Climate change is a significant change in earth’s overall conditions, which can be measured by major changes in the distribution of weather patterns – such as temperature or precipitation, among other effects – that occur over several decades or longer. Climate change is mainly caused by global warming due to increasing concentrations of greenhouse gases in our atmosphere.
The consequences of climate change vary across the globe. Here in the Northeast we are already seeing significant impacts to the coastline due to rising sea levels. We are also seeing increased precipitation, increased air and ocean temperatures, more flooding, higher storm surge, more intense storms, and more.
The National Oceanographic and Atmospheric Association (NOAA) estimates a sea level rise of 3.05 feet by 2065 in the northeastern U.S. However, some believe sea levels could be rising even faster. For example, sea levels along the northeast coast rose nearly 3.9 inches in just a two year period (2009-2010) according to a Feb 24, 2015 study from the University of Arizona and NOAA. At this rate, sea levels could be more than 8 feet higher in 50 years.
Several studies also suggest precipitation amounts will increase in the future – projected to increase by 20-30% by 2070 to 2100 (Stratz and Hossain, 2014; Kunkel et al., 2013). Specifically in the Northeast, heavy rainfall events have increased (~70% from 1958-2012) and are projected to increase further in the coming years (Melillo et al., 2014).
Risks to Coastal Energy Infrastructure
The climate-related impacts discussed above pose risks to coastal energy infrastructure. In July 2013, the U.S. Department of Energy published a report outlining vulnerabilities of energy facilities to climate trends. The report cited issues such as increasing air/water temperature, increasing intensity of storms, sea level rise, and storm surge all as having potential negative implications. Among such implications is increased risk of physical damage.
Over the years, we have advocated for better assessments of flooding and other coastal risks at energy facilities located on Cape Cod Bay, where there are two large energy facilities: Pilgrim Nuclear Power Station and NRG’s Canal Station (oil and gas).
Given that Pilgrim will shut down by May 31, 2019, it is more important than ever to fully understand the risks associated with coastal hazards. For example…
1) Pilgrim’s nuclear waste storage areas are located too close to shore. Its dry cask nuclear waste storage project is currently sited about 150 feet from the Cape Cod Bay shoreline, and its so-called “low-level” waste storage area is only about 30 feet away from the coastal bank. These areas are vulnerable to storm surge, rising sea levels, flooding, salt water degradation, and other coastal risks – raising concerns about potential accidents and leaks. Nuclear waste could remain at this location for decades, if not hundreds of years – meaning coastal impacts will increasingly become more of a problem over time.
Unless Pilgrim’s dry casks will be transported off-site within a decade, regulators and officials must ensure that Pilgrim’s waste is moved to higher elevation, farther away from Cape Cod Bay and securely protected from natural and man-made hazards, or moved off-site immediately.
2) Climate-related impacts could also undermine successful remediation of contaminants on-site. Upon shutown, Entergy could opt for long-term “SAFSTOR,” a decommissioning process that would allow Pilgrim to sit idle for up to 60-years before decommissioning is completed. We know that Pilgrim has been releasing radioactive materials and other contaminants deliberately and accidentally into groundwater, surface water, and soils since it began operating in 1972. As sea levels increase, so do groundwater elevations. Contamination present on Pilgrim’s site will, no doubt, continue to migrate toward Cape Cod Bay even after Pilgrim stops generating power. Achieving a fully remediated site will also progressively become more difficult as a result of climate-related issues.
Regulators and elected officials need to ensure that Pilgrim’s pollution is surveyed and cleaned up within a decade of closure in order to protect public and environmental health.
NRG, the owner of Canal Station, is soon building an additional fossil fuel facility (Unit 3) that would have a lifespan of 40 years. NRG has admitted that the new Unit 3 facility will be affected by nearly 3 feet of sea level rise (3 feet above mean sea level based on NOAA data), flooding, storm surge and wave action in the future.
In February 2016, we submitted comments on the company’s petition to build the new unit. Some of our concerns related to coastal hazards are:
- NRG should outline how and when it will check the stability of underground tanks/pipes, and how leaks will be detected. As sea levels rise, so will groundwater levels – impacts from salt water intrusion on underground infrastructure should be addressed.
- NRG should consider future climatic conditions that are projected to increase precipitation and temperatures, particularly in the Northeast; and use the most conservative value of 2.93 feet above mean sea level by 2060 to develop plans to protect the site.
- The state should require Canal Station’s Units 1 & 2, which are outdated, environmentally destructive and have been operating under an expired Clean Water Act NPDES permit since 1994, be decommissioned before an additional unit is approved.
We are also concerned that Massachusetts is becoming overly-reliant on natural gas and NRG’s project is another step in that direction. Our state is already heavily dependent on this source — more than 50% of our in-state electricity generation currently comes from natural gas. Becoming overly-reliant on natural gas creates financial risk, places the economy and consumers at risk from fluctuating gas prices, and weakens efforts to cut emissions. While natural gas electrical generation produces much less carbon emissions than coal or oil, it still produces emissions. Drilling, storage, extraction, and pipeline activities associated with natural gas result in methane leaks. Compared to carbon dioxide, methane is a far more potent greenhouse gas that could escalate climate problems.
Flooding and Sea Level Rise Assessments
As a result of the 2011 Fukushima Daiichi Nuclear Power Plant disaster, the U.S. Nuclear Regulatory Commission (NRC) required all nuclear power plants in the U.S., including Pilgrim, to assess on-site flood hazards. Pilgrim’s flood hazard evaluation report, called the “AREVA report,” was issued in March 2015.
Florida-based Coastal Risk Consulting (CRC) assisted us with evaluating the AREVA report. CRC’s report, Analysis of AREVA Flood Hazard Re-Evaluation Report: Pilgrim Nuclear Power Station, Plymouth, MA (“CRC Report”), was published in Dec. 2015 and outlines how the AREVA report underestimates and omits important risk factors, uses outdated data, and does not consider future risk estimates for rainfall and sea level rise. For example:
- “Local intense precipitation” is found in Entergy’s AREVA Report as a primary hazard of concern that could inundate the site with several feet of rainwater. Despite this, CRC found that this mechanism is underestimated in Entergy’s report since it uses outdated precipitation data and does not consider future climatic conditions that are projected to increase precipitation amounts during heavy rainfall events (think of the October 2015 events in South Carolina).
- While the storm surge analysis in Entergy’s AREVA Report was robust, sea level rise over the next 50 years is understated since it relies heavily on historic sea level rise rates – producing a sea level rise more than 2.5 feet lower than current projections.
- Groundwater, subsidence, and erosion are not considered in Pilgrim’s flood assessment; further underestimating risks (especially related to extreme storm events).
- Pilgrim’s flood assessment focuses solely on past risk conditions and does not include scenarios that address updated projections for future risk, specifically with regard to climate change. The CRC report shows that the Pilgrim site will be inundated with non-storm tidal flooding by mid-century and that a surge from a category 4 hurricane could already flood the site today.
We also commission site maps from Northeastern Geospatial Research Professionals (NGRP). NGRP recently updated the maps in Feb. 2016 →
These maps confirm elevation inaccuracies in Entergy’s site plans for Pilgrim’s infrastructure and the nuclear waste storage areas. This shows that there is more accurate elevation information that the NRC should consider when determining flood risks at Pilgrim, and that Entergy’s claims that Pilgrim is safe from flood impacts is based on some inaccurate information. For example:
- Entergy’s site maps prior to 2014 use outdated data from 1968 (mean sea level today is >6 in. higher than 1968) to develop site plans for infrastructure (e.g., dry cask storage facility); those plans do not reflect current NAVD88 topographical elevations and do not provide an accurate basis for evaluating risks of sea level rise and other coastal impacts.
- The height of the breakwater jetties and other elevations in NGRP’s maps appear significantly lower than those shown in Entergy’s plans, and are uneven, demonstrating that the site is not as protected from flooding and sea level rise as Entergy reports.
- There are discrepancies ranging from +4 in. to -15 ft. when comparing Entergy’s plans to more current elevation information because Entergy uses mixed and outdated standards of measurements for vertical elevations and water levels.
We will continue to raise these concerns and pressure regulators to require changes to ensure Pilgrim’s infrastructure and nuclear waste storage areas are protected from climate-related coastal impacts.
- NASA Climate Page. Current news and data streams about global warming and climate change.
- NOAA Climate Page. Data, tools, and information to help people understand and prepare for climate variability and change.
- Earth Nullschool. Current wind, weather, ocean, and pollution conditions, as forecast by supercomputers, on an interactive animated map. Updated every three hours.
- Is Nuclear Power Clean Energy? CCBW Factsheet (Mar. 2016)
- OF NUCLEAR INTEREST: Replacing Pilgrim with Renewables, Conservation. Dec 2015.
- National Geographic: As Sea Level Rises, Are Coastal Nuclear Plants Ready? Dec. 2015.
- Short Answers to Hard Questions About Climate Change. Nov. 2015. New York Times, J. Gillis.
- JRWA/CCBW’s letter to the Boston Globe. Oct 2015. Re: Article claiming Pilgrim is carbon-free.
- NRDC. Nov 2013. Energy Experts Respond to Scientists’ Letter Advocating Nuclear Power.
- Nuclear Facts: Nuclear is not Carbon Free.
- Nov 2013. Of Nuclear Interest: Nuclear Power in Our Changing Climate.
- Huffington Post. May 2014. Nuclear Energy Is Not a Solution for Global Warming.
- NIRS. Nuclear Power and Climate Change.