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Overview: New England’s fishing stocks are depleted; fishermen face restrictions. Pilgrim should never be allowed to continue with an unrestricted fishing permit. Enough harm has been done to our marine ecosystem; license renewal should not be considered without a dry cooling system installed as a prior condition of operations; and in the interim simple mitigation measures required. 

Simple mitigating measures to be considered in the interim:

bullet Pilgrim NPS now runs its water intake pumps continually at 100%. However, it is not necessary to run the pumps all the time; and they can operate variably at 25% to 75%. If the flow is reduced, the number of eggs, larvae and juvenile fish entrained will be reduced; and the number of fish entrapped reduced.
bullet Pilgrim NPS should target the date of their refueling outages so that it coincides with the period that most fish eggs are in the waters, March.


License Renewal Process and Environmental Review

Environmental Impact Statements


NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants," Final Supplement 29, regarding Pilgrim Nuclear Power Station Final Report, was published July 2007. This supplement documents the NRC staff's review of the environmental issues at Pilgrim Nuclear Power Station regarding Entergy Nuclear Operations, Inc., application for license renewal of that facility. The supplement was prepared in accordance with 10 CFR 51.71. This supplemental environmental impact statement includes the staff's analysis that considers and weighs the environmental effects of the proposed action, the environmental impacts of alternatives to the proposed action, and alternatives available for reducing or avoiding adverse impacts. It also includes the staff's recommendation regarding the proposed actions.


License Renewal -Marine Aquatic Resources

What NRC had to Say

NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants," Final Supplement 29, regarding Pilgrim Nuclear Power Station Final Report, was published July 2007.The NRC staff concluded that cumulative impacts of PNPS license renewal would be SMALL for most potentially affected resources, with the exception of the local winter flounder population and Jones River population of rainbow smelt, for which impacts would be MODERATE (p.9-5).

What’s Wrong? 

Methods used to Assess Impact: How did NRC come to their conclusion when marine impact cannot be assessed at present because definite numbers have not been set on what constitutes “significant impact?”  A yardstick has to be firmly established for each species (plant and animal) with appropriate federal, state and independent partners and rationales provided to the public; and Thermal backwash was not considered. During a thermal backwash, about 155,000 gpm of heated water (>105°F) is sent into the intake embayment for a period of about 1.5-2 hrs. Studies to evaluate potential impacts of the thermal backwash have not been performed.  

Determining Impact: There appear to be many methods used to determine impact, each with drawbacks. Pilgrim Watch argued that it should be determined before going forward with a 20-year license extension what methods provide the most reliable estimates of impact, with a detailed rationale; a requirement that these methods are followed by the licensee unless better methods are established and independently approved.  

We understand that there has been no policy statement regarding losses on a square mile basis by any state or federal agency. NRC should in its review process determine what percent loss is a significant detriment to any population [figure depending on population], with a detailed rationale.

Entrainment: Winter Flounder – methods used by Entergy to determine impact 

1. Equivalent adult method:  “researchers conducting this work have assumed an otter trawl efficiency of 50%, but the actual efficiency may be much lower (or higher), which would alter the number of fish in the study area per square mile and the apparent impact. Second, entrainment sampling results are quite variable. Third, it is difficult to determine the accuracy, and therefore, the applicability, of the survival matrix used in estimating equivalent adults.” Whether or not these levels of impact are a “significant” detriment to the population, and will result in slowing the return to much higher population densities, is currently unknown and a policy statement regarding losses on a square mile basis has not been issued by any of the state or federal agencies. EPA Region 1 has stated in the past that population impacts of 5% or greater are typically of concern. However, to DEP’s and Pilgrim Watch’s knowledge, the geographic bounds of this particular population have not been agreed upon by state or federal agencies.  

2. Second method is to estimate the percentage of the total larval population passing in front of the facility that is entrained. 

3. The third method used by the facility to evaluate impact was the RAMAS (Risk Analysis Management Alternative System; Ferson, 1993) winter flounder model. It was used from 1999-2001 to further evaluate the effects of the facility on the Cape Cod Bay winter flounder population. Results suggested that stock reductions from 2.3 to 5.2% might occur as the direct result of entrainment at the facility.  

It should be determined and agreed upon by NRC, appropriate state agencies and independent analysts what method or methods actually provide accurate information needed to assess more accurately impact before the license is approved.  

4. An analysis of Backwash effects has not been performed to the best of our knowledge.

Potential Mitigation Measures: 12 measures are listed; however “The NRC staff has not conducted an analysis of each of these measures relative to their applicability to PNPS. It is expected that a more thorough analysis of the costs and benefits of these technologies would be conducted as part of the 316(b) CDS currently being conducted by PNPS in support of the NPDES permit renewal.”

Missing from the list is thermal discharge – allowable maximum temperature of the water discharged and its measurement. Discharge temperature is now averaged over an hour; instantaneous measurement should be required. We are told that instantaneous releases have been over the allowable limit. Those reading do not appear on the record because they can be countered by a lower release – a way to cook the books and the fish that happen to be swimming by at the wrong time. 

5. Cape Cod Bay is an Ocean Sanctuary. Therefore greater consideration of a wider range of species needs to be analyzed further.


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