Massachusetts Attorney General 

Appeals to Federal Court

Massachusetts Attorney General Martha Coakley petitioned the First Circuit Court of Appeals in Boston

to make spent fuel storage part of re-licensing procedures for the Pilgrim Nuclear Power Station, 

Plymouth MA, and the Vermont Yankee Nuclear Power Station in Vernon, Vt. 

Support for the Massachusetts Attorney General’s Petition 

for Rulemaking- Spent Fuel Storage

The NRC does not consider spent fuel storage in its re-licensing review process. 
The Massachusetts Attorney General filed a petition for rulemaking to change this rule 

so that spent fuel storage would be considered as part of the Environmental Impact Statement (EIS). 

There was widespread support for the petition from, for example, the entire 

Massachusetts Congressional delegation, members of the Massachusetts State Senate 

and House, Attorneys General, local Selectmen, public interest groups and citizens.

 Draft Environmental Impact Statement

December 8, 2006:  DRAFT Environmental Impact Statement published
http://www.nrc.gov/reactors/operating/licensing/renewal/applications/pilgrim.html#eistatement

What is it?
Environmental Impact Statements:NUREG-1437, "Generic Environmental Impact
Statement for License Renewal of Nuclear Plants," Draft Supplement 29, regarding
Pilgrim Nuclear Power Station Draft Report for Comment, was published December 2006.

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;
and 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.

Public Participation - What do you think?
January 24, 2006:  Public Meeting regarding Draft SEIS - Radisson Hotel in Plymouth. There will be two sessions 1:30-4:30 and 7:00 -10:00; informal sessions will be held one hour before each session where the NRC will make a general presentation.
February 28, 2006: End public comment period Draft SEIS

Atomic Safety Licensing Board (ASLB) Ruling on Contentions Petitioners

Atomic Safety Licensing Board (ASLB) accepts 2 motions filed by Pilgrim Watch, on a limited basis
and denied Massachusetts Attorney General Motion, Oct 16th. The AGO will appeal and Pilgrim
Watch will join their appeal.

ASLB decision regarding Pilgrim Watch's Motion

Contention 1 - regarding inspection of underground leaks: The board will limit the
contention to buried pipes and tanks that fall within those described in 10 CFR part 54. As so limited,
the admitted contention reads as follows: The Aging Management program proposed is inadequate
with regard to aging management of buried pipes and tanks that contain radioactively contaminated
water, because it does not provide for monitoring wells that would detect leakage.  

Contention 3- regarding Severe Accident Mitigation Analysis: The board will admit the
part of the contention having to do with the input data for evacuation, economic and
meteorological information. As so limited, the admitted contention reads as follows: Applicant's SAMA
analysis is deficient in that the input data concerning (1) evacuation times, (2) economic consequences,
and (3) meteorological patterns are incorrect, resulting in incorrect conclusions about the costs
versus benefits of possible mitigation alternatives, such that further analysis is called for.

With a hearing, a final decision on the application will be 30 months after the receipt of the application.

By November 6, 2006, the Town of Plymouth, other interested state, local governmental body and affected
Indian Tribes may file a request to participate in the hearing on these (2) contentions to the extent defined in the
ruling.

NRC Document library at: http://www.nrc.gov/reading-rm/adams/web-based.html.
Adams Accession Number  ML062890259.
 

Background: Pilgrim Watch and Massachusetts Attorney General - File Motions to Intervene 

Pilgrim Watch and the Massachusetts Attorney General Thomas Reilly each filed Motions requesting intervention
and a hearing in the review of Pilgrim’s re-licensing application to extend operations an additional 20 years to 2032.

The Atomic Safety and Licensing Board Panel is expected to issue a decision on whether to accept all or a portion of 

the Motions by August 17, 2006. 

PILGRIM WATCH’S REQUEST FOR HEARING AND PETITION TO INTERVENE IN PILGRIM’S LICENSE RENEWAL

NRC Document library at: http://www.nrc.gov/reading-rm/adams/web-based.html. 
Adams Accession Number "ML061630125"  
Petitioners submitted five valid contentions for consideration:  

1.  The Aging Management Plan does not adequately inspect and monitor for leaks in all systems
and components that may contain radioactively contaminated water.
2.  The Aging Management Plan is inadequate because it does not adequately monitor for 
corrosion in the Drywell Container.
3.  The Environmental Report is inadequate because it ignores the true off-site radiological
and economic consequences at Pilgrim in its Severe Accident Mitigation Alternative (SAMA) analysis.
4.  The Environmental Report fails to address Severe Accident Mitigation Alternatives (SAMAs) 
which reduce the potential for spent fuel pool water loss and fires.
5.  New Information shows that another twenty years of operations at Pilgrim may have greater
off-site radiological impacts on human health than was previously known.

Two of these contentions concern defects in the Applicant’s Aging Management Plan, and three concern defects in the Applicant’s Environmental Report.  All of these contentions are admissible and meet the requirements of 10 CFR § 2.309.

MASSACHUSETTS ATTORNEY GENERAL’S REQUEST FOR HEARING AND PETITION TO INTERVENE IN PILGRIM’S & VERMONT YANKEE LICENSE RENEWAL APPLICATIONS

NRC Document library at: http://www.nrc.gov/reading-rm/adams/web-based.html.
Adams Accession Number "ML061630088"

The motion was filed to ensure that NRC does not grant the license renewals before Entergy and NRC address the risk of severe accident in the spent fuel pool and comply with federal laws for the protection of public health, safety and the environment; and require Entergy to backfit Pilgrim’s and VY’s designs to eliminate or substantially mitigate the risk of a pool fire. The hearing request and backfit petition arise from safety and environmental risks posed by Entergy’s plan to continue with “high-density” spent fuel storage racks in the pool.

Environmental Scoping and Screening

NEW: Environmental Summary Scoping Report, September 26, 2006 - comments received at the May 17, 2006 meetings, by letter, and email; and NRC Staff responses. To access report go to the NRC Electronic Reading Room, http://www.nrc.gov/reading-rm/adams/web-based.html, the Accession number is "ML062710517."

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REPORTS of interest

Nuclear Power Plant Security
Are These Towers Safe? Time Magazine, June 20, 2005  read this article  

National Academy of Science Report released to public
It concluded that spent radioactive fuel pools are vulnerable to terrorist attack.
Pools in  reactors designed like Pilgrim's are the most dangerous  for more

National Academy of Sciences Report, Health Risks from Exposure to Low Levels of Ionizing Radiation (BEIR VII - Phase 2) states that even low does of ionizing radiation are likely to pose some risk of adverse health effects, June 2005  read this report

NRC Status of Allegation Program, 2004 Annual Report: Pilgrim had a significant increase in allegations, primarily in the area of security, June 2005   for more

Duxbury Town Meeting Approves Article Opposing Re-Licensing  for more

Should Pilgrim be re-licensed to operate for an additional 20 years, to 2032 – when there is no public benefit but plenty of risk?

10 Reasons to Oppose Re-Licensing

1.  Costs - the true costs of Pilgrim’s electricity are subsidized by you.

2.  Terrorism - the prospect of suicidal terrorists targeting Pilgrim, a vulnerable site with catastrophic consequence, is reason enough not to re-license.

3.  Accidents-  terrorism aside, we know that accidents can and do happen especially with an aging reactor of faulty design.

4.  Waste - Spent Fuel Rods are the most radioactive and long-lived poison on earth and they are accumulating at Pilgrim with no near-term solution to remove them off-site. Plymouth’s densely populated, eroding coastline, vulnerable to terrorist attack is not a suitable radioactive dump site. Let’s not add another 800 metric tons to the pile. Other radioactive wastes, far from benign, continue to be generated – control rods, resins, sludge, filters, and will include the entire nuclear power reactor if and when dismantled. Will South Carolina continue to accept our radioactive garbage or will it be left in Plymouth?

5.  Federal oversight is lacking - the risk of an accident or terrorist attack is exacerbated by the lack of federal oversight – industry’s bottom line, not public safety, is NRC’s priority.

6.  Health - Pilgrim releases radiation as part of its normal operations. Radiation causes cancer, disease, birth defects and reproductive disorders. Its effects are cumulative and it works with other toxins to enhance one another’s mischief. The footprints of radiation-linked disease are documented in communities around Pilgrim. We should not add to the existing biological burden – the population is damaged.

7.  Environment – Pilgrim harms the ecosystem is other important ways. For example, to remove excess heat it draws in 487,840,000 gallons of water a day from Cape Cod Bay. Along with the water it sucks in fish eggs and larvae and entraps larger fish on its intake screens. The marine life that is drawn in is pulverized and emerges as sediment, clouding the ocean floor. Light is blocked, a desert created and the ecosystem disrupted. The water that is drawn in is then cycled through and released at 30 degrees above Bay temperatures – again, disrupting the ecosystem. Our marine ecology is delicate, intertwined and threatened. Commercial fishermen have borne the brunt with depleted stocks and restrictions; but, Pilgrim continues with an unlimited fishing permit.

8.  Global Warming – there is nothing clean and green about nuclear – a dangerous and polluting industry.

9.  Emergency Plans – plans can be improved but they will never be adequate – the population has exploded and the infrastructure is inadequate to deal with a nuclear disaster.

10.  Re-licensing Process - a rubber stamp; ignoring important public health and safety issues; disallowing meaningful state and public participation.

Learn More

Should Pilgrim be re-licenses to operate for an additional 20 years – to 2032 – when there is no public benefit but plenty of risk? More

What is involved in re-licensing; what “say” does the public have? More

Terrorism – is “terrorism” allowed to be brought forward in NRC licensing decisions? More

Sample Environmental Impact Statement for the license renewal of aging nuclear plants: San Luis Obispo Mothers for Peace More