According to NOAA National Weather Service, there’s currently a hazardous weather outlook for Plymouth County, including a coastal flood advisory and wind advisory (29 mph with gusts up to 39 mph).[1] These, coupled with the consistent light rain (1.25-1.5 in. of rain expected from now until tomorrow night.), is making it cold, rainy, windy and raw out there.

We don’t have Joaquin to thank for this unpleasant reminder that fall is upon us, but rather a stalled front just to our southeast. This, together with a gusty northeast wind, is making it feel like a Nor’easter.

While this current storm is not expected to be severe, the seas have been building over the next few days (and will continue to do so) and there have been some higher than usual tides. Take the tide today, around 3pm, which was about 12 feet MLLW according to NOAA. This is a predicted tide height of only 0.8 ft. lower than an astronomical high tide. Add the surge on top of that and we’re looking at 13+ feet (plus the wave action!). This scenario is likely causing 10 foot waves at the shore.

Check out our video below, taken at Bert’s Landing in Plymouth around 4pm today (10/2/15) – about 1 hour after high tide. Bert’s Landing in Plymouth, located approximately 2 miles NW of PNPS, has a similar rubble embankment and is severely impacted during storms, especially Nor’easters.[2] The velocity zone (the area subject to wave action) for Bert’s is 14 ft., while Pilgrim’s velocity zone is 16-18 ft. depending on the location onsite.

While this isn’t a significant storm event like ones we have written about in the past (here, here, here and here are just a few examples), it’s certainly worth some attention, especially pertaining to operations at Entergy’s Pilgrim Nuclear Power Station. It’s important to understand the potential implications that these weather hazards – and 10 foot waves in this particular storm – can have on a coastally-sited nuclear plant such as Pilgrim. Read this blog, First Nor’easter of the Season, to learn more about what the specific risks are at the site.

Times of strong northeasterly winds, surge, high tides, coastal flooding, and rain are always a concern to us. We strongly believe that Pilgrim 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.).

Although the Nuclear Regulatory Commission (NRC) continues to state that Pilgrim is protected by two jetties – it is still not completely protected. If the waves at the Pilgrim site amount to 10 feet during this storm, there could be splash-over in the switchyard…and so the unplanned outage season at Pilgrim begins.

Pilgrim relies on offsite power via above-ground transmission lines in a switchyard that is vulnerable to weather events, such as heavy snowfall, salt spray, icing, and storm conditions. Pilgrim has had problems with its switchyard since the 1970s, which causes the plant to lose offsite power. Losing offsite power means Pilgrim can’t pump in water to cool its reactor and spent fuel pool, and then it has to rely on backup emergency generators for cooling operations. Every time Pilgrim has an unplanned shutdown (aka, scram), the risk level goes up. The processes of manually or automatically scramming a reactor leave a lot of room for error, and furthermore, generators are not always a fail-safe emergency system as proved during the Fukushima disaster. These chronic switchyard problems can undoubtedly occur during storms – even one that might seem insignificant – due to the salt spray occurring from wave action and wind, as well as any flooding on the site.

Back in 2012, the NRC requested that all nuclear facilities in the U.S., including Pilgrim, reassess the flooding potential at their sites (after the Fukushima nuclear disaster proved that flooding can have dire consequences at nuclear plants). Entergy submitted its flooding re-evaluation to the NRC in March of this year.

According to the report, two mechanisms could result in inundation at the site: combined effect flood and flooding due to local intense precipitation. The report goes on to say that inundation wouldn’t be a problem anyway, since “safety-related systems and equipment” would not be affected. We disagree.

First, there are serious deficiencies in the report and it fails to fully evaluate all plausible flooding mechanisms such as Nor’easters and wave action (our final assessment of the flooding reevaluation report will be coming out soon – stay tuned!). Second, it’s important to note that non-safety systems and equipment can cause serious problems at nuclear facilities.

Dr. David Lochbaum from the Union of Concerned Scientists has stated, “The March 1979 meltdown of Three Mile Island Unit 2 reactor was triggered by the failure of a non-safety related component. The April 1986 accident at Chernobyl Unit 4 was triggered by a badly conducted test of a non-safety related component. When non-safety related components caused two of the worst nuclear plant accidents in recorded history, it’s hard to dismiss non-safety related component problems so cavalierly.”

And remember, Pilgrim’s has serious problems and deficiencies even without hazardous weather added to the equation. Just last month, the NRC announced that Pilgrim’s performance rating was downgraded to a Category IV – only one step below mandatory shutdown by the federal government. Pilgrim is currently being allowed to operate, despite its many deficiencies, while it assesses whether to spend the money required to make serious safety upgrades or to shut down.

Earlier today we requested photos be taken by resident NRC inspectors on the Pilgrim site during the high tide. Not surprisingly, they said no. We continue to believe that Entergy is underestimating the flooding potential at Pilgrim, and we will continue to push for better assessments of the risk. Once a clearer picture is painted, we know regulators will agree that Pilgrim should be decommissioned at the earliest time possible and its spent nuclear fuel moved and stored at elevated and enclosed areas.

We will be posting a review of Pilgrim’s flooding re-evaluation report very soon, which will identify deficiencies and other flooding scenarios that were omitted by Entergy.

Footnotes

[1] NWS Alert
[2] https://www.youtube.com/watch?v=NZV2vPVEAqI