The following is a request from the Jones River Watershed Association to the Nuclear Regulatory Commission regarding the impending winter storm.

As the storm approaches our area, and has the potential to match the Blizzard of ’78 standard for fierce weather in the region, I am renewing my request that the on-site NRC inspectors at Pilgrim, not only observe the “still water” height of the water at the facility, but get eyes outside as well. Your reply letter to my request of just over a year ago is attached below for reference.

As you know this past year Pilgrim/Entergy has proposed a FLEX strategy that includes deploying a truck mounted portable pump to the Mean High Tide line in the event of a Beyond Design Basis External Event (BDBEE) that causes a loss of normal operating power and requires back up cooling to the reactor and the spent fuel pool. JRWA and others made numerous comments on this plan to both the town and MA DEP because of our concern that a station blackout is most likely to be caused by a BDBEE that is weather driven – such as the impending storm named “Juno”.

Our great concern is that storm surge, plus wind driven surf and waves would make it impossible for employees to respond with this equipment as Entergy plans – while at the same time disabling plant operations. With the prediction of several feet of snow – perhaps as much as 30 inches – the snow and ice conditions increase hazards at the facility if not generate a crippling event.

We knew that last winter’s event would be a manageable storm – but we saw it as an opportunity for NRC to be onsite in lousy conditions – and measure – not the still water elevation – which is not to say it should not be measured – but to measure the wind and wave velocities – and think more about emergency planning and siting of the nuclear waste. Now on the anniversary of your letter is another opportunity. We would like pictures of the site during the storm – maximum wave height, reach on the site – pictures of the “dry cask” bottom vents, proximity of the water to the ISFSI, an understanding of measures taken to protect the “stranded waste” that sits 30 feet from the shore, and many more concerns that time will not allow me to type now.

Over the past year we have worked with a mapping expert to try to get our point across to you that Entergy is not providing accurate information. Even as you say in last year’s letter that “there was no observable damage to the jetties” The maps that NGPR produced for us from the most current publicly available data appear to show that the jetties have sunk as much as two feet below the elevation shown on Entergy’s site plans. This will impact modeling of storms and floods on site.

NRC and others should require that Entergy perform a thorough on-site survey by professionals, that does not rely on out-dated information (like old benchmarks), in order to have accurate information and make the most informed decisions possible about this facility.

Please see the letter from last year and one of our maps attached.

Thank you, and Good Luck,

Pine duBois,
Executive Director
Jones River Watershed Association
Jones River Landing
55 Landing Road, Kingston, MA 02364