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THE
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NO PUBLIC BENEFIT - BUT PLENTY OF RISK There is no public benefit to justify re-licensing Pilgrim NPS. Pilgrim supplies a mere 2% of the electricity to the New England power grid – cheaper and safer replacement power is available. During a refueling outage or when a New England reactor is down for extensive repairs, for example, lights stay on. Costs: Pilgrim’s electricity, like all nuclear power, is expensive. Although the cost per kilowatt hour appears competitive, it is not. We pay the true costs of Pilgrim’s power in hidden subsidies and taxes. No other electric industry receives such public largesse. Start with costs foisted on consumers when Massachusetts deregulated its electric market - the Electric Deregulation Act, 1997. These costs amount to over a billion dollars to be paid by all electric ratepayers over a ten year period for Pilgrim, irrespective of where your electricity comes from. These so-called “stranded costs” cover Pilgrim’s owner’s original bad investments and unpaid bills – the remainder of Pilgrim’s construction costs and unpaid and expensive repair bills. Included, too, are some costs going forward - such as a hefty chunk of annual tax payments to Plymouth and decommissioning or clean up costs when the reactor finally closes. Other hidden costs that you pay include, for example: liability insurance; waste disposal; and, external costs resulting from environmental damage and human disease and deaths that result from its operations. Safety: Money aside, the prospect of suicidal terrorists targeting Pilgrim is reason enough alone not to re-license Pilgrim. There are two principal scenarios - a core melt, and failure of the spent fuel pool. According to the federal government, the consequence of an attack or accident at Pilgrim that results in a core melt is as follows:
A spent fuel accident would be much worse - Far more radioactive fuel is stored in the spent fuel pool than in the reactor core. A spent fuel pool accident would contaminate an area three times the size of Massachusetts. No other electric generator has the potential for a catastrophe of this magnitude. Terrorism aside, we know accidents can and do happen. The risk of an accident - involving either the core or the spent fuel pool -- is greater today and increases each year the reactor operates for the following reasons –aging, deregulation, design flaws, lack of regulatory oversight. Aging: Pilgrim was designed in the 1960’s and went on line in 1972. It is an antique. Nuclear power reactors are similar to cars or any other piece of complicated machinery – they have a limited shelf-life. When it gets old it breaks down. Replacing components is costly and avoided. Entergy does not want to incur large expenses in a deregulated (competitive) electric market; and Entergy Nuclear is a limited liability company. Faulty design: Pilgrim was built with a faulty containment system. The purpose of the containment is to provide a barrier between the lethal radiation inside the reactor and the public. However it was discovered that in the event of a nuclear accident Pilgrim’s containment would fail. A cheap fix was put in place. A vent was installed to relieve pressure build up. However, the vent was not directed underground into a bed of filters as it should have been; instead unfiltered and highly radioactive steam will go directly into our atmosphere. Spent fuel pool/ So-Called, “High-Level” Waste: Spent fuel, i.e., the fuel rods that have served their useful generating life and are being removed from the reactor, is more radioactive than new fuel rods. Pilgrim’s spent fuel pool is located outside primary containment - high up in the main reactor building with a light roof overhead; and is especially vulnerable location to attack. The pool is designed to hold only 880 spent fuel rod assemblies; however, it now holds three times that number, in the same space. The pool must be filled continuously with cooled water because the fuel releases intense heat and radiation. If the cooling is halted, water in the fuel pool would heat up and boil away. If the water boils off or is drained, and there are many scenarios by which this can happen, the spent fuel will overheat, melt, it will catch on fire, the cladding protecting the rods will melt, and radiation will be released. NRC concedes a fire would be so intense and so much radiation released in the area that it could not be extinguished. The radiation that could be released from the spent fuel pool at Pilgrim would contaminate over 25,000 square miles (three times the area of the state of Massachusetts) for tens, hundreds or thousands of years. Federal studies also show that thousands of people could die from the radiation released in a spent fuel pool accident. Despite the fact that the crowded fuel pool is a disaster waiting to happen and the mountain of radioactive waste should never be stored on Cape Cod’s coastline in densely populated Plymouth, it will remain there for years to come. Yucca Mountain, the proposed federal repository, won’t solve the waste problem –any time soon - legal suits are pending. If Yucca is found scientifically suitable and if transportation route issues resolved, Yucca would open 2012 at the earliest. It will take 30-40 years to transfer waste from around the nation. We do not know where Pilgrim will be on the federal shipping schedule. Plant owners can sell or trade their place. Reactors that are closed, decommissioned, will go to the head of the line. As of 2004, ten (10) reactors are permanently shut. When Pilgrim’s turn comes and they choose to ship, they will not be required to unload the entire inventory either – that would cost big money. Furthermore, Yucca, if it is ever built, will run out of room before it can take the spent fuel from existing reactors, to say nothing about the waste from re-licensed reactors. By 2013 the total waste generated by our nation’s nuclear reactors will have exceeded the 77,000 ton limit for Yucca designated by Congress. Therefore, Yucca will not provide storage for any waste generated after 2013. This means that we will need two repositories. The second repository is required to be in the East. Therefore, Plymouth will be a long-term waste site. Re-licensing Pilgrim for an additional twenty years of operations will add an additional 800 metric tons to the pile. Therefore: (1) it must be stored more safely in the interim – return to a low-density pool and secured dry cask storage; and (2) it makes no sense to generate 20 more years worth of waste when we do not need Pilgrim’s electricity. There are cheaper, cleaner and safer ways to generate electricity. “Low-Level” Waste: So called “low level” radioactive waste at Pilgrim includes, for example the control rods, resins, sludge, filters, and will include the entire nuclear power reactor if and when dismantled. The waste contains highly toxic and long-lived radioactive materials. Pilgrim’s low level waste currently is shipped to South Carolina. There is no guarantee they will continue to accept the waste. Attempts to build new low-level radioactive sites in the nation have failed. Therefore, that waste, too, will grow and may wind up in Plymouth over the long term. Federal Oversight, Lacking: The risk of an accident or terrorist attack is exacerbated by the lack of federal oversight. NRC has failed to require Pilgrim and the industry in general to adhere to their licensing requirements and allowed the industry to essentially write their own rules and self-regulate. Health: Accidents and sabotage: lessons learned from an analysis by the Nuclear Control Institute at Indian Point can be applied to Pilgrim. The study showed that after a shutdown of twenty days the number of acute fatalities (within a 10-mile radius) from a core meltdown and breach of containment would be reduced by around 80 percent and the number of long-term cancer deaths (within a 50-mile radius) by about 50 percent. Accidents and sabotage to one side, Pilgrim is dangerous under normal operating conditions. Pilgrim releases radiation routinely into our air and water; and there is no safe dose of radiation. Radiations’ effects are cumulative and radiation acts synergistically with other toxins. The federal government allows 100 millirem a year to be released. The National Academy's 2005 BEIR VII Report stated that (1) in (100) members of the public would get cancer if exposed to 100 millirem over a 70 -year lifetime; and (1) fatal cancer in every (175) people so exposed. In contrast, the allowable release from an industry that discharges a toxic chemical into the air is a lifetime cancer incidence of one in one million. We know cancer is not the only health effect from radiation exposure. We know also that Pilgrim monitors itself and that their monitors and reporting are neither accurate nor reliable. Therefore it is no surprise that the footprints of radiation linked disease are documented in communities around Pilgrim NPS – elevated leukemia and other cancers, thyroid and autoimmune disease, birth defects and reproductive disorders. Our community is damaged; it would be wrong to add to our existing biological burden. Environment: Radiation is harmful to all living organisms; releases pollute vegetation, marine life, wildlife, farm and domestic animals – ending up on our dinner tables or in reported unusual tumors by local veterinarians. Marine Impact:
Pilgrim should be required to employ the “best technology available to minimize adverse environmental impact” but, simply to avoid expense, it isn’t required to do so. Brayton Point Electric generating station, for example, and other industries that draw coolant water from the oceans, bays or rivers are required to retrofit to a dry cooling system, why not Pilgrim? Tsunami Threat: Global Warming: Proponents of re-licensing nuclear reactors incorrectly argue that since the nuclear fission process emits no carbon dioxide, increasing nuclear power production can help address global warming. An analysis of the entire nuclear fuel cycle reveals that nuclear power does result in carbon dioxide emissions from mining, fuel enrichment and plant construction. Uranium mining, in fact, is one of the most carbon intensive industrial operations. Add all the CO2 emissions up and nuclear power releases 4-5 times more CO2 per unit of energy produced than renewable energy sources like wind and solar. Emergency plans are another major reason not to re-license Pilgrim. Plans can be improved; however, they will never be adequate. This is because Pilgrim is located in a populated area - the fastest growing area of the state. The infrastructure is insufficient to meet today’s needs, let alone tomorrows. Roads, for example, are clogged during regular commuting hours and summer week-ends, never mind a nuclear disaster. Support services required to respond to an accident are insufficient, too. Cape Cod is another major stumbling block. Its year-round population is increasing and it skyrockets during the summer. Most of its citizens live within the first year peak fatal zone, all within the peak first year injury radius. The Cape is downwind most of the year. Evacuation is not realistic. One bridge is closed to outgoing traffic in a disaster and traffic on the other bridge is restricted to one lane. Citizens are trapped.
Re-licensing Process – a rubber stamp NRC’s re-licensing process is no more than a rubber stamp. Thirty reactors have applied; 30 approvals have been granted so far. The rules allow a licensee to apply for a re-license to extend operations an additional 20 years when their original license is only half way completed. Clearly NRC can not evaluate what the status of safety components and the environmental impact of the reactor will be twenty years down the road. NRC’s failure to perform proper safety analyses prior to approving a re-licensing application is demonstrated by the fact that NRC has re-licensed reactors and only a few months later serious problems that compromise safety have occurred. For example, in May of 2000, Entergy’s Oconee plant underwent technical and safety reviews and was re-licensed. Just months later, serious cracking was discovered in the nozzles of the control rod drive mechanism - used to shut down the reactor for maintenance or in case of an emergency. A similar problem was discovered at Entergy’s Arkansas Nuclear I, just months after a license extension was approved. Re-licensing Pilgrim should be opposed. There is no public benefit and the risks of going forward are too great. Indeed, with all these safety issues outstanding today, why should Pilgrim be operating now?
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