ML16062A391
| ML16062A391 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/29/2016 |
| From: | Dubois P Jones River Watershed Association |
| To: | Arthur Burritt, Jennifer Davis, Dan Dorman, Robert Kuntz Japan Lessons-Learned Division, NRC Region 1, NRC/RGN-I/DRP/PB5 |
| Venkataraman B, NRR/DORL, 415-2934 | |
| Shared Package | |
| ML16062A393 | List: |
| References | |
| LTR-16-0110 | |
| Download: ML16062A391 (7) | |
Text
February 29, 2016 Arthur Burritt, Chief Jack Davis, Director Reactor Projects Branch 5 (Region 1) Japan Lessons Learned Division Division of Reactor Projects Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Daniel Dorman Robert Kuntz Region 1 Office Administrator Senior Project Manager, Hazards Management Branch U.S. Nuclear Regulatory Commission Japan Lessons Learned Division Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Re: Updated NGRP Site Maps for Pilgrim Nuclear Power Station
Dear NRC Staff,
On behalf of Jones River Watershed Association (JRWA), I would like to provide you with updated site maps for Entergys Pilgrim Nuclear Power Station that were commissioned from Northeastern Geospatial Research Professionals (NGRP).
In our January 18, 2016 letter1 concerning an analysis of AREVAs Flood Hazard Re-Evaluation Report (the AREVA Report) for Pilgrim, we mentioned that we would soon be forwarding you updated maps from NGRP. These new maps are updated from those originally provided to your agency in February 2015 and are based on more current LiDAR information processed by the company Coastal Risk Consulting, and improved tidal datum based on the Boston buoy. Links to the maps are provided at the end of this letter.
These new 2016 maps illustrate:
Entergys site maps prior to 2014 used outdated data from 1968 (mean sea level today is more than 6 inches higher than it was in 1968) to develop site plans for infrastructure (including its dry cask storage facility); those plans do not reflect current NAVD88 topographical elevations and do not provide an accurate basis for evaluating risks of sea level rise and other coastal impacts.
The height of the breakwater jetties and other elevations in NGRPs maps appear significantly lower than those shown in Entergys plans, and are uneven, demonstrating that the site is not as protected from flooding and sea level rise as Entergy reports.
There are discrepancies ranging from +4 in. to -15 ft. when comparing Entergys plans to more current elevation information because Entergy uses mixed and outdated standards of measurements for vertical elevations and water levels.
Entergy claims that it performed a site survey and its own aerial LiDAR mapping for the Pilgrim site (2014), but has not made these products publically available. It would be most useful to be able to compare Entergys 2014 site survey and LiDAR maps that are referred to in the AREVA Report to the products produced by NGRP.
1 JRWA letter to NRC, Jan. 18, 2016. Re: Analysis of AREVA Flood Hazard Re-Evaluation Report for Pilgrim Nuclear Power Station See:
www.capecodbaywatch.org/wp-content/uploads/2016/01/LetterJRWAtoNRC_2016Jan18_FINAL.pdf 1
Entergys previous site plans falsely claim the site is more protected than it actually is. Since Pilgrim will be ending operations soon, it is critically important to fully understand the risks associated with coastal hazards in order to implement a timely clean up and decommissioning strategy. As sea levels increase, so do groundwater elevations that will affect contamination present on the site. These new NGRP maps illustrate the need for Pilgrim to be decontaminated and decommissioned within a decade of closure, as opposed to being allowed to sit idle for decades or up to 60 years under long-term SAFSTOR.
Pilgrims dry cask storage facility and stranded low-level radiological waste storage areas are also adjacent to the shoreline, and vulnerable to coastal inundation. Climate change will bring a radical increase in regional sea levels and coastal storms. Increasingly, predictions dictate that all nuclear waste should be shipped offsite within a decade of closure. These corrected NGRP maps illustrate certain urgency for nuclear waste storage areas to be moved farther away from Cape Cod Bay and to higher elevations, or moved offsite, in order to protect people and the environment. This will help avoid potential accidents and leaks and will set the stage for complete and thorough site cleanup. This issue should be addressed immediately, before more casks are filled after shutdown.
We look forward to further discussing these issues with NRC staff. Please contact me at your earliest convenience to set up a time to meet and discuss these issues.
Sincerely, Pine duBois Executive Director, Jones River Watershed Association pine@jonesriver.org
Enclosure:
Northeastern Geospatial Research Professionals updated Pilgrim site maps (2016). Images attached and links to high-resolution PDF maps are as follows:
Updated in 2016: Shoreline Profile Sections; FEMA Flood and LIDAR Elevations New in 2016: Historic Site Plan and Elevations; FEMA Flood Zones and Historical Site Plan cc:
Governor Baker Congressman William Keating Rep. Tom Calter Senator Edward Markey Senator Vinny deMacedo Rep. Matt Muratore Attorney General Maura Healy Plymouth Board of Selectmen Rep. Randy Hunt Senator Elizabeth Warren Mr. Matthew Beaton, EOEAA Secretary Mr. Stephen Burns, NRC Chair Mr. Bruce Carlisle, MassCZM Director Mr. Curt Spalding, EPA Region I Administrator Mr. Martin Suuberg, MassDEP Commissioner Mr. Dave Webster, EPA Water Permit Branch Chief Ms. Jan Sullivan, MassDPH Acting Assistant Commissioner f
Mr. Arnie Gunderson, Fairewinds Mr. David Lochbaum, UCS Mr. Tim Judson, NIRS Dr. Marvin Resnikoff, Radioactive Waste Management Assoc.
Ms. Deb Katz, CAN Mr. Raymond Shadis, New England Coalition 2
3 4
5 6
CHAIRMAN Resource From: Karen Vale <karen@jonesriver.org>
Sent: Tuesday, March 01, 2016 2:31 PM To: Burritt, Arthur; Davis, Jack; Kuntz, Robert; daniel.dorman@nrc.gov Cc: Stolle.singleton@state.ma.us; Calter, Thomas - Rep. (HOU); Vinny.deMacedo@masenate.gov; ago@state.ma.us; Hunt, Randy - Rep (HOU); Jackman, Michael; Freedhoff, Michal (Markey);
Muratore, Mathew - Rep. (HOU); Stephanie_Houghton@warren.senate.gov; env.internet@state.ma.us; CHAIRMAN Resource; Bruce.carlisle@state.ma.us; spalding.curt@epa.gov; Sullivan, Jan (DPH); martin.suuberg@state;ma.us; webster.david@epa.gov; radwaste@rwma.com; sailchamplain@gmail.com; timj@nirs.org; deb katz; Dlochbaum@ucsusa.org; Ray Shadis
Subject:
[External_Sender] Updated NGRP Site Maps for Pilgrim Nuclear Power Station Attachments: Letter to NRC_2016Feb_NewMaps_FINAL.pdf
Dear NRC Staff,
Please see attached for updated site maps for Entergy's Pilgrim Nuclear Power Station, commissioned from Northeastern Geospatial Research Professionals. These new site maps are updated from those originally provided to your agency in February 2015 and are based on more current LiDAR information and improved tidal datum.
Please let me, or Pine duBois (pine@jonesriver.org), know if you have any questions.
Thank you, Karen Vale Karen Vale Program Manager Jones River Watershed Association karen@ jonesrive r. org 508-951-4723 Web: www.jonesriver.org Facebook: www. face book. com!JonesRive rlanding Flickr: www.flickr.com/photos/jonesriver/sets 1
February 29, 2016 Arthur Burritt, Chief Jack Davis, Director Reactor Projects Branch 5 (Region 1) Japan Lessons Learned Division Division of Reactor Projects Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Daniel Dorman Robert Kuntz Region 1 Office Administrator Senior Project Manager, Hazards Management Branch U.S. Nuclear Regulatory Commission Japan Lessons Learned Division Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Re: Updated NGRP Site Maps for Pilgrim Nuclear Power Station
Dear NRC Staff,
On behalf of Jones River Watershed Association (JRWA), I would like to provide you with updated site maps for Entergys Pilgrim Nuclear Power Station that were commissioned from Northeastern Geospatial Research Professionals (NGRP).
In our January 18, 2016 letter1 concerning an analysis of AREVAs Flood Hazard Re-Evaluation Report (the AREVA Report) for Pilgrim, we mentioned that we would soon be forwarding you updated maps from NGRP. These new maps are updated from those originally provided to your agency in February 2015 and are based on more current LiDAR information processed by the company Coastal Risk Consulting, and improved tidal datum based on the Boston buoy. Links to the maps are provided at the end of this letter.
These new 2016 maps illustrate:
Entergys site maps prior to 2014 used outdated data from 1968 (mean sea level today is more than 6 inches higher than it was in 1968) to develop site plans for infrastructure (including its dry cask storage facility); those plans do not reflect current NAVD88 topographical elevations and do not provide an accurate basis for evaluating risks of sea level rise and other coastal impacts.
The height of the breakwater jetties and other elevations in NGRPs maps appear significantly lower than those shown in Entergys plans, and are uneven, demonstrating that the site is not as protected from flooding and sea level rise as Entergy reports.
There are discrepancies ranging from +4 in. to -15 ft. when comparing Entergys plans to more current elevation information because Entergy uses mixed and outdated standards of measurements for vertical elevations and water levels.
Entergy claims that it performed a site survey and its own aerial LiDAR mapping for the Pilgrim site (2014), but has not made these products publically available. It would be most useful to be able to compare Entergys 2014 site survey and LiDAR maps that are referred to in the AREVA Report to the products produced by NGRP.
1 JRWA letter to NRC, Jan. 18, 2016. Re: Analysis of AREVA Flood Hazard Re-Evaluation Report for Pilgrim Nuclear Power Station See:
www.capecodbaywatch.org/wp-content/uploads/2016/01/LetterJRWAtoNRC_2016Jan18_FINAL.pdf 1
Entergys previous site plans falsely claim the site is more protected than it actually is. Since Pilgrim will be ending operations soon, it is critically important to fully understand the risks associated with coastal hazards in order to implement a timely clean up and decommissioning strategy. As sea levels increase, so do groundwater elevations that will affect contamination present on the site. These new NGRP maps illustrate the need for Pilgrim to be decontaminated and decommissioned within a decade of closure, as opposed to being allowed to sit idle for decades or up to 60 years under long-term SAFSTOR.
Pilgrims dry cask storage facility and stranded low-level radiological waste storage areas are also adjacent to the shoreline, and vulnerable to coastal inundation. Climate change will bring a radical increase in regional sea levels and coastal storms. Increasingly, predictions dictate that all nuclear waste should be shipped offsite within a decade of closure. These corrected NGRP maps illustrate certain urgency for nuclear waste storage areas to be moved farther away from Cape Cod Bay and to higher elevations, or moved offsite, in order to protect people and the environment. This will help avoid potential accidents and leaks and will set the stage for complete and thorough site cleanup. This issue should be addressed immediately, before more casks are filled after shutdown.
We look forward to further discussing these issues with NRC staff. Please contact me at your earliest convenience to set up a time to meet and discuss these issues.
Sincerely, Pine duBois Executive Director, Jones River Watershed Association pine@jonesriver.org
Enclosure:
Northeastern Geospatial Research Professionals updated Pilgrim site maps (2016). Images attached and links to high-resolution PDF maps are as follows:
Updated in 2016: Shoreline Profile Sections; FEMA Flood and LIDAR Elevations New in 2016: Historic Site Plan and Elevations; FEMA Flood Zones and Historical Site Plan cc:
Governor Baker Congressman William Keating Rep. Tom Calter Senator Edward Markey Senator Vinny deMacedo Rep. Matt Muratore Attorney General Maura Healy Plymouth Board of Selectmen Rep. Randy Hunt Senator Elizabeth Warren Mr. Matthew Beaton, EOEAA Secretary Mr. Stephen Burns, NRC Chair Mr. Bruce Carlisle, MassCZM Director Mr. Curt Spalding, EPA Region I Administrator Mr. Martin Suuberg, MassDEP Commissioner Mr. Dave Webster, EPA Water Permit Branch Chief Ms. Jan Sullivan, MassDPH Acting Assistant Commissioner f
Mr. Arnie Gunderson, Fairewinds Mr. David Lochbaum, UCS Mr. Tim Judson, NIRS Dr. Marvin Resnikoff, Radioactive Waste Management Assoc.
Ms. Deb Katz, CAN Mr. Raymond Shadis, New England Coalition 2
3 4
5 6
CHAIRMAN Resource From: Karen Vale <karen@jonesriver.org>
Sent: Tuesday, March 01, 2016 2:31 PM To: Burritt, Arthur; Davis, Jack; Kuntz, Robert; daniel.dorman@nrc.gov Cc: Stolle.singleton@state.ma.us; Calter, Thomas - Rep. (HOU); Vinny.deMacedo@masenate.gov; ago@state.ma.us; Hunt, Randy - Rep (HOU); Jackman, Michael; Freedhoff, Michal (Markey);
Muratore, Mathew - Rep. (HOU); Stephanie_Houghton@warren.senate.gov; env.internet@state.ma.us; CHAIRMAN Resource; Bruce.carlisle@state.ma.us; spalding.curt@epa.gov; Sullivan, Jan (DPH); martin.suuberg@state;ma.us; webster.david@epa.gov; radwaste@rwma.com; sailchamplain@gmail.com; timj@nirs.org; deb katz; Dlochbaum@ucsusa.org; Ray Shadis
Subject:
[External_Sender] Updated NGRP Site Maps for Pilgrim Nuclear Power Station Attachments: Letter to NRC_2016Feb_NewMaps_FINAL.pdf
Dear NRC Staff,
Please see attached for updated site maps for Entergy's Pilgrim Nuclear Power Station, commissioned from Northeastern Geospatial Research Professionals. These new site maps are updated from those originally provided to your agency in February 2015 and are based on more current LiDAR information and improved tidal datum.
Please let me, or Pine duBois (pine@jonesriver.org), know if you have any questions.
Thank you, Karen Vale Karen Vale Program Manager Jones River Watershed Association karen@ jonesrive r. org 508-951-4723 Web: www.jonesriver.org Facebook: www. face book. com!JonesRive rlanding Flickr: www.flickr.com/photos/jonesriver/sets 1