Pilgrim Watch

What is Decommissioning – Process – Costs - Environmental Impacts - What should be Done to Protect our Communities?

Decommissioning Pilgrim

1967 – Boston Edison began construction

1972 – Operations began

May 31, 2019 – Pilgrim will shut down – Entergy losing money

After Pilgrim shuts down. • Entergy hopes to sell Pilgrim to Holtec • Nuclear fuel removed from reactor into spent fuel pool • Spent nuclear fuel moved from spent fuel pool into dry casks • Dry casks stored on concrete pad (ISFSI) for indefinite period of

time

Over the next 60 years, • Except for the ISFSI, Pilgrim will be decommissioned, probably by

Holtec • At some time, the ISFSI will be decommissioned when offsite

storage available

Overview – Pilgrim Chronology

Entergy and Holtec asked NRC to transfer Pilgrim’s licenses to Holtec Decommissioning International (HDI).

• The Massachusetts Attorney General and Pilgrim Watch filed petitions to intervene in the transfer licensing procedure. (February 20, 2019)

• If the petitions are accepted, there will be a hearing before the NRC’s Atomic Safety Licensing Board.

Both Entergy and Pilgrim have filed Post Shutdown Decommissioning Activities Reports (PSDAR)

• A PSDAR gives an overview of how a company plans to decommission a plant (but not an ISFSI) and its estimated costs.

• Comments on Holtec’s PSDAR had to be filed by March 4. Comments on Entergy’s PSDAR had to be filed by March 21.

• No hearing or NRC approval required on whether a PSDAR is adequate.

What is Happening Now

The Attorney General’s and Pilgrim Watch’s petitions to intervene in the licensing procedure each raise the same two issues.

First Issue Is there “assurance” that Holtec will have enough money to decommission Pilgrim?

• The Holtec subsidiaries that will do the work are Limited Liability Corporations.

• Their only asset is Pilgrim’s Decommissioning Trust Fund. • Based on Pilgrim Watch’s review of the estimates, there will

likely be a hundreds of millions of dollar shortfall.

The License Transfer Petitions

Second Issue NRC regulations and the National Environment Protection Act require a new environmental assessment.

Without a new assessment at the beginning of the decommissioning process, neither Holtec, Entergy nor the Commonwealth will know what clean-up is required and what it will cost.

Due to the topography of the site, contamination will flow downgrade into Cape Cod Bay and the Plymouth-Carver aquifer is beneath the site.

Climate change (sea level rise, increased storms, and flooding) will hasten contamination flowing into the bay, unless it is identified and cleaned up.

The License Transfer Petitions

Most People assume decommissioning Pilgrim will include:

• Removing all radioactivity

• Dismantling and removing the reactor • Demolishing and removing all existing buildings/structures

• Safely storing spent fuel and other wastes until they are eventually moved off-site

• Removing any contaminated soil • Restoring the site to its original condition

What is Decommissioning?

It Won’t!

• NRC’s definition of decommissioning is much narrower:

“The safe removal of a facility from service and reduction of residual radioactivity to a level that permits termination of the NRC license.”

• NRC’s definition does not include:

✦ The removal or storage of spent fuel

✦ Demolition of decontaminated structures

✦ Site restoration activities after residual radioactivity has been removed

• NRC Rules restrict use of the Decommissioning Trust Fund to reducing “radiological radioactivity.” NRC is granting exemptions to allow DTF to be used for demolition and site restoration.

NRC’s Definition of Decommissioning

1. Decontamination (DECON)

Structures and components contaminated with radioactivity are either cleaned, or removed and shipped to a licensed radioactive dump site

2. Safe Storage (SAFSTOR)

The facility is placed in nuclear limbo for up to 60 years for later decontamination

3. Entombment (ENTOMB)

The facility is basically covered over in cement and left forever. • Entombment has never been used.

NRC’s Three Decommissioning Options

How and when Pilgrim will be decommissioned depends on who owns it – Entergy or Holtec

Holtec International founded in 1986- specialized in spent fuel dry cask storage systems.

Its new ventures: decommissioning 6 reactor sites simultaneously (Pilgrim, Oyster Creek, Palisades, 3 units at Indian Point) & establishing an interim spent fuel storage facility (NM)

Holtec-Pilgrim, a subsidiary will own Pilgrim. It will own Pilgrim’s Decommissioning Trust Fund (DTF) and pay costs out of it.

Holtec Decommissioning International (HDI),another subsidiary, will be Pilgrim’s licensed operator.

Comprehensive Decommissioning International (CDI) is jointly owned by Holtec International and the SNC-Lavalin Group -CDI will actually do the decommissioning work.

Holtec-Pilgrim, HDI and CDI are all limited liability corporations.

Who is Holtec?

Holtec Organizational Chart

Holtec’s Decommissioning Plan

Entergy’s Decommissioning Plan

Shutdown May 31, 2019

Spent Nuclear Fuel

• Dormancy & Pool Storage: 2019-2022 Dormancy and

• Dry Cask Storage: 2022-2062

• Dormancy no fuel storage: 2062-2073

• 2062 assumes DOE will have taken all of the spent fuel dry casks by then.

Dismantlement & Decontamination (D&D): 2074-2078

Issues that must be addressed:

1. Money – is there enough?

2. Site Restoration

3. Spent Fuel

NO MATTER WHO OWNS PILGRIM

Pilgrim’s Decommissioning Trust Fund (DTF): $1.028 billion. (Dec 31, 2018)

Holtec’s estimated cost of decommissioning is $1.134 billion.

Holtec expects the DTF to grow enough through investment to make up the difference.

Holtec expects about $3.6 million (0.36%) of the DTF to be left over.

Not much of a “rainy day” fund.

Both the Attorney General’s and Pilgrim Watch’s Petitions to Intervene say that Holtec’s cost estimates are not realistic, and that there will not be enough money.

1. Money – Is There Enough?

Holtec’s assumptions that DTF is sufficient are questionable. For example, Holtec incorrectly assumes:

Decommissioning costs will not rise faster than inflation. The NRC says that costs will rise faster, at a rate of about 5% to 9% a year.

Pilgrim’s site is “clean.” Pilgrim’s history and the license transfer Petitions to Intervene show that it is not. Holtec admits that new site assessments are necessary to identify radiological and hazardous wastes. In other words, they admit that they do not know now.

Spent fuel will begin leaving site 2030 and all offsite by 2062. This requires a permanent and interim storage site to be constructed and ready to accept Pilgrim’s fuel starting in 2030 - unrealistic. Substantial post-2062 spent fuel storage costs, including new casks, are likely.

Money – Is There Enough?

The NRC cost “formula” only requires the fund to be sufficient to cover decommissioning – removing radioactivity.

The formula does not require the fund to have enough money for spent fuel management or site restoration.

NRC rules say the fund can only be used to reduce radioactivity. But the NRC regularly allows the fund to be used to cover other costs, thus reducing what will actually be available for decommissioning. Costs including: Spent fuel management; site restoration; emergency planning; state assessments; taxes; legal and lobbying fees.

Decommissioning Profit – How much profit has Holtec built into its decommissioning cost estimates?

An expected profit of $250 million to $350 million (25% to 30%) would not be unusual.

Spent fuel management costs recovered from the Department of Entergy • About half of the Decommissioning Trust Fund $501.5 million) is for spent fuel

management. • Holtec expects to recover what it spends on spent fuel management from DOE. • Holtec has indicated that this recovery will not go back into the trust fund, even

though the fund paid the costs in the first place; and neither Entergy nor Holtec put a dime into the fund. It was established long ago by Massachusetts ratepayers.

• Will the recovery go into some other Holtec pocket as more “profit?”

Holtec has indicated that only Holtec Pilgrim and HDI will be responsible for decommissioning costs.

If Holtec doesn’t pay all the costs to do the job, who will? Massachusetts taxpayers.

Money – Is More Available?

Key Issues:

• Site Analysis

• How clean is clean – Who decides?

• Are all structures removed?

• How long will it take?

2. Site Restoration No Matter Who Owns Pilgrim

NRC does not require a site assessment until (2) years before the license is terminated. Absent a thorough site assessment at the beginning of the decommissioning process: • There is no way to estimate decommissioning

costs • Contaminants are allowed to run offsite

Site Restoration Site Analysis

History of Contamination Pilgrim opened with bad fuel & no filtration

Pilgrim blew its filters in 1982

Hazardous waste on property – oil, asbestos, PCBs, degreasers, etc.

Mass DPH onsite monitoring wells show contamination

History of mismanagement – Pilgrim is ranked in NRC’s least safe category – leads to equipment malfunction, leaks & spills

Mass. AGO & Pilgrim Watch Requests for Hearing on License Transfer (Feb 20, 2019) provide data on leaks and spills.

Site Restoration Is the Site “Clean” or Contaminated?

NRC’s Radiation Cleanup Standard

• Release site to unrestricted use: 25 millirem per year total effective dose equivalent to an average member of the critical group - limit includes the dose from drinking groundwater

• Release site to restricted use: 100 or 500 millirem/year for restricted use.

• Massachusetts may, but has not set a more conservative standard that applies to decommissioning reactor sites.

Unanswered Questions

• How is dose determined? How far down is soil tested?

• Is Entergy required to return Pilgrim’s site to “greenfield” for unrestricted use?

Site Restoration How Clean is Clean?

The standard will be protective of public health and safety only if the models used to assess dose during remediation are conservative.

Dose rates shall be determined using:

• The Resident Farmer Scenario that assumes a person lives on the site and consumes food raised on the site; and

• The Basement Inventory Model that requires taking dose measurements over the entire service left below ground, not averaging dose diluted with clean fill.

Determining Dose

Lifetime Exposure (millirem/year) 70 year Risk of Developing Any Cancer

Current MA limit for Unrestricted 10 Use for its licensees. Does not Apply to Pilgrim, an NRC licensee

70/100,000 (0.7/1,000)

NRC Limit for Unrestricted Use 25 175/100,000 (1.75/1,000)

NRC & MA Limits for 100 Restricted Use

700/100,000 (7/1,000)

NRC & MA Limits for 500 Restricted Use

3,500/100,000 (35/1,000)

Risk of Fatal Cancer is one half to two thirds the risk of developing any cancer.

Reproductive disorders occur at lower levels of radiation exposure than cancer.

The level of risk for radionuclides is significantly higher than for chemicals.

DEP’s risk level goal for a mixture of chemicals is a lifetime cancer incidence risk of 1 in 100,000. DEP risk level goal for one chemical is a lifetime cancer incidence risk of 1 in a million.

Based on Radiation: BEIR VII Phase 2. Washington, DC: The National Academies Press; 2006

Not all structures onsite are removed What is removed? • Major radioactive components, such as the

reactor vessel, steam generators, or other components that are comparably radioactive are removed

• Structures required to be removed to 3 feet below grade (reactor building foundation is 25.5’ below mean sea level)

Site Restoration- Structures Removed

How long will it take? Holtec International – 8 years

Entergy – 60 years

How much will it cost? Holtec and Entergy’s PDSARs say that the cost of site restoration will be relatively small.

At other sites, previously undiscovered contamination greatly increased the cost of site restoration. Example: Connecticut ratepayers had to pay a $480 million shortfall for cleanup of CT Yankee- strontium 90 found later to have contaminated water table surrounding plant.

Site Restoration

• All nuclear fuel used for the past 45 years remains on-site.

• Most is now stored in a spent fuel pool located in the upper floor of the reactor.

• Some was moved outside, now in dry casks on a concrete pad near the reactor.

• Fuel will remain in the reactor until shut-down.

• By 2022, all of the spent fuel will be moved into 70 dry casks, 68 assemblies each. Greater-Than-Class C waste is also placed in casks.

• The spent fuel in dry casks will remain on site for decades, perhaps indefinitely.

3. Pilgrim’s Spent Nuclear FuelNo Matter Who Owns Pilgrim

Location of Pilgrim’s Spent Fuel Pool

! Location: Pilgrim’s pool is located in the upper floor of the reactor. It is outside primary containment with a thin and vulnerable roof overhead.

! Crowded: Pilgrim’s pool was designed to hold 880 used fuel assemblies; it now holds about 2,000. When Pilgrim shuts-down, 580 additional fuel assemblies, now in the reactor, will be moved into the pool. Pool is licensed for a maximum capacity of 3,859 assemblies.

! Boraflex panels were added between Pilgrim’s pool assemblies to protect against overheating. – Entergy says about 900 are degrading (April 2017)

! Risk of Fire: If pool loses water simply to the top of the assemblies, a pool fire can occur, releasing radiation.

What’s the Problem with Pilgrim’s Spent Fuel Pool?

Fukushima-Unit 4: Hoses adding water after building exploded – pool at top of reactor

• 2016 Study: Major Spent Fuel Pool fire could contaminate over 38,000 square miles of land - almost four times the area of Massachusetts - and force millions to evacuate.

• 2006 Pilgrim Study: $488 Billion dollars, 24,000 cancers, land uninhabitable for hundreds of miles downwind

• These risks will be reduced by transferring all the spent fuel from the pool to dry casks as soon as possible after shutdown.

CONSEQUENCES OF A SPENT FUEL POOL FIRE

DRY CASK STORAGE

Dry cask storage is far safer than pool storage, but there are problems… potential leakage. According to the Nuclear Regulatory Commission (NRC):

The thin (0.5”) stainless steel canisters may crack within 30 years.

Currently, no technology exists to inspect, repair or replace cracked canisters. Therefore, it is important to have spare overpacks onsite.

With limited monitoring, we will only know after a canister leaks radiation. Each cask needs monitors for radiation, heat, and helium.

Each dry cask contains ½ as much Cesium-137 as the total released at Chernobyl

DRY CASK STORAGE SAFETY ISSUES

Security - Pilgrim’s Pad to be relocated from shoreline uphill - 300’ from Rocky Hill Road

Pilgrim’s spent fuel will likely remain on-site for many years. It needs added security to prevent a line-of-sight attack-such as a “dirt cheap” earthen berm.

Offsite Storage Options are not available- neither approved nor developed.

• Permanent Repository- Yucca Mountain

• Proposed Interim Sites- West Texas & New Mexico

Nevertheless, Entergy and Holtec predict and assume, absent facts, an interim facility will be available in 2030 and all fuel offsite by 2062.

Spent Fuel After Shutdown

NRC’s Nuclear Waste Rule Allows:

• Spent fuel to stay in either the pool or in dry casks for 60 years

• During subsequent 300 years, spent fuel assemblies may be kept in dry casks onsite – changing pad and casks every 100 years.

Who will pay?

Until there are Viable Offsite Solutions

Spent Fuel - Spent nuclear fuel assemblies should be: moved out of the pool, placed in hardened dry casks inside a secured building, and monitored for radiation, heat and helium.

Finances - The Licensee (i.e. Entergy or Holtec) pays for decommissioning in full, not the Commonwealth’s taxpayers.

Decommissioning Trust Fund – Restrict its use to decommissioning; not taxes and operating expenses.

Timing - Decommissioning should occur ASAP following closure. Do not defer dismantlement & cleanup for decades.

TO PROTECT OUR COMMUNITIES

Site Restoration: Site returned to “greenfield” for unrestricted use - radioactivity and chemical contamination cleaned up. Radiological Clean-up Standard: <10 ml/rem/yr. & < 4ml/rem drinking water sources. Dose must be assessed using the most conservative Resident Farmer Scenario and Basement Inventory Model for structures left below-grade. Prohibit rubblization: Instead, “Rip and Ship” to licensed disposal site. Site Characterization: Require a thorough radiological and hazardous material site characterization at the beginning of the decommissioning process - not wait until the end of the process. Perform a full NEPA analysis.

Public Safety: Retain current offsite emergency planning, funded by licensee, until spent fuel pool is emptied. Continue licensee-funded offsite emergency planning, on a reduced level, until fuel leaves the site. MDPH continue and expand offsite radiological monitoring and onsite tritium monitoring. Licensee continue to provide funding.

TO PROTECT OUR COMMUNITIES (Continued)

Workers: Retain Skilled workforce for decommissioning; Provide: job training, compensation package, placement operating reactor. NRC Oversight: Reinstate NRC inspections and oversight during decommissioning ➢Currently the NRC has little to no meaningful oversight during

decommissioning. There are no resident inspectors and no regular inspections.

➢Lack of NRC oversight means licensee compliance with regulations is impossible to verify and enforce on a timely basis. Lack of regular reporting leaves the public in the dark.

NEPA: Require a NEPA-compliant comprehensive analysis of all potential environmental and economic impacts of Entergy’s post-closure plans - needed to assure accurate cost estimates

TO PROTECT OUR COMMUNITIES (Continued)

Commonwealth actions to prepare for decommissioning:

Nuclear Decommissioning Citizens Advisory Committee

• Members include:(6) state officials; (8) members appointed by state officials; (2) Entergy officials; (1) representative from the Utility Workers Union America Local 369 who either works or worked at Pilgrim; (1) representative from the Old Colony Planning Council; and (3) appointees from the Town of Plymouth.

• The Panel is advisory.

Interagency Decommissioning Panel established in Executive Branch to oversee Pilgrim’s decommissioning.

TO PROTECT OUR COMMUNITIES (Continued)

! Legislation

! Write Governor

! Write AGO

! Write NRC

! Get your friends and neighbors to do so also.

What Can You Do?

Pilgrim Watch www.pilgrimwatch.org

mary.lampert@comcast.net

Thank you for your interest!

Questions & Discussion