Due to the Fukushima Daiichi nuclear accident that happened on March 11, 2011, the Nuclear Regulatory Commission (NRC) established a task force to review the accident in order to improve response and readiness of the U.S. nuclear fleet to beyond design basis events.

The task force developed a report and recommendations. One of these recommendations concerned flooding, and requested that a flood hazard re-evaluation analysis be carried out by U.S. nuclear facilities. The AREVA report – commissioned by Entergy for its Pilgrim Nuclear Power Station (PNPS) – was developed to meet the task force’s required response.

JRWA reviewed this flooding re-evaluation report, and last week provided comments to the NRC and elected officials. As explained in our comments, we believe PNPS is inherently unsafe due to structural, environmental, and site-specific problems (e.g., located in a salt water/air environment and approximately 2 ft. above the FEMA flood zone, facing N-NE directly on the Atlantic Ocean, subjected to ocean-based storms, waves and wind, suffering from age-related degradation, etc.). No amount of re-evaluation can change these fundamental flaws. Pilgrim should be decommissioned at the earliest time possible and PNPS’s spent nuclear fuel moved and stored at elevated and enclosed areas.

Nonetheless, we reviewed the report and provided detailed comments that address numerous issues that we believe need further attention by the NRC, other federal and state regulatory and legislative bodies and the general public.

Here is a sample of some of the concerns outlined in our letter:

  1. The AREVA report identifies two mechanisms that would result in inundation at PNPS: 1) combined effect flood, and 2) flooding due to local intense precipitation. However, AREVA claims that inundation will not impact systems, structures, and components (SSCs) important to safety – we believe this conclusion is flawed for a variety of reasons outlined in our letter.
  2. In addition to local intense precipitation and combined effect flood, which can inundate the PNPS site, we believe that Nor’easters, tsunamis, salt, and ice have the potential to negatively impact the PNPS site and systems, structures, and components (SSCs) important to safety, as well as non-safety systems and equipment.
  3. Nor’easters are known to cause long duration wind and storm waves against the western shore of Cape Cod Bay throughout the year; the AREVA report inaccurately assesses the combined impact of “waves” that can add to surge at the PNPS site.
  4. Ice-induced flooding is also inappropriately characterized as only a potential frazil hazard at the intake/discharge areas, but as demonstrated during January-April 2015, ice can significantly influence ocean impacts.
  5. The impact of salt on the SSC’s important to safety onsite was not evaluated.
  6. Elevation values used in the AREVA report are not the most accurate data available.
  7. Mean sea level has changed since the current licensing basis was adopted in 1968-1970; it’s likely that the AREVA report is considering the PNPS site to be 6.5 in. more elevated than reality, creating a false sense of security for areas of the PNPS site vulnerable to flooding.
  8. Precipitation-induced flooding is not currently addressed in the current licensing basis for PNPS. The NRC should require PNPS’s to include flooding caused by local intense precipitation/probable maximum precipitation events, and adopt approved protective measures in defense.
  9. Non-safety systems and equipment can cause serious problems at nuclear facilities, but only SSCs important to safety were considered in the AREVA report.

There are many more concerns outlined in our comment letter, which you can read here in its entirety →

This is the first step in our effort to understand flooding risks at PNPS. We will continue to make efforts to improve our review of the models used, and hope to elaborate on our concerns in the near future.