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PILGRIM’S ENVIRONMENTAL RADIATION REPORTS

Unreliable

Overview: Pilgrim has a long history claiming that the amount of radiation released is so small that it is inconceivable that any cancer or negative health impact would result. Do not buy it. There is at the heart of Pilgrim’s argument, a fundamental flaw – no one knows how much radiation Pilgrim has actually released. What we know is that it is more, and again who knows how much more, than is shown in their reports.
There are a number of reasons that this is so. The monitoring equipment is not state of the art; not all potential egress routes are monitored; sampling, the scope and the frequency of the sampling program has been reduced over the years and the so-called "control" sampling locations are too close to the reactor, in truth they are indicator stations; Pilgrim's own laboratory analyzes the samples and writes the reports, their is no meaningful outside verification by either the state or federal government.

Monitoring Equipment

The instrumentation used to make measurements: It is simply not accurate – for an analysis, please see monitoring section; and from the "horse's mouth," the NRC, we have confirmation.

NRC's LIQUID RADIOACTIVE RELEASE LESSONS LEARNED TASK FORCE FINAL Report, September 1,2006

http://www.nrc.gov/reactors/operating/ops-experience/grndwtr-contam-tritium.html

"The radiation detection capabilities specified in the BTP  [Branch Technical Division]  are the 1970’s state-of-the-art for routine environmental measurements in laboratories. More sensitive radiation detection capability exists today, but there is no regulatory requirement for the plants to have this equipment. The guidance primarily focuses on gamma isotopic analysis of environmental material and on tritium in water samples. There are minimal requirements for analyzing environmental samples for beta- and alpha -emitting radionuclides." P.18

Potential Egress Routes Not Monitored

Another reason for the likely difference between real emissions and what Pilgrim reported is that reports ignore the potential airborne radionuclide emission points. One such point was the turbine room; it was not monitored at all until the early 1990’s. Today there are not continuous monitors on the outflow pipe into Cape Cod Bay; and the four onsite monitoring wells are not placed according to standard accepted design criteria, are inadequate in number, and the sampling is neither frequent enough nor encompasses testing for all the potential radionuclides that can leak and be harmful. How many other points were, and remain, unmonitored?

Sampling

The NRC allows licensee's to reduce the scope and frequency of the sampling program. We deserve more not less because (1) older reactors leak with greater frequency; the National Academies has said unequivocally that even low doses of radiation are more harmful than previously thought; and radiation bio-accumulates in the environment.

Again from the "horse's mouth," NRC, LIQUID RADIOACTIVE RELEASE LESSONS LEARNED TASK FORCE FINAL Report 2006

"The regulatory guidance provides built in flexibility in the scope of the REMP [ Radiological Environmental Monitoring Program]. It …allows licensees to reduce the scope of and frequency of the sampling program, without the NRC approval, on historical data. .. if a licensee’s environmental samples have not detected licensed radioactive material in several years, then the licensee typically reduces the scope and sample frequency of the associated environmental pathway. NRC inspections have observed reductions in the scope and frequency of licensee programs…" p.19

Example:

Milk Radioactivity Analyses: Prior to 2000, milk samples were obtained from an indicator station, Plymouth County farm, and from a control station located in Whitman. Plymouth County Farm stopped milking cows and since that time Entergy has claimed that they could not identify any additional milk animals within 5 kilometers of Pilgrim. They have not looked hard enough – Plymouth Plantation is nearby, Duxbury's O'Neil Farm is the oldest operating dairy farm in the country and is within the Emergency Planning Zone, and goats are abundant in Plymouth – and if none were available, they could pay a farmer to provide an appropriate sample. Milk is a key indicator.

Locations of control stations- Pilgrim NPS:

To determine Pilgrim’s radiological impact on the general public, samples are collected and analyzed for radioactivity. The sampling locations are divided into two classes, indicator and control. Indicator locations are those that are expected to show effects from PNPS operations. These locations were primarily selected on the basis of where the highest predicted environmental concentrations would occur. While the indicator locations are typically within a few kilometers of the plant, the control stations are generally located so as to be outside the influence of Pilgrim Station. They provide a basis on which to evaluate fluctuations at indicator locations relative to natural background radiation and natural radioactivity and fallout from prior nuclear weapons tests.

Many so-called control stations are within sight of the reactor and within the official Emergency Planning Zone Communities. In reality they are indicator stations. If radiation is above expected in a sample collected from a “control station” it is attributed to weapons fallout, not Pilgrim. Also radioactive particulates released to the air from the stack, will be carried by the wind some distance and deposited some distance from the reactor site.

Terrestrial and Aquatic Sampling Locations, Figure 2.2-5, page 64 – Pilgrim Nuclear Power Station, Radiological Monitoring Program, Report No. 32, January 1 through December 31, 1999, Entergy

Description Distance/Location
Surface Water  
Powder Point Control 13 km NNW
Irish Moss  
Brant Rock Control 18 km NNW
Shellfish  
Duxbury Bay Control 13 km NNW
Powder Point Control 13 km NNW
Green Harbor Control 16 km NNW
Lobster  
Duxbury Bay Control 11 km NNW
Fishes  
Jones River Control 13 km WNW
Sediment  
Duxbury Bay Control 14 km WNW
Green Harbor Control 18 km WNW


Analysis Samples & Reports

Pilgrim analyzes its own samples and writes up the reports at the Fitzpatrick Lab that they happen to own.

Implausible excuses for high findings -Pilgrim’s reports are ludicrous on their face.

a. Milk: Milk historically was tested for radionuclides, both in farms around Pilgrim and at a control station in Whitman, 22 miles away. Pilgrim’s environmental impact report for 1980 noted that , at the farms around Pilgrim, “the measured average concentrations of both CS-137 and SR-90 were respectively 10,000 and 1,000,000 times in excess of the concentrations expected to be present…” and went on to say that this is unquestionably due to atmospheric fallout resulting from atmosphere testing.” The effort to blame the increase on “atmosphere fallout” ignores a critical fact – no similar increase was experienced at the control station in Whitman. How fallout like a smart bomb, was able to find Pilgrim’s farms while simultaneously missing those in Whitman, is beyond comprehension.

Milk, late June 1982: the cesium-137 concentrations in the cow’s milk, Kings Residence were 1,000,000 times in excess of the concentrations expected. Pilgrim’s report attributes the increase, in a new and novel way, to the cow’s pregnancy, “It is not uncommon to find marked increases of CS-137 associated with a cow’s pregnancy, and this was most likely the cause.” Page 3-69. Animals do not produce cesium on their own. It must be introduced into the cow’s system from an environmental source. The likely source was the nuclear reactor up the street.

Vegetation, June 1982: the cesium-137 measurements detected in vegetable samples from the Evans Residence (0.7 miles W) and the Whipple Residence (1.5 miles SSW) were 1,000,000 times what would be expected and once again according to Pilgrim, “strongly indicates fallout.”
Shellfish, June 1982: Positive measurements of BE_7, Cs-137 and CO_60 found at Plymouth Harbor. The Cs-137 again according to Pilgrim is, “…due to fallout.”

b. Vegetation & Shellfish: The same “he did it” attitude is found in yearly reports in previous and subsequent years right up to now, not only in milk but in such things as cranberries, vegetation and shellfish. For example, report for 1988 stated that “no iodine-131 was detected in milk during 1988 (but, once again, the cesium-137 and strontium-90 is considered to be attributable to fallout from previous atmospheric testing…”) Iodine-131 was found in 1980. Again the reason for both years’ reports seems obvious. Pilgrim was closed from 1986 through 1988. Relatively short-lived iodine-131 was thus unlikely to be detected after two years, but quite expectedly reappeared when the plant opened in 1990. Cesium-137 and strontium-90, on the other hand, are long-lived, and can far more plausibly be attributed to emissions in 1986 and before that to some far off “atmosphere testing.”

c. Plutonium on Duxbury Beach: Plutonium found in Duxbury Bay sediment samples are dismissed by Entergy – attributed to either   weapons testing, cross-contamination from the lab’s glassware or the sample is simply lost.

Sediment Radioactivity Analyses – sediment is collected at the Duxbury Bay Control Station, 14 m NNW from Pilgrim.

(1) In 2001, citizens brought to the NRC’s attention the level of plutonium reported for Duxbury’s sample and complained that the sample station, in reality, was an indicator station due to its proximity and wind direction. Perhaps we should have added plutonium's atomic weight - making it likely to fall on Duxbury Beach if the wind is blowing that way.

REMP Report for 1998 2.17 #31
Sediment Radioactivity Analyses

Plutonium 239/240 was detected in four of the indicator station samples, as well as in the control station samples.

Plutonium 239/240 levels in the indicator samples ranged from 2.2 to 7.9 Pi/kg. The concentration of PU 239/240 in the single sample collected in the control locations beyond the influence of Pilgrim Station was 12.4 Pi/kg. The fact that the results from the indicator locations are lower than those from the control stations indicates that the source of this activity is not Pilgrim Station. The levels detected are also comparable to concentrations observed in the past few years and are indicative of plutonium deposited in the environment from nuclear weapons testing. Emphasis added, Page 33

NRC responded – no convincing justification provided.

(2) Radiological Environmental Monitoring Program Report for 1999
2.17 Sediment Radioactivity Analyses

No plutonium-239/240 was detected in the four indicator station samples, but was detected in both of the control station samples. The concentration of Pu-239/240 in the samples collected from the control locations beyond the influence of Pilgrim Station ranged from 21 to 23 pCi/kg. The levels detected are comparable to concentrations observed in the past few years and are indicative of plutonium deposited in the environment from nuclear weapons testing.

(3) Radiological Environmental Monitoring Program Report for 2000
Plutonium-238 was detected in 2 of 4 indicator samples, and both control samples. Plutonium-239/240 was also detected in two of four indicator station samples, and both of the control station samples.

(4) Radiological Environmental Monitoring Program Report for 2001 Page 32 2.17 Sediment Radioactivity Analyses

As part of the comparison of sediment analyses results to previous years, questions were raised about the abnormally high plutonium-238 concentrations observed in samples collected during 2000. Follow-up investigations conducted by the analytical laboratory that performed the
2000 analyses concluded that the results were invalid due to cross-contamination from laboratory glassware. This laboratory also analyzes samples for Department of Energy clean- up projects. Due to the expense of the specialized glassware, it is re-used. Updated tables from the 2000

(5) Radiological Environmental Monitoring Program Report for 2002.
2.17 Sediment Radioactivity Analyses
Plutonium analyses are also performed on a mid- depth section from the discharge canal sample and Duxbury sample. Two sets of samples of sediment collected during the first half of the year were not analyzed as
required. Although records indicate that the samples were collected and delivered to the analytical laboratory in June, analyses were not performed and the samples could not be located. Eight depth- incremental sub- samples from Plymouth Harbor, as well as the eight depth- incremental sub- samples from Duxbury Bay were delivered to the lab on 27- Jun- 2002 along with 38 samples from the other sampling locations. It is surmised that the samples were assumed to be backup samples from the other locations, not requiring analysis. Two of the samples from the control location in Duxbury were to be analyzed for plutonium, to establish a baseline for comparison to the indicator locations closer to the plant. Plutonium analyses from indicator locations (Discharge Canal Outfall and Manomet Point) indicated no detectable plutonium.
 

Background radiation- false assurances in an attempt to diminish impact

So-called "natural background radiation:" Entergy attempts to diminish the impact of Pilgrim’s releases by comparing them to the amount they claim that we receive from background radiation - natural resources (300 mrem per year) and manmade sources (60 mrem per year) – totaling (360 mrem per year).

Table 1.2-1 (Source: Entergy REMP 2002)
Radiation Sources and Corresponding Doses

NATURAL

 MAN-MADE

 Source               

(mrem/year)

Source           (mrem/year)
Cosmic/cosmogenic  

30

Medical/Dental X-Rays        39
Internal                  

40

Nuclear Medicine               14
Terrestrial                  

30

Consumer Products            10
Radon/Thoron         

 200

Weapons Fallout                 1
   
Nuclear Power Plants          
1
Approximate Total   

300

Approximate Total             60
         


The number (360 mrem) should be viewed with skepticism. It is an average based on industry’s national figures. For example, radon varies considerably throughout the country. Pilgrim is located in Plymouth an area composed mainly of sand – radon is negligible. Further radionuclides from “background” radiation found in nature - in cosmic rays and the earth’s surface  -is different from Pilgrim’s radiation. Background radiation, while still harmful, does not specifically attack the thyroid gland, bones, or other organs.



 


 

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