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THE
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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:
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
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