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Cape residents and visitors are "in harm's way" in the event of a radiological accident at the Pilgrim Nuclear Power Station in Plymouth - Massachusetts Emergency Management Agency Director Kurt Schwartz

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Twenty more years for a failed technology?

On May 24, 2012, the NRC voted 4 to 1 to relicense Pilgrim for another 20 years. Chairman Jakzo voted against reclicensing. "All the NRC commissioners except Chairman Jaczko have caved to industry and political pressure and abandoned the NRC's own procedure that requires hearings on a license renewal application is completed before license renewal is granted," said Mary Lampert, director of Pilgrim Watch, who has long called for the plant to be closed.

See July 6, 2006 Statement before Atomic Safety Licensing Board in support of Motions to Intervene

Did you know?

As of 6/1/2011, sixty-four U.S. commercial reactors had been granted 20-year license extensions. Four of these were granted after Fukushima. By November of 2012, 73 relicenses were issued - with none refused.

Emergency planning is a forbidden topic in the NRC nuclear relicensing process. That's right, can't talk about it. The agency that proudly proclaims that protecting the public's safety is it's mission somehow figures that whether the public can escape a radioactive plume is irrelevant to allowing a reactor to operate for another 20 years. Also, a reactor can continue to operate indefinitely while the relicensing process drags on. Yup, Pilgrim's license expires in 2012, but if the rubber stamp... um, I mean license extension isn't ready for several more years, no problem. The original 40-year license doesn't actually expire if the operator wants to continue...

Mary Lampert of Pilgrim Watch on why Pilgrim Relicensing should have been postponed.

Statement of Cape Downwinders on Pilgrim relicensing:

The Entergy Corporation has announced it's intention to submit an application in December, 2004 to extend the operating license for the Pilgrim Nuclear Power Station until 2032 (the present 40-year license is due to expire in 2012).

The NRC stated in Boston, July 2003, that they expect 100 reactors to apply for re-licensing in the next two years. A nuclear power reactor licensee may apply to the NRC to renew its license for another 20 years of operations as early as 20 years or as late as five years before expiration of its current license. License renewal is expected to take about 30 months. The license renewal process proceeds along two tracks: one for technical reviews of safety issues (Part 54) and another for environmental issues (Part 51). There is some opportunity for the public to intervene and take action.

Emergency planning, security against terrorist attack, control of routine emissions, containment integrity, spent fuel storage - each of these critical systems was inadequate in the early seventies; all are inadequate and most are far worse now. We have much greater population density, a far greater terrorist risk environment, an allowable radioactive emissions standard greater than the original design specification, an admittedly-inferior reactor containment which has been further compromised by the added direct torus vent, and above-ground fuel storage which exceeds it's maximum design capacity by three times.

Does re-licensing make sense with uninspected safety components which have 3 decades of stress-corrosion cracking and embrittlement, or with once-thru cooling - which would not be allowed in another generating station - harming the marine environment of Cape Cod Bay?

Much has changed in forty years; there should be a thorough, independent, cost-benefit analysis. And Price-Anderson, originally sold as a temporary subsidy for an industry too new to be insurable, continues today because the marketplace has determined that nuclear energy is too risky to insure.

Cape Downwinders opposes relicensing of the Pilgrim nuclear power station for the following reasons:

  1. Emergency planning
  2. Radioactive waste
  3. Containment structures
  4. Off-site power supply
  5. Age degradation
  6. Radioactive release
  7. Off-site real-time meteorological and radiation monitoring
  8. Compliance with all NRC fire regulations
  9. Security
  10. Analysis of costs, benefits and alternatives
  11. Marine life must be protected

1. Emergency planning must be upgraded to prepare for a fast breaking event of significant radiological consequence - which would impact an area far beyond the current 10-mile Emergency Planning Zone. Updated independent studies of worst-case accident consequences must be done at the operator's expense, and "shadow evacuation" must be anticipated. The EPZ must be expanded to a 20-mile radius, which more closely corresponds to federal studies estimating the consequences of a core melt. Due to risks imposed by PNPS and exacerbated by their unique geographic location, Cape Cod and the Islands must also be included in the EPZ. Emergency planning must be realistically and regularly tested. All local plans must be certified as having the full confidence of their local governments.

2. Radioactive waste must be stored in a manner to ensure no risk of fire and attendant catastrophic contamination. According to a report from the Massachusetts Attorney General's Office, the consequences could reach $488 billion dollars, 24,000 latent cancers, and contamination of over 100 square miles. As argued by the Massachusetts Attorney General, all but recently unloaded fuel must be transferred to hardened dry casks, returning the spent fuel pool to its original and safer design of low-density racks.

3. Containment structures must be upgraded as required to provide reliable containment of radioactive material in the event of a core-melt accident. All three real-world tests of the direct torus-vent failed at Fukushima. Therefore the torus-vent system must be fully evaluated and re-engineered to assure successful protection of the containment from over-pressurization as well as complete closure after venting.

4. Off-site power supply must be independently evaluated, and upgraded as needed to ensure reliability. All cables buried in wet or marine environments must be qualified to operate in such an environment. Additionally, Pilgrim must: demonstrate that it can withstand and adequately respond to loss of the primary operating power source for at least 14 days and a loss of the primary backup operating power source for at least 72 hours; store at least 14 days worth of emergency power system fuel on-site; have sufficient secondary emergency power to power the licensed facility in the event of a loss of both the primary operating power source and the emergency power system for at least 72 hours.

5. Age degradation of components must be assessed by federal, on-site, inspection of all safety components, with certification that such components meet design specifications.

6. Radioactive releases: Dose-effects must be re-calculated based upon: our specific population profiles (although women and children are far more susceptible to radiation, the current practice uses only a hypothetical healthy young adult male); and modern radiation-risk estimates. (There has been a three- to ten-fold increase in cancer risk coefficients since 1972, given the latest studies on radiation risk at low dose [Beyea, 2006 and Cardis et al. 2005]). There must be verification of compliance by monitoring all egress routes, including the torus vent, and replacement of current radiation monitors with the latest, more sensitive technology which must report to the public in real-time. Torus vent releases must be filtered before final venting.

7. Off-site real-time meteorological and radiation monitoring, ringed from Cape Cod to Scituate, for emergency planning and activation as well as meaningful epidemiological data, must be installed and report in real-time to MDPH and MEMA.

8. PNPS must demonstrate full compliance with all NRC fire regulations. The NRC has estimated that the reactor meltdown risk from fire hazards is roughly equal to the meltdown risk from ALL other hazards combined, assuming that the plants are in complete compliance with fire protection regulations. And there have been an average of about 10 fires per year at U.S. reactors over the past 15 years, according to NRC records. Yet NRC Commissioner Gregory Jaczko stated in July 2008: "I don't think there is one plant right now that is in compliance with those regulations."

9. Security must be sufficient to guarantee the successful deterrence of an attack on the reactor building, its support structures and spent fuel storage from the air, land, and water by a dedicated, well-organized team of well-equipped terrorists. The NRC has said of it's strategies for preventing terrorist damage to reactor sites, "identified response capabilities will not ensure success under the full spectrum of potential damage states." (NRC's B5b guidance)

10. Analysis of costs, benefits and alternatives must be independently performed to demonstrate that: the reactor can compete, without subsidies, with other energy sources, and; there is a need for its continued operation to meet our projected energy requirements.

11. Marine life must be protected and PNPS must be held to the same standards as other individuals and groups impacting aquatic ecology. Once-through cooling of inefficient nuclear technology, with thermal pollution of one billion gallons per day, must be replaced with cooling towers - the best technology available to prevent harm to marine life. (see Licensed to Kill).

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