On January 26th, the NRC issued an audit report concerning two orders that Entergy (owner of Pilgrim Nuclear Power Station) has to comply with. Both orders require Entergy to submit “Overall Integrated Plans” (OIPs) including descriptions of how compliance will be achieved.

As part of Pilgrim’s OIP, Entergy plans to use public tidelands along the shoreline in front of Pilgrim for an emergency back-up cooling system during a station blackout event. A station black out event would occur if Pilgrim were to lose offsite power and cooling water operations, and then the backup generators were also taken out of service (this is the FLEX plan we have written about:

As part of Pilgrim’s FLEX plan, during a station black out event Entergy proposes to send workers from Pilgrim (or the Plymouth fire department) to the shoreline where they would set up a portable pump and hose. This equipment would be used to pull water from Cape Cod Bay to manually cool the reactor and spent fuel pool.

One of our many concerns with this plan is whether it would be feasible to have workers standing on the shoreline setting up equipment during harsh weather conditions (such as an intense Nor’easter like Juno that hit Plymouth on Jan 27-28th). If this plan were ever actually needed, it would likely be due to a severe weather event. We do not believe this to be a workable plan in hurricane force winds, severe flooding, white out conditions, frigid temperatures, icing conditions, and strong storm surges and waves.

During the NRC’s Jan. 26th audit, they reviewed Entergy’s strategy for setting up and deploying the equipment to be used in the above described plan during a hurricane. Apparently Entergy’s procedures direct workers not to deploy the FLEX equipment before or during a hurricane event. But wouldn’t during a hurricane be the most likely time the FLEX equipment would be needed?

As described in the audit report, the NRC requested that Entergy provide information on the duration and intensity of hurricanes that impact the Pilgrim site and whether FLEX equipment would be needed during a hurricane. Entergy informed the NRC that hurricanes are “infrequent and of low intensity” at the Pilgrim site and that Nor’easters are the real concern. Energy got this half right.

Let’s start with the wrong half. Hurricanes should definitely be a concern and considered when developing backup safety plans at Pilgrim. Remember Hurricane Sandy? At least six nuclear stations were affected by Sandy in 2012. Oyster Creek Nuclear Station in New Jersey declared a rare “emergency alert” due to power outages and safety equipment dangerously close to being submerged. Due to a rising tide and storm surges, the Oyster Creek’s pump used for cooling was only 6 inches away from being completely submerged after water levels rose 6.5 ft. It also experienced a power outage that required the use of two backup diesel generators – also at risk of submersion. This scenario could have easily happened at Pilgrim during Hurricane Sandy if tides and storm surges had been higher in Massachusetts.

Now let’s consider the right half. Nor’easters are a huge concern along our coast, and especially for Pilgrim because it is located directly on the shoreline facing northeast without any landmass protecting it in that direction. A Nor’easter is a low pressure storm with continuously strong winds blowing in from the northeast direction. These storms can occur any time in the year, but are strongest between October and April.

In the NRC’s audit report, Entergy stated that it will provide a written overview of the frequency, duration and intensity of Nor’easters that impact the Pilgrim site and whether or not FLEX equipment would be (and could be) deployed during a storm. Entergy also must provide a written overview about whether FLEX equipment and refueling trucks can be “reasonably protected from non-tornado high wind events that affect the entire site.”

These follow-up responses by Entergy will be very interesting to read. Stay tuned!

Hopefully, the NRC will consider the Elevation Analysis that we recently developed in conjunction with Northeastern Geospatial Research Professionals, Inc. As you will see from the elevation analysis maps, there is certainly valid concern about flooding and storm impacts on the Pilgrim site!