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Turn over the requested reports concerning Millstone's radiation releasing details and satisfy the other items outlined in the letter below.

This petition had 4 supporters


Jeffrey Semancic

Director, Radiation Division

Department of Energy and Environmental Protection

79 Elm Street
Hartford CT 06106

Dear Mr. Semancic:

We are alarmed to learn that in September 2014, without prior notice to the public or opportunity for public comment, the U.S. Nuclear Regulatory Commission revised its rules to allow the Millstone Nuclear Power Plant to operate at full power for up to 24 hours with its main station radiation monitors deliberately disabled and inoperable, where the previous standard was 15 minutes, as long as the releases coincide with “pre-planned maintenance.”

 Please reference the October 8, 2014 letter of the NRC’s Raymond R. McKinley to the Union of Concerned Scientists (UCS) responding to the UCS’s query to him dated August 15, 2014 regarding Millstone’s frequently recurring inoperability of its main station radiation monitors. (For your reference, copies of both letters are being sent to you by U.S. Mail.)

The UCS query derived from reviews of reports posted on the NRC website when Millstone’s main station radiation monitors were inoperable for periods in excess of 15 minutes.

The NRC letter confirms that Millstone holds the U.S. record for frequency of reporting of radiation monitor inoperability.

Our alarm particularly focuses on the statement  in the McKinley letter concerning whether NRC verifies whether Dominion may pre-plan its worst and dirtiest radiation releases to coincide with “pre-planned” radiation monitor shutdowns.

The NRC told UCS that Millstone is permitted to vent its “batch” releases containing heavier-than-normal concentrations of radionuclides even when it lacks the capability to adequately monitor the releases because of the monitor shutdowns.

 Although the NRC letter seeks to provide assurances that Dominion will take adequate “compensatory measures” – such as air samples and analysis – when it deactivates the radiation monitors, here is what the NRC acknowledges in response to the UCS query as to whether the NRC actually verifies that Dominion has taken such compensatory measures:

 “This level of detailed information is not required to be submitted to the NRC.”

We are gravely concerned that the public health and safety have been put at far greater risk of radiation exposure as a result of the NRC’s decision allowing Millstone to operate at full power for up to 24 hours with the loss of its most critical radiation monitors without having to report the loss of monitoring capability to the NRC and, hence, the public. Further, we are at a loss to understand how the welfare of the public is served when Dominion is excused from having to report its deliberate disabling of the critical radiation monitors as long as it “pre-plans maintenance” to coincide with the dangerous releases.

 As you know, Connecticut General Statutes §22a-135 (“Duties of Department of Energy and Environmental Protection re: nuclear energy and radiation”) mandates that with regard to “posting of planned radiationreleases,” your office must require that Dominion “immediately report [to it] . . . (A) any release of radiation which is . . . unmonitored.”

In accordance with this law, we request, pursuant to the Connecticut Freedom of Information Act, the opportunity to review and copy all DEEP records regarding Dominion’s reports to it of “unmonitored” radiation releases (that is, occurring while critical station radiation monitors were inoperable) during the past two years during which Millstone has attained the U.S. record of frequency of reports of inoperative radiation monitors.

Most particularly, we request such records as pertain to those occasions when Dominion has reported inoperability of radiation monitors to the NRC, as follows:

Unit 2

8/29/13

Event Number 49313

High range stack radiation monitor RM-8168

“removed . . . from service for pre-planned maintenance”

 

Unit 2

9/16/13

Event Number 49349

RM-8169 Vent Stack Radiation Monitor

“Pre-Planned Maintenance”

 

Unit 2

3/11/14

Event Number 49893

“Stack RadMonitor out-of-service for pre-planned maintenance”

Unit 2

6/3/14

Event Number 50165

“High range stack monitor taken out of service for planned maintenance”

 

Unit 2

8/5/14

Event Number 50343

“Removal of stack high radiation monitor for maintenance”

 

Unit 2

8/12/14

Event Number 50357

“Site stack radiation monitor out of service for planned maintenance”

Unit 3

1/15/14

Event Number 49724

“Normal ventilation radiation monitor removed from service for planned maintenance”

 

Unit 3

3/11/14

Event Number 49891

“Normal ventilation process radiation monitor out of service for planned maintenance”

 

Unit 3

3/24/14

Event Number 49951

“[Supplementary Leakage Collection and Release System] radiation monitor out of service for pre-planned maintenance”

 

Furthermore, pursuant to Connecticut General Statutes §22a-135(4) (“DEEP shall . . . (4) monitor radiation originating from nuclear plants and perform tests to detect any buildup of radioactivity in the soil, water, plants or animals of the state”), please inform us what steps you have taken as DEEP’s Radiation Bureau Director to monitor Millstone radiation releases on those occasions when Millstone’s radiation monitor have been disabled for “pre-planned maintenance.”

 We particularly request that you implement forthwith a program to monitor goat milk from among the 17 locations within 20 miles of Millstone as were identified by Dominion in its most recent (2013) Annual Radiological Environmental Operating Report. That reports states that Dominion did not sample goat milk as part of its environmental monitoring program during 2013. We request as well that you implement forthwith a program to monitor human breast milk pursuant to the statute.

Furthermore, we request that you act on your statutory authority (Connecticut General Statutes §22a-135(a)(6) and (7)) to petition the NRC to reverse its decision allowing Dominion to operate at full power for 24 hours with disabled radiation monitors for “pre-planned maintenance” without reporting the inoperability of the monitors to the NRC. 

Finally we request that you act on your statutory authority (Connecticut General Statutes §22a-135(a)(6) and (7) to petition the NRC to revise its regulations and policies to require that Dominion shut down Millstone during periods when its critical radiation monitors are deliberately disabled for “pre-planned maintenance.”

We appreciate your response at your earliest convenience.

Sincerely,

Nancy Burton

DirectorConnecticut Coalition Against Millstone



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