ML16069A335

Comment (14) of Susan Shapiro, on Behalf of Phase on Entergy Nuclear Operations, Inc.; Indian Point Nuclear Generating Unit Nos. 2 and 3; Draft Supplemental Environmental Impact Statement; Request Comment

ML16069A335
Person / Time
Site:	Indian Point
Issue date:	03/03/2016
From:	Shapiro S Public Health & Sustainable Energy (PHASE)
To:	Rules, Announcements, and Directives Branch
References
80FR81377 00014, NRC-2008-0672
Download: ML16069A335 (10)

Text

Page 1 of 1As of: 3/7/16 2:29 PMReceived: March,03, 2016PUBLIC SUBMISSIONStts enlgotComments Due: March 04, 2(Submission Type: WebDocket: NRC-2008-0672Environmental Impact Statement; Availability, etc.: Indian Point Nuclear Generating Unit Nos. 2 and 3,Buchanan, NY; License Renewal and Public MeetingComment On: NRC-2008-0672-0029Entergy Nuclear Operations, Inc.; Indian Point Nuclear Generating Unit Nos. 2 and 3; Draft SupplementalEnvironmental Impact Statement; Request for CommentDocument: NRC-2008-0672-DRAFT-003 1Comment on FR Doc # 20 15-32777Submitter Information.....-.,I....,..,,Name: Susan Shapiro, Esq.General Comment .........Please find attached public comments for Docket Number 2008-0672: The Nuclear G-(NRC) Notice: Entergy Nuclear Operations, Inc.; Indian Point Nuclear Generating Unit Nos. 2 and 3; DraftSupplemental Environmental Impact Statement; Request for Comment, Federal Register Number: 2015-32777.AttachmentsPHASE Letter to NRC re IP SEIS commentsSUNSI Review CompleteTemplate = ADM -013E-RIDS= ADM-03Ahttps://www.fdms.gov/fdms/getcontent?obj ectld=090000648 1 e9f69f&format=xml&showorig=false 0/72103/07/2016 MILTON B. SHAPIROATTORNEYS AT LAWSUSAN H. SHAPIRO75 N. MIDDLETOWN ROAD * (4ANUET[ NEW YORK 10954 (4)3]20(845) 371-3721 -FAXmb3@ou rrockIlfldof fw:.comMarch 4. 2016NRCPublic CommentsIRE: Docket Number 2008-0672: The Nuclear Regulatory Commission (NRC)Notice: Entergy Nuclear Operations, Inc.; Indian Point Nuclear Generating UnitNos. 2 and 3; Draft Supplemlental Environmental Impact Statement; Request forComment. Federal Register Number: 2015-327771 am submitting these comments on behalf of Public Health and Sustainable Energy(PH-ASE) in response to the SEIS issued on December 29, 2015.Since the SETS was written prior to significant "new information" and the change ofcircumstance as a result o[" the dramatically increased levels of" tritiunm found in thegroundwater in February 2016, the SEIS contains misleading inf'ormation and cannot beaccepted as accurate and complete. Either significant corrections must be made to theSEIS or this Board should require another SEIS be conducted to address the unconsideredsignificant increase o~fradionuclides in groundwater.The SETS incorrectly states that the radioactivity in the leaks is reducing, when in f'act theradioactivity has progressively increased fr'om when leaks at Indian Point were firstreported in the 1990's yet have never been f'ully identified or stopped.In M'arch 2014, readings were as high as 660,000 pCi/liter, which is 33 times higher thanthe safe drinking water limit (20,000 pCi/I).February 2015 readings were as high as 900,000 pCi/I -45 times higher than the safedrinking water limit.The February 2016 new reading of 8,000,000) pCi/I is not only 400 times above the safedrinking water limit of 20,000 pCi/I, but it is nearly 10 times higher than a year ago.

Leaks at Indian Point have been progressively getting worse (by an order of magnitude)yet Entergy's only solution is to allow for "natural attenuation" which results in dumpingincreasingly high levels of tritium into the groundwater and the I-udson River.Entergy has not provided any plan to find all the leaks, stop the leaks and clean up thesite, except to discharge radioactive waste into the Hudson River through naturalattenuation. To repeat an old adage. "Dilution is not a solution to pollution."The NRC's staff conclusion thiat during the relicensing period, rapid dilution of anunknuown amount of radionuclides into the Hudson has SMALL ( SEIS p 99)environmental impact, has no rational basis, since the source of the leaks from SpentFuel Pool #12 remains unknown "the full extent of the leaks is not known" (SEIS p 92, 8)and thereibre cannot be sustainedSince the I-udson is a tidal estuary river, radioactive pollution does not only go down-river, but also goes up-river, where communities, including environmental justicecommulnities of Poughkeepsie, has no other supply and rely on the Hudson for its thedrinking water.If the NRC accepts this SEIS as accurate, it will be improperly condemning communitiesthat rely upon the Hudson River to drink tritium spiked water."Once ingested, tritium's minimal penetration depth could be suflicient to inflictdeleterious effects". (4.2.1 Physical and Chemical Properties of Trititum, LawrenceBerkeley National Laboratory http://www2.lbi.gov/ehs/esg/tritium/tritium/TritCh4.htmlSEIS incorrectly states that 1122 and IP~3 will not adversely affect operations of theproposed Haverstraw Waler Supply Project. While cun'ently the lHudson River is notcurrently being used as a drinking water supply, in part it is due to thle increasingradioactive pollution into the Hudson by Indian Point. The Suez/United Water plan todesalinate the Hudson River water in the l-averstraw Bay, three (3) miles downriver fromIndian Point, was vehemently opposed by Rockland County residents, for among otherreasons, the people of Rockland County refused to finance the desalination plant whichwould always be at risk of contamination in the event the leaks at Indian Point continueto increase.The samples from the pilot desalination plant in the Haverstraw Bay identifiedmeasurable levels of Strontium 90 detected in the majority of the samples which weretaken in 2007, (see Exhibit 1).In 2007 levels of total radiation is 9030 picocuries (pCi/l). The 2015 levels of tritiumlevels 8,000,000 pCi/I.

Water ResourcesThle SEIS incorrectly states in 5.4.1.3 Water Resources that"Potable water sources near the IlP2 and IP3 site are not presently derived fromgroundwater sources or the lHudson River (NRC 2010). There are no residential ormunicipal drinking water wells near IP2 and [P3 (Entergy 201 2a; NYSDEC 2007;NRC 2010)."1P2 and 1P3 should not be allowed to continue releasing radioactive pollution intogroundwater and Hudson River. New York State law requires that all groundwater inthe state is potable.Entergy notes, that the inspection report was supposed to begin a remediation effort tostop the spread of contamination and get the leaks under control. This Board must askthen why is the problem getting so much worse, and not better?The comparison to Flint must be made; if the NRC adopts this SETS, groundwater will bepolluted because government regulators have failed in their job of protecting publichealth and safety.These leaks maps included in the SEIS show that the radioactive effluent is imbeddeddeeply in fracture bedr'ocks to depths 2 to 3 times the height of the containment structure.The containment structure is 27 stories, or 276 feet; underground wells of radioactivewaste are as much as 54-81 stories or 552 ft to 828 feet deep. (a mining permit is neededfor infiltration into the ground of more than 500 :feet). A new SETS must be ordered toinvestigate the impact of increasing radiation plumes over 500 feet deep.The SEIS fails to consider the airborne impacts of increased leaks which releasesincreased levels of radiation into the H-udson River, as a result of evaporation andcondensation.Although the NRC has acknowledged that Spent Fuel Pool 112 has seismic cracks and a 9inch "pin-hole", they had failed to require it be repaired, or even fully inspected. To date,only 40% of the pooi has been inspected.In 201.4 monitoring wells showed 616,000 pci,In 201 5 monitoring well showed 900,000 pciNow in 2016 its over 8,000,000 pciThe leaks have been progressively getting worse.Based on recent dramatic increase in leak levels, SEIS section 5.4.2 RadionuclidesRelease to Groundwater is wholly incomplete and insufficient and a supplemental SEISmust be conducted on this issue, especially since Entergy acknowledges in the SEIS thatthey do not know, "How these radlionuclides got into the groundwater has not beendetermined". (SEIS5 p 81, 7)

The SEIS provides no mitigation measures to find, stop and remediate all the leaks atIndian Point. Although more comprehensive monitoring is necessary for both air andwater releases, just increasing monitoring or watching as leaks occur is not an agingmanagement strategy to protect the environment and htmnan health of increase exposureto toxic radiation. Thus, the SEIS is incomplete, since the only mitigating measuresconsidered is to increase "natural attenuation" leaking into New York State'sgroundwater and I-udson River.In September 2009. thle NRC staff issued a report that confirmed that Entergy wasconforming to NRC regulatory requirements that protect public health and safety and theenvironment (NRC 2012e)", and "there is no radiological impact to the surroundingenvironment from the 1P2 and IP3 site 40 (NRC 2010)". it is unfounded to include thisstatement in the SEIS, in light of the large new leaks.The SEIS claims that, '"The planned remedy for the strontium-90 contamination (i.e.,removal of the spent fnel and water from the IP1 spent fulel pool) will remove the activesource of contamination for that plume, but residual contamination will continue formany years."Theref'ore, since it is acknowledged that tritium contamaination primarily came from. the1P2 spent fuel pool, and since, "the full extent of the leaks is not known because of aninability to inspect the liner in the IP2 spent fuel pool while the unit is operating", theNRC must order IP2 spent fuel pool to be immediately shut down, excessive spent fuelmust be removed from the pool and placed into dry cask storage, immediately, and acomplete inspection, identification and remediation of the entire spent fuel pool must beconducted.The SEIS's planned use of monitored natural attenuation is NOT an acceptable approachto maanaging the remaining strontium-90 and tritiunm plumes.Entergy's aging management plan to increase radioactive pollution in the IHudson Rivercannot rationally or reasonably be approved as have SMALL impact.SEIS incorrectly asserts that if the NRC approves a 20 year license for Entergy tocontinue operations at Indian Point "the mass of a radiological. contaminants decreases,the concentration of that radiological contaminants would see a corresponding decrease".(SETS p 69).This is utter nonsense. If the plant operates for 20 more years. every day it continues tooperate the amount of radiological contamainants correspondingly increase. If amounts ofnuclear waste increases , so does the amount of radiological contaminants.The NRC can not adopt this SETS ,as it includes too many misrepresentations, whichdefy simple reason and logic.

While we agree that, "When the source of water containing tritium is stopped, thecontaminated water reaching the water table should eventually stop." (SEIS p 69-70)Yet, the current SEIS allows for continued attenuation of the leaks into the H-udson River.Based on the new circumstances of the progressively worsening leaks, the SEIS includesa statement which is patently incorrect, and must be changed, "From 2007 through 2014,tritium concentrations have generally decreased,.... [and] concentrations ofradionuclides in groundwater entering the river are generally remaining the same ordecreasing. Therefore, over the period of license renewal, the Hudson River is unlikely tosee higher concentrations of radionuclides flowing into the Hudson River." (SEIS p. 71)The recent larger leaks are clear evidence that the tritium concentrations have increased,not decreased at Entergy projected. Thus, any references to decreasing concentration ofradionuclides of tritium in the SEIS must be removed, otherwise the document is notbased in fact, but fiction.Entergy's claim that they can predict that the leaks at Indian Point will decrease duringthe next 20 years, cannot be relied upon, since this assertion has already been shown to beuntrue by incontraverable evidence.SEIS Table 5 -3 Yearly Average of Radionuclide Concentration in GroundwaterSampling Station Located near Hudson River shows that in 2007, 9,030 pCi/L ofTritium were found in the groundwater. Now 9 years later in 2016. over 8,000,000pCi/L of' tritium has been found.This is 1000 fold increase in levels of radiation being leaked into the ground water andH-udson River. The new leaks have created a significant new circumstance upon whichthe NRC must require an additional SEIS be conducted to consider the environmentalimpacts of the radiological continuing and increasing radioactive leaks at Indian Point.The current SETS is inadequate, as it contains many incorrect statements such as that,"The sealing of leaks associated with the 1P2 spent fuel pool has stopped the leakage oftritium into the groundwater in those sources." (SEIS p 99) And that "tritiumconcentrations in the groundwater have deceased substantially." (SEIS p 94) Thisstatement is factually incorrect and should not be included in the SEIS.The NRC's conclusion that impacts to groundwater quality could be mitigated to SMALLduring the license renewal term through elimination radionuclides leaks to thegroundwater and the use of monitored natural attenuation. (SEIS p1 28)This board must either require a rewrite of the SEIS or a new SEIS based on thesignificant new information and change of circumstances, which found an increase inradioactive material, and one of the wells showed a 65,000 percent increase in radioactivewaste, for which Entergy's only plan for remediation is to allow it to pollute the HudsonRiver.

CLIMATE CHANGESEIS 5.13. Greenhouse Gas Emissions and Climate Change, correctlyconcludes that, "the effects from climate change could have negative implications forindustrial cooling and potable water use." (SEIS p.1 104) Yet it does not provide anymitigation measures to address these significant issues.The SETS fails to consider the impact of increased levels of the Hudson River duringlarger storm systems associated with climate change and rising sea levels. Super StormnSandy was approximately only a foot away :from breaching the banks of the Hudson andflooding Indian Point, which would result enormous releases of radiation into the Hudsonand Hudson Valley air.SETS Table 5-6 Comparison of GHG Emission Inventories, is inaccurate andincomplete and does not include the new carbon atoms, Carbon 14. produced by IndianPoint every day from :fission. Every day nuclear fission occurs, new carbon atoms,Carbon 14 atoms, are created and released as radioactive C02 and methane emission fromIP2 and 3. Unlike fossil fuels which release sequestered carbon during energy production,:fission actually creates new carbon atoms, which changes the Earth's carbon balance.Thus the newly created carbon emissions from nuclear fission are not monitored, butonly estimated since 2010, theref~ore Table 5-4 cannot be accepted by this Board as beingfactually accurate or complete. Without actual data and measurements the statement"that GUG emissions restulting fr'om operations at 1P2 and 1P3 are below the EPA'sreporting threshold of 25,000 MT (27,558 tons) of C02." is without factual basis.Please refer to the EPRI 2010 Technical Report, Estimation of Carbon-14 in NuclearPower Plant Gaseous Effluents which references a study which found that "people living1 km from thae site could potentially double their carbon body burden if all of the gaseousreleases were as C02 (EPRI 2010 report 4-1 1).Thus Indian Point's impacts on climate change have not been fuflly considered and theSEIS cannot be relied upon.The SEIS f'ails to consider the impacts of direct of thermal pollution produced by IndianPoint 2 and 3 on climate ch,-nge.

The above thermal infr'a-red image taken by scientists from GER/SpectroTech, Inc.indicates discharge temperatures lfrom Indian Point to be up to 14.5 degrees hotter thanambient river water. One scientist noted that the plume appeared to be devoid of life.This image was taken in 1998, prior to the use of high-burn up fuel, which burns muchhotter and most likely creates hotter discharge temperatures.One of the primary byproducts of nuclear fuel generation is hot water, since water is usedto cool the nuclear reactor and heats up during the process. Much of that hot water isdumped into lakes and streams; the process could potentially raise the temperature bothof these bodies of water and of the ground.Swedish scientists B3o Nordell and Bruno Gervet, in the International Journal of GlobalWarming, 2010, found that heat itself, not jutst gas, could change the climate, as net heatemissions, which includes lowv-temperature waste heat which is dumped into sea/riverwater or the atmosphere or heat leakage fi'om buildings is transferred to the surroundingair or ground. Accordingly nuclear power is a large contributor to global warming Forty years of nuclear energy production worldwide has produced approximately 11 % ofworldwide electricity, yet has released approximately 1 .58E +/-18 BTUs, which is enoughthermal heat to melt 25% of the earth's ice.Indian Point 2 and Indian Point 3 has released 7.89E +15E BTUs over the past 40 years.20 more years of operation, if' permitted, would increase thermal pollution by 3.84E+15IBTU. Thle cumulative thermal pollution releases fr'om Indian Point 2 and 3 areapproximately 1.18E +16.The SETS does not consider thermal pollution impacts to climate change.Nor does the SEIS consider thle climate change impacts ozone production released fromIndian Point.Nor does the SETS consider climate change impacts which, over the next 20 years, stormswill increase in size <and intensity, which will result in increased storms surges, floodingand will raise Hudson River water levels.During Super Storm Sandy, the lHudson River rose swiftly and nearly breached IndianPoint's storm surge barrier. Yet, this important matter has not been addressed in theSETS.6.0 Continued Storage of Spent Nuclear FuelThe SEIS finding that short term (120 year) storage of additional radioactive wasteproduced if the requested new 20 years of a license is approved will have only SMALLimpacts. is wholly unsupported by f'act.The statement that indefinite timeframe -- continuing to store nuclear fuel indefinitely --is unlikely, as well as wholly unsupported by fact or historical evidence.Additionally the SETS fails to consider how both long and short term storage will bemaintained and continued without adequate decommissioning funds being available inperpetuity.In conclusion, there is no reasonable or rational basis for this Board to accept this SEIS asbeing accurate or complete.Sincerely yours.ux,.gsa/i, -I hapiiE ~sq.Onb b~'alf ofP PASE I'EXHIBIT IChapter 2: Projcet iDescription?A DIOL OGIC,4 L A NA.L Y'SISDue to the presence of the Indian Point nuclear power plant on the eastern shore of thle HudsonRiver in Buchanan, NY, some have expressed concern regarding the possible radiologicalcontamination of groundwater as well as the Hudson River close to the plant. A summary of theradiological results from United Water's sampling program is provided below. Table 2-4summarizes the analyses performed for radionuelides in water samples collected at severallocations in the H-udson River iin 2007 and 2008.Table 2-4Results of Radiontlelide SamplingResults: Results:Radloriuelicte a Rag veae MCL2 NotesGross alpha 1lB 0-20 3.5 15 pCilL ...Gross beta 19 0-62 10.8 50 pCiIL Dosage:4 mrems/yrRadium 226/228 16 ND 5 pCi/L(combined)Total uranium 19 0-0.689 0.400 30 ug/L ___________Strontium 90 11 0-0.82 0.680 8 Not detected In 5 out of________ ________ ___________11 samplesTritium 11 0-397 36 20,000 pCi/L3 Not detected in 10 outNotes:of1sapen= Number of samples1 Not detected treated as 0.2 MCL = Maximum contamninant level, the standard set by EPA for these radionuclides. MCLs arecalculated as ttie average of tour quarterly samples.3 Used as guidance whengross beta < 50 pci/I.Drinking water standards for radionuclides first require the determination of "gross alpha" and"gross beta" measurements; these measurements are useful in providing an overall screening todetermine if further analysis of specific radionuclides is needed. Standards of the U.S.Environmental Protection Agency (EPA) may be satisfied by testing for gross alpha and grossbeta radioactivity. The standards are considered to be met when the gross beta activity is lowerthan or at the maximum contaminant level (MCL) set by EPA and concentrations of tritium andstrontium 90 are lower than or at thle MCL. (MCLs for these radionuclides are calculated as tileaverage of four quarterly samples.) As shown in Table 2-4, both gross alpha and gross beta werewell below the EPA MCLs. Also. ,raditum, uranium, strontium 90, and tritium were well belowtheir respective N4lCLs and/or guidance values.

Page 1 of 1As of: 3/7/16 2:29 PMReceived: March,03, 2016PUBLIC SUBMISSIONStts enlgotComments Due: March 04, 2(Submission Type: WebDocket: NRC-2008-0672Environmental Impact Statement; Availability, etc.: Indian Point Nuclear Generating Unit Nos. 2 and 3,Buchanan, NY; License Renewal and Public MeetingComment On: NRC-2008-0672-0029Entergy Nuclear Operations, Inc.; Indian Point Nuclear Generating Unit Nos. 2 and 3; Draft SupplementalEnvironmental Impact Statement; Request for CommentDocument: NRC-2008-0672-DRAFT-003 1Comment on FR Doc # 20 15-32777Submitter Information.....-.,I....,..,,Name: Susan Shapiro, Esq.General Comment .........Please find attached public comments for Docket Number 2008-0672: The Nuclear G-(NRC) Notice: Entergy Nuclear Operations, Inc.; Indian Point Nuclear Generating Unit Nos. 2 and 3; DraftSupplemental Environmental Impact Statement; Request for Comment, Federal Register Number: 2015-32777.AttachmentsPHASE Letter to NRC re IP SEIS commentsSUNSI Review CompleteTemplate = ADM -013E-RIDS= ADM-03Ahttps://www.fdms.gov/fdms/getcontent?obj ectld=090000648 1 e9f69f&format=xml&showorig=false 0/72103/07/2016 MILTON B. SHAPIROATTORNEYS AT LAWSUSAN H. SHAPIRO75 N. MIDDLETOWN ROAD * (4ANUET[ NEW YORK 10954 (4)3]20(845) 371-3721 -FAXmb3@ou rrockIlfldof fw:.comMarch 4. 2016NRCPublic CommentsIRE: Docket Number 2008-0672: The Nuclear Regulatory Commission (NRC)Notice: Entergy Nuclear Operations, Inc.; Indian Point Nuclear Generating UnitNos. 2 and 3; Draft Supplemlental Environmental Impact Statement; Request forComment. Federal Register Number: 2015-327771 am submitting these comments on behalf of Public Health and Sustainable Energy(PH-ASE) in response to the SEIS issued on December 29, 2015.Since the SETS was written prior to significant "new information" and the change ofcircumstance as a result o[" the dramatically increased levels of" tritiunm found in thegroundwater in February 2016, the SEIS contains misleading inf'ormation and cannot beaccepted as accurate and complete. Either significant corrections must be made to theSEIS or this Board should require another SEIS be conducted to address the unconsideredsignificant increase o~fradionuclides in groundwater.The SETS incorrectly states that the radioactivity in the leaks is reducing, when in f'act theradioactivity has progressively increased fr'om when leaks at Indian Point were firstreported in the 1990's yet have never been f'ully identified or stopped.In M'arch 2014, readings were as high as 660,000 pCi/liter, which is 33 times higher thanthe safe drinking water limit (20,000 pCi/I).February 2015 readings were as high as 900,000 pCi/I -45 times higher than the safedrinking water limit.The February 2016 new reading of 8,000,000) pCi/I is not only 400 times above the safedrinking water limit of 20,000 pCi/I, but it is nearly 10 times higher than a year ago.

Leaks at Indian Point have been progressively getting worse (by an order of magnitude)yet Entergy's only solution is to allow for "natural attenuation" which results in dumpingincreasingly high levels of tritium into the groundwater and the I-udson River.Entergy has not provided any plan to find all the leaks, stop the leaks and clean up thesite, except to discharge radioactive waste into the Hudson River through naturalattenuation. To repeat an old adage. "Dilution is not a solution to pollution."The NRC's staff conclusion thiat during the relicensing period, rapid dilution of anunknuown amount of radionuclides into the Hudson has SMALL ( SEIS p 99)environmental impact, has no rational basis, since the source of the leaks from SpentFuel Pool #12 remains unknown "the full extent of the leaks is not known" (SEIS p 92, 8)and thereibre cannot be sustainedSince the I-udson is a tidal estuary river, radioactive pollution does not only go down-river, but also goes up-river, where communities, including environmental justicecommulnities of Poughkeepsie, has no other supply and rely on the Hudson for its thedrinking water.If the NRC accepts this SEIS as accurate, it will be improperly condemning communitiesthat rely upon the Hudson River to drink tritium spiked water."Once ingested, tritium's minimal penetration depth could be suflicient to inflictdeleterious effects". (4.2.1 Physical and Chemical Properties of Trititum, LawrenceBerkeley National Laboratory http://www2.lbi.gov/ehs/esg/tritium/tritium/TritCh4.htmlSEIS incorrectly states that 1122 and IP~3 will not adversely affect operations of theproposed Haverstraw Waler Supply Project. While cun'ently the lHudson River is notcurrently being used as a drinking water supply, in part it is due to thle increasingradioactive pollution into the Hudson by Indian Point. The Suez/United Water plan todesalinate the Hudson River water in the l-averstraw Bay, three (3) miles downriver fromIndian Point, was vehemently opposed by Rockland County residents, for among otherreasons, the people of Rockland County refused to finance the desalination plant whichwould always be at risk of contamination in the event the leaks at Indian Point continueto increase.The samples from the pilot desalination plant in the Haverstraw Bay identifiedmeasurable levels of Strontium 90 detected in the majority of the samples which weretaken in 2007, (see Exhibit 1).In 2007 levels of total radiation is 9030 picocuries (pCi/l). The 2015 levels of tritiumlevels 8,000,000 pCi/I.

Water ResourcesThle SEIS incorrectly states in 5.4.1.3 Water Resources that"Potable water sources near the IlP2 and IP3 site are not presently derived fromgroundwater sources or the lHudson River (NRC 2010). There are no residential ormunicipal drinking water wells near IP2 and [P3 (Entergy 201 2a; NYSDEC 2007;NRC 2010)."1P2 and 1P3 should not be allowed to continue releasing radioactive pollution intogroundwater and Hudson River. New York State law requires that all groundwater inthe state is potable.Entergy notes, that the inspection report was supposed to begin a remediation effort tostop the spread of contamination and get the leaks under control. This Board must askthen why is the problem getting so much worse, and not better?The comparison to Flint must be made; if the NRC adopts this SETS, groundwater will bepolluted because government regulators have failed in their job of protecting publichealth and safety.These leaks maps included in the SEIS show that the radioactive effluent is imbeddeddeeply in fracture bedr'ocks to depths 2 to 3 times the height of the containment structure.The containment structure is 27 stories, or 276 feet; underground wells of radioactivewaste are as much as 54-81 stories or 552 ft to 828 feet deep. (a mining permit is neededfor infiltration into the ground of more than 500 :feet). A new SETS must be ordered toinvestigate the impact of increasing radiation plumes over 500 feet deep.The SEIS fails to consider the airborne impacts of increased leaks which releasesincreased levels of radiation into the H-udson River, as a result of evaporation andcondensation.Although the NRC has acknowledged that Spent Fuel Pool 112 has seismic cracks and a 9inch "pin-hole", they had failed to require it be repaired, or even fully inspected. To date,only 40% of the pooi has been inspected.In 201.4 monitoring wells showed 616,000 pci,In 201 5 monitoring well showed 900,000 pciNow in 2016 its over 8,000,000 pciThe leaks have been progressively getting worse.Based on recent dramatic increase in leak levels, SEIS section 5.4.2 RadionuclidesRelease to Groundwater is wholly incomplete and insufficient and a supplemental SEISmust be conducted on this issue, especially since Entergy acknowledges in the SEIS thatthey do not know, "How these radlionuclides got into the groundwater has not beendetermined". (SEIS5 p 81, 7)

The SEIS provides no mitigation measures to find, stop and remediate all the leaks atIndian Point. Although more comprehensive monitoring is necessary for both air andwater releases, just increasing monitoring or watching as leaks occur is not an agingmanagement strategy to protect the environment and htmnan health of increase exposureto toxic radiation. Thus, the SEIS is incomplete, since the only mitigating measuresconsidered is to increase "natural attenuation" leaking into New York State'sgroundwater and I-udson River.In September 2009. thle NRC staff issued a report that confirmed that Entergy wasconforming to NRC regulatory requirements that protect public health and safety and theenvironment (NRC 2012e)", and "there is no radiological impact to the surroundingenvironment from the 1P2 and IP3 site 40 (NRC 2010)". it is unfounded to include thisstatement in the SEIS, in light of the large new leaks.The SEIS claims that, '"The planned remedy for the strontium-90 contamination (i.e.,removal of the spent fnel and water from the IP1 spent fulel pool) will remove the activesource of contamination for that plume, but residual contamination will continue formany years."Theref'ore, since it is acknowledged that tritium contamaination primarily came from. the1P2 spent fuel pool, and since, "the full extent of the leaks is not known because of aninability to inspect the liner in the IP2 spent fuel pool while the unit is operating", theNRC must order IP2 spent fuel pool to be immediately shut down, excessive spent fuelmust be removed from the pool and placed into dry cask storage, immediately, and acomplete inspection, identification and remediation of the entire spent fuel pool must beconducted.The SEIS's planned use of monitored natural attenuation is NOT an acceptable approachto maanaging the remaining strontium-90 and tritiunm plumes.Entergy's aging management plan to increase radioactive pollution in the IHudson Rivercannot rationally or reasonably be approved as have SMALL impact.SEIS incorrectly asserts that if the NRC approves a 20 year license for Entergy tocontinue operations at Indian Point "the mass of a radiological. contaminants decreases,the concentration of that radiological contaminants would see a corresponding decrease".(SETS p 69).This is utter nonsense. If the plant operates for 20 more years. every day it continues tooperate the amount of radiological contamainants correspondingly increase. If amounts ofnuclear waste increases , so does the amount of radiological contaminants.The NRC can not adopt this SETS ,as it includes too many misrepresentations, whichdefy simple reason and logic.

While we agree that, "When the source of water containing tritium is stopped, thecontaminated water reaching the water table should eventually stop." (SEIS p 69-70)Yet, the current SEIS allows for continued attenuation of the leaks into the H-udson River.Based on the new circumstances of the progressively worsening leaks, the SEIS includesa statement which is patently incorrect, and must be changed, "From 2007 through 2014,tritium concentrations have generally decreased,.... [and] concentrations ofradionuclides in groundwater entering the river are generally remaining the same ordecreasing. Therefore, over the period of license renewal, the Hudson River is unlikely tosee higher concentrations of radionuclides flowing into the Hudson River." (SEIS p. 71)The recent larger leaks are clear evidence that the tritium concentrations have increased,not decreased at Entergy projected. Thus, any references to decreasing concentration ofradionuclides of tritium in the SEIS must be removed, otherwise the document is notbased in fact, but fiction.Entergy's claim that they can predict that the leaks at Indian Point will decrease duringthe next 20 years, cannot be relied upon, since this assertion has already been shown to beuntrue by incontraverable evidence.SEIS Table 5 -3 Yearly Average of Radionuclide Concentration in GroundwaterSampling Station Located near Hudson River shows that in 2007, 9,030 pCi/L ofTritium were found in the groundwater. Now 9 years later in 2016. over 8,000,000pCi/L of' tritium has been found.This is 1000 fold increase in levels of radiation being leaked into the ground water andH-udson River. The new leaks have created a significant new circumstance upon whichthe NRC must require an additional SEIS be conducted to consider the environmentalimpacts of the radiological continuing and increasing radioactive leaks at Indian Point.The current SETS is inadequate, as it contains many incorrect statements such as that,"The sealing of leaks associated with the 1P2 spent fuel pool has stopped the leakage oftritium into the groundwater in those sources." (SEIS p 99) And that "tritiumconcentrations in the groundwater have deceased substantially." (SEIS p 94) Thisstatement is factually incorrect and should not be included in the SEIS.The NRC's conclusion that impacts to groundwater quality could be mitigated to SMALLduring the license renewal term through elimination radionuclides leaks to thegroundwater and the use of monitored natural attenuation. (SEIS p1 28)This board must either require a rewrite of the SEIS or a new SEIS based on thesignificant new information and change of circumstances, which found an increase inradioactive material, and one of the wells showed a 65,000 percent increase in radioactivewaste, for which Entergy's only plan for remediation is to allow it to pollute the HudsonRiver.

CLIMATE CHANGESEIS 5.13. Greenhouse Gas Emissions and Climate Change, correctlyconcludes that, "the effects from climate change could have negative implications forindustrial cooling and potable water use." (SEIS p.1 104) Yet it does not provide anymitigation measures to address these significant issues.The SETS fails to consider the impact of increased levels of the Hudson River duringlarger storm systems associated with climate change and rising sea levels. Super StormnSandy was approximately only a foot away :from breaching the banks of the Hudson andflooding Indian Point, which would result enormous releases of radiation into the Hudsonand Hudson Valley air.SETS Table 5-6 Comparison of GHG Emission Inventories, is inaccurate andincomplete and does not include the new carbon atoms, Carbon 14. produced by IndianPoint every day from :fission. Every day nuclear fission occurs, new carbon atoms,Carbon 14 atoms, are created and released as radioactive C02 and methane emission fromIP2 and 3. Unlike fossil fuels which release sequestered carbon during energy production,:fission actually creates new carbon atoms, which changes the Earth's carbon balance.Thus the newly created carbon emissions from nuclear fission are not monitored, butonly estimated since 2010, theref~ore Table 5-4 cannot be accepted by this Board as beingfactually accurate or complete. Without actual data and measurements the statement"that GUG emissions restulting fr'om operations at 1P2 and 1P3 are below the EPA'sreporting threshold of 25,000 MT (27,558 tons) of C02." is without factual basis.Please refer to the EPRI 2010 Technical Report, Estimation of Carbon-14 in NuclearPower Plant Gaseous Effluents which references a study which found that "people living1 km from thae site could potentially double their carbon body burden if all of the gaseousreleases were as C02 (EPRI 2010 report 4-1 1).Thus Indian Point's impacts on climate change have not been fuflly considered and theSEIS cannot be relied upon.The SEIS f'ails to consider the impacts of direct of thermal pollution produced by IndianPoint 2 and 3 on climate ch,-nge.

The above thermal infr'a-red image taken by scientists from GER/SpectroTech, Inc.indicates discharge temperatures lfrom Indian Point to be up to 14.5 degrees hotter thanambient river water. One scientist noted that the plume appeared to be devoid of life.This image was taken in 1998, prior to the use of high-burn up fuel, which burns muchhotter and most likely creates hotter discharge temperatures.One of the primary byproducts of nuclear fuel generation is hot water, since water is usedto cool the nuclear reactor and heats up during the process. Much of that hot water isdumped into lakes and streams; the process could potentially raise the temperature bothof these bodies of water and of the ground.Swedish scientists B3o Nordell and Bruno Gervet, in the International Journal of GlobalWarming, 2010, found that heat itself, not jutst gas, could change the climate, as net heatemissions, which includes lowv-temperature waste heat which is dumped into sea/riverwater or the atmosphere or heat leakage fi'om buildings is transferred to the surroundingair or ground. Accordingly nuclear power is a large contributor to global warming Forty years of nuclear energy production worldwide has produced approximately 11 % ofworldwide electricity, yet has released approximately 1 .58E +/-18 BTUs, which is enoughthermal heat to melt 25% of the earth's ice.Indian Point 2 and Indian Point 3 has released 7.89E +15E BTUs over the past 40 years.20 more years of operation, if' permitted, would increase thermal pollution by 3.84E+15IBTU. Thle cumulative thermal pollution releases fr'om Indian Point 2 and 3 areapproximately 1.18E +16.The SETS does not consider thermal pollution impacts to climate change.Nor does the SEIS consider thle climate change impacts ozone production released fromIndian Point.Nor does the SETS consider climate change impacts which, over the next 20 years, stormswill increase in size <and intensity, which will result in increased storms surges, floodingand will raise Hudson River water levels.During Super Storm Sandy, the lHudson River rose swiftly and nearly breached IndianPoint's storm surge barrier. Yet, this important matter has not been addressed in theSETS.6.0 Continued Storage of Spent Nuclear FuelThe SEIS finding that short term (120 year) storage of additional radioactive wasteproduced if the requested new 20 years of a license is approved will have only SMALLimpacts. is wholly unsupported by f'act.The statement that indefinite timeframe -- continuing to store nuclear fuel indefinitely --is unlikely, as well as wholly unsupported by fact or historical evidence.Additionally the SETS fails to consider how both long and short term storage will bemaintained and continued without adequate decommissioning funds being available inperpetuity.In conclusion, there is no reasonable or rational basis for this Board to accept this SEIS asbeing accurate or complete.Sincerely yours.ux,.gsa/i, -I hapiiE ~sq.Onb b~'alf ofP PASE I'EXHIBIT IChapter 2: Projcet iDescription?A DIOL OGIC,4 L A NA.L Y'SISDue to the presence of the Indian Point nuclear power plant on the eastern shore of thle HudsonRiver in Buchanan, NY, some have expressed concern regarding the possible radiologicalcontamination of groundwater as well as the Hudson River close to the plant. A summary of theradiological results from United Water's sampling program is provided below. Table 2-4summarizes the analyses performed for radionuelides in water samples collected at severallocations in the H-udson River iin 2007 and 2008.Table 2-4Results of Radiontlelide SamplingResults: Results:Radloriuelicte a Rag veae MCL2 NotesGross alpha 1lB 0-20 3.5 15 pCilL ...Gross beta 19 0-62 10.8 50 pCiIL Dosage:4 mrems/yrRadium 226/228 16 ND 5 pCi/L(combined)Total uranium 19 0-0.689 0.400 30 ug/L ___________Strontium 90 11 0-0.82 0.680 8 Not detected In 5 out of________ ________ ___________11 samplesTritium 11 0-397 36 20,000 pCi/L3 Not detected in 10 outNotes:of1sapen= Number of samples1 Not detected treated as 0.2 MCL = Maximum contamninant level, the standard set by EPA for these radionuclides. MCLs arecalculated as ttie average of tour quarterly samples.3 Used as guidance whengross beta < 50 pci/I.Drinking water standards for radionuclides first require the determination of "gross alpha" and"gross beta" measurements; these measurements are useful in providing an overall screening todetermine if further analysis of specific radionuclides is needed. Standards of the U.S.Environmental Protection Agency (EPA) may be satisfied by testing for gross alpha and grossbeta radioactivity. The standards are considered to be met when the gross beta activity is lowerthan or at the maximum contaminant level (MCL) set by EPA and concentrations of tritium andstrontium 90 are lower than or at thle MCL. (MCLs for these radionuclides are calculated as tileaverage of four quarterly samples.) As shown in Table 2-4, both gross alpha and gross beta werewell below the EPA MCLs. Also. ,raditum, uranium, strontium 90, and tritium were well belowtheir respective N4lCLs and/or guidance values.