Summary Report of the BPBCA Millstone Committee – August 22, 2013
1. Dry Cask Storage – Connecticut Siting Council Proceedings
As previously reported, Tom Kelly appeared at the Connecticut Siting Council Hearing in January and request that Millstone not be authorized to construct **the infrastructure for the full 135 dry cask storage units. *refresh Board’s collective memory that the 135 number is an increase from 19 currently existing, and that Dominion had previously been authorized approval for expansion to 49 for the infrastructure and dry casks.
Unfortunately, the Siting Council approved the full amount requested by Millstone. **It should be pointed out the CSC decision was rendered w/o comment, rationale, instruction, reference….nothing. Although Nancy Burton, a long-time and active opponent of Millstone, has appealed, BPBCA has not joined in that appeal. For all practical purposes, BPBCA participation in that issue is completed.
2. New Issues Arising This Summer
a. Millstone’s application to amend its license to increase the limit on Long Island Sound cooling water from 75 degrees to 80 degrees. This application is now pending before the Nuclear Regulatory Commission (NRC) with an expected decision by late spring 2014.
b. Millstone’s proposal to utilize high burn up fuel. Millstone has met with the NRC to discuss this issue but has not yet filed an application. High burn up fuel produces higher levels of radioactive waste, and there appears to be some question whether the Dry Cask Storage system that Millstone intends to install is approved for high burn up fuel. The proposal to use high burn up fuel is being considered by the NRC on both an industry wide basis and in the context of specific facilities.
c. Millstone has recently been cited for safety violations. One of them relates to the failure to report the malfunction of the radiation monitoring system. However, the NRC has continued to permit Millstone to operate while the radiation monitoring system is being repaired. Although the NRC may believe that this does not present a safety threat, the failure of either Millstone or the NRC to provide any meaningful information on the risks related to operating without the radiation monitor required by NRC regulations is of concern.
3. Possible BPBCA Further Participation
There are various actions BPCA could consider with respect to the three new issues
2a. Raising the Long Island Sound water temperature limit to 80 degrees affects both the safety of the plant’s operation and its environmental impact. BPBCA could intervene in the NRC proceedings to stress these concerns. If this is undertaken, it is likely that significant financial resources would be required to engage legal and nuclear experts as consultants. If the Board wishes to proceed, we can try to develop a budget for Board approval before any major commitments are made.
2b. Participating in the high burn up fuel issue if Millstone makes an application to the NRC would be similar to 2a.
2c. The issues of continued safety violations that are never clearly explained by either the NRC or Millstone is most effectively dealt with as a PR initiative. There is no specific NRC proceeding. Thus, letter writing campaigns to local, state and Federal officials along with newspaper coverage might serve to ensure that our community’s interests are properly protected. ** Miscellaneous thoughts/options: petition Dominion for the formation of a citizens’ advisory board; timely outreach to other E.L. beaches to act in concert with BPBCA in the event the BP board authorizes future actions. Also inform board that the federal government has commissioned (and funded) a comprehensive study of possible health consequences in connection with the long term operation of MPS.
It has been a frustrating effort to challenge the nuclear establishment, and easy victories on any of the new issues are unlikely. However, we believe that we need to make sure that we take whatever steps can help protect the safety and enjoyment of the BPBCA community and we are willing to continue to serve on the committee if the Board wishes to proceed.