ML19052A187

Exhibit 4 to Pilgrim Watch Petition to Intervene and Hearing Request

ML19052A187
Person / Time
Site:	Pilgrim
Issue date:	02/21/2019
From:	Lampert M Pilgrim Watch
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-293-LT, 72-1044-LT, License Transfer, RAS 54812
Download: ML19052A187 (22)

Text

Version 2, Oct. 21, 2015 1 CHRONOLOGY OF EVENTS1 PILGRIM NUCLEAR POWER STATION PLYMOUTH, MA 1960s 1967: In July 1967, the Town of PlymouthZoning Board of Appeals (ZBA) issues a Special Permit to Boston Edison for construction and operation of a nuclear plant, under the Town Zoning Bylaw. Plymouth is selected as the reactor site after a location closer to population centers near Boston was rejected. The ZBA issues established or future character of the neighborhood and the town in view of the conditions and safeguards which will be imposed by the U.S. Atomic Energy Commission upon the operation of such nuclear-powered plant, and the comparative isolation of the site of the plant itself.2 According to the Atomic Ene Provisional Construction Permit issued to Boston Edison, in 1965 the total residential and seasonal population within 1 mile of the site was 1,046; within 3 miles, 5,659; and within 10 miles, 44,629. Original building plans for Pilgrim show storage of spent nuclear fuel (high-level radioactive waste) inside the reactor building, and discuss shipping waste offsite. U.S. Nuclear Regulatory Commission (NRC) records also indicate spent nuclear fuel is intended to spend a relatively short time in the wet pool before being sent offsite to a reprocessing facility. Construction begins in 1967. The site is extensively altered by excavation and fill. Used construction equipment, including cranes, is buried on site.3 1970s 1970s: Massachusetts seeks sed-system for the approximate 500 million gallons of water required to run Pilgrim daily. Boston Edison files a legal challenge to avoid the cost of a -ailing. -. It was well-known at the time that a once-through system causes destruction of marine life. The Sierra Club and other public interest groups oppose once-through cooling. 1 This chronology attempts to capture the major milestones related to Pilgrim Nuclear Power Station beginning with 2 Plymouth Board of Appeals on the Zoning Bylaw: Notice of Special Permit August 22, 1967. 3 Source available on request.

Version 2, Oct. 21, 2015 2 1970s-1980s: Pilgrim has several spills and accidents resulting in the release of radioactive materials into the environment. There are multiple radioactive resin spills into the building and through the storm drain into Cape Cod Bay.4 1972: The predecessor to the NRC, the Atomic Energy Commission, issues Boston Edison an operating license. Pilgrim begins nuclear -cooling water system that impinges and entrains marine life and discharges thermal plume to Cape Cod Bay. Federal Clean Water Act becomes law. Pilgrim begins discharging radiological materials to the air and water during routine operations. 1973, which is defined as those events involving greater than 20 fish per hour and an overall event total of 1,000 fish or more.5 From August to September 1973, 1,600 clupeids are impinged In April 1973, a large kill of Atlantic menhaden occurs canal and thermal plume; approximately 90% of the fish exhibit signs of gas bubble disease. The resulting kill was estimated at 43,000 fish. The only assessments of were done from 1973 to 1975.6 1974: Boston Edison installs an off gas treatment system, a technology which attempts to reduce the radioactivity of gases that are removed from the radioactive steam that turns the turbine in the condenser.7 1974-1975: Boston Edison proposes to add 2 additional nuclear reactors to the Pilgrim site (Units 2 and 3). Proposal generates significant opposition. 1974-1980: at Pilgrim (Units 2 and 3) builds on a local and state-wide level, especially after the Three Mile Island nuclear accident in 1979. Following numerous legal appeals by Plymouth County Nuclear Information Committee and others, Boston Edison withdraws its proposals by 1980. Attorney Bill Abbott and others represents local residents seeking to block Units 2 and 3. 4 Boston Edison memo PNPS File No. TCH 82-73. 5 Normandeau Associates. Apr. 2013. Impingement of organisms on the intake screens at Pilgrim Nuclear Power Station, Jan. Dec. 2012. In: Entergy Nuclear Pilgrim Station. 2013. Marine Ecology Studies Jan. 2012 Dec. 2012, Report No. 81, Section 2.3. 6 Toner R.C. Zooplankton of western Cape Cod Bay; Toner R.C. Phytoplankton of western Cape Cod Bay. Both in: Observations on the ecology and biology of western Cape Cod Bay, Massachusetts. 1984. Eds, Davis, J.D. and D. Merriman. Springer-Verlag. 7 Cargill E.B. Survey of Documents Concerning the Operation of Pilgrim Nuclear Power Station [Preliminary Draft]. <http://www.pilgrimwatch.org/cargill.pdf>

Version 2, Oct. 21, 2015 3 1975: Massachusetts Department of Environmental Protection (MassDEP) and U.S. Environmental Protection Agency (EPA) issue water pollution permit under state and federal laws to Boston er pollutants into Cape Cod Bay.8 Use of once-through cooling water system continues unchanged; Pilgrim continues to discharge radiological waste to Cape Cod Bay. On the issue of spent fuel storage (high level radioactive waste), legal notice in the U.S. Federal Register of September 16, 1975 says, contemplated that the used or spent fuel discharged from the reactors would be chemically It was contemplated by the nuclear industry that spent fuel would be discharged periodically from operating reactors, stored in onsite fuel storage pools for a period of time to permit decay of the radioactive materials contained within the fuel and to cool, and periodically shipped offsite for processing. 1976: Scientists concerned about the Cape Cod Bay advocate for monitoring and oversight. Study of ichthyoplankton populations completed. On August 5, 1976 a and 1,900 alewife (a species of protected 1978: On February 6, 1978 Pilgrim has an emergency scram when heavy snowfall caused by the Blizzard of 1978 causes electrical breakers in the 345 kilovolt switchyard to flashover and trip.9 Pilgrim has another emergency scram on August 6, 1978: the reactor automatically scrams from 100% power when lightning strikes transmission lines causing a LOOP (loss of offsite power). The emergency diesel generators automatically started and connected to their electrical buses. The operators manually started the reactor core isolation cooling and high pressure coolant injection systems to maintain reactor water level. The operators opened a safety relief valve to control reactor pressure. Offsite power is restored about 30 minutes later.10 From November 23-28, 1978 another and 10,200 Atlantic menhaden ember 11-impinge6,200 rainbow smelt 8 Entergy v. MassDEP, 459 Mass. 319 (2011), Decision by Mass. Supreme Judicial Court 9 Attachment 3 to March 3, 2015 Letter to Governor Baker. Summary and Excerpts from: NRC Supplemental Inspection Report 05000293/2014008 and Assignment of Two Parallel White Performance Indicator Findings, 1/26/15. <https://files.ctctcdn.com/3f5c2ed6201/d4fc04ec-bcef-481b-a9e8-9cfb8ef3aea1.pdf> 10 Exhibit 3 to Affidavit of William Maurer, submitted with Petitioners' Pre-Filed Testimony in Waterways Appeal, June 29, 2015 MassDEP's Office of Appeals and Dispute Resolution, Docket 2015-009. <http://www.capecodbaywatch.org/wp-content/uploads/2015/09/Maurer-Exhibit-3.pdf>

Version 2, Oct. 21, 2015 4 1979: In March 1979, there is a meltdown at Three Mile Island nuclear reactor in Pennsylvania. In March and April 1979, a where 1,100 Atlantic silversides are impinged. On July 27, 1979, Pilgrim has another emergency scram. The reactor automatically scrams when a lightning strike causes a LOOP.11 About a month later, on August 28, 1979, Pilgrim has another emergency scram. Again, the reactor automatically scrams when a lightning strike causes a LOOP.12 1980s 1981: Over a 2-day period (September 23-24, 1981) 6,000 Atlantic silversides are killed in a 1982: In January 1982, NRC issues a $550,000 penalty to Boston Edison for mismanagement and mechanical failures at Pilgrim, one of the largest NRC fines in U.S. history.13 U.S. Congress passes the National Waste Policy Act in 1982, in an effort to deal with high level nuclear waste disposal (spent fuel). reactor, and is never sent off site for reprocessing or disposal as planned in 1967 when Pilgrim was built. The law requires the U.S. Energy Department to identify and built two sites for long term In June 1982, a radioactive material, Cesium-137 is released into the air when burst.14 Highly radioactive resin beads and particulate matter were found to have been accidentally injected into the ventilation system and outside the building. Material was discovered on roofs of Environmental Radiation 1982 Report outlines test results for milk and vegetation samples from farms 0.7 to 12 miles away from Pilgrim. Due to contamination by radioactive materials, cows at the Plymouth County Farm on Obery Street in Plymouth are killed and buried on site.15 On October 12, 1982, high winds cause salt accumulation on electrical equipment that led to an electrical fault and a LOOP lasting about 1 minute.16,17 11 Ibid. 10 12 Ibid. 10 13 Ackerman J. Jan. 20, 1982. $550,000 fine asked for Pilgrim N-plant. Boston Globe. 14 http://www.pilgrimwatch.org/emissions.html> 15 Source: available on request. 16 [Pilgrim] Licensee Event Report LER 1982051. See Maurer W. Aug. 5, 2015 email to NRC. <http://pbadupws.nrc.gov/docs/ML1521/ML15218A227.pdf> 17 Ibid. 10 Version 2, Oct. 21, 2015 5 1983: Pilgrim loses off site power due to a February 1983 aster/blizzard. High winds cause salt accumulation on electrical equipment that leads to an electrical fault and LOOP lasting about 1 minute.18 Pilgrim shuts down in December 1983 to replace cracked circulation system piping.19 In July 1983, EPA and MassDEP issue joint water pollution permit (National Pollutant Discharge Elimination System, or NPDES, permit) under the Fe-through cooling water system. 1986-1989: From April 1986 to January 1989, Pilgrim shuts down due to a series of mechanical failures.20 1986: In April 1986, there is a nuclear meltdown at Chernobyl nuclear power plant in the Ukraine. In May 1986, the NRC identifies Pilgrim as one of the most unsafe nuclear facilities in the U.S.21 In July 1986, MASSPIRG, 50 state legislators, and more than a dozen citizen groups file a petition with the NRC requesoperate. The NRC failed to consider the petition fully and fairly.22 On November 19, 1986, while the plant is in cold-shutdown, ice buildup on electrical equipment causes a fault and a LOOP lasting about 1 minute.23 Also in November 1986, voters in Plymouth and Kingston approve local referenda to shut down Pilgrim. 1987: On March 31, 1987, while the plant is in cold-shutdown, heavy winds cause an electrical fault and a LOOP lasting about 1 minute.24 Court testimony of Dr. Richard Clapp, epidemiologist, Boston University in 2014 states that, in 1987, Pilgrim exposed more of its workers to radiation than any other commercial nuclear plant in the U.S.25 18 Ibid. 9 19 Sovacool BK. Jan. 2011. Questioning the safety and reliability of nuclear power: An assessment of nuclear incidents and accidents. Gaia, 20/2: 95-103. <http://www.capecodbaywatch.org/wp-content/uploads/2012/06/Sovacool-Gaia-Nuclear-Accidents.pdf> 20 Lochbaum D. May 2004. U.S. nuclear plants in the 21st century: The risk of a lifetime. Report by the Union of Concerned Scientists. <http://www.capecodbaywatch.org/wp-content/uploads/2012/06/nuclear04fnl.pdf> 21 Pertman A. May 23, 1986. Boston Globe article. Pilgrim on list of worst-run nuclear units; NRC cites potential hazards. 22 Congressional Hearing. Jan. 7, 1988. Plymouth. Transcript available at <https://archive.org/stream/restartofpilgrim00unit/restartofpilgrim00unit_djvu.txt> and U.S. Government Printing Office 83-478. 23 Ibid. 10 24 Ibid. 10; LER 1987005 Version 2, Oct. 21, 2015 6 A study is published in 1987 shows 5 towns around Pilgrim with a 60% increase in leukemia rate, excluding leukemia not caused by radiation exposure. The rate of myelogenous leukemia (the type most likely to be triggered by exposure to radiation) among males in the 5 towns found to be 2.5x greater than statewide average.26 In 1987, protesters affiliated with Citizens Urging Responsible Energy and others opposed to Pilgrim coming back online after the 1986-1989 shutdown are arrested for blocking the entrance to Pilgrim. Issues include lack of adequate emergency planning. In October 1987, critics including license due to inadequate emergency plans and public safety hazards.27 On November 12, 1987, while the plant is in cold-shutdown, high winds caused salt accumulation on electrical equipment that led to an electrical fault and a LOOP lasting 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> and 3 minutes.28 1988: Before Pilgrim comes back online in 1989, a congressional hearing is held in Plymouth on January 7, 1988 before the Senate Committee on Labor and Human Resources (under Ted Kennedy) examining the proposed restart of Pilgrim and the potential implications for public safety and health.29 On January 21, 1988, a 5,000 cubic yard pile of dirt containing radioactive cesium-134, cesium-137, and cobalt-60 is found in a parking lot near the reactor.30 In October 1988, at a public meeting about Pilgrim, the NRC has an aide to Governor Dukakis removed for saying that Boston Edison lacked an adequate emergency plan for Pilgrim. The NRC subsequently apologized. 25 tion to dismiss tanding. June 2014. 19 pp. 26 Cobb S. et al. Leukemia in Five Massachusetts Coastal Towns. Abstract for the American Epidemiologic Society. March 18, 1987.; and Clapp RW, Cobb S, Chan, Walker B. 1987. Leukemia near Massachusetts nuclear power plant. Lancet. 2:1324-5. PMID 2890916. <http://www.ncbi.nlm.nih.gov/pubmed/2890916> 27 New York Times. Jan. 1, 1989. Pilgrim Reactor Restarted After 3-Year Shutdown. <http://www.capecodbaywatch.org/wp-content/uploads/2012/06/1989.01.01_NewYorkTimes_RestartsAfter3Years.pdf> 28 Ibid. 10 29 Ibid. 22 30 Tye L. Boston Globe. Jan. 21, 1988. Radioactivity detected in dirt pile near Pilgrim. <http://www.capecodbaywatch.org/wp-content/uploads/2012/06/1988.01.21._BG_RadioactiveDirtPile.pdf>

Version 2, Oct. 21, 2015 7 1989: In January 1989, Pilgrim goes back online after a two year and three month shut down following mechanical failures including radiological emissions resulting from blown air filters. National media covers the story, including New York Times.31 1990s 1990: In October 1990, the Massachusetts Department of Public Health (MassDPH), Division of Environmental Health Assessment publishes a report health study, 1978-1986, to investigate if communities near Pilgrim have elevated leukemia mortality rates associated with radioactive plant discharges. The report found a two to four fold increase in the risk of leukemia among residents of certain towns within a 20 mile radius from the plant.32 1991: From July 22-25, 1991 a and 4,200 rainbow smelt are On October 30, 1991, a n that evolved into a hurricane, nicknamed the Perfect Storm, forces shut down of Pilgrim when it blows seaweed into the intake structure, clogging the circulating water pumps, and causing a loss of condenser vacuum.33 EPA and MassDEP, in 1991, renews NPDES permit for continued use of once-through cooling water system and discharges of heated water and other pollutants to Cape Cod Bay. remains unchanged, no technology improvements required. Impingement and entrainment of marine life continues. Permit set to expire in 1996 (pursuant to the five year term set by law). discharges to Cape Cod Bay. 1992: On December 13, 1992 a n/blizzard causes an emergency shut down. Forced automatic scram occurs due to a generator load rejection caused by flashovers in the switchyard, which are caused by salt deposits during the severe storm.34 1993: On March 13, 1993 a superstorm nicknamed the Storm of the Centuryreactor to automatically shut down due to a generator load rejection caused by flashovers in the switchyard which are caused by wind-packed snow during blizzard conditions.35 31 Ibid. 26 32 Morris, M., and Knorr, R.: The southeastern Massachusetts health study, 1978-1986. Report of Massachusetts Department of Public Health, Boston, October 1990. 33 Ibid. 10; LER 1991024 Loss of Preferred and Secondary Offsite Power Due to Severe Coastal Storm While Shutdown. 34Ibid.10; LER 1992016 Automatic Scram Resulting From Load Rejection at 48 Percent Reactor Power. 35 Ibid. 10; LER 1993004 Version 2, Oct. 21, 2015 8 On September 10, 1993 reactor automatically shuts down after lightning strikes cause switchyard breakers to open.36 From December 15-28, 1993 a and 5,100 Atlantic silversides 1994: U.S. EPA and MassDEP 1991 Clean Water Act NPDES permit to allow discharges of additional pollutants. From November 26-28, 1994 a and 5,800 Atlantic silversides December 26-28, where 11,400 Atlantic silversides and rainbow smelt are killed. 1995: In a two day period (September 8-9, 1995), 13,100 alewife are killed in a 1996: Clean Water Act NPDES permit expiresU.S. EPA and MassDEP. 1997: Massachusetts deregulates the energy industry.37 In through the Pilgrim facility in 1997 resulted in a loss to the adult Plymouth/Duxbury Bay population of 9-41% (range based on pr38 1998: In 1998, one of the highest records of larval winter flounder entrainment occurred (77,000 equivalent adults), which was nearly 30% loss of the adult population that year.39 1999: Entergy Nuclear Generation Company purchases Pilgrim, including 1,600 acres of land, from Boston Edison for $80 million; $13 million was for the facility and the 1,600-acres, and the remaining $67 million was for the nuclear fuel. Clean Water Act NPDES permit transferred to Entergy. 36 Ibid. 10; LER 1993022 37 Commonwealth of Mass. Legislature. 1997. Chapter 164. An Act Relative to Restructuring the Electric Utility Industry in the Commonwealth, Regulating the Provision of electricity and other services, and promoting enhanced consumer protections therein. 38 Letter to EPA from Szal G.M. (PATC), Dec. 8, 1998. Re: Pilgrim Nuclear Power Plant. 39 Letter to EPA from MassCZM, Jun. 27, 2000. Re: MCZM review of the Entergy-Pilgrim Station §316 Demonstration Report.

Version 2, Oct. 21, 2015 9 In August 1999, EPA and MassDEP designate the Plymouth-Carver Aquifer as a Sole Source Aquifer under the Safe Drinking Water Act. The dwould pose a significant health hazard and a serious financia40 Pilgrim sits on top of the aquifer, and has been leaking radionuclides into the ground since at least 2007.41 In a 2-day period (September 17-18, 1999), a occurs where 4,910 Atlantic menhaden are 2000 to 2005 2000: From November 17-20, 2000 a and 19,900 Atlantic menhaden 2001: The September 11th terrorist attacks on the U.S. raise new issues about the vulnerability of Pilgrim as a terrorist target. One of the planes flown by the terrorists took off from Boston and flew 2002: In January 2002, the U.S. Coast Guard unilaterally imposes safety the shoreline in front of Pilgrim.42 The public is excluded from the area, which includes 1 mile of Massachusettsidelands. The tidelands are public lands, held in trust for public benefit, and activities undertaken by private entities such as Entergy in the tidelands are governed by the Massachusetts Waterways Law, Chapter 91 and associated regulations. Entergy never obtained Chapter 91 approval for the safety and security zone in front of Pilgrim. This zone will exclude the public as long as Pilgrim operates and/or spent nuclear fuel is stored at the site. State regulators have failed to act to protect public interest in the tidelands in front of Pilgrim. On February 5, 2002, Stratus Consulting publishHabitat-based replacement costs: An ecological valuation of the benefits of minimizing impingement and entrainment at the cooling water intake structure of the Pilgrim Power Generating Station in report estimates that, on average, 14.5 million fish and 160 billion blue mussels are killed each year at Pilgrim through impingement and entrainment combined.43 40 55 Fed. Reg. 32137. 41 MassDPH. Summary of Tritium Detected in Groundwater Monitoring Wells, Pilgrim Nuclear Power Station, Plymouth, MA, 2007. <http://www.mass.gov/eohhs/gov/departments/dph/programs/environmental-health/exposure-topics/radiation/environmental-monitoring.html> 42 67 Fed. Reg. 4218 43 Stratus Consulting. 2002. Habitat-based replacement costs: An ecological valuation of the benefits of minimizing impingement and entrainment at the cooling water intake structure of the Pilgrim Power Generating Station in Plymouth, Massachusetts. Report for the U.S. EPA, Region 1. <http://www.capecodbaywatch.org/library/stratusreport>

Version 2, Oct. 21, 2015 10 In August and September, 2002, a and 33,300 Atlantic menhaden 2003: On May 19, 2003 scrams due to spurious operation of the turbine bypass valves. On November 1, 2003 a and 2,500 Atlantic menhaden are impinged on Pilgri In the same month, three more shappen: From November 12-17, 63,900 Atlantic menhaden are impinged, from November 19-21, 17,900 sand lance and Atlantic menhaden are impinged, and on November 29, 3,900 Atlantic silversides are impinged. the more than 300,000 fish Entergy impinged in 2005 were Atlantic menhaden. There were also 19 impingement events where more than twenty fish were collected off the intake screens per hour, which consisted primarily of Atlantic menhaden and Atlantic silversides. There was one large impingement event in 2005 (August 16-18) which involved exclusively young Atlantic menhaden. This event in 2005 was with a total of 107,000 fish impinged. The National Academies of Science develops a report in 2005 finds that there is no safe level of exposure to radiation; even low doses can cause cancer. To address this, EPA sets a Maximum Contaminant Level Goal (MCLG) for all radionuclides (including tritium) as ZERO. 2006 to 2010 2006: Entergy files application seeking to renew its operating license with the NRC for a 20-year extension, until 2032. The NRC process for relicensing Pilgrim begins. By the time Pilgrim is -year hotly contested relicensing application will make the proceeding the longest in NRC history. In 2006, the Nuclear Entergy Institute proposes that nuclear facilities in the U.S. begin voluntary tritium monitoring in groundwater. This recommendation came after tritium, a radioactive isotope of hydrogen, was being found at high levels at several nuclear facilities throughout the U.S. 44 44 Normandeau Associates. Mar. 2007. Impingement monitoring, Section 3.3. In: Entergy Nuclear Pilgrim Station. 2007. Marine Ecology Studies Jan. 2006 Dec. 2006, Report No. 69.

Version 2, Oct. 21, 2015 11 2007: In January 2007, Entergy sues MassDEP to prevent implementation of new state Clean Waters Act regulations at Pilgrim. The new regulations seek to -through cooling system.45 Entergy lost the case and the regulations take effect, but MassDEP fails to enforce the regulations. Entergy is allowed to continue to operate with an expired NPDES permit and outdated once-through cooling system.46 On March 17, 2007 operators drywell leakage. its first 6 monitoring wells on the Pilgrim site (by 2015, 24 wells exist). Radioactive tritium has found in groundwater at Pilgrim every year since testing began. Other radionuclides also present.47 --48 2008: On December 19, 2008 a nblizzard causes reactor to automatically scram when icing occurs in the main switchyard.49 2010: In January 2010, Vermont Yankee Nuclear Power Station (also owned by Entergy) notifies the Vermont Department of Health that samples taken in November 2009 from a groundwater monitoring well contains dangerously high tritium levels (a radioactive form of hydrogen). The Vermont leak prompts Plymouth-area citizens groups to demand more test wells at Pilgrim. 45 Entergy v. Mass. Department of Environmental Protection, 459 Mass. 319 (2011). 46 47MassDPH reports available at <http://www.mass.gov/eohhs/gov/departments/dph/programs/environmental-health/exposure-topics/radiation/environmental-monitoring.html> 48 Normandeau Associates. Oct. 2008. Impingement monitoring, Section 3.3. In: Entergy Nuclear Pilgrim Station. 2008. Marine Ecology Studies Jan. 2007 Dec. 2007, Report No. 71. 49 Ibid. 10; LER 2008007.

Version 2, Oct. 21, 2015 12 Due to rising levels of tritium than 25,000 picocuries per liter (pCi/L) is found), DPH recommended that Entergy install even more wells and start testing surface water as well. By August 2010, 6 additional wells were installed. On July 29, 2010 a and 1,061 alewife intake screens. 2011 to 2012 2011: On March 11, 2011 a massive earthquake off the northeastern coast of Japan and the devastating tsunami that followed set off a chain of problems at the Fukushima Daiichi Nuclear Power Station that eventually led to the worst nuclear accident since Chernobyl. Tsunami floods backup generators, causing failures and cutting power to pumps overheating and meltdowns ultimately occur. Pilgrimis the same General Electric Mark I design as those at Fukushima. Unconfirmed reports say that the reactor parts built by General Electric for the cancelled Units 2 and 3 at Pilgrim were sent to Japan for use at Fukushima. scrams on high-high flux on the intermediate range monitors during startup. 2012: On March 12, 2012 the NRC sends a letter to all U.S. nuclear reactors requesting information to support the Near-Term Task Force (NTTF) review of the Fukushima Dai-ichi nuclear accident.50 The NRC establishes the NTTF after the Fukushima accident to review what happened and improve response and readiness of the U.S. nuclear fleet to beyond design basis events. The NTTF developed a report and recommendations. The NRC requires the nuclear industry, including Pilgrim, to implement to address certain -Design- es to reevaluate flood hazards at reactor sites. On March 30, 2012 the Cape Cod National Seashore Advisory Commission sends letter to NRC asking that Pilgrim not be relicensed. 50 NRC, Mar. 12, 2012. <http://pbadupws.nrc.gov/docs/ML1205/ML12053A340.pdf>

Version 2, Oct. 21, 2015 13 On May 3, 2012 State Senator Dan Wolf calls for the closing of Pilgrim in a letter to the NRC.51 On May 11, 2012 the NRC provides nuclear licensees with a prioritization plan and the resultant list of due dates for all for individual plants to complete flood reevaluations (based on their March 12th Request for Information).52 March 12, 2015. Later in May (12th), Plymouth voters approve a referendum 59% to 41% asking the NRC to not relicense Pilgrim until their recommendations learned from Fukushima could be implemented.53 At this point Duxbury, Provincetown, Kingston, Scituate, Marshfield, Truro, Mashpee and Brewster all approve referendums saying the same thing. A labor dispute at Pilgrim begins in May 2012. On May 16, 201254 Pilgrim Watch and Jones River Watershed Association (JRWA) file a legal petition asking the NRC to close Pilgrim since the plant replacement workers that have not received site specific training; do not have years of experience at the site; do not have a history specific to Pilgrim. Pilgrim Watch, on May 18th, files a supplemental petition.55 On May 22, 2012 operators shut down, or scram, increasing condenser pressure. On May 25, 2012 NRC votes 3-1 to extend license for another 20 years, until 2032. NRC Chairman Jazcko opposes relicensing and in lengthy comments cites to the unprecedented situation of the NRC commissioners voting to relicense Pilgrim despite pending citizen . On June 4, 2012 labor dispute boils over, with Entergy management locking out 250 unionized workers for more than a month and both sides accusing the other of compromising implements an emergency staffing plan. Pilgrim Watch files five supplemental requests in June 2012 based on new facts and events they say show Entergy is violating its NRC operating license.56 51 http://www.pilgrimcoalition.org/wp-content/uploads/2012/05/050312-Wolf-to-NRC.pdf 52 <http://www.capecodbaywatch.org/wp-content/uploads/2012/06/May-11-2012-NRC-Response-Dates.pdf> 53 Pilgrim Coalition press release: Plymouth Votes to ask NRC to Suspend Relicensing of Pilgrim Reactor. 54 <http://www.capecodbaywatch.org/wp-content/uploads/2012/06/05.-16.12-STRIKE-2.206.pdf> 55 <http://www.capecodbaywatch.org/wp-content/uploads/2012/06/05.-16.12-STRIKE-2.206.pdf> 56 <http://www.capecodbaywatch.org/2012/06/supplement-to-2-206-enforcement-petition-regarding-labor-dispute-at-pilgrim/>

Version 2, Oct. 21, 2015 14 On June 8, 2012 flooding aspects of Recommendations 2.1 and 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident. On October 3, 2012 the Mass. Emergency Management Agency (MEMA) publicly admits the Bourne and Sagamore Bridges will be closed if there is an accident at Pilgrim. MEMA says Cape has been evacuated.57 On October 5, 2012 local residents send letAct.58 Entergy threatens to sue citizens in return. Due to the intent to sue, EPA and MassDEP promise to renew expired Clean Water Act NPDES permit by December 2012 - promise broken. On October 29, 2012 Hurricane Sandy hits New York. Oyster Creek Nuclear Station in New Jersey declares a rare "emergency alert" due to power outages and equipment dangerously close to being submerged. America's nuclear safety, including at Pilgrim, comes under scrutiny after Oyster Creek's Sandy alert. 2013 2013: On January 10, 2013 operators shut down pumps tripped. On Jan 12, 2013 a critically endangered North Atlantic right whale mother named Wart and her newborn calf are seen swimming close to Pilgrim. This is the first mother-calf right whale sighting in Cape Cod Bay in January in 27 years, and the only mother-calf pair ever documented occurring near Pilgrim. Local groups ask the National Marine Fisheries Service and the NRC to reinitiate consultation under Section 7 of the Endangered Species Act (ESA). 57 Remarks by MEMA director Kurt Schwartz at the Barnstable County Regional Emergency Planning Committee Oct. 3, 2012 Harwich Community Center <http://capedownwinders.org/wp-content/uploads/pdf/MEMA_Dir_Schwartz_BCREPC_121003_highlighted.pdf> 58 http://www.capecodbaywatch.org/wp-content/uploads/2012/10/10.05.12-noi-w-exhibits.pdf Version 2, Oct. 21, 2015 15 On February 8, 2013 shuts down when a blizzard nicknamed Nemocauses a LOOP.59 eparated and begun leaking tritium. The tritium leak is accidentally discovered when water was discovered coming out of an electrical junction box at the facility.60 On April 14, 2013 operators manually shut down ssure lowering beyond established control bands. On June 10, 2013 the Cape Cod National Seashore Advisory Commission sends a letter to Governor Patrick asking him to support 14 Massachusetts towns on Cape Cod that have passed warrant articles or ballot questions calling on NRC to shut Pilgrim.61 During the July 2013 heatwave, , requiring Pilgrim to shut down in order to comply with its NRC license. In July 2013, the U.S. Department of Energy published a report outlining vulnerabilities to climate trends at energy facilities, including nuclear power stations. The report specifically cites climate change patterns such as increasing air and water temperatures, increasing intensity of storm events, sea level rise, and storm surges as having potential negative implications for thermoelectric forms of power generation (including nuclear facilities).62 In August 2013, a report commissioned by the Pentagon and published in August 2013 highlights the vulnerability of nuclear power plants nationwide to terrorist attacks. The report specifically cites Pilgrim as one of eight plants most vulnerable to a water-borne attack.63 In August 2013, local residents file Town of Plymouth zoning laws for dry cask storage facility for long term storage of high-level nuclear waste. (Legal appeal pending in Massachusetts Land Court as of September 2015.) On August 22, 2013 operators shut down level. The cause of the lowering water level was due to the trip of all three feedwater pumps. 59 NRC. Event Report 48736. <http://www.nrc.gov/reading-rm/doc-collections/event-status/event/2013/20130211en.html> 60 Old Colony Memorial. Apr. 20, 2013. PILGRIM STATION: Tritium source accidently discovered. <http://www.capecodbaywatch.org/wp-content/uploads/2012/10/Print.pdf> 61 Cape Cod National Seashore Advisory Commission Letter to Governor Patrick, Jun. 10, 2013. <http://www.nps.gov/caco/learn/management/upload/Adv-Com-letter-to-Gov-Patrick-re-Pilgrrim-nuclear-plant-6-10-13.pdf> 62 U.S. Dpt. of Energy. 2013. U.S. Energy Sector Vulnerabilities to Climate Change and Extreme Weather. 84 pp. 63 Kirkham L., and A.J. Kuperman. Aug. 2013. Protecting U.S. nuclear facilities from terrorist attack: re-assessing the pproach. Nuclear Proliferation Prevention Project, LBJ School of Public Affairs, University of Texas at Austin. Working paper #1. 33 pp.

Version 2, Oct. 21, 2015 16 In September 2013, MassDPH reported that sampling wells was trending higher than other wells on the site (4,882-5,307 pCi/L of tritium detected in well #216 in August). MassDPH reported that the leak could be related to the separated 64 On Oct 14, 2013, a LOOP occurs due to the loss of the second 345kV line 355 (power line out of service). In October 2013, tritium levels in ell #216 continue to trend higher than the other wells (3,330-5,720 pCi/L). Tritium levels in wells #209 and #211 are also trending higher (797-as a possible source by MassDPH. Tritium, cobalt-60, and cesium-137 is also found in soil at levels above normal.65 In 2013, led by Cape Downwinders, all 15 towns on Cape Cod vote to support a nonbinding ballot question or a town meeting warrant article that gives citizens the opportunity to vote yes on a statement asking Governor Patrick to call upon the Nuclear Regulatory Commission (NRC) to shut down Pilgrim based on safety concerns. 2014 2014: By January 2014, nine months since neutralizing sump pump discharge line was originally suspected to have separated and begun leaking tritium, the leak(s) continue. Excessive levels of tritium (69,000-70,000 pCi/L) were detected in monitoring well #219.66 On January 2-3, 2014 and simultaneous high tides affect the Massachusetts coast. The storm drops 8-13 inches of snow in Plymouth County along with high winds, frigid temperatures, and coastal flooding. What is different about this storm is that at least 2 astronomical high tides occur at the same time as the storm a relatively rare event. JRWA sends a letter to the NRC suggesting that the storm/tidal events could be a valuable opportunity for the NRC to assess the flooding potential at Pilgrim more accurately. 64 MassDPH. PNPS groundwater monitoring update as of Sept. 3, 2013. <http://www.capecodbaywatch.org/wp-content/uploads/2013/09/PNPSUpdate-9-3-20131.pdf> 65 MassDPH. PNPS groundwater monitoring update as of Oct. 18, 2013. <http://www.capecodbaywatch.org/wp-content/uploads/2013/11/PNPSUpdate-10-18-2013.pdf> 66 Cape Cod Bay Watch. Jan. 28, 2014. Pollution of the Plymouth-Carver Sole Source Aquifer Continues. <http://www.capecodbaywatch.org/2014/01/pollution-of-the-plymouth-carver-sole-source-aquifer-continues/>

Version 2, Oct. 21, 2015 17 On January 28, 2014 Cape Cod Bay Watch (CCBW) NPDES permit - 18 years expired at this time. In a letter to EPA Administrator Gina McCarthy, CCBW points ouenew Pilgrember 2013, and that the 18-year delay is unacceptable.67 In February, 2014 NRC identifies Pilgrim as one of the nine worst performing nuclear reactors in the U.S. On March 10, 2014 about 65 Cape Codders gathered at Mass. Statehouse to provide testimony to Governor Patrick, urging him to comply with non-binding referenda passed in every Cape town and ask the NRC to close Pilgrim. About G, and a meeting occurs. A week later (March 17), Governor sends letter to NRC Chairman expressing concern about Pilgrim. In his letter he I urge you to require that the plant be decommissioned should Pilgrim not comply with all health, safety and environmental regulations On March 18, 2014 a criminal trial is held involving 11 activists charged with criminal trespass at Pilgrim. The activists ,their actions were necessary to prevent the unacceptable danger caused by s. Dr. Richard Clapp, epidemiologist from Boston University, testifies that k and an The activists were found guilty and sentenced to one day in jail.68 In March 2014, The Association to Preserve Cape Cod issues a position statement regarding threats calls on public officials and regulatory agencies to .69 On May 10, 2014 Plymouth residents overwhelmingly voted to approve Question 1, with 83% of voters voting yes. Question 1 encourages town leaders to ensure that spent nuclear fuel assemblies (nuclear waste) stored at the Pilgrim Nuclear Power Station are transferred from wet pool to dry cask storage quickly and in the safest way possible. May 14, 2014 Entergy applies to MassDEP for a 30-year Chapter 91 permit under the Public Waterfront Act (Mass. General Laws chapter 91) to use the public lands along the Cape Cod Bay shoreline in front of Pilgrim to install equipment for an emergency cooling water system. Entergy needs to install the equipment to comply with the NRCFLEX strategy.70 67 CCBW. Letter to EPA, Jan. 28, 2014. <http://www.capecodbaywatch.org/wp-content/uploads/2014/01/NPDESLetter_Final_2014Jan28.pdf> 68 Gellerman B. Mar. 21, 2014. 12 Protesters Found Guilty of Trespassing at Pilgrim Nuclear. WBUR. 69 APCC. Pilgrim Position Statement, March 17, 2014. <http://www.apcc.org/positionstatements/statements/2014/Pilgrim-3-17-14.pdf> 70 <http://www.capecodbaywatch.org/wp-content/uploads/2014/10/Entergy-Chapter-91-Application.pdf>

Version 2, Oct. 21, 2015 18 In May 2014, the NRC new data from the U.S. Geological Survey that says that Pilgrim is more at risk than previously thought.71 On July 10, 2014 as required by the Clean Water Act, EPA claims that it cannot improve the cooling water intake operations at Pilgrim to prevent environmental destr On July 21 and July 31, local groups, including JRWA, submit comments to MassDEP concerning Chapter 91 application to install equipment for an emergency cooling water system in Cape Cod Bay.72 MassDPH issues its August 2014 report on groundwater testing at Pilgrim. Tritium levels in wells #216, #218, and #219 are still trending higher.73 In September 2014, Pilgrim Watch and Cape Downwinders file a petition with the NRC suspend, or take any other action to the operating license of Pilgrim Station until the NRC can assure sufficient land-based security at Pilgrim Station is in place to provide reasonable assurance ding). In November 2014, a public hearing takes place MassDEP application for a Chapter 91 Waterways License under state law Chapter 91. Approximately 100 people attend the public hearing in Plymouth held by MassDEP. Entergy needs the Waterways License to implement part of its FLEX plan to provide emergency cooling water from Cape Cod Bay. On November 4, 2014 74% of voters in the Cape & Islands Senatorial District vote in favor of the s district be instructed to vote in favor of legislation to expand the radiological Plume Exposure Emergency Planning Zone around the Pilgrim Nuclear Power Station in Plymouth, an approximately 10 mile-radius area, to include all of Barnstable, Dukes and N 74 71 Legere C. May 1, 2014. Seismic activity exceeds Pilgrim <http://www.capecodbaywatch.org/wp-content/uploads/2012/06/2014.05.01_CCT_Seismic.pdf> 72 <http://www.capecodbaywatch.org/2014/07/Opportunity-for-public-comments-on-Entergy's-Use-of-Public-Land> 73 MassDPH. PNPS groundwater monitoring update as of Aug. 5, 2014. <http://www.capecodbaywatch.org/wp-content/uploads/2014/08/DPH_Tritium_Aug-2014.pdf> 74 Entergy. Nov. 2014. Discharge Monitoring Report October 2014.; and Entergy. Jan. 20, 2015. Discharge Monitoring Report December 2014.

Version 2, Oct. 21, 2015 19 2015 2015: On January 26, 2015 the NRC issues a Supplemental Inspection Report75 based on an inspection carried out from November 3, 2013 to December 12, 2014. This was a response to the able unplanned scrams in 2013. The NRC found that after inspection, Entergy had not adequately addressed problems that had caused the scramsreport, the team cites several examples where fixes were not completed as intended or were 76 In the report the NRC also announces it will continue to place Pilgrim in the degraded cornerstone In January-February 2015, Entergy fills the first 3 dry casks with nuclear waste on the Pilgrim site. On January Junocauses an unplanned shutdown at Pilgrim due to a LOOP and a variety of other problems.77 It remains offline until February 8. This event triggers the NRC to send a Special Inspection Team problems following the shutdownfinal report identifies 8 violations of federal safety requirements. Pilgrim earns -cited violation. By early June, On February 14, 2015 Neptunecauses planned shutdown. In February 2015, to install emergency cooling equipment in Cape Cod Bay by issuing a determination letter. In February 2015, JRWA asks the NRC and Entergy to provide an updated site assessment for the Pilgrim site (for vulnerability to flooding, storm and wave impacts). In a letter to the NRC dated t Entergy has provided 78 75 NRC 9002 Supplemental Inspection Report 05000293/2014008 76 NRC Blog, www.nrc.gov, 1/28/15. 77 Ibid. 10 78 <http://www.capecodbaywatch.org/2015/02/press-release-pilgrim-site-maps-cut-and-paste-local-group-wants-updates/>

Version 2, Oct. 21, 2015 20 flooding reevaluation reportNRC, which has many deficiencies. In March 2015, local residents and JRWA file a legal appeal challenging MassDEP decision to issue a Fukushima plan, which will to put an emergency cooling water system on the Cape Cod Bay shoreline. [Appeal pending] Also in March 2015, the NRC holds its annual public meeting Unlike past years, hundreds of people attend the meeting in Plymouth. Entergy organizes employees, grantees, and others to speak in favor of Pilgrim. Opponents seek answers from NRC on continuing groundwater pollution, inadequate emergency planning, pollution, etc. In May 2015, Clean Water Act NPDES permit become 19 years expired (1996). On May 26, 2015 loss of condenser vacuum causes an unplanned shutdown. On June 8, 2015, Cape Cod Bay Watch issu-year history of Entergy, Our Bay is . Twenty-four state and regional groups endorse the report.79 On June 11, 2015 Pilgrim Watch, Cape Downwinders, and the Town of Duxbury Nuclear Advisory Committee file a 2.206 petition to the NRC operating license of Pilgrim until the NRC can provide reasonable assurance that adequate From June 13-16, 2015 the March for Our ChildrenMass. Downwinders, takes place. The march is a 4-day, 54-mile event to raise public awareness and to let elected officials know that Pilgrim is a danger to health, economy, and environment. The event ends with a rally (June 16) at Mass. Statehouse. Speakers include former Gov. Mike Dukakis, State Sen. Dan Wolf, and Paul Gunter, founder of Clamshell Alliance and Subrata Ghoshroy, research affiliate at the Program in Science, Technology, and Society at MIT speaking on his recent trip to Fukushima. Joint Committee on Public Health and Safety hears testimony on several bills relating to emergency planning and radiological monitoring at Pilgrim. On August 9, 2015 Pilgrim is forced to reduce power due to the water in Cape Cod Bay being too warm. Later in the month, on August 22, Pilgrim experiences an unplanned shutdown, or scram, due to a valve problem. 79 CCBW. June 8, 2015. Entergy, our bay is not your dump. <http://www.capecodbaywatch.org/2015-water-pollution-report/#toc>

Version 2, Oct. 21, 2015 21 On September 1, 2015 oblem during Winter Storm "Juno, the NRC announces it maintains finding. One day later (September 2) Pilgrim is degraded to category IV by the NRC 99 reactors. This downgrade is based on numerous forced shutdowns and equipment failures, and is just one step away from mandatory shutdown by federal regulators. Only 2 other reactors in the country are currently in that category: Arkansas Nuclear One and Arkansas Nuclear Two. These two, like Pilgrim, are Entergy-owned. On September 17, 2015 Entergy officials announce that closure of Pilgrim is on the table.80 If Entergy cannot afford the multi-million dollar safety improvements and other updates required by federal regulators, then the plant will go offline. On September 24, 2015 a hearing takes place at the MassDEP offices in Lakeville, Mass. The hearing is held before an administrative law judge, and concerns a residents/JRWA appeal that Fukushima plans at Pilgrim. The appeal is still pending. On October 2, 2015 an NRC inspection Of Pilgrim revealed malfunctioning meteorological towers at the facility. About a week later, on October 7, media reports reveal that Pilgrim has posted workers on fire watch after realizing the plant never addressed a 1992 federal advisory regarding remote reactor shutdown. On October 13, 2015 Entergy announces that Pilgrim will close no later than June 2019. 80 Abel, D. Sept. 17, 2015. Pilgrim nuclear plant says it may shut down. Boston Globe. <http://www.capecodbaywatch.org/wp-content/uploads/2015/09/2015.09.17_BosGlobe_PilgMayShutDown.pdf>

Version 2, Oct. 21, 2015 22 Additional Resources: Beyond Nuclear www.beyondnuclear.org Cape Cod Bay Watch www.capecodbaywatch.org Cape Downwinders www.capedownwinders.info Cape Downwinders Cooperative www.capedownwinders.org Concerned Neighbors of Pilgrim www.concernedneighborsofpilgrim.org Massachusetts Downwinders www.madownwinders.org Pilgrim Coalition www.pilgrimcoalition.org Pilgrim Watch www.pilgrimwatch.org Nuclear Information Resource Service www.nirs.org Union of Concerned Scientists www.ucsusa.org/nuclear-power U. S. Nuclear Regulatory Commission www.nrc.gov Acronyms: EPA U.S. Environmental Protection Agency FLEX Diverse and Flexible Coping Strategies JRWA Jones River Watershed Association LOOP loss of offsite power MassDEP Massachusetts Department of Environmental Protection MassDPH Massachusetts Department of Public Health MEMA Mass. Emergency Management Agency NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NTTF NRC's Near-Term Task Force pCi/L picocuries per liter SIT Special Investigation Team ZBA