Alternatives sought to dumping of contaminated water into Cape Cod Bay

Doug Fraser 

Cape Cod Times 

Published Jan. 15, 2022 

Opposition to a proposal to dump up to 1 million gallons of treated radioactive water into Cape Cod Bay continues to burn brightly among local elected officials.

U.S. Reps. William Keating and Seth Moulton, along with U.S. Sens. Elizabeth Warren and Edward Markey, sent a letter this week to the company decommissioning the closed Pilgrim Nuclear Power Station in Plymouth. They urged Holtec Decommissioning International, which has considered releasing the water used to cool spent nuclear fuel rods and the reactor at Pilgrim, "to pursue — and publicly share information about — alternative methods of disposal."

"Forcing this latest discharge upon the community would threaten the reputations and operations of the many businesses and organizations that rely on Cape Cod Bay's reputation for clean and safe water," the four Massachusetts federal delegation members wrote in the Jan. 12 letter to Holtec's president Kelly Trice.

"The strong public opposition to news of the proposed discharge reflects Holtec’s failure to engage in the forthright, open, and transparent process that it promised the Plymouth community and the Commonwealth of Massachusetts when it took over the operating license for the decommissioning of Pilgrim," the letter stated.

The possibility that Holtec was considering releasing up to 1 million gallons of radioactive water into the bay was revealed by state Department of Environmental Protection Deputy Regional Director Seth Pickering at a decommissioning citizens' advisory panel meeting Nov. 22. It was contemplated as one way to get rid of water in a pool used to store spent nuclear fuel rods and water in the "donut" that helps cool the reactor.  

The other options were to truck the water off-site to an approved facility in Idaho, or evaporate it. Holtec has said the company hasn't made a decision yet on the disposal method and would not release any radioactive water into Cape Cod Bay in 2022 while it is making its decision.

Letter: Ship radioactive water to Idaho

Citing a 2021 Nuclear Regulatory Commission approval for the closed Vermont Yankee Nuclear Power Plant to ship approximately 2 million gallons of radioactive water to the US Ecology facility in Grand View, Idaho, and widespread public opposition to dumping in Cape Cod Bay, the delegation said Holtec should pursue such an option.

"This would be a viable alternative to the discharge of radioactive material into one of the most important areas of marine life and economy in the United States," the letter stated. 

Known as "overboarding," discharging radioactive water is considered routine practice within the nuclear power industry. The water is filtered to reduce radioactivity to a level acceptable to regulators, and then can be released. It has been used at Pilgrim in the past, plant operators say.

But opponents contend it would tarnish the reputations of the fish and shellfish harvested in Cape Cod Bay as well as make beaches less attractive in an area heavily dependent on tourism.  

A long list of maritime businesses including fishermen, aquaculture operations, state legislators and watchdog groups oppose dumping the radioactive water into the bay.

Assembly of Delegates weigh in on Pilgrim

Earlier this week, the Barnstable County Assembly of Delegates also sent a letter to Trice expressing its unanimous opposition to any bay dumping. 

"Your proposed plan to release radioactive water into Cape Cod Bay, an environmentally fragile area, is an intolerable threat and this hazardous proposal must be permanently discarded," the assembly wrote in the letter that also requested that Trice, or a Holtec representative, appear before the assembly at a future meeting. 

Cape Cod towns were also being asked to sign on in opposition with a letter circulating to town select board meetings for a vote. The nuclear watchdog group Cape Downwinders has also planned a speakout against the bay disposal option for 5 to 6:15 p.m. Jan. 31 at Plymouth Town Hall. 

Last month, Holtec finished moving all the spent fuel rods from the pool at the Pilgrim plant to what are known as dry casks that sit atop a concrete pad awaiting future transport on an as-yet-unknown date to a federal facility that the U.S. Department of Energy has yet to open. 

With the fuel safely stored, demolition of remaining buildings on the Plymouth property can begin. A Holtec spokesman said they expect to have all structures demolished and the site cleaned up by 2024. Only the spent fuel storage facility will remain. 

Holtec spokesman Patrick O'Brien said the remaining costs to finish the job at the Plymouth plant amounted to $824 million at the close of 2020 with a balance of $881 million left in the $1.03 billion decommissioning trust fund. He said Holtec will update those figures in March to reflect the cost of work in 2021.

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Seafood, aquaculture trades oppose possible discharge of radioactive water in Cape Cod Bay

Doug Fraser Cape Cod Times 

Published Dec 20, 2021 

PLYMOUTH — The company in charge of decommissioning Pilgrim Nuclear Power Station recently backed off from making a decision on whether to discharge up to a million gallons of radioactive water into Cape Cod Bay, but opponents say it should never happen. 

In an email last week, Holtec Decommissioning International spokesman Patrick O'Brien repeated the assertion that his company, which is handling the decommissioning of the closed nuclear power plant in Plymouth, is still in the early phases of making a decision on how to dispose of the water from the plant's reactor and spent fuel pool. He reiterated that Holtec will not discharge any of that water into Cape Cod Bay in 2022.

Despite assurances from the Nuclear Regulatory Commission and Holtec that releasing radioactive water into Cape Cod Bay has been done in the past — and can continue to be done, safely — those who depend on the marine environment for their livelihood or for recreation are lining up in opposition.

Related:Holtec says it won't dump radioactive water in Cape Cod Bay in 2022

"We will definitely be hard against it," said Arthur "Sooky" Sawyer, a Gloucester lobsterman and president of the Massachusetts Lobstermen's Association. "I can't say how much fear people have of radioactive waste going into Cape Cod Bay. There are red flags all over it."

The Massachusetts Seafood Collaborative, representing 60 seafood businesses, sent a letter to Holtec and state and federal legislators and officials last week "strenuously" opposing the disposal into the ocean as an option. They want it taken off the list of alternatives.

Scott Soares, of the Massachusetts Aquaculture Association, said his organization is urging active opposition. Soares said the MAA wants a guarantee that there will be no discharge of radioactive materials from the Pilgrim Nuclear Power Station at any time during decommissioning.

"We believe prioritizing the bottom line of one corporation above the health and brand of our marine economy, of which shellfish aquaculture is a large part, is a travesty that the Commonwealth cannot afford to risk," Soares wrote in an email Monday.

Reduce, reuse, recycle:8 Wellfleet restaurants to recycle oyster shells

The oyster harvest comes mostly from aquaculture and was worth over $30 million paid to fishermen in 2019. Harvested lobsters were valued at over $93 million, according to state Division of Marine Fisheries statistics.

"Our industry is in jeopardy because someone wants to take the cheap way out and poison the water where our families live and our kids swim," said aquaculturist Gregg Morris, of Duxbury. "We need a public outcry to say 'No' to this. It isn't acceptable, and we need to do better to protect our ecology, our livelihoods."

NRC: Discharging radioactive water into the ocean is common practice

Known in the nuclear industry as "overboarding," discharging radioactive water into the ocean is a common practice, say federal regulators and nuclear power plant operators.

"As long as that plant (Pilgrim Nuclear Power Station) was in operation for four decades, they were doing effluent releases (radioactive water into Cape Cod Bay)," said NRC spokesman Neil Sheehan. "And if it were to resume, it would happen in the same fashion. The water would be filtered, treated, put into a storage tank, characterized as to its nuclear make-up."

Plant operators would then calculate a rate of release that would allow for dispersion in the ocean at acceptable levels, Sheehan explained.

"This is not something new," he said. 

The National Academies of Science Engineering and Medicine reviewed radiation exposure studies worldwide in a 2006 publication, assessing health risks from exposure to low-level radiation. It found that the nuclear fuel cycle contributed around 1% of that exposure risk, with natural background radiation (from sources such as radon in the soil) at 82%. 

The NRC, National Academies and other federal agencies agree that radiation can cause cancer at high doses and high dose rates. But low doses and dose rates remain problematic in studies. Although exposure to ionizing radiation can cause gene mutations that can lead to cancer, low exposure studies haven't clearly established that link.

"Even so, the radiation protection community conservatively assumes that any amount of radiation may pose some risk for causing cancer and hereditary effect," the NRC warns on its website.  

Previous reporting:Pilgrim nuclear plant may release 1M gallons of radioactive water into bay. What we know

Although a nuclear power plant is built like a Russian doll, with shell upon shell of thick concrete and steel protecting the public from catastrophic exposure, it's the small stuff that can also add up to big problems when it comes to radioactive waste, experts say. Maintenance work, valve leaks, pipe corrosion and radioactivity passing into coolant water, all contribute to contaminated water and air that has to be controlled and cleaned. 

During the decommissioning of Pilgrim, which permanently closed in May 2019, the spent fuel rods are removed from the cooling pool and placed in dry casks for storage. The million gallons of contaminated water in the pool and the reactor's coolant and pressure-relief system — as well as water that collects in other areas of the plant and has been exposed to radioactivity — must be removed so that demolition of the main buildings can commence, Sheehan said.

"Every operating nuclear power plant is allowed to discharge into the air and water as long as they are below these standards," said physicist Edwin Lyman of the Union of Concerned Scientists. 

"But just because it is allowed doesn't mean you should do it," said Lyman, the author of "Fukushima: The Story of A Nuclear Disaster."

Decommissioning Pilgrim Nuclear Power Station:Holtec says it won't dump radioactive water in Cape Cod Bay in 2022

His concern is rooted in the nature of water.

"If there are other options, and you could avoid planned or uncontrolled discharges into the water, you should," he said, noting that land-based disposal problems have more certainty about the fate of the radioactive material than the ocean.

"You can't really control where it goes in the ocean. You should look for ways to dispose of it where you have more certainty of where it should go," he said.

Cape elected officials oppose bay discharge

State legislators also voiced opposition to discharging radioactive waters into Cape Cod Bay and to the public and state being excluded from the decision process. 

State Sen. Susan Moran, D- Falmouth, said which disposal option Holtec chooses needs to be a "transparent process that doesn't catch anyone by surprise."

"We don't want to have dumping of (radioactive waste) into the water as the default solution," said Moran. She said the Cape and Plymouth legislative delegations have asked for a meeting with Attorney General Maura Healey's office, the Department of Public Health and the Department of Environmental Protection.

"My concern is that we are taking a process (decommissioning of a nuclear power plant) that really demands the utmost public trust and giving the procedural dismantling to a corporation that is, like any business, just trying to be profitable," Moran said.

Rep. William Keating:Holtec has decided to dump radioactive water into Cape Cod Bay

Calling it a terrible idea, state Rep. Sarah Peake, D-Provincetown, said she was working with the the state's Congressional delegation, legislators from Plymouth and the Cape, the town of Plymouth, Massachusetts Lobstermen's Association and the Center For Coastal Studies in Provincetown to stop the discharge of radioactive water from happening.

Discharging radioactive water into ocean is least expensive option

But releasing low-level radioactive waste into the ocean or river is the cheapest method of disposal and may be an economic necessity, some argue. 

"They have to balance what they can do, with the costs, due to the limitations of the decommissioning trust," said Chris Campany, executive director of the Windham Regional Commission. Much like the Cape Cod Commission, the Windham commission handles regional planning in a part of Vermont that includes Vernon, the town where the now-closed Vermont Yankee Nuclear Power Station is located.

Several years ago, Vermont Yankee contemplated releasing thousands of gallons of treated radioactive water into the Connecticut River. Campany doesn't know why the plant contractor and owner NorthStar Decommissioning Company decided instead to ship the water by rail to Idaho.

300-foot main emissions stack:Main emissions stack at Pilgrim Nuclear Power Station set to come down

The Connecticut River runs through New Hampshire, Vermont, Massachusetts and Connecticut and empties into Long Island Sound. It may be that NorthStar may have wanted to avoid a fight. The Vermont plant, like Pilgrim, had been the scene of repeated protests, with activists coming from all four states, plus New York, ever since it was built in 1972.

But decommissioning is a relatively new industry, and Campany said he worried how the added expense of shipping the water affected NorthStar's ability to complete the project.

"Always in the back of my mind is, is the decommissioning trust going to be sufficient? It's not cheap to ship water somewhere else," said Campany. "What you don't want to have happen is you get part of the way through and you find out you don't have enough money." 

"I've not heard a satisfactory answer as to what happens if a license holder goes bankrupt," Campany said.

One alternative is to mothball the plant, something called SAFSTOR, in which the plant remains closed but maintained for up to 60 years until funds can be found to dismantle the plant and decontaminate the property, according to the NRC.

Decommissioning trust funds are built up during operation using a surcharge on ratepayers and are one of two major sources of revenue for companies like Holtec and NorthStar. The other source is a longstanding lawsuit in which nuclear plant license holders, either the operator or the decommissioning company, sue the federal Department of Energy for the cost of maintaining spent fuel because the DOE never opened up a repository for spent nuclear fuel and radioactive waste as they were required to do by law.

According to the Maine Yankee Nuclear Power Plant's citizen advisory panel website, the DOE has paid out $576 million to three Yankee power companies for plants in Connecticut, Massachusetts, and Maine — for the storage costs incurred up to 2020 of spent fuel rods kept in casks on a concrete pad similar to the facility nearly completed at Pilgrim. 

Holtec's O'Brien said his company expects to reach the point where all the structures have been demolished and radioactivity reduced to the level where the land can be used for any purpose by 2024. Only the spent fuel storage facility will remain, he said, until the DOE opens up a permanent storage facility.

O'Brien said that, as of the close of 2020, the remaining costs to finish the job at the Plymouth plant amounted to $824 million, and that there was $881 million remaining in the $1.03 billion trust fund. He said Holtec will update those figures in March to reflect the cost of work in 2021.

Campany equated the job of decommissioning companies to a contractor who has bid on a project and then has to figure out how to wrest a profit from it.  Sometimes, contractors cut corners to achieve that, he said.

Profit-driven decommissioning companies a concern to some

But it's one thing to skimp on trim work and cheap appliances and an entirely different issue to trade off safety for savings, say nuclear power watchdogs. They worry that this new decommissioning industry, with companies specializing in finding profits in an enterprise that the big utilities like Entergy want to avoid, is going to try and do it on the cheap.  

Lyman calls them "scavengers."

"My concern is that they can only turn a profit by decommissioning cheaply enough so they don't spend the trust fund. It's an incentive to cut corners," Lyman said.

In 2019, the state's Executive Office of Environmental Affairs and the attorney general's office questioned Holtec's financial ability to do the decommissioning and filed to intervene in the NRC review that ultimately transferred the plant's operating license from Entergy to Holtec. Healey wrote a letter to the commission that questioned the company's truthfulness in other states, including an admission of bribery in Tennessee and lying on an application in New Jersey that resulted in that state freezing a $260 million tax break.

In 2015, Pilgrim was listed by the NRC in a category comprised of the worst-performing plants in the country, one step from mandatory shutdown. It was closed for 60 days in 2018 for equipment problems.  

State Sen. Julian Cyr, D-Truro, said he is also worried about cost-cutting.

In the 2018 settlement agreement in Healey's lawsuit against the NRC for cutting the public and state agencies out of the licensing process, Holtec agreed to financial concessions intended to provide for cost increases and unforeseen expenses and to provide funding so that the state Department of Public Health could monitor air, milk, grass and other food sources as well as the marine environment, including fish, shellfish and other creatures in the food chain, similar to what is required by the NRC. 

According to that agreement, the money dramatically drops off once all the fuel rods are removed from a cooling pool and placed in casks on the pad at what is known as an Independent Spent Fuel Storage Installation.

According to the settlement agreement, Holtec paid over $522,000 for emergency planning and environmental monitoring, and that amount will continue to be paid until all the spent fuel rods are in the storage installation. Sheehan anticipates that will happen soon. After that, Holtec funding for the state program drops down to $250,000 by 2023, and continues dropping in succeeding years. 

Cyr said those cuts were not enough to support the state's radiology lab that acts as an independent check on Holtec's own monitoring program. Gov. Charlie Baker has added language in his latest budget proposal for a new assessment process that requires companies engaged in decommissioning to continue to fund the sampling and the state radiology lab.

Cyr said the environmental program that the NRC requires, as well as the state's own monitoring, have shown that the radiation impact on the environment and on people has been low, but he thinks it's important for the state to continue its own program.

"We are not seeing a pattern of contamination with all the monitoring being done now," said Cyr. "But the prospect that they are even considering discharge as an option means we need to have robust environmental monitoring done until the plant is fully decommissioned."