ML22154A162

Letter and Email from Save Our Bay/Diane Turco Regarding Irradiated Water Release from Pilgrim

ML22154A162
Person / Time
Site:	Pilgrim
Issue date:	05/26/2022
From:	Turco D Cape Downwinders, Save Our Bay MA
To:	Christopher Hanson NRC/Chairman
Sturzebecher K
References
Download: ML22154A162 (4)

Text

Save Our Bay MA via Cape Downwinders PO Box 303 South Harwich, MA 02661 Chairman Christoper T. Hanson U.S. Nuclear Regulatory Commission Mail Stop O-16 B33 Washington, DC 20555-0001 26 May 2022 RE: Holtec-Pilgrim plans to dump one million gallons of radioactive water into Cape Cod Bay

Dear Chairman Hanson,

We are writing to you regarding the urgent matter of Holtec Decommissioning International plans to dump a million gallons of radioactive waste water into Cape Cod Bay. Senator Edward Markey, Senator Elizabeth Warren, and Representative Bill Keating along with our state and local representatives, town boards, and citizen petition initiatives on the South Shore, Cape Cod, and Marthas Vineyard have called on Holtec to not dump any radioactive water into our bay. There is a huge public outcry to halt Holtecs plan.

There is a way you can help us to prohibit this dumping that would harm our families, damage the local "shing and shell"sh industry, hurt the coastal real estate and tourism, harm the habitat of marine life, particularly the endangered right whale, and violate our right to safety. Local economies would be devastated as would our environment.

10 CFR 20.1310(f) states, The Commission may impose additional restrictions on radiation levels in unrestricted areas and on the total quantity of radionuclides that a licensee may release in euents in order to restrict the collective dose.

Thus, we request the NRC implement this regulation to prohibit Holtec from discharging radioactive water into Cape Cod Bay by restricting the amount of radionuclides in the euent to ZERO.

In addition, Holtec cannot meet the NRC ALARA [As Low As Reasonably Achievable]

requirement by reducing the amount of radioactivity in Pilgrims contaminated water before it is dumped into the bay or by evaporating it on-site. NRCs Backgrounder on Tritium states that, In principle, no dose should be acceptable if it can be avoided. In addition, NUREG/CR-2907, Vo.24, 1.2 states, Maintaining radiation doses from radioactive euents as low as reasonably achievable is an NRC requirement.

NRC also states it supports no threshold-no safe dose as does the National Academies of Science in their Biological Eects of Ionizing Radiation VII report. The science tells us and we all can agree, there is no safe dose, particularly for the fetus, infant, child, and females.

Holtec can avoid any doses and meet the ALARA requirement only by using their other option-transporting the contaminated water to an o-site radioactive low-level waste facility for containment. The waste water must be contained from the environment.

We respectfully concur that these NRC positions clearly lead to shipping and containment, not dumping Pilgrims one million radioactive contaminated water into our Ocean Sanctuary. Damaging impacts would ripple throughout our communities when a viable option is available to avoid such consequences. With the option to truck the water to a licensed facility like Vermont Yankee chose to implement, there is no need to contaminate our fragile and precious Cape Cod Bay.

However, dumping into the bay is still Holtecs priority plan and must be removed. In order to uphold the NRC mandate to protect the people and environment, we request the NRC invoke CFR 20.1310(f) to prevent Holtec from discharging radioactive water by restricting the amount of radionuclides in the Pilgrim liquid euent to ZERO.

Can we schedule a virtual meeting with you to have a conversation regarding our concerns and rationale for no dumping?

We look forward to your response as this is a timely matter.

For the Save Our Bay MA Coalition, Diane Turco, Director, Cape Downwinders tturco@comcast.net Mark DeCristoforo, Massachusetts Seafood Collaborative marke@maseafoodcollab.com Mary and Jim Lampert, Pilgrim Watch mary.lampert@comcast.net james.lampert@comcast.net Henrietta Cosentino, League of Women Voters of the Plymouth Area henrietta.cosentino@gmail.com CC:

Senator Ed Markey Senator Elizabeth Warren Rep. Bill Keating Governor Charlie Baker Attorney General Maura Healey Secretary, Energy and Environmental Aairs Beth Card

Senator Susan Moran Senator Julian Cyr Senator Patrick OConnor Senator President Karen Spilka House Speaker Ronald Mariano Rep. Josh Cutler Rep. Kathleen LaNatra Rep. David Vieira Rep. Dylan Fernandes Rep. Kip Diggs Rep. Timothy Whelan Rep. Sarah Peake John Mahoney, Co-Chair, Nuclear Decommissioning Citizens Advisory Panel Pine DuBois, Co-Chair, Nuclear Decommissioning Citizens Advisory Panel Dr. Barry Potvin, Chair, Plymouth Board of Health

1 Chairman Resource From:

Diane Turco <tturco@comcast.net>

Sent:

Thursday, May 26, 2022 5:26 PM To:

Chairman Resource Cc:

edward_markey@markey.senate.gov; Thomas, Benjamin (Markey); Rodrigues, Paige (Markey);

elizabeth_warren@warren.senate.gov; Benson, Hannah (Warren); Jackman, Michael; Schofield, Seth (AGO); Alicia Rebello-Pradas; Cyr, Julian (SEN); Moran, Susan (SEN); Holcomb, Michael (SEN); Ganz, Elizabeth (SEN); Syrniotis, Maria (SEN); Sen. Patrick O'Connor; karen.spilka@masenate.gov; ronald.mariano@mahouse.gov; Josh Cutler; Rep Kathleen LaNatra; David Vieira; Fernandes, Dylan -

Rep. (HOU); kip.diggs@mahouse.gov; timothy.whelan@mahouse.gov; Ferrara, Sarah (HOU); Sarah Peake; John Mahoney; Pine duBois; Barry Potvin; craig.gilvarg@mass.gov; env.internet@mass.gov; beth.card@mass.gov; charlie.baker@mass.gov; karyn.polito@mass.gov; Mark E. DeCristoforo; Mary Lampert; James lampert; Henrietta Cosentino; Pickering, Seth (DEP); Priest, Jack (DPH)

Subject:

[External_Sender] URGENT: NRC enforce 10 CFR 20.1310(f) to protect Cape Cod Bay Attachments:

Save Our Bay NRC CFR restricitionsALARA.pdf

DearChairmanHanson,

AttachedisaletterfromtheSaveOurBayMACoalitionrequestingtheNRCimplement10CFR20.1310(f)forCapeCod BaytoprotectthepeopleandenvironmentfromHoltecsplantodischargeamilliongallonsofPilgrimsradioactive waterintoourpreciouscoastandmarinesanctuary.Thepotentialpublichealthandeconomicimpactofsucha dischargeisimmeasurable.Notonlyisthepublichealththreattoresidentsalongtheshoreandthosewhousethebay forrecreationsignificant,butthepotentialforsevereeconomicharmisparamount,particularlyforthoseinthefishing, tourist,andrealestateindustries.

StakeholdersinMassachusettsareoverwhelminglyagainstthedischargeasareSenatorMarkey,SenatorWarren,and Rep.Keating.

ThismatterisurgentandrequirestheNRCtoactonourbehalf.

Welookforwardtohearingfromyou.

Thankyouforyourtimeandconsideration, DianeTurco,Director CapeDownwindersforSaveOurBayMACoalition