February 11, 2010
Dear Governor Douglas:
I believe the tritium leak at ENVY is a greater environmental disaster than you realize. Just one gram of tritium contaminates 500 billion liters of water up to the fed. limit of 20,000pCi/L. The leak has been allowed to continue at full speed for over one month. The level of tritiated water found in groundwater monitoring wells is now at 2.7 million pCi/L, near the level of the reactor water itself. This represents a breach of containment, understood as the systems in the reactor and powerplant intended to isolate radioactive contamination from the public.
The groundwater belongs to the public, not to ENVY. ENVY’s leak has polluted our groundwater to the second highest level of all tritium leaks from reactors in the country. NRC rules have allowed contamination of groundwater resources at 27 leaking nuclear reactors. This is illegal in Vermont. Your agencies can stop the leak by shutting down the reactor, but they are waiting for you to give the nod. You must protect public trust resources. Please instruct your agencies (DPS, ANR, VDH) to act swiftly to turn off the reactor water that is contaminating the groundwater by shutting down the reactor.
It is not necessary to run the reactor at overpressure levels to find the leak. Drilling wells just maps the toxicity and extent of the plume, it does not find the leak. All power plants have design drawings, sophisticated gauges and flow meters on their pipes and engineers who can do mass balance calculations to detect leaks. This has gone on far too long, is based on industry lies and incompetence and NRC tolerance of groundwater pollution, and MUST BE STOPPED IMMEDIATELY. Please do the right thing and act.
Thank you for your rapid consideration of my concerns.
An 11th generation Vermonter and mother, living in the EPZ.
A letter from Sally Shaw’s husband, Bart Bales, follows.
Leak detection in plant systems with regard to the VT Yankee tritium leak.
By Bart Bales, P.E., M.S.M.E
February 9, 2010
This is an evaluation of the facts surrounding the VT Yankee tritium leak as reported in the press and to the public through the VT Dept. of Health’s website. It is the opinion of a registered mechanical engineer with twenty-five years of professional experience in energy engineering. It provides approaches to leak detection in power plant piping systems in general, and evaluates the approach being employed, according to public information, to find the tritium leak at VT Yankee.
1. A plant operator should have up-to-date schematics for all piping and the expected pressures and flow rates throughout the piping network.
2. Design pipe layouts and as-built pipe layouts are necessary elements for responsible operation and maintenance of a power plant.
3. Use of design and as-built drawings and specifications along with gauge and instrumentation operating parameters should provide information sufficient to determine expected flow rates and pressures in the piping networks.
4. The design documents at VT Yankee should enable plant personnel to identify a limited number of pipes that could contain tritiated water.
5. Plant personnel should determine actual flows through and between elements and components of those piping networks that contain tritium, and determine quantities in various storage vessels by a mass balance calculation.
6. These calculations can determine flows from within the plant enclosure to the piping network and storage vessels outside the enclosure and should provide information sufficient to identify the leaking pipe loop.
7. Differences in flows into and out of parts of the network can help localize the leak as the mass balance will indicate a shortfall in expected values for the piping network containing the leak.
8. This is a more prudent approach to leak detection that can allow the plant system to be operated at lower and safer pressures and flow rates until the leak is found and repaired.
9. It is expected that there would be existing flow meters on all the various piping loops, especially those conveying radioactive liquids or gases. These should be calibrated, serviced or replaced and rendered reliably functional to determine flow rates and diagnose leaks.
10. Maintenance of full pressure ratings throughout the power plant should not be necessary to accomplish leak detection. Maintenance of even moderate pressures in the piping will produce a sufficient gradient for leak detection.
11. There is no justification for maintaining pressures at uprated or even original design conditions for leak detection.
12. Fluid flow through holes in the leaking pipes erodes the edges of these holes. Larger holes result in even higher rates of leakage.
13. It should be recognized that the higher the pressure the greater the flow through leaks, and the faster the introduction of contaminants into the groundwater.
14. A higher influx rate into the groundwater increases the rate of migration of the plume into adjacent areas and into the Connecticut River.
15. A more responsible leak detection protocol would be to shut down the plant, evaluate and model analytically, prioritizing the pipe systems most likely to be leaking tritium, then test each system progressively in order of probability that it is the source of the leak.
16. This approach to leak detection methods from inside the plant employs existing flow gauges or installation of mechanical measuring gauges, and use of ultrasonic or inflow measurements.
17. For a plant operator or engineer to lack knowledge of location of piping networks and their contents is an unacceptable situation, especially in the handling of potentially hazardous fluids.