By
FRANK CARINI/ecoRI News staff
 |
| The town of Plymouth, on Cape Cod Bay, has been home to the Pilgrim Nuclear Power Station since the facility opened in 1972. |
EDITOR’S
NOTE: Pilgrim is the second-closest nuclear power plant to Charlestown. The
closest plant – Millstone Nuclear Power station near New London – is only 20
miles away, but it shares most of the problems that Pilgrim has. Before coming to Charlestown, Town Administrator Mark Stankiewicz was Plymouth's town manager and had to deal with Plymoth as one of the town's main employers - and polluters.
PLYMOUTH, Mass. — Broken promises and financial interests are
polluting Cape Cod Bay. For nearly two decades, federal and state authorities
have allowed the Pilgrim Nuclear Power Station to operate with an expired Clean
Water Act permit.
Two dozen public-health and environmental groups find it
unacceptable that a power plant on the shore of an ecologically rich water body
that hosts a diverse array of habitats is allowed to continue to use technology
from the 1960s. Last month, this statewide coalition issued a report that
“exposes the failure of the Environmental Protection Agency (EPA) and
Massachusetts Department of Environmental Protection (DEP) to properly regulate
the Pilgrim Nuclear Power Station under federal and state environmental laws.”
The coalition is asking the agencies to suspend Entergy Corp.’s
water pollution permit, said Meg Sheehan, a volunteer attorney with the Cape
Cod Bay Watch, because it’s allowing the
continued pollution of the bay and destruction of marine ecosystems — in
violation of the very basis of the Clean Water Act.
When the plant pumps in water from the bay, Sheehan said, it kills
marine life that either gets trapped on the intake screens (impingement) or
gets pulled through the screens into the internal piping.
After Pilgrim uses
the seawater for cooling — about 350,000 gallons a minute — the water is pumped
back into the bay, heated and polluted. This water is some 30 degrees
Fahrenheit hotter — the permit allows for a maximum temperature of 102 degrees
— when it returns to the bay and it contains chemicals such a corrosion
inhibitors, chlorine and radioactive materials. These discharges are part of
the facility’s routine operations.
The federal Clean Water Act requires EPA to review permits every
five years to ensure industrial polluters are using the “best available
technology” to minimize environmental and public-health impacts. When Congress
enacted the Clean Water Act in 1972 — the same year Pilgrim went on-line — the
law was intended to reduce industrial pollution by constantly requiring better
technology and controls. The EPA issued Pilgrim’s first Clean Water Act permit
in 1983.
The 24-member coalition’s report shows that Entergy’s Clean Water Act permit expired
in 1996 and is based on technology introduced five decades ago. Under this
expired permit, Entergy is allowed to take up to 510 million gallons of water
from Cape Cod Bay daily.
The 41-page report reveals the contents of thousands of pages of
internal government agency documents and relies on Entergy’s own reports to
highlight the environmental impact being caused by the power plant’s outdated
cooling system. The report claims about two-thirds of the heat energy produced
at the plant is dumped into Cape Cod Bay as waste heat. The rest is converted
into electricity for consumers. At this rate, Sheehan said, Pilgrim is about as
efficient as a typical coal-fired power plant.
Better technology exists and the EPA and DEP should have required
it long ago, Sheehan said. Until they issue a new Clean Water Act permit, the
nuclear power plant shouldn’t be allowed to operate, she added.
The coalition notes that these wasteful operations are sanctioned
under the outdated permit. Sheehan said the EPA and the DEP continue to allow
Entergy to use an inefficient system for cooling water— similar to the system
once used at the coal-fired Brayton Point Power Station in Somerset, which was upgraded several years ago at
a cost of about $500 million — instead of requiring a more efficient
closed-loop system.
Sheehan said Entergy’s use of Cape Cod Bay for cooling its power
plant is supposed to be tightly regulated, to make sure Pilgrim uses the best
technologies available to reduce environmental harm. The agencies aren’t doing
their job, she said.
“The Clean Water Act was never intended to allow industry to
continue to pollute with outdated technology,” said Sheehan, noting that
Entergy’s outdated power plant is the largest polluter of Cape Cod Bay.
To put Pilgrim’s wastefulness and inefficiency into perspective,
the coalition report notes that the amount of heat energy Entergy dumps into
Cape Cod Bay every year, about 42 trillion BTUs, is enough to heat 437,800
homes annually — more than four times the number of households on the Cape and
the Islands and more than two times the number of households in Plymouth
County.
Sheehan, a Cambridge-based public interest environmental lawyer
for the Earthrise Law Center and the lead author of the report, which was two years in
the making, traveled to the EPA Region 1 (New England) office in Boston to
examine the agency’s Pilgrim file. “I was astounded to find that the EPA has
largely ignored this huge file for 20 years,” she said.
Under the Clean Water Act, Entergy is required to submit monthly
discharge reports to the EPA. Sheehan said she found dozens of these reports in
unopened envelopes in the Pilgrim file. The longtime environmental attorney who
once worked as an enforcement lawyer for the Massachusetts attorney general
also said she found violations that dated back years.
In 2012, Sheehan said the EPA promised it would have Pilgrim’s permit
revised by the end of the year. It made the same promise for the end of 2013.
“It’s obvious this matter isn’t a priority for the EPA or the
DEP,” said Sheehan. “The EPA has done nothing but renege on promises. No
enforcement, just promises and excuses.”
The EPA didn’t respond to a request for comment from ecoRI News.
Edmund Coletta, director of DEP’s Office of Public Affairs, wrote in an e-mail
that EPA Region 1 is the lead agency for Pilgrim discharge issues.
“For the last few years, MassDEP has been working with EPA Region
1 to draft a new discharge permit for Pilgrim,” he wrote. “A major part of that
work is a cooling water intake analysis that is currently being completed by
the EPA. Once that analysis is finished, the draft permit will be made available
for public comment. In the meantime, the current discharge permit remains in
force.”
Diagram of Pilgrim’s
once-through cooling system from the coalition’s recent report. The volume of
water Entergy dumps into the Cape Cod Bay annually is more than enough to run a
shower in every household on the Cape and Islands every day, all day, all year
long. It’s also 100 times more than the Plymouth Water Department pumps to meet
the entire town’s municipal and domestic water requirements each year,
according to the coalition.
Seafood stew
Coalition members claim it’s well documented that Entergy’s
current operation causes marine degradation and pollution of Cape Cod Bay. They
say the crux of the problem is the plant’s “once-through” cooling system, which
draws in and kills plankton, fish and other marine life.
“Pilgrim’s seawater intake system has been impacting fisheries in
western Cape Cod Bay for years,” said Jo Ann Muramoto, senior scientist at
the Association
to Preserve Cape Cod, in a June 8
coalition press release. “The discharge of heated seawater back into the bay is
likely causing further stress to local marine ecosystems that are also dealing
with ocean warming due to climate change.”
Species such as krill and other plankton, cod, mackerel and
lobster have been found to be particularly vulnerable to warming water
temperatures, according to last month’s report.
The report claims tens of millions of fish and billions of
planktonic organisms — the foundation of the marine food web — are killed by
the cooling system annually. Fish and shellfish are killed when they are drawn
onto Pilgrim’s intake screens, and smaller marine life such as the eggs and
larvae of fish and shellfish and planktonic organisms are killed when they are
drawn through the screens and into the cooling water system, where they are
exposed to hot water and chemicals and battered by mechanical equipment,
according to the report.
One of the world’s most endangered marine mammals, the North Atlantic
right whale, uses Cape Cod Bay as a feeding area and is frequently found near
Pilgrim. Much of the bay is designated “critical habitat” under federal law for
the endangered species. NOAA Fisheries has proposed expanding the designated
area to include the entire bay.
From 1980 to 2007, 73 species of fish and 18 taxa of invertebrates
were recorded during system sampling, according to a May 17, 2012 letter from
the National Marine Fisheries Service of the National Oceanic and Atmospheric
Administration (NOAA) to the Nuclear Regulatory Commission (NRC).
In that letter, NOAA noted that the NRC claimed the losses due to
impingement in the Pilgrim system were less than 1 percent of the population
for each of the recorded species, with the exception of cunner and rainbow
smelt.
“Nothing at Pilgrim makes less sense than the fisheries Cuisinart
the EPA allows Entergy to operate,” Ed DeWitt, executive director of the
Association to Preserve Cape Cod, one of the coalition’s 24 organizations, said
in last month’s press release. “Taxpayers spend a billion dollars a year on
fisheries management and protection. We might as well shred the money in the
Pilgrim cooling system along with all the fish being killed.”
The Pilgrim Nuclear Power
Station’s track record is less than stellar, at least according to the Nuclear
Regulatory Commission, which, in 2012, extended the plant’s license to 2032.
(Entergy Corp.)
Record setting
The Pilgrim Nuclear Power Station was built in 1972 by Boston
Edison at a cost of $231 million. Before the plant was built, state regulators
ordered Boston Edison to install a closed-cycle cooling water system that would
cause less environmental damage and comply with state law. Boston Edison sued
to prevent having to install such a system, winning the case and installing the
cheaper once-through system still in use today.
Louisiana-based Entergy bought the facility in 1999. Entergy Corp. has annual
revenues of more than $12 billion, according to the corporation’s 2014 annual report.
The total compensation for Entergy Corp. CEO Leo Denault in fiscal 2014 was
$8.2 million.
Pilgrim has the capacity to produce up to 690 megawatts of
electricity, which it sells to the New England power grid. The power plant also
is a vital part of the regional economy, according to a recent report by the
Center for Economic Development (CED) at the University of Massachusetts
Amherst.
As of February, there were 586 employees at Pilgrim, with a
payroll of about $55 million and a weekly wage of $1,805, according to
the CED report. This
represents 2.5 percent of the jobs held in Plymouth and 5.3 percent of the
wages paid in Plymouth. Pilgrim’s average weekly wage is 50 percent higher than
the state average, according to the 71-page report.
The coalition’s report, however, alleges Pilgrim has been one of
the worst performing commercial nuclear reactors in the United States since the
early 1980s. In 1982, the NRC penalized Boston Edison $550,000 for violating
regulations.
Four years later, in May 1986, Pilgrim was ranked one of the
nation’s most unsafe reactors. The NRC closed the plant from 1986 to 1988
because of mismanagement and operating errors that resulted in an accident that
released excessive radiation into the surrounding community.
Despite the power plant’s use of outdated technology and poor
record, in 2012 the NRC extended Pilgrim’s license to 2032. A year later, the
NRC further downgraded Pilgrim because of operating failures and ranked it
among one of the 22 worst performing reactors in the country. The NRC has since
ranked Pilgrim one of the 10 worst performing U.S. reactors.
Three years ago, a group of local residents filed notice of intent
to sue Entergy for violations of the Clean Water Act. Since 1996, there have been 33,253 violations of the
Clean Water Act at the Pilgrim station, according to a letter sent to the
company and federal officials by the group in October 2012. Entergy responded
by threatening a countersuit, Sheehan said.
Those behind the push for Entergy to renew its Clean Water Act
permit or stop operations say Cape Cod Bay is a natural resource that belongs
to the public and must be properly protected. All 15 Cape Cod towns have called
for Pilgrim’s closure.
Cape Cod Bay contributes a minimum of $1.5 billion a year to the
region’s economy, according to a 2012 study. The
tourism and fishing industries supported by the bay — designated as a state
ocean sanctuary in 1970 — are dependent on good water quality and the
protection of coastal and marine habitats, according to the coalition.
The
report cited by the coalition claims industrial stormwater runoff into the bay
from the power plant’s storm drains is improperly managed and not in compliance
with current laws.
The EPA’s nearly two-decade delay in renewing Entergy’s water pollution
permit means there is no realistic expectation that Pilgrim’s pollution and
destruction of marine life will stop, Sheehan said. Terminating Entergy’s
permit, she said, would likely result in a more innovative approach to power
production at Pilgrim.
Sheehan said another lawsuit, based on violations of the public
trust, is a possibility.
“Government agencies are ignoring their responsibility to protect
the public trust. The EPA and DEP have failed to execute their duties,” she
said. “Natural resources belong to everyone and don’t exist for Entergy to
destroy. But corporations have the power and leverage to put pressure on the
EPA and challenge regulations. This is just one example of how the system is
broken.”
Questions and
answers
ecoRI
News was asked by Entergy spokeswoman Lauren Burm to e-mail her
questions. Here are the unedited questions and answers:
ecoRI
News: What kind of impact is Pilgrim, most notably the
5-decade-old cooling system, having on Cape Cod Bay?
Entergy: Pilgrim’s
operations are not adversely impacting Cape Cod Bay. Pilgrim operates in
accordance with a valid National Pollutant Discharge Elimination System (NPDES)
permit issued by Environmental Protection Agency (EPA). In compliance with this
permit, Entergy conducts an extensive biological monitoring program, which
establishes that Pilgrim’s operations are in full compliance with all
requirements. In light of the presence of Northern right whales Entergy
developed a supplemental monitoring program for Pilgrim that was submitted to the
NRC at the end of 2013 and implemented during the spring of 2014.
ecoRI
News: Does Entergy consider Pilgrim’s technology outdated?
Entergy: Pilgrim’s
technology meets all requirements for safe operations.
ecoRI
News: How much would it cost to upgrade the plant to a
closed-loop cooling system? Would it be similar to the one built at Brayton
Point?
Entergy: We cannot speak to the system used by Brayton Point
and therefore cannot make any comparisons.
ecoRI
News: Why is Pilgrim operating on an expired Clean Water Act
permit that is nearly 20 years old?
Entergy: Pilgrim
operates in accordance with a valid National Pollutant Discharge Elimination
System (NPDES) permit issued by Environmental Protection Agency (EPA) and
Massachusetts Department of Environmental Protection (MassDEP). Entergy
has been working with the agencies.
ecoRI
News: How much of the energy produced by the plant is converted
into electricity?
Entergy: During
2014 Pilgrim operated at 97 percent capacity. No other generating source came
close. Moreover of the generation that is carbon-free in the southeastern MA
load zone, which includes the Cape and Islands, Pilgrim provides nearly 100% of
that carbon-free power (solar/wind ≈.03 of 1%).
ecoRI
News: How much seawater is dumped back into Cape Cod Bay daily
after it is used to cool the plant?
Entergy: Pilgrim
takes in about 460 million gallons of water a day from the bay and runs it
through our system for cooling purposes and sends it back into the bay in
compliance with all clean water standards and permits.
ecoRI
News: How much hotter is the water pumped back into the bay after
cooling and what kinds of chemicals/materials does it contain?
Entergy: The
bay water Pilgrim takes in and runs through our system for cooling purposes
never comes in contact with any radioactive material and meets all clean water
standards. The NPDES Permit specifies that the plant is not allowed to withdraw
or heat up water from the bay in excess of the limits established by EPA. On
average, the returning water temperature is warmed by 28 degrees Fahrenheit,
about 4 degrees below the maximum limit.
ecoRI
News: In 2013, the NRC downgraded Pilgrim because of operating
failures and ranked it among one of the 22 worst performing reactors in the
country. In 2014 and 2015, the NRC further downgraded Pilgrim to one of the 10
worst performing reactors. What is Entergy doing to address these issues?
Entergy: Pilgrim
successfully completed the inspection related to the 2013 downgrade as was
published in a report by the NRC on June 18, 2015. Pilgrim remains under
additional NRC oversight until the final resolution of the Special Inspection
that resulted from the shutdown during storm Juno in January 2015. All of the
issues raised in the Special Inspection report have been addressed. A
Regulatory Conference with the NRC was held on July 8 and the NRC is currently
evaluating the new facts on the Special Inspection that the Pilgrim team
presented. We expect to hear a final conclusion from the NRC in early August,
2015. Entergy has invested over $500 million in safety-related upgrades and new
equipment in Pilgrim since 2000. Most recently, during May 2015, $70 million
was invested during our biennial refueling outage. The entire Pilgrim team is
committed to safety and works hard every day to operate the plant at the
highest levels of safety and performance.