ML17013A013

Y020170004 - Letter Expressing Concerns About Flooding Risks at Pilgrim Nuclear Power Station

ML17013A013
Person / Time
Site:	Pilgrim
Issue date:	12/26/2016
From:	Dubois P, Vale-Vasilev K Cape Cod Bay Watch, Jones River Watershed Association
To:	Arthur Burritt, Jennifer Davis, Bill Dean, Dan Dorman, Griffith A, Robert Kuntz Office of Nuclear Reactor Regulation, Japan Lessons-Learned Division, NRC/RGN-I/DRP/PB5, Region 1 Administrator, US Dept of Energy, Office of Nuclear Energy
DORL
Shared Package
ML17013A011	List: ML17013A013 ML17034A280
References
Y020170004
Download: ML17013A013 (7)

Text

781-585-2322

• 55 LANDING ROAD, KINGSTON, MASSACHUSETTS 02364

• WWW.JONESRIVER.ORG December 26, 2016 William Dean, Director Jack Davis, Director U.S. Nuclear Regulatory Commission Japan Lessons Learned Division Office of Nuclear Reactor Regulation Daniel Dorman U.S. Nuclear Regulatory Commission Region 1 Office Administrator U.S. Nuclear Regulatory Commission Robert Kuntz, Senior Project Manager Hazards Management Branch Arthur Burritt, Chief Japan Lessons Learned Division Reactor Projects Branch 5 (Region 1) Office of Nuclear Reactor Regulation Division of Reactor Projects U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Mr. Andrew Griffith Associate Deputy Assistant Secretary for Fuel Cycle Technologies U.S. Department of Energy, Office of Nuclear Energy 1000 Independence Ave SW, Washington, DC 20585 RE: Pilgrim Nuclear Power Station, Plymouth, Massachusetts

Dear NRC and DOE Staff,

We are writing to express legitimate concerns about the Pilgrim Nuclear Power Station (PNPS) site that should be immediately addressed by your agencies. We continue to believe that the PNPS site, including its nuclear waste storage area, are at risk from flooding and storms. New aerial photos underscore these concerns.

In 2015 and 2016, we provided NRC staff with several letters expressing concern about potential flooding and storm impacts on the PNPS site.1 We first forwarded NRC staff a 2015 report called Analysis of AREVA Flood Hazard Re-Evaluation Report for Pilgrim Nuclear Power Station, which we had commissioned from Coastal Risk Consultants. According to this report, Entergys March 2015 Pilgrim Nuclear Power Station Flooding Hazard Reevaluation Report

(#51-9226940-000) underestimates and omits important risk factors, uses outdated data, and does not consider future risk estimates for rainfall and sea level rise.

1 JRWA letter to NRC. Jan. 18, 2015. Re: Analysis of AREVA Flood Hazard Re-evaluation Report for Pilgrim Nuclear Power Station; JRWA letter to NRC. Feb. 11, 2015. Re: Entergys Hazards Reevaluation Report of Pilgrim Nuclear Power Station, Plymouth, MA (License no. DPR-35); JRWA letter to NRC. Feb. 29, 2016. Re: Updated NGRP Site Maps for Pilgrim Nuclear Power Station.

In February 2016, we also forwarded NRC staff updated site maps for the PNPS site that we had commissioned from Northeastern Geospatial Research Professionals (NGRP). These site maps highlighted inaccurate elevation data used by Entergy when estimating flood risk at the PNPS site.

We are now bringing to your attention two aerial photographs taken in November 2016 (Appendix A), which show that NGRPs site maps are accurate (Appendix B). These photos validate the LiDAR data used by NGRP to generate the site maps - the jetty in the photos are over-washed with seawater in the same locations depicted as lower elevations in the site maps, despite Entergys claims that the PNPS elevations are higher. Its important to note that the photos, based on tidal marks and rack lines, are of the PNPS site during moderate wind and weather conditions and likely after high tide (Appendix C). During just a Category 1 storm, both the easterly revetment and the southerly jetty would be inundated.

We again urge your agencies to review these maps and recognize the threat posed by coastal flooding and storms at the PNPS site. We strongly urge you to require PNPS to permanently stop operations now, and require its stockpile of nuclear waste to be moved to higher elevation and further from the shoreline. Climate change will only bring harsher conditions to our shores.

PNPSs nuclear waste should be moved now, before more casks are filled and it becomes more problematic to move.

PNPS is currently in Column 4 of the NRC's Action Matrix. Your agency just finished two weeks of an intensive inspection where, based on a memo inadvertently emailed to the public, highlighted non-compliances, poor maintenance, poor engineering practices, equipment reliability problems, and an overwhelmed staff. Additionally, PNPS was recently forced to shut down due to leaks in three main steam isolation valves.

We anticipate that due to degradation of the boron panels in the spent fuel pool, PNPS will escalate transfer of waste fuel to the dry casks. This requires urgent review of the default coastal location of PNPSs dry cask storage facility.

Furthermore, we vigorously oppose the refueling planned for early 2017 due to the added burden it will place on Plymouth and expansion of the time frame for site clean-up. We strongly urge the NRC to require shut down prior to refueling. We especially urge DOE to require PNPSs nuclear waste storage area to be move farther from coastal risks and salt water degradation, away from Cape Cod Bay and to higher elevation. We encourage all regulators and officials to escalate the timeframe for decommissioning PNPS and clean-up of the site.

JRWA page 2 of 3

Please contact us with any questions.

Sincerely, Pine duBois Karen Vale-Vasilev Executive Director Program Manager Jones River Watershed Association JRWAs Cape Cod Bay Watch Program Enclosure cc:

Stephen Burns, NRC Chair Curt Spalding, EPA Region I Administrator Dave Webster, EPA Water Permit Branch Chief Governor Charlie Baker Mark Beaton, Secretary, EOEEA Martin Suuberg, Commissioner, DEP Beth Card, Assistant Commissioner, DEP Bruce Carlisle, Director, CZM Board of Selectmen, Town of Plymouth Nuclear Matters Committee, Town of Plymouth Massachusetts Delegates JRWA page 3 of 3

APPENDIX A Photos: Pilgrim Nuclear Power Station on November 18, 2016 Estimated to be just after a 12 ft. high tide and with moderate wind conditions (6-14 mph) from NNE

APPENDIX B One of the NGRP maps showing the height of the breakwater jetties and other elevations that appear significantly lower than those shown in Entergys plans, demonstrating that the site is not as protected from flooding and sea level rise as Entergy reports. Note the breaks in the northerly jetty, which match the photographs in Appendix A. See all NGRP maps here: http://jonesriver.org/pilgrim-elevation-analysis

APPENDIX C Weather Conditions Nov. 18, 2016 Source: Weather Underground, Plymouth, MA, Daily History DEW TIME TEMP HUMIDITY PRESSURE VIS WIND DIR WIND SPEED CONDITION POINT 12:52 PM 57.0 °F 39.9 °F 53% 30.01 in 10.0 mi NNE 13.8 mph Clear 2:52 PM 59.0 °F 39.9 °F 49% 30.01 in 10.0 mi N 9.2 mph Clear 3:52 PM 57.0 °F 39.9 °F 53% 30.01 in 10.0 mi NNW 5.8 mph Clear Tidal Conditions Nov. 18, 2016 High tide in Plymouth at 1:51 PM: 12.0 ft. Source: BoatMA.com Note tidal elevations based on MLLW of Boston buoy

Below are elevation datum from the Boston buoy. The Boston buoy is the closest and most relevant tidal buoy for PNPS. Below are the current and previous tidal epochs (each epoch is 18 years). The previous 1960-1978 epoch was the information used when PNPS was first developed. It is significant that the jetties were first compromised in the blizzard of 1978. The 1983-2001 is the present epoch and shows a rise in sea level. Local present day tide charts are based on this. We are nearly done with the third epoch (2002-2020), when information will be brought to reflect present day conditions.

Source: https://tidesandcurrents.noaa.gov/stationhome.html?id=8443970