Millstone Power Station, Unit 3 (MPS3) as part of the Environmental Report (ER) (Dominion

2004a). This assessment was based on the most recent MPS3 Probabilistic Risk Assessment

(PRA) available at that time, a plant-specific offsite consequence analysis performed using the'

MELCOR Accident Consequence Code System 2 (MACCS2)'computer program, and insights

frohm the MPS3 Individual Plant Examination (IPE) (NNECO'1990) and Individual Plant

Examination of Extemal Events (IPEEE) (NNECO1991). In identifying and evaluating potential

SAMAs, Dominion considered SAMA analyses performed for other operating plants, as well as,

industry and NRC documents that discuss potential plant improvements, such as NUREG-1560'

(NRC 1997a). Dominion identified 185 potential SAMA candidates. This list was reduced to 52

unique SAMA candidates by eliminating SAMAs that were not applicable to MPS3 due to design

differences, had already been implemented, or were related to a reactor coolant pump (RCP)

seal loss of coolant accident (LOCA)' Dominion assessed the costs and benefits associated

with each of the remaining'SAMAs and concluded in the ER that none'of the candidate SAMAs

evaluated would be cost-ben'eficial for MPS3. v -;- - - , . . ->>*?'*

Based on a review of the SAMA assessment, the NRC issued a request for additional

information (RAI) to Dominion by letter dated June 22, 2004 (NRC 2004). Key questions

concerned the following areas: peer reviews of the PRA, 'dominant risk contributors'at MPS3

and the SAMAs that address'these'corntributors, the mapping "of Level 1 PRA results into the

Level 2 analysis, the potential impact of external event initiators and uncertainties on the

assessment results, detailed information on some specific candidate SAMAs, and consideration

of additional SAMAs. Dominion submitted additiorinl infoirmation bVletter dated

August 13,2004 (Dominion 2004b) including summaries of peer review comments and their

impact on the SAMA analysis; importance measures and corresponding SAMA candidates;

information regarding the Level 2 analysis; informatio'n related to the resolution of IPEEE

outliers and the impact of external events in the risk anaiysis, an assessment of the' impact of

uncertainties; and additional information 'regarding specific SAMAs. Dominioin's responses

July 2005' 1-1 NUREG-1 437, Supplement 22
Appendix I

addressed the staff's concerns. As a result, Dominion identified one SAMA that would be costbeneficial if it can be accomplished via a severe accident management guideline, without a

hardware modification.

An assessment of SAMAs for MPS3 is presented below.

1.2 Estimate of Risk for MPS3

Dominion's estimates of offsite risk at MPS3 are summarized in Section 1.2.1. The summary is

followed by the staff's review of Dominion's risk estimates in Section 1.2.2.

1.2.1 Dominion's Risk Estimates

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA

analysis: (1) the MPS3 Level 1 and 2 PRA model, which is an updated version of the IPE

(NNECO 1990), and (2) a supplemental analysis of offsite consequences and economic

impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The

identification of candidate SAMAs was based on Revision 4 of the PRA model, dated October

1999; the quantification of SAMA benefits was based on an October 2002 update of the PRA

(referred to as Revision 0, using a new naming convention) (Dominion 2004b). The scope of

the MPS3 PRA does not include external events.

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is

approximately 2.57 x 1 o5 per year. The CDF is based on the risk assessment for internally

initiated events. Dominion did not include the contribution to risk from external events or

internal flooding within the MPS3 risk estimates; however,- it did account for the potential risk

reduction benefits associated with external events by increasing the estimated benefits for

internal events by 60 percent. This is discussed further in Sections 1.4 and 1.6.2.

The breakdown of CDF by initiating event is provided in Table 1-1. As shown in this table,

LOCAs, RCP seal LOCAs, transients including anticipated transients without scram (ATWS),

and loss of offsite power (LOOP) are dominant contributors to the CDF. Bypass events

(i.e., steam generator tube rupture [SGTR] and interfacing systems LOCA [ISLOCA])]

contribute less than 5 percent to the total internal events CDF. The contribution to CDF from

internal floods is estimated to be 8.6 x 10' per year (NNECO 1990).

The Level 2 PRA model is based on the Level 2 model used in the Millstone Unit 3 Probabilistic

Safety Study (NNECO 1983) and the IPE (NNECO 1990). The result of this analysis is a set of

formulae for transforming the MPS3 plant damage state (PDS) frequencies into containment

NUREG-1437, Supplement 22 1-2 July2005

I
Appendix I

release category frequencies. The source terms for each release category (also termed the

source term category) were obtained from the results of MAAP 4 analyses of the dominant core

damage sequences in the IPE. -:-

Table i-1. MPS3 Core Damage Frequency -.

- . Initiating Event or , : CDF ~ % Contribution to

Accident Class (Per Year) CDF

RCP Seal LOCA - - 5.66 x 1046 22.0

Transients -. _ -4.04 x 1045 ' -- 15.7 - -

LOCAs 3.42 x 104 13.3

LOOP 2.77 x 104 10.8

ATWS 2.39 x 104 9.3

Steamline break inside containment 2.31 x 104 9.0

Station blackout (SI80) 1.78 x 104 6.9

Total loss of service water 1.28 x 104 5.0

SGTR 1.00x 104 3.9

Loss of one vital DC bus . _ 4.18 x 10-7 . . 1.6

Steamline break outside containment - 3.79 x.107_ _.... - 1.5 '

ISLOCA 2.21x107 - 0.9

Instrument tube LOCA 5.04 x 10a8 . 0.2

Total CDF 2.57 x 10- 100

The offsite consequences and economic impact analyses use the MACCS2 code to determine

the offsite risk impacts on the surrounding environment and public. Inputs for this analysis

include plant-specific and site-specific input values for core radionuclide inventory, source term

and release characteristics, site meteorological data, projected population distribution within a

80 kilometer (km) (50-mile [mi]) radius for the year 2040, emergency response evacuation

modeling, and economic data.. The core radionuclide inventory is based on the generic

pressurized water reactor (PWR) inventory provided in the MACCS2 manual, adjusted to

represent the MPS3 power level of 3411 megawatts thermal (MW[t]). The magnitude of the

onsite impacts (in terms of clean-up and decontamination costs and occupational dose) is

based on information provided in NUREG/BR-0184 (NRC- 1997b).

In the ER, Dominion estimated the dose to the population within 80 km (50 mi) of the MPS3 site*

to be approximately 0.128 person-sieverts (person-Sv) (12.8 person-roentgen equivalent man |

[person-rem]) per year. The breakdown of the total population dose by containment release

July 2005:. 1-3 -\ NUREG-1437, Supplement 22
Appendix I

mode is summarized in Table 1-2. Late-containment failures dominate the population dose risk,

at MPS3, followed by SGTR and ISLOCAs. Early failures and containment isolation failures are

each indicated to be zero contributors to risk. As indicated in the response to an RAI, these

release modes were deleted from the IPE model because of low contribution (i.e., <0.1 percent)

(Dominion 2004b).

Table 1-2. Breakdown of Population Dose by Containment Release Mode (Unit 3)

Population Dose

Containment Release Mode (Person-rem(a) Per Year) % Contribution

Late failure 6.60 51.5

SGTR 2.77 21.6

ISLOCA 2.23 17.4

Intermediate failure 0.93 7.2

No containment failure 0.24 1.9

Basemat failure 0.05 0.4

Early failure 0 0

Containment isolation failure 0 0

Total Population Dose 12.8 100

(a) One person-rem = 0.01 person-Sv

1.2.2 Review of Dominion's Risk Estimates

Dominions's determination of offsite risk at MPS3 is based on the following three major

elements of analysis:

* the Level I and 2 risk models that form the bases for the 1990 IPE submittal (NNECO

1990) and the 1991 IPEEE submittal (NNECO 1991),

* the major modifications to the IPE models that have been incorporated in the MPS3

PRA, and

* the MACCS2 analyses performed to translate fission product source terms and release

frequencies from the Level 2 PRA model into offsite consequence measures.

Each of these analyses was reviewed to determine the acceptability of Dominion's risk

estimates for the SAMA analysis, as summarized below.

NUREG-1437, Supplement 22 1-4 July 2005
Appendix I

The staff's review of the MPS3 IPE is described in an NRC report dated May 5,1992-

(NRC 1992). Based on a review of the original IPE submittal, the staff concluded that IPE

submittal met the intent of Generic Letter 88-20 (NRC 1988); that is, the IPE was of adequate"

quality to be used to look for design or operational vulnerabilities. The staff did, however,

identify a number of weaknesses in the IPE analysis. In response to an RAI, Dominion

indicated that all of these weaknesses have been addressed in the PRA used for the'SAMA

analysis (Dominion 2004b). -- -

: , ,~~~~ . , , . .- . L_.......................................

A comparison of internal events risk profiles between the IPE and the PRA used in the SAMA

analysis indicates a decrease of approximately 3x1 O"per year in the total CDF (from 5.52 x .1 0'5

per year to 2.57 x 1 05 per year).- -The change is a net result of modeling improvements and

some minor plant design changes that have been implemented at MPS3 since the IPE was

submitted. A summary listing of those changes that resulted in the greatest impact on the total

CDF was provided in the ER and in response to an RAI (Dominion 2004a, 2004b), and include

the following: -

* modified the SBO logic to consider the SBO diesel battery capacity limitation and

hardware/procedural changes implemented to cope with the condition, "I

* incorporated the latest revision of the MPS3 plant-specific database,

* modified the SBO event tree to incorporate the results of core uncovery time based on the

most probable RCP seal LOCA leakage rates,

* incorporated the accident sequence analysis for LOCAs, SBO, ATWS, and total loss of

service water (SW), x. -

* removed initiating events associated with common cause failure (CCF) to run 3and 4 SW

.-pumps, based on industry guidance on identification of CCF-groupings. -

:- . . *. .; ;- i. . - ' . .1. I.; i . ; - . , - : - ... : .

An additional change that has a significant impact on the CDF value is the truncation'value

used in the PRA model. For the PRA version used for the SAMA analysis, Dominion used a

truncation value of 1.0 x 1 0-1. Jn contrast, use of a truncation value of 2.0 x 1 '.9 (as used in

previous versions of the PRA) would result in a CDF of about 2.04 x 1O 5per year rather than a

value of 2.57 x 10-5 per year as used in the SAMA analysis:..:: -- . --

The IPE CDF value for MPS3 is comparable to the CDF.yalues reported in the IPEs for other

Westinghouse PWR plants. Figure 11.6 of NUREG-1560 shows that the IPE-based total

internal events CDF for four-loop Westinghouse plants ranges from 4 x 1 04 to 3 x 1 per year

(NRC 1997a). It is recognized that other plants have reduced the values for CDF subsequent.-. -

July 2005 l-5 NUREG-1437, Supplement 22
Appendix I

to the IPE submittals due to modeling and hardware changes. The current internal events CDF

results for MPS3 remain comparable to the results for other plants of similar vintage and

characteristics.

The staff considered the peer review performed for the MPS3 PRA, and the potential impact of

the review findings on the SAMA evaluation. In response to an RAI, Dominion described the

external peer review, which was the Westinghouse Owners Group Peer Review performed in

September 1999 (Dominion 2004b). The review resulted in four Level A facts and observations

(extremely important and necessary) and 41 Level B facts and observations (important and

necessary but may be delayed until next update). Two of the Level A and 24 of the Level B

recommendations are yet to be incorporated. The Level A recommendations not yet

incorporated are in the areas of accident sequence analysis and human reliability analysis.

Both involve the completeness of the treatment of pre-initiator human errors. The Level B

recommendations not yet incorporated affect essentially all PRA elements. Dominion has

reviewed all of the unresolved facts and observations and concluded that they have negligible

impact on the SAMA analysis (Dominion 2004b). The staff has also reviewed Dominion's

assessment of the impacts of the outstanding peer review comments and has come to the

same conclusion.

Given that (1) the MPS3 PRA has been peer reviewed and the potential impact of the peer

review findings on the SAMA evaluation has been assessed, (2) Dominion satisfactorily

addressed staff questions regarding the PRA (Dominion 2004b), and (3) the CDF falls within

the range of contemporary CDFs for Westinghouse plants, the staff concludes that the Level 1

PRA model is of sufficient quality to support the SAMA evaluation.

The licensee included external events in the IPE submittal in August 1990 (NNECO 1990). The

external events analysis in the IPE/IPEEE is taken from the uMillstone Unit 3 Probabilistic Safety

Study" (NNECO 1983). This submittal and several updates were reviewed extensively by the

NRC staff as documented in NUREG-1 152 (NRC 1985a) and by contractors'as documented in

NUREG/CR-4142 (NRC 1985b) and NUREG/CR-4143 (NRC 1985c). While the IPEEE

submittal did not identify any vulnerabilities to severe accident risk from external events, a

number of minor improvements were identified. In a letter dated May 26, 1998, the staff

concluded that the IPEEE submittal met the intent of Supplement 4 to Generic Letter 88-20,

and that the licensee's IPEEE process is capable of identifying the most likely severe accidents

and severe accident vulnerabilities (NRC 1998).

'The seismic PRA performed for MPS3 resulted in a seismic CDF of 9.1 x 1i0 per year. The

dominant contributor to this was seismically induced SBO. In NUREG-1 152, the staff

recommended that two alternatives be further evaluated (improve the anchorage' system for the

emergency diesel generator lube oil coolers and add a manually-operated, AC independent

containment spray system). In response to an RAI, Dominion indicated that the first of these

NUREG-1437, Supplement 22 1-6 July 2005
Appendix I

alternatives has been implemented at MPS3. Dominion provided additional information

concerning the costs related to the other alternative. Dominion concluded that, because of

adequate seismic margins and the complexity associated with increasing the seismic capacity

of a structures and components, no cost-effective SAMAs could be identified (Dominion 2004b).

The staff agrees that it is unlikely that cost-effective SAMAs to further reduce seismic risk will

exist. This is due to high cost of structural modifications compared to the benefits expected.

The fire PRA performed for MPS3 resulted in a fire CDF of 4.9 x 104- per year. The dominant

contributors are fires in the charging and component cooling pump area, cable spreading area,

and control room. The dominant fire areas and the associated CDF for those areas are:

Fire Area Description - O:CDF(ervear)

AB-1 Charging and component cooling pumps area,- -1.07 x 1 0-6

CB-8 .-Cable spreading area - ; . 9.89 x 107

CB-9 Control room - . 7.28x107

A subsequent modification to the fire detection system in the cable spreading area has reduced

the CDF in this area to 3.75 x 107 per year (Dominion 2004b). - - * :

- _ . 4_,fs;,r .5, -'4

In a RAI, the staff asked Dominion to explain, for each important fire area, what measures were

taken to further reduce risk, and explain why these CDFs cannot be further reduced in a

cost-effective manner (NRC 2004).. For each area, Dominion provided a discussion of the

major fire contributors assumed in the analysis and the existing plant features to address fire

events. Dominion identified several improvements that have been implemented to address

fire-related issues. Dominion also discussed the potential for further cost-effective hardware

changes to address the fire-related matters listed above, including improvements to detection,

systems, enhancements to suppression capabilities, and changes that would improve cable

separation and train separation (Dominion 2004b). Dominion concluded that no further

modifications would be cost-effective for any of the fire areas.

- . . , ,,.. . , t. - . . . - 4 .if .

The staff notes that although additional SAMAs to reduce the fire risk contributors might be

viable,-given the low level of risk from fires and the improvements that have already been

implemented, it is unlikely that further modifications would both substantially reduce risk and

remain cost-beneficial.

>, ,- ,, - . '-, " .'' , ', .' -' -; -' - i_;-:';!f-- . . ' - . -

In the SAMA analysis, Dominion accounted for the additional risk contribution due to external

events by increasing the benefit derived from the internal events model by 60 percent. This

was determined by summing the following CDFcontributions: ; .- - -

I; .' ' . . ' ', ' t -, . : , ' , _ , - '. . , - . 5 . ' ,' el t' ,. ;.'

.~~~~ ~ ~ . .,* ~ .- . ..-. , , -*

I

I

July 2005 . 1-7. NUREG-1 437, Supplement 22
Appendix I

* Fire 4.9 x 1 04 per year

* Internal flooding 0.9 x 10.6 per year

* Seismic 9.1 x 10.8 per year

The fire contribution is discussed above. The internal flooding CDF of 8.6 x 10i7 per year was

obtained directly from the MPS3 IPE (NNECO 1990). This value is the result of a bounding,

screening-type analysis. The total external events CDF from the above is 1.49 x 10-5 per year,

or approximately 58 percent of the CDF due to internal events. This was rounded up to

60 percent for the SAMA analysis.

The MPS3 Level 2 PRA analysis is based on the IPE (NNECO 1990). The result of this

analysis is a set of formulae for transforming the MPS3 plant damage state (PDS) frequencies

into containment release category frequencies. This is described in Section 1.2.3 of the ER

(Dominion 2004a), and further clarified in response to RAls (Dominion 2004b, 2004c). The

formulae and the release category frequencies are provided in Tables 1.2-4 and 1.2-6 of the ER,

respectively (Dominion 2004a). The release fractions for each release category were obtained

from MAAP 4 analysis for the dominant sequences in the IPE and are provided in Table 1.1-2 of

the ER (Dominion 2004a). In response to an RAI concerning the use of IPE dominant

sequences to determine the release fractions used in the SAMA analysis, Dominion provided a

discussion and a comparison of the PDSs and release categories for the IPE and SAMA

analyses (Dominion 2004b). The staff reviewed Dominion's source term estimates for the

major release categories and found the release fractions to be within the range of the release

fractions for like plants. Dominion also provided results of several sensitivity studies relative to

the source term and release characteristics including doubling the plume release height,

doubling the duration of source term release time, and varying source term release fractions.

The results showed that these parameter variations had only a minor impact (less than

20 percent) on the estimated dollar benefits for the candidate SAMAs. The staff concludes that

the process used for determining the release category frequencies and source terms is

reasonable and appropriate for the purposes of the SAMA analysis.

During the staff's review of the Level 2 model, the staff identified an error in the formulae used

to translate PDS frequencies into release category frequencies. Dominion confirmed the error

and determined that it resulted in a slight overestimation of the benefits for candidate SAMAs,

which is conservative for the cost-benefit analysis (Dominion 2004b).

As discussed previously, the fission product inventory used in the consequence analysis is

based on a fission product inventory scaled from generic information. In response to an RAI

concerning the impact of current and future fuel management practices, Dominion described a

conservative bounding analysis of core fission product inventory considering a range of

enrichments and bumups (Dominion 2004b). Using this inventory would result in a 28-percent

increase in total benefit from eliminating all risk. Using realistic mid-life or average conditions

NUREG-1437, Supplement 22 I-8 July 2005
Appendix I

would result in a smaller increase in the maximum benefit. The'staff concludes that the scaling

based on the plant-specific power level yields'suff iciently accurate and reasonable results for

the dose assessment.

The staff reviewed the process used by Dominion to extend the containment performance'

(Level 2) portion of the PRA'to' an assessment of offsite consequences (essentially a Level 3

PRA). 'This included con'sideratiorn of the mrajdr input assuriptions used in the offsite

consequence analyses. The MACCS2 code was utilized to estiimate offsite consequences.

Plant-specific input to the-code includes the source terms for each release category and the

MPS3 reactor core radionuclide inventory (both discussed above), site-specific meteorological

data, projected population distribution within a 80 km (50 mile) radius for the year 2040, and'

emergency evacuation' modeling.' This information is provided in Appendix G to the ER

(Dominion, 2004a). .

Dominion used site-specific meteorological data processed from hourly measurements for the

2000 calendar year as input to the MACCS2 code. -The hourly data (wind direction, wind speed,

and stability class) were collected from the onsite meteorological tower. Precipitation data were

recorded at the Green Airport near Providence, Rhode Island, the closest weather station toMillstone. Morning and afternoon mixing height values were obtained from the National

Climatic Data Center. The applicant also considered the impact on SAMA benefits of using

meteorological data for 1998 and 1999. .The results of .these sensitivity cases showed that the

benefits increased by an average of about five percent. The staff considers the use of the 2000

data in the base case to be reasonable. - .- - - --

The population distribution the applicant used as input to the MACCS2 analysis was estimated

* for the year 2040, based primarily on SECPOP90 (NRC 1997c).; U.S. Census Bureau Year,:-;

2000 population data, projected to year 2040, was then used to update the SECPOP90 -

population data (Dominion 2004a). The staff questioned the difference between the use of

SECPOP90 and SECPOP2000, and what the impact would be if the latter was used. In

response, Dominion noted that the expected impact of using SECPOP2000 would be negligible

since census data from 2000 was used to update the SECPOPp9 file. The staff considers the r

methods and assumptions for estimating population reasonable and acceptable for purposes of

the SAMA evaluation.

The emergency evacuation model was modeled as a single evacuation zone extending out

16 km (10 mi) from the plant. It was assumed that 100 percent of the population would move at N

an average speed of approximately 1.49 meters per second with a .delayed start time of 7200

seconds from the offsite alarm reference time point (Dominion 2004a). Dominion performed

sensitivity studies exploring the impact of the fraction of population that evacuates and the

evacuation speed. The results demonstrated that the total dose and economic cost results are

July 2005 ' 1_9 NUREG-1437, Supplement 22
Appendix I

insensitive to these parameters (Dominion 2004a). The staff concludes that the evacuation

assumptions and analysis are reasonable and acceptable for the purposes of the SAMA

evaluation.

Much of the site-specific economic data were provided from SECPOP90 (NRC 1 997c) by

specifying the data for counties surrounding the plant to a distance of 50 miles. The

SECPOP90 input file was updated to 2001 using cost of living and other data from the Bureau

of the Census and the Department of Agriculture (Dominion 2004). The agricultural economic

data were updated using available data from the 1997 Census of Agriculture (USDA 1998).

The staff concludes that the methodology used by Dominion to estimate the offsite,

consequences for MPS3 provides an acceptable basis from which to proceed with an

assessment of risk reduction potential for candidate SAMAs. Accordingly, the staff based its

assessment of offsite risk on the CDF and offsite doses reported by Dominion.

1.3 Potential Plant Improvements

The process for identifying potential plant improvements, an evaluation of that process, and the

improvements evaluated in detail by Dominion are discussed in this section.

1.3.1 Process for Identifying Potential Plant Improvements

Dominion's process for identifying potential plant improvements (SAMAs) consisted of the

following elements:

* review of the most significant basic events from the MPS3 PRA Model, Rev. 4

(October 1999),

* review of items not already evaluated and/or implemented during the IPE and IPEEE,

* review of SAMA analyses submitted in support of original licensing and license renewal

activities for other operating nuclear power plants, and

* review of other NRC and industry documentation discussing potential plant improvements.

Based on this process, an initial set of 185 candidate SAMAs was identified. In Phase 1 of the

evaluation, Dominion performed a qualitative screening of the initial list of SAMAs and

eliminated SAMAs from further consideration using the following criteria:

* the SAMA is not applicable at MPS3,

NUREG-1 437, Supplement 22 1-10 July 2005
Appendix I

* the SAMA has already been implemented at MPS3, or the MPS3 design meets the intent of

the SAMA, or -

.-the SAMA is related to a RCP seal vulnerability stemming from charging pump dependency

on component cooling water (CCW). (MPS3 does not hIave this vulnerability because the:

charging pumps do not rely on CCW for RCP seal injection.)

Based on this screening, 133 SAMAs were eliminated leaving 52 for further evaluation. Of the

SAMAs eliminated, 47 were eliminated because they were not applicable, 77 were eliminrated'

because they already had been implemented, and 9 were eliminated because they were related

to RCP seal vulnerability. -A cost estimate was prepared for'each'of the 52 remaining

candidates to focus on those that had a possibility of having a net positive benefit.. To account'

for the potential impact of external events, the estimated benefits based on internal 'events of

each SAMA were multiplied by a factor of 1.6 for all SAMAs except those related to ISLOCA

and SGTR-initiated events.

The 52 SAMAs were evaluated and subsequently eliminated, -as described in Sections 1.4 and'

1.6.1 below.' - - -

1.3.2 Review of Dominion's Process

Dominion's efforts to identify potential SAMAs focused primarily on areas associated with

internal initiating events. 'The initial list of SAMAs generally addressed the accident categories''

that are dominant CDF contributors or issues that tend to hav-e 'a'large impact on a number of

accident sequences at MPS3' -.

The preliminary review of Dominion's SAMA identification p'rocess raised some concerns

regarding the completeness of the set of SAMAs identified and the inclusion of plant-specific

risk contributors. The staff requested additional information regarding the top 30 cut sets and

certain sequences (NRC 2004). In response to the RAI, D6miinion provided a listing of the top '

contributors to'risk, the associated plant damage state, and across-reference between the top

contributors to risk from a later version of the PRA and the'SAMAs'that addressed those' risk

contributors (Dominion 2004b).- l - - ' E , -

The staff noted that Dominion based the SAMA identification process on PRA Revision 4 (dated,

October 1999) and the SAMA quantification on an October 2002'update of the PRA (referred to

as Revision 0). The'staff questioned Dominion regarding the' impact on the'SAMA identificationprocess if the later version of the PRA was used to identify potential SAMAs (NRC 2004). In

response, Dominion reassessed the SAMA identification process considering the later PRA

revision. The basic events not included in the initial Unit 3 PRA importance list were identified.

Those events with a risk reduction worth greater than or equal to 1.005 from the more recent

July 2005 : 1-1 1: - NUREG-1437, Supplement 22
Appendix I

PRA model were specifically evaluated. These events were compared to the SAMA list to

determine which events were already addressed by a SAMA. Dominion determined that all of

the additional basic events map to previously identified SAMAs. As a result, no new SAMAs

were created (Dominion 2004c). Based on these additional assessments, Dominion concluded

that the set of 185 SAMAs evaluated in the ER addresses the-major contributors to CDF and

offsite dose, and that the review of the top risk contributors does not reveal any new SAMAs.

The staff questioned Dominion regarding use of the second screening criterion (i.e., screening

out a SAMA on the basis that it has already been implemented at MPS3) to eliminate SAMAs

that were identified based on review of the PRA (NRC 2004). In response, Dominion provided

qualitative or quantitative details on the plant-specific SAMAs that were screened using this

criterion (SAMAs 159, 163, 165, 166, 167, 174, 181 and 185). None of these SAMAs were

determined to be cost-beneficial based on this further evaluation.

The staff questioned Dominion about lower-cost alternatives to some of the SAMAs evaluated,

including the use of portable battery chargers and a direct-drive diesel auxiliary feedwater

(AFW) pump (NRC 2004). In response, Dominion identified several lower-cost alternatives, all

of which are covered by an existing procedure or severe accident management guideline

(SAMG), or could be instituted following evaluation and guidance by the Technical Support

Center. This is discussed further in Section 1.6.2.

The staff notes that the set of SAMAs submitted is not all inclusive, since additional, possibly

even less expensive, design alternatives can always be postulated. However, the staff

concludes that the benefits of any additional modifications are unlikely to exceed the benefits of

the modifications evaluated and that the alternative improvements would not likely cost less

than the least-expensive alternatives evaluated, when the subsidiary costs associated with

maintenance, procedures, and training are considered.

The staff concludes that Dominion used a systematic and comprehensive process for

identifying potential plant improvements for MPS3, and that the set of potential plant

improvements identified by Dominion is reasonably comprehensive and therefore acceptable.

This search included reviewing insights from the IPE and IPEEE and other plant-specific

studies, reviewing plant improvements considered in previous SAMA analyses, and using the

knowledge and experience of its PRA personnel. While explicit treatment of external events in

the SAMA identification process was limited, it is recognized that the prior implementation of

plant modifications for seismic and fire events and the absence of external event vulnerabilities

reasonably justifies examining primarily the internal events risk results for this purpose.

NUREG-1 437, Supplement 22 1-12 July 2005
Appendix I

1.4 Risk Reduction Potential of Plant Improvements

Dominion evaluated the risk-reduction potential of the 52 remaining SAMAs that were

applicable to MPS3. A majority of the SAMA evaluations were performed in a bounding fashion

in that the SAMA was assumed to completely eliminate the risk associated with the proposed

enhancement. Such bounding calculations overestimate the benefit and are conservative.

Dominion estimated the potential benefits for each SAMA by generating a revised set of PDS

frequencies. Using these revised frequencies, a revised Level 3 (dollars averted) calculation

was performed. The benefit was calculated using the fault trees, event trees, and databases

from Revision 0 of the MPS3 PRA. The assumptions made to evaluate the benefit were

provided in response to an RAI (Dominion 2004b, 2004c). Table 1-3 lists the assumptions

considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk

reduction in terms of percent reduction in CDF and population dose, and the estimated total

benefit (preserit value) of the averted risk (including the 1.6 multiplier to account for benefits in

external events). The determination of the benefits for the various SAMAs is further-discussed

in Section 1.6.

The staff has reviewed Dominion's bases for calculating the risk reduction for the various plant

improvements and concludes that the rationale and assumptions for estimating risk reduction

are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what

would actually be realized). Accordingly, the staff based its estimates of averted risk for the

various SAMAs on Dominion's-risk reduction estimates. The estimated risk reduction for

several of the SAMAs was negligible or zero.:- In these instances, the SAMA either affects

sequences or phenomena that do not contribute to risk at MPS3, or represents an ineffective

plant improvement. As such, a minimal impact on risk is not ufireasonable in those cases.

1.5 Cost Impacts of Candidate Plant Improvements

Dominion personnel experienced in estimating the cost of performing work at a nuclear plant

estimated the costs of implementing the 52 candidate SAMAs. For some of the SAMAs

considered, the cost estimates were sufficiently greater than the benefits calculated that it was

not necessary to perform a detailed cost estimate. Cost estimates typically included

procedures, engineering analysis, training, and documentation, in addition to any hardware.

The staff reviewed the bases for the applicant's cost estimates (presented in Section 1.3 of

Appendix G to the ER). For certain improvements, the staff also compared the cost estimates

to estimates developed elsewhere for similar improvements, including estimates developed as

part of other licensees' analyses of SAMAs for operating reactors and advanced light-water

reactors. The cost estimates provided were in the form of ranges. For purposes of evaluating

specific SAMAs, the staff selected the low end values from the range to represent the costs.

July2005 1-13 NUREG-1437, Supplement 22
z >

E-D

C) Q.

:,4 Table 1-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 3

Cl)

c % Risk Reduction

D SAMA Assumptions Total Benefit (P) Cost ($)

C CDF Dose

9 - Provide additional SW pump that can Set failures of SW pumps and CCF of 8.5 9.6 164,800 10.000.000

M be connected to either SW header SW pumps to zero

10 - Create an independent RCP seal Eliminate the need for RCP cooling 22.8 22.3 419.800 10.000.000

cooling system with dedicated diesel from the fault tree

11 - Create an Independent RCP seal Same as SAMA #10 22.8 22.3 419,800 5,000,000 cooling system without dedicated diesel

20/21 - Develop a new procedure for Changed fault tree from failure of one 1.7 0.3 14,100 150,000

cross-tying either the CCW pumps or train to failure of one train of SW AND

SW pumps (including analysis, failure of the opposite train or failure of

validation, and training) operator action to align the opposite

train (prob. 0.10)

34 - Install a containment vent large Set failure of reactor protection system 9.3 1.3 103,400 10,000,000

enough to remove ATWS decay heat electrical components (except reactor

trip breakers), CCF of reactor trip

breakers, CCF of 10 or more control

rods to insert, and CCF of 35 or more

control rods to insert to zero

35 - Install a filtered containment vent to Set CCF of recirculation air conditioning 5.8 6.4 110,800 12,000,000

remove decay heat units to operate, misalignment of

manual valve 3RHS*V43, loss of the

recirculation spray system, CCF of

motor-operated valves (MOV)

3SWP MOV50A/B to close, and CCF of

3SWP*MOV71A/B to close to zero

CC

0

.11

- . . I
C_

Table 1-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 3

o % Risk Reduction

SAMA Assumptions Total Benefit (S) Cost (S)

CDF Dose

36-Install an unfiltered hardened Same as SAMA #35 5.8 6.4 110,800 10,000,000 containment vent

43 -Create a reactor cavity flooding Set release categories with <0.1 41.9 344,800 18,000,000 system Intermediate and late containment

........... failure and basemat failure to zero

44 - Creating other options for reactor Same as SAMA #43 <0.1 41.9 344,800 18,000,000 cavity flooding . . .

60-- Provide additional DC battery Lengthen time for restoration of offsite 2.2 2.6 42,800 600,000 capability power to become available to prolong

DC battery life

61 - Use fuel cells instead of lead-acid Same as SAMA #60 2.2 2.6 42,800 3,000,000 batteries

63- Improved bus cross tie ability Changed fault tree from failure of one 27.8 17.9 429,600 2,000,000

en AC bus to failure of one AC bus AND -;failure of the opposite AC bus or failure

of operator action to align the opposite

AC bus (prob. 0.01). . 64 -Alternate battery charging capability Same as SAMA #60 2.2 2.6 42,800 5,000,000 67 -Create AC power cross tie capability Create crdss-tle logic (prob. 0.02) with 8.6 10.4 170,800 4,000,000 across units; iJ the Millstone Power Station, Unit 2

(MPS2) emergency diesel generators C , '.-; -i *, ' ' (EDGs) In the fault tree

m 73-Installgasturbin'egenerftors Set failures of EDGs 'A and 'B and 29.9 24.2 500,100 8,000,000 l .- CCF of EDGs 'A and 'B' to zero

CO

to ) - . .. . C . ......-

CCT

r' .. , ....

3o .. ..... ;.. .

(D >:

M ,, . - - -- - - ; - -; ~~~~~~' ^;,;;,:,; :..1:,
z 

M >

m 

Table 1-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 3 n _( GO % Risk Reduction

SAMA Assumptions Population Total Benefit (S) Cost (S)

n CDF Dose

V 75 - Create a river water backup for Same as SAMA #76 0.7 0.5 11,100 750,000 diesel cooling

CD 76 - Use firewater as a backup for diesel Eliminate failures of SW supply to the 0.7 0.5 11,100 750,000 . cooling EDGs from the fault tree

77 - Provide a connection to alternate Eliminate failures of LOOP from the 38.4 30.0 635,100 6,000,000 offsite power source (the nearest dam) fault tree

80 - Create an auto-loading of the SBO Set failure of the operator to correctly 2.4 2.9 47,400 7,000,000 diesel start and align the SBO diesel to zero

87 - Replace steam generators with new Eliminate the possibility of SGTR 3.5 21.6 144,800 175,000,000 design events from the fault tree

93 - Additional instrumentation and Set the iSLOCA containment release 0.8 17.4 83,600 9,000,000 inspection to prevent ISLOCA category frequency to zero

sequences

94 - Increase frequency of valve leak Same as SAMA #93 0.8 17.4 83,600 2,000,000 testing

99 - Ensure all ISLOCA releases are Same as SAMA #93 0.8 17.4 83,600 4,000,000 scrubbed

100 - Add redundant and diverse limit Same as SAMA #93 0.8 17.4 83,600 18,000,000 switch to each containment isolation

valve

112 - Proceduralize local manual Set all recoveries of offsite power to 2.2 2.6 42,800 100,000 operation of AFW when control power is zero

lost

C_

rQ

0

0

Ln
CTable 1-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 3

o % Risk Reduction -- SAMA - - - Assumptions ' Total Benefit:(S) Cost(S) Assumptions Population cs S - -CDF Dose

113 - Provide portable generators to be Bounded by SAMA #112 1.9 2.3 38,400 5,000,000

hooked In to the turbine driven AFW train

after battery depletion

120 - Create passive secondary side Eliminate failures of the AFW system 40.6 15.4 532,900 50,000,000

coolers from the fault tree

123 - Provide capability for diesel-driven, Eliminate failures of the emergency 19.7 22.9 396,000 7,500,000

low pressure vessel makeup core cooling system Injection from the

- fault tree

124/125 - Provide an additional high Set failures of HPSI pumps and CCF of 3.5 1 42,800 10,000,000

pressure injection (HPSI) pump with HPSI pumps to zero

independent diesel

138 - Create automatic swapover to Set failure of operator to establish sump 1.7 0.3 19,800 2,000,000

recirculation on refueling water storage recirculation after a LOCA'to zero

., tank depletion '

156 - Install secondary side guard pipes Eliminate steam line break inside 13.4 22.5 335,700 10,000,000

up to the main steam isolation valves, ' containment from the fault tree

(MSIVs) :

160 - Install turbine-driven AFW pump Set failures of the turbine-driven AFW 42.0 33.5 712,200 12,000,000

"':. ! pumps to zero

161 - Install SBO diesel Set failures of the SBO diesel to zero 5.3 6.4 105,400 8,000,000

162 - Install charging system train Set failures'of charging pu-m'ps'an'd 7.2 3.6 103,300 20,000,000

CCF of charging pumps to zero

Z 164 - Install safety Injection train Set failures of HPSI pumps and CCF of 3.5 1 42,800 20,000,000

I HPSI pumps to zero

O 168 - Automate feed and bleed Set failures of operator to establish feed 28.8 21.5 480,800 1,000,000

and bleed cooling to zero

C 169 - Improve boron Injection reliability Eliminate failures of emergency 0 0 0 2,000,000 - with new procedure and hardware boratlon from the fault tree

170- Add another air-operated valve CDc Set failures of MOVs 3SWP*MOV5OAIB 7.1 8.9 143,800 2,000,000 >

3 (AOV) to Isolate SW and 3SWP*MOV7lAIB to close, CCF of ', CD ( C 3SWP*MOV5OANB to close, and CCF of . . .

3SWPMOV71AB to close to zero - a . . -
z

C

m

C')

ED

2

oD

-4

Table 1-3. SAMA Cost-Benefit Screening Analysis for Millstone Power Station, Unit 3

% Risk Reduction

SAMA Assumptions Population Total Benefit (S) Cost (

CDF Dose

171 - Install another containment Same as SAMA #172 1.7 1.5 28,800 10,000,000 recirculation system (RSS) parallel flow

path

172 - Add a redundant train of RSS Set failures of RSS pumps and CCF of 1.7 1.5 28,800 20,000,000 RSS pumps to zero

173 - Add additional SW AOVs (air-lo- Same as SAMA #170 7.1 8.9 143,800 2,000,000 close/air-to-open)

175 - Add a redundant DC bus Set failures of vital 120 VDC buses 0.3 0.5 7,000 5,000,000 301 A1 and 301 B1 to zero

176 - Add a redundant charging pump Set failures of the charging pumps and 7.2 3.6 103,300 10,000,000 CCF of the charging pumps to zero

177 - Add a redundant block valve for Eliminate failures of the PORVs to 3.4 2.5 55,100 2,000,000 the power-operated relief valve (PORV) reseat from the fault tree

178 - Add redundant MSIVs Eliminate failures of the MSIVs to close 0.8 0.2 10,000 5,000,000 from the fault tree

179 - Add a redundant SW pump Eliminate failure of the SW train 'A' and 2.1 1.7 34,700 1,000,000 ventilation train train 'B' pump cubicle ventilation from

the fault tree

180 - Add a redundant valve in series to Eliminate failures of the steam dump 4 0.5 44,300 5,000,000 isolate the steam line dumps to valves to the condenser from the fault

condenser tree

182 - Add redundant AC bus Changed fault tree from failure of one 27.8 17.9 429,600 15,000,000 AC bus to failure of one AC bus AND

failure of the opposite AC bus or failure

of operator to align the opposite AC bus

(prob. 0.01)

183 - Add redundant AFW flow path Set CCF of the discharge and injection 0.9 0.3 11,200 15,000,000 AFW check valves to open to zero

184 - Add redundant demineralized Set failure of the DWST to zero 0.8 0.2 9,800 5,000,000 water storage tank (DWST)

-O

CD

r0.

x

I

CC:

01

CA
Appendix I

For some SAMAs, the costs appeared to be overestimated. Therefore, the staff asked the

applicant to justify the costs for those SAMAs that had significant benefits (NRC 2004). In

response to the staff's request, Dominion provided a discussion of the components and

activities that were considered in estimating the costs of those SAMAs for which the benefit was

determined to be $50,000 or more. The discussion included a description of the modification, if

any procedure changes and training would be required, and if any new instrumentation and

maintenance would be required (Dominion 2004b). The staff reviewed the costs and

subsequent explanations and found them to be reasonable and generally consistent with

estimates provided in support of other plants' analyses. - -

The staff concludes that the cost estimates provided by Dominion are sufficient and appropriate

for use in the SAMA evaluation. ,

1.6 Cost-Benefit ComparisonmDominion's cost-benefit analysis and the staff's review are described in the following sections.

1.6.1 Dominion Evaluation

The methodology used by Dominion was based primarily on NRC's guidance for performing

cost-benefit analysis, i.e., NUREG/BR-01 84, Regulatory Analysis TechnicalEvaluation

Handbook (NRC 1 997b). The guidance involves determining the net value for each SAMA

according to the following formula: , -

Net Value = (APE + AOC +AOE + AOSC) - O-E

where, . ;

APE,= present value of averted public exposure ($) --

AOC = present value of averted offsite property damage costs ($)

AOE = present value of averted occupational exposure costs ($) ,

AOSC = present value of averted onsite costs ($) -

COE = cost of enhancement ($). ;

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the

benefit associated with the SAMA and it is not considered cost-beneficial. Dominion's -

derivation of each of the associated costs is summarized below. -

July 2005 1-19 NUREG-1437, Supplement 22

I
Appendix I

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (Aperson-rem/year)

x monetary equivalent of unit dose ($2,000 per person-rem)

x present value conversion factor (10.76 based on a 20-year period with a

7-percent discount rate).

As stated in NUREG/BR-01 84 (NRC 1997b), it is important to note that the monetary value of

the public health risk after discounting does not represent the expected reduction in public

health risk due to a single accident. Rather, it is the present value of a stream of potential

losses extending over the remaining lifetime (in this case, the renewal period) of the facility.

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an

accident could occur at any time over the renewal period, and the effect of discounting these

potential future losses to present value. For the purposes of initial screening, Dominion

calculated an APE of approximately $275,900 for the 20-year license renewal period, which

assumes elimination of all severe accidents.

Averted Offsite Propertv Damaae Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction

x offsite economic costs associated with a severe accident (on a per-event basis)

x present value conversion factor.

For the purposes of initial screening, which assumes all severe accidents are eliminated,

Dominion calculated an annual offsite economic risk of about $21,800 based on the Level 3 risk

analysis. This results in a discounted value of approximately $234,700 for the 20-year license

renewal period.

Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction

x occupational exposure per core damage event

x monetary equivalent of unit dose

x present value conversion factor.

NUREG-1437, Supplement 22 1-20 July 2005
Appendix I

Dominion derived the values for averted occupational exposure from information provided in'

Section 5.7.3 of the regulatory analysis handbook (NRC 1 997b).; Best estimate values provided'

for immediate occupational dose (3300 person-rem) and long-term occupational dose '-- - '

(20,000 person-rem over'a 1 0-year cleanup period) were tused.'" The present value of these

doses was calculated using the equations provided in the handbook in conjunction with a

monetary equivalent of unit dose of $2,000 per person-rem a real -discount rate of 7 percent,

and a time periodof 20'years to represent the license renewal period.' For the purposes of

initial screening, which assumes all severe accidents are eliminated, Dominion calculated an

AOE of approximately $11,000 for the 20-year license renewal period.

Averted Onsite Costs (AOSC) - -

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and avertedpower replacement costs. Repair and refurbishment costs are'considered for'recoverable

accidents only and riot for severe accidents. Dominion derived the values for AOSC based on

information provided in Section 5.7.6 of the regulatory analysis handbook (NRC 1 997b).

Dominion divided this cost element into two parts -the Onsite Cleanup and Decontamination

Cost, also commonly referred to as averted cleanup and decontamination costs, and the

replacement power cost..

Averted cleanup and decontamination costs (ACC) were calculated using the following formula:

ACC = Annual CDFreduction -

x present value of cleanup costs per core damage eventx present value conversion factor. ..- -

The total cost of cleanup and decontamination subsequent'to a'severe accident is estimated in -

the regulatory analysis handbook to be $1.5 billion (undiscounted). This value was converted to

present costs over- a 10-year cleanup period and integrated over the term of the proposed - 4: -

license extension. For the purposes of initial screening, which assumes all severe accidents

are eliminated, Dominion calculated an ACC of approximately $334,400 for the 20-year license

renewal period.

Long-term replacement power costs (RPC) were calculated using the following formula:

RPC = - Annual CDF reduction 4 ,

x present value of replacement power for a single event .A - -,;

-x factor to account for remaining service years for which replacement power is -

required - . - -

x reactor power scaling factor

July 2005 -- 1-21 NUREG-1437, Supplement 22
Appendix I

Dominion based its calculations on the value of 1154 megawatts electric (MW[e]). Therefore,

Dominion applied power scaling factor of 1154 MW(e)/910 MW(e) to determine the replacement

power cost. For the purposes of initial screening, which assumes all severe accidents are

eliminated, Dominion calculated the RPC to be approximately $288,600.

Using the above equations, Dominion estimated the total present dollar value equivalent

unassociated with completely eliminating severe accidents at MPS3 to be about $1,145,000.

Dominion's Results

The total benefit associated with each of the 52 SAMAs evaluated by Dominion is provided in

Table 1-3. These values were determined based on the above equations for the various averted

costs together with the estimated annual reductions in CDF and population dose, and then

increased by a multiplier of 1.6 to account for additional risk reduction in external events. The

values for total benefit reported in Table 1-3 include this multiplier. As a result, all SAMAs that

were evaluated were eliminated because the cost was expected to exceed the estimated

benefit.

In response to an RAI regarding the costs of SAMA 1 2 (proceduralize local manual operation

of AFW when control power is lost), Dominion assessed the applicability/feasibility of a

procedure for manual operation of the turbine-driven AFW (TDAFW) pump when control power

is lost, similar to that in place at MPS2. Dominion stated that this SAMA would likely require a

plant modification to provide the level indication that would be necessary during SBO, in

addition to a new procedure. However, Dominion stated that if this SAMA can be accomplished

via a SAMG, without a hardware modification, then the SAMA would be cost-beneficial and willbe implemented prior to the period of extended operation (Dominion 2004b).

1.6.2 Review of Dominion's Cost-Benefit Evaluation

The cost-benefit analysis performed by Dominion was based primarily on NUREG/BR-01 84

(NRC 1997b) and was conducted in a manner consistent with this guidance.

i

In order to account for uncertainties in the cost estimates, Dominion applied a factor of two

margin in assessing whether SAMAs were cost-beneficial, i.e., a SAMA was considered to be

cost-beneficial if the total benefit is within a factor of two of the estimated cost. The staff asked

the applicant to consider the impact of uncertainty in the CDF (NRC 2004). In response,

Dominion stated that CDF uncertainty calculations are not available in the current version of the

Millstone PRA model. However, based on a review of recent SAMA analyses in support of

license renewal, the 951 percentile CDF ranged from a factor of 2.0 to a factor of 6.4 greater

than the mean CDF. Dominion stated that in order to provide conservatism, it compared the

NUREG-1437, Supplement 22 1-22 July 2005
Appendix I

cost to twice the calculated benefit. Dominion further indicated that most of the benefit -

calculations were performed in a bounding fashion, i.e., the SAMA is completely effective; and

that such estimates would be substantially less if a more realistic analysis were performed for

each SAMA (Dominion 2004b). - - -

The staff questioned the approach of increasing the benefit (based on internal events) by

60 percent to account for external events (NRC 2004). In response to the RAI, Dominion stated

that a multiplier of 1.6 was used because the external events'analyses are not readily. . - -.

quantifiable (Dominion 2004b). The use of a multiplier on the benefits obtained from the '

internal events PRA to incorporate the impact of external events makes the implicit assumption

that the consequences from external events sequences are the same as the consequences'..

from internal events sequences. To demonstrate the robustness of the analysis,- Dominion

performed a sensitivity study that increased the assumed contribution from external events from

60 percent to 120 percent of the internal event benefits. iThe result was that the increased

benefit exceeded the lower bound of the cost estimate range for only 2 SAMAs (112 and 168).

Dominion stated that external events are dominated by LOOP and SBO (approximately 85

percent of the external events CDF comes from SBO). SAMA 168 (automate feed and bleed)

would have no benefit for SBO sequences because feed and bleed cannot be achieved without

power. Additionally, this SAMA could create additional means for a spurious power-operated

relief valve opening or safety, injection (a negative benefit).- Therefore, Dominion concluded that

the use of the 1.6 multiplier is acceptable. SAMA 112 is discussed further below. -

Dominion assessed the impact of other factors on the analysis results, such as the contribution'

of external event initiators that were not explicitly included in the MPS2 risk profile, the use of a

3 percent discount rate as compared to the 7 percent discount rate used in the baseline

calculations, as well as a-15-percent real discount rate (Dominion 2004a). -These sensitivity

cases resulted in an increase in the benefit calculation of about 30 percent or less. These

analyses did not change Dominion's conclusion that none of the candidate SAMAs would be

cost-beneficial except as noted above. In addition, Dominion performed sensitivity analyses'

that addressed assumptions made in other parts of the cost-benefit analysis, including

meteorological data, source term, and evacuation. Dominion also considered the sensitivity to

the impact of current and future fuel management practices. These sensitivity cases are

generally bounded by the 3-percent discount rate sensitivity study.

The staff notes that accounting for each of these factors would tend to increase the benefit as

compared to the baseline case analysis. -However, the calculated benefits used in the baseline .

analysis are generally overestimated and, therefore, conservative. The staff concludes that the

use of the factor of two to account for uncertainties, coupled with the fact that the calculated

benefits are generally conservative, provides a reasonable treatment of uncertainties and is

adequate for the SAMA evaluation.

July 2005. 1-23 - NUREG-1437, Supplement 22'-.
Appendix I

The staff questioned Dominion about lower cost alternatives to some of the SAMAs evaluated,

including the use of a direct-drive diesel AFW pump (NRC 2004). With regard to the specific

lower-cost alternative involving a direct-drive diesel AFW pump, Dominion stated that the

alternative would not be viable at MPS3 due to room and ventilation constraints as well as

costs. Dominion further stated that MPS3 has a SAMG for using the diesel fire pump to provide

water to the AFW system (Dominion 2004b).

Dominion also identified and evaluated several lower-cost alternatives to those considered in

the ER. These included (1) installing an unfiltered hardened containment'vent, (2) using

existing systems to flood the reactor cavity, (3) creating a new SAMG to direct manual control of

AFW, and (4) using the fire water system to fill the steam generators. Dominion concluded that

three of the alternatives are covered by an existing procedure or SAMG, or could be instituted

following evaluation and guidance by the Technical Support Center. The alternative involving

creation of a new SAMG to direct manual control of the AFW pump is not currently covered by

an existing procedure, but is related to SAMA 112.

SAMA 112 involves physical modifications to provide steam generator level indication in an

SBO scenario, as well as the development of an emergency operating procedure that would

direct the manual control of the TDAFW pump (Dominion 2004b). This SAMA was estimated to

have a benefit of about $43,000 and an implementation cost of about $100,000. As such, it

would not be cost-beneficial. As an alternative to SAMA 112, Dominion considered the

development of a SAMG without the hardware modification. This improvement could be

effective in a more limited number of sequences in which auxiliary feedwater control power is'

lost, but steam generator level indications are not. Development of a SAMG for manual control

of the pump would involve engineering to determine the feasibility,, creation of the new SAMG,

field verification of the' actual operation, and final SAMG production. Dominion estimated the

cost of this alternative to be in the range of $50,000 to $60,000. The estimated benefit of this

modification (after doubling to account for uncertainty) is greater than the expected cost;

therefore, it is potentially cost-beneficial. As indicated in its RAI response, Dominion plans to

complete its evaluation of this SAMA and, if it is cost-beneficial, will develop a SAMG

addressing manual control of the

turbine-driven AFW pump prior to the period of extended operation (Dominion 2004b).

The staff concludes that, with the exception of one potentially cost-beneficial SAMA discussed

above, the costs of the SAMAs would be higher than the associated benefits. This conclusion

is supported by uncertainty assessment and sensitivity analyses and upheld despite a number

of additional uncertainties and non-quantifiable factors in the calculations, summarized as

follows:

NUREG-1437, Supplement 22 1-24 July 2005
Appendix I

* A factor of two was used to account for uncertainties.' Even'if 'a higher factor were

considered to reflect a larger uncertainty in CDF, e.g., a factor of five, only one additional

SAMA would be close to becoming cost-beneficial -SAMAl 68. However, this SAMA is '

not expected to be cost-beneficial under more realistic assumptions regarding risk reduction

and implementation costs. -

* Sensitivity calculations were performed with respect to the discount rate (3 percent and

15 percent) and various MACCS2 parameters,'including' meteorological data, evacuation'

speed, evacuation delay tirrie, and source terms. The results of these sensitivity studies'

showed that none of the risk benefits was increased by more than 40 percent. Since this is

less than the margin between cost and benefit for the SAMAs considered, the uncertainties:

in these parameters would not alter the conclusions.

1.7 Conclusions --..

Dominion compiled a list of 185 SAMA candidates using the SAMA analyses as submitted in

support of licensing activities for other nuclear power plants, NRC and industry' documents"

discussing potential plant improvements, plant-specific insights from the MPS3 PRA model.' A

qualitative screening removed SAMA candidates that (1) were not applicable at MPS3 due to

design differences, (2) had already been implemented at MPS3,'or (3) were related to' RCP seal

vulnerability. A total of 133 SAMAs were eliminated, leaving 52 for further evaluation.

For the remaining SAMA candidates, a more detailed design and cost estimate were developed

as shown in Table G-3. The cost-benefit analyses showed that none of the SAMA candidates

was potentially cost-beneficial. Upon completion of a 3-percent discount rate sensitivity study,

as well as other sensitivity studies, no additional SAMA candidates were determined to be',

potentially cost-beneficial. To account for uncertainties, Dominion compared the cost of thevSAMA with twice the calculated benefit. As a result, no additional SAMAs were cost-beneficial.

The staff reviewed the Dominion analysis and concluded that the methods used and the

implementation of those methods was sound. The treatment of SAMA benefits and costs, the

generally large negative'net benefits, and the inherently small baseline risks support the

general conclusion that the SAMA evaluations performed by Dominion are reasonable and

sufficient for the license renewal submittal. The unavailability of an external event PRA model'

precluded a quantitative evaluation of SAMAs specifically aimed at reducing risk of external

event initiators; however, improvements that have been realized as a result of the IPEEE

process and the inclusion of a multiplier to account forexternal events would minimize 'the

likelihood of identifying cost-beneficial enhancements in this area."'"

July 2005 1-25 NUREG-1437, Supplement 22
Appendix I

Based on its review of the Dominion SAMA analysis, the staff concurs that none of the

candidate SAMAs are cost-beneficial, except for SAMA 112- proceduralize local manual

operation of AFW when control power is lost. This is based on conservative treatment of costs

and benefits. This conclusion is consistent with the low residual level of risk indicated in the

MPS3 PRA and the fact that MPS3 has already implemented many of plant improvements

identified from the IPE and IPEEE processes. Although SAMA 112 may be cost-beneficial if it

can be implemented via procedural enhancements, this SAMA does not relate to adequately

managing the effects of aging during the period of extended operation. Therefore, it need not

be implemented as part of the license renewal pursuant to 10 CFR Part 54.

1.8 References

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.'

Dominion Nuclear Connecticut, Inc. (Dominion). 2004a. Applicant's Environmental

Report-Operating License Renewal Stage, Millstone Power Station, Units 2 and 3. Dominion

Nuclear Connecticut, Inc., Richmond, Virginia. January 2004.

Dominion Nuclear Connecticut, Inc. (Dominion). 2004b. Letter from Leslie N. Hartz, Dominion,

to United States Nuclear Regulatory Commission Document Control Desk. Subject: Dominion

Nuclear Connecticut, Inc., Millstone Power Sation, Units 2 and 3, Response to Request for

Additional Information, License Renewal Applications. (August 13, 2004).

Dominion Nuclear Connecticut, Inc. (Dominion). 2004c. Email from Richard J. Gallagher,

Dominion, to Richard Emch, NRC. Subject: Clarification of RAI Responses. (September 16,

2004).

Northeast Nuclear Energy Company (NNECO). 1983. Millstone Unit 3 Probabilistic Safety

Study. August 1983.

Northeast Nuclear Energy Company (NNECO). 1990. Letter from E. J. Mroczka, NNECO, to

U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Millstone Nuclear

Power Station Unit No. 3, Response to Generic Letter 88-20, Individual Plant Examination for

Severe Accident Vulnerabilities, Summary Report Submittal. (August 31, 1990).

Northeast Nuclear Energy Company (NNECO). 1991. Letter from J. F. Opeka, NNECO, to

U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Millstone Nuclear

Power Station, Unit Nos. 1, 2 and 3, Response to Generic Letter 88-20 Supplement 4, Revised

NUREG-1437, Supplement 22 1-26 July 2005
Appendix I

Response to Generic Letter 88-20 Supplement 1, Individual Plant Examinations (IPE) for

Severe Accident Vulnerabilities (December 23, 1991).

U.S. Nuclear Regulatory Commission (NRC). 1985a. -NUREG-1 152, Millstone 3 Risk

Evaluation Report, An Overall Review and Evaluation of the Millstone Unit 3 Probabilistic Safety

Study, Washington, D.C. -

U.S. Nuclear Regulatory Commission (NRC). 1985b. 'NUREG/CR-4142, A Review of the

Millstone Probabilistic Safety Study, Washington, D.C. -

U.S. Nuclear Regulatory Commission (NRC). 1985g. NUREG/CR-4143, Review and'-,

Evaluation of the Millstone Unit 3 Probabilistic Safety Study, Containment Faihfre Modes,

Radiological Source-Terms and Offsite Consequences, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, "Individual Plant

Examination for Severe Accident Vulnerabilities." November 23,1988.

U.S. Nuclear Regulatory Commission (NRC). 1990. NUREG-1150, Severe Accident Risks: An

Assessment for Five U.S. Nuclear Power Plants, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1991. NUREG-1407, ProceduralandSubmittal

Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident

Vulnerabilities, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1992. Letter from Vernon L. Rooney, U.S. NRC,

to John F. Opeka, NNECO. Subject: Staff Evaluation of Millstone 3 Individual Plant

Examination (IPE) - Internal Events, GL 88-20 (TAC NO. M74434). (May 5,1992).

U.S. Nuclear Regulatory Commission. 1996. NUREG-1437, Generic Environmental Impact

Statement for License Renewal of Nuclear Plants, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997a. NUREG-1560, Individual Plant

Examination Program: Perspectives on Reactor Safety and Plant Performance, Washington,

D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997b. NUREG/BR-0184, RegulatoryAnalysis

Technical Evaluation Handbook, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997c. NUREG/CR-6525, SECPOP90: Sector

Population, Land Fraction, and Economic Estimation Program, Washington, D.C.

July 2005 1-27 NUREG-1437, Supplement 22
Appendix I

U.S. Nuclear Regulatory Commission (NRC). 1998. Letter from James W. Andersen, NRC, to

Martin L. Bowling, Jr., NNECO. Subject: Millstone Nuclear Power Station, Unit No. 3 -

Individual Plant Examination of External Events (TAC NO. M83643). (May 26,1998).

U.S. Nuclear Regulatory Commission (NRC). 2004. Letter from Richard L. Emch, Jr., NRC, to

David A. Christian, Dominion. Subject: Request for Additional Information (RAI) Regarding

Severe Accident Mitigation Alternatives for the Millstone Power Station, Units 2 and 3 (TAC

NOS. MCi 827 and MCI 828). (June 22, 2004).

U.S. Department of Agriculture (USDA). 1998. 1997 Census of Agriculture, National

Agriculture Statistics Service, 1998.

NUREG-1437, Supplement 22 1-28 July 2005

I
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9-2004) (Assigned by NRC. Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, If any.)

BIBLIOGRAPHIC DATA SHEET

(See hIstructions on the reverse) NUREG-1437, Supplement 22

2 TITLE AND SUBTITLE 3. DATE REPORT PUBUSHED

Generic Environmental Impact Statement for Ucense Renewal of Nuclear Plants (GEIS) MONTH YEAR

Supplement 22

Regarding Millstone Power Station, Units 2 and 3 July2005

Final Report 4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inldusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (ItNRC. pie Diviion. Office orRefon, U.S Near Regulatory Commisson, and maling address;Itcontractors

provide name and malkig address.)

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (ItNRC, type Same as abowe;i otcoprvidoHRC D~ision, twfice orRegion, U.S. Nucteareftulatory Commisseon,

and makig addres&)

Same as 8 above

10. SUPPLEMENTARY NOTES

Docket Numbers 50-336, 50-423

I1. ABSTRACT 1200 worts or less)

This final supplemental environmental Impact statement (SEIS) has been prepared in response to an application submitted to

the NRC by Dominion Nuclear Connecticut, Inc. (Dominion) to renew the operating license for Millstone Power Station, Units 2

and 3 (Millstone) for an additional 20 years under 10 CFR Part 54. The final SEIS includes the NRC staff's analysis that

considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives to the

proposed action, and mitigation measures available for reducing or avoiding adverse Impacts. It also includes the staffs

recommendation regarding the proposed action.

The NRC staffs recommendation is that the Commission determine that the adverse environmental Impacts of license renewal

for Millstone are not so great that preserving the option of license renewal for energy-planning decisionmakers would be

unreasonable. This recommendation Is based on (1) the analysis and findings in the GEIS; (2) the Environmental Report

submitted by Dominion; (3) consultation with Federal, State, and local agencies; (4) the staffs own independent review; and (5)

the staff's consideration of public comments.

12. KEY WORDSIDESCRIPTORS (Lst words orphrases thatwiassist researchers hI tocatng the report.) 13. AVAILABILITY STATEMENT

Millstone Power Station, Units 2 and 3 . unlimited

Millstone - -. SECURITY CLASSIFICATION

Final Supplement to the Generic Environmental Impact Statement - (This Page)

FSEIS . unclassified

National Environmental Policy Act (Ths Report)

NEPA - : - unclassified Ucense Renewal

GEIS 15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER
Printed

on recycled

paper

Federal Recycling Program
UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

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