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ENVIRONMENTAL IMPACT-RESPONSIBILITY FOR ASSESSMENT

NRC has ultimate responsibility; however they have not been a responsible agency is this regard - in all practicality monitoring , testing and reporting is left to the licensee. NRC "rubber-stamps" the results.

Entergy collects its samples; tests the samples in their own laboratory; and reports the results. The licensee is required to issue Annual Environmental Monitoring reports; they are submitted in May. In addition, the licensee issues annual reports specifically on Marine Ecology Studies, titled Marine Ecology Studies Related to Operation of Pilgrim Station.The reports are  available on NRC's Electronic Library. Pilgrim's environmental assessment program is discussed in the Monitoring section of this website.

Massachusetts Department of Public Health has responsibility under Chapter 111 Section 5K to assess Entergy monies to fund the department's Radiation Control Division so that they can perform their duties under the section. Duties include:

Chapter 111: Section 5K.Nuclear reactors; monitoring and surveillance; charges and assessments http://www.mass.gov/legis/laws/mgl/111-5k.htm

Section 5K. (A) The department, subject to appropriation, shall adopt rules and regulations that monitor the use and release of nuclear materials, source materials, or radioactive materials, whether irradiated or not, as they pertain to the operation of nuclear reactors.

(B) The department shall, subject to appropriation, establish and maintain a monitoring and surveillance program for all nuclear reactors. Such a program shall include, but not be limited to, the following activities:—

(1) The department, subject to appropriation, shall create a network of monitoring stations not all in fixed locations, to ascertain the movement, dispersal and reconcentration of any radioactive materials originating from nuclear reactors, whether in gaseous, liquid or solid form. For the purpose of this section, the department may utilize, (I) equipment owned and operated by the department, (II) equipment maintained and operated by the nuclear reactor operators either directly or indirectly and (III) the data obtained therefrom.

(2) The department shall, subject to appropriation, conduct periodic surveys to determine the extent and seriousness of radiation doses received by humans and animal life resulting from the reconcentration of radioactive materials, released from nuclear reactors. Such surveys and monitoring programs may be conducted in cooperation with other departments or agencies of the commonwealth or of any other state, or with the federal environmental protection agency the nuclear regulatory commission, or any other federal agency, or with any other suitable qualified persons or institutions.

(3) The department shall, subject to appropriation, make inspections either announced or unannounced, of each nuclear reactor installation or site located within the commonwealth. For the purposes of such inspections, the department is hereby specifically authorized to enter at any time (I) upon the site of said nuclear reactor installation whether said reactor is proposed, under construction, or in operation and (II) any buildings or facilities thereon, as may be necessary, in the judgment of the department, to determine compliance with its rules and regulations adopted under the provisions of this section. Subject to appropriation, the commissioner may appoint and remove inspectors to comply with the provisions of this section. Said inspectors shall have all the power and authority of inspectors as defined by section nine of this chapter.

(C) The department shall, subject to appropriation, publish and make available to the general public or to any interested party on a semi-annual basis, for each operating nuclear reactor, a summary and discussion of the results of the monitoring and surveillance program for the previous six months, including the results of any surveys completed under provisions of clause (2) of paragraph (B).

The summary for each nuclear reactor shall include, at a minimum: (1) a comparison of actual emissions and emission rates of radioactive materials, whether in a liquid or gaseous form, with those allowed by the technical specifications appearing in the facility operating license of the reactor; (2) the estimated radiation doses received as a result of said emissions at various geographical locations under various occupancy assumptions; (3) a comparison of said estimated doses with applicable federal exposure guidelines; and (4) a listing and discussion of all accidents or abnormal occurrences, as defined by 42 USC sec. 5848, that were reported to the nuclear regulatory commission, pursuant to 42 USC secs. 5841 to 5849, inclusive, to rules and regulations promulgated under the authority of said statute, or to the requirements of the facility operating license of nuclear reactors.

(D) To support the development and operation of a state radiation monitoring program, the operators of nuclear reactors shall have reasonable charges levied against them.

(E) The department is hereby authorized to make an assessment against the operator of each existing and proposed nuclear power plant in the commonwealth in an amount equal to the costs incurred in the prior fiscal year by the department’s radiation control program in the performance of its duties under this section. The department is hereby further authorized to make a collection, based on that assessment, of monies from said operators of nuclear power plants to defray the cost of such activities. Said amount shall not exceed $90,000 per annum, per facility, which shall be expended for any such facility, including, but not be limited to, a facilities located in the town of Rowe and in the town of Plymouth, and in Seabrook, New Hampshire. The department shall send notice of its assessment to the individual company against which the assessment is made, and said company shall pay such assessment within 30 days of the notice of the assessment; provided, however, that such company shall have a reasonable opportunity to submit objections concerning said assessment to the department for review. If, after completion of such review, the department determines the assessment is valid, the department shall issue a demand for such assessment, and the company against which such assessment is made shall pay such assessment immediately. If a company subject to assessment under this section fails to pay the assessment within 30 days of the notice of the assessment, or fails to pay the demand for assessment upon completion of the final review, whichever occurs later, the department may refer such matter to the department of revenue for the collection of the assessment in accordance with applicable enforcement provisions pursuant to chapter 62C. The amount so collected shall be deposited into the General Fund and credited to the department.

Both MDPH’s and Entergy’s environmental monitoring programs consist of sampling media in the environment including animal forage, vegetation, cranberries, seawater, sediment, Irish moss, shellfish, American lobster, and fishes.

MDPH’s Program’s environmental samples are provided by Entergy with the exception of air and milk. Although radiation is released to the environment daily and bio-accumulates, the MDPH’s samples are a single sample taken some day, in one month or another. The control samples are improperly labeled. They were taken from locations within the expected influence of Pilgrim Station. This should be obvious, for example, because MDPH’s milk sample is from Duxbury and labeled by MDPH as an indicator sample. The analysis, like the air samples, essentially measures gamma and avoids measuring important beta and alpha particulates. The NRC recently pointed out that analysis for only gamma particles would miss radionuclides significant to public health and does not suit today’s waste streams and technology. We understand from NRC documents that today, as a result of better fuel performance, and improved radioactive source term reduction programs that the new liquid radioactive effluent source term is made up of a lower fraction of gamma emitting radionuclides and a higher fraction of beta emitters. MDPH provides no public reports; with computers this should not be either expensive or difficult for MDPH to do. The Commonwealth’s Radiation Lab (MERL) and the Radiation Department at MDPH are slated to disappear in FY10 if the Administration’s budget passes.

Groundwater Monitoring

NRC Lessons Learned Task Force: In response to reports of leaks from reactors across the country, some resulting in radioactive contamination to offsite drinking wells, NRC formed a Groundwater Contamination Task Force.  Lessons Learned Task Force Report on groundwater contamination at nearly 20 plants, the NRC acknowledges that its own regulations fail to adequately address underground leaks of radioactive water from plant piping and spent fuel pools. Indeed, the current regulations do not require plant owners to monitor the groundwater onsite for contamination if he onsite water is not used for drinking, nor is there a requirement to immediately remediate a spill or leak once it’s discovered. The report also concludes that, due to the gaps in the agency’s inspection regime, slow underground leaks can continue undetected for extended periods of time. NRC, instead of requiring monitoring wells, allowed the industry instead to have its own voluntary groundwater monitoring initiative. Leaks from Pilgrim's aging components into Cape Cod Bay is obvious concern. 

Pilgrim Station’s Voluntary Groundwater Monitoring Initiative: NRC does not require monitoring wells onsite unless the onsite water is used for drinking. The nuclear industry initiated a voluntary groundwater initiative in response to the “epidemic” of leaks at reactors around the country, some leaking radioactive liquids into offsite drinking wells and into waterways.

Pilgrim recently joined this voluntary program in November 2007. Pilgrim’s topography is such that any leak would go into the Bay. Pilgrim has one- mile of shoreline.  They placed three wells between the Main Reactor Building and Cape Cod Bay; we have no information on screen depth(s) on each well.  A well upgrade, that had been installed years before to keep track of an oil spill, is now being called a "control well." Many local gasoline stations have at least four monitoring wells; therefore a nuclear reactor should have many more. The wells were placed without a thorough hydro-geological assessment; instead the hydrologists reviewed old studies and walked the property. They have one control well – a well that was placed long ago up-gradient to keep tabs on an old oil leak. It would be coincidental if that well were ideally placed.  

The wells are sampled only for gamma and tritium. Again, with the exception of tritium, beta and alpha particles are ignored. This is especially troubling because strontium-90, cobalt -60, cesium-137 and transuranics were found during decommissioning work at Yankee Atomic, Maine Yankee and Connecticut Yankee and an array of beta emitters were discovered from leaks at currently operating reactors - such as at Entergy’s Indian Point where they found high levels of tritium (250,000 to 300,000 pCi/L), cesium, cobalt, strontium and nickel. We do not understand not testing for an array unless they have something to hide. Tritium, after all, is a beta emitter. Tritium was discovered in one of the wells; the actual onsite source cannot be determined for many months.

MDPH is given split samples from these 4-monitoring wells. We have little information on MDPH’s role– is there a contract; will MDPH analyze for a whole spectrum of radionuclides or simply follow the inadequate protocol followed by the licensee; and is MDPH implying approval of Entergy’s program by its cooperation?

For more about monitoring, see the Monitoring section of this website

 

And for More about Pilgrim's environmental impact

 

PilgrimWatch.org