September
19, 2007
Comment on Indian Point 2&3 re-licensing application proposal:
The Rockland
County Conservation Association (RCCA) has opposed the Indian Point
facility since Indian Point 1 was first proposed. Throughout the
years of reviews and assurances of compliance and safety our confidence
in the safety of the facility has been greatly challenged by radioactive
leaks, personnel literally sleeping at the switch, and failed promises
to meet deadlines of a fully functioning siren system. Now we are
called upon again to believe that all is safe and well with a facility
that is leaking strontium 90, tritium and has unplanned shutdowns.
As recent
as September 11, 2007, the Journal News reported Feds Suspend Inspection
at Indian Point 3 (http://www.thejournalnews.com/apps/pbcs.dll/article?AID=2007709110344).
“BUCHANAN -The Nuclear Regulatory Commission has suspended an
inspection at Indian Point 3 after federal experts found plant officials
unprepared to answer questions about a series of unplanned shutdowns
that led the agency to lower the reactor's safety rating in April.
"They
just didn't have the documentation we needed," said NRC regional
spokesman, Neil Sheehan, noting that such suspensions are rare.
"But also, the types of questions we are asking, they did not have
answers for at this point."
Again, public
confidence for the safety of this facility is marginalized. Further
the article reports Kathy McMullin, an Indian Point spokeswoman,
said the matter was "really much ado about nothing" and wouldn't
have reached the level of public notification without the current
regulatory climate surrounding the plant.
"In this
particular environment, the NRC erred on the abundance-of-caution
side, as we have done on issues that on their face might not seem
all that significant," she said. "It's not necessarily routine that
an inspection would be postponed, but it's not that unusual either."
So we are
to understand that the NRC has made an error in judgment and that
postponement of an inspection because the operator of a nuclear
facility was unprepared to answer questions about the operation
of its facility would not have been revealed if not for the regulatory
climate surrounding the plant. Does this infer out of sight out
of mind is an acceptable position for a nuclear facility operator?
The residents
in the Hudson Valley have just been advised of the FAA’s decision
to increase air traffic in the region. Rockland County residents
were not advised of the proposed plan until until a few weeks before
the end of the comment period. In fact, the County has filed a lawsuit
on the merits of the environmental review process conducted by the
FAA. Where there were few to no aircraft flying over the County
we can now expect up to 600 flights per day increasing the noise
level. On average every two to three minutes the noise of aircraft
flying overhead will be heard.
Entergy’s
Environmental review reports no foreseeable related Federal projects
were identified. As the FAA Redesign Project is a Federal project,
we ask what effect the background noise of increased air traffic
might have on the efficacy of the emergency alert system. Specifically,
was the system designed to be heard above the increased noise coming
from the increased noise levels projected for Rockland County?
[“2.13
Related Federal Project Activities
During the preparation of this report, Entergy did not identify
any known or reasonably foreseeable federal projects or other activities
that could contribute to the cumulative environmental impacts of
license renewal at the site.” http://www.nrc.gov/reactors/operating/licensing/renewal/applications/indian-point/1-ipec-lra-appendix-e_1-
2.pdf, pg 113 of 156)]
A proposal
for a desalinization plant along the Hudson in a location not yet
disclosed, though it is anticipated to be in Stony Point or Haverstraw,
has been submitted for review by United Water of New York (UWNY).
As the proposed facility is anticipated to be in use by UWNY within
the proposed license period of Indian Point 2 & 3, we ask that this
exposure be considered in Entergy’s environmental impact study.
Further if it is deemed that it is not appropriate until approval
for a desalination plant is granted, we ask the Indian Point facility
be required to assess its potential impacts to the desalinization
plant. Given the leakage of strontium 90 and tritium we do not believe
that this is unreasonable. Further, it would be unreasonable for
UWNY customers to have to pay related costs to remove, if possible,
radionuclide’s emanating from Indian Point.
