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Twenty more years for a failed technology?
See July 6, 2006 Statement before Atomic Safety Licensing Board in support of Motions to Intervene
Statement of Cape Downwinders on Pilgrim relicensing:
The Entergy Corporation has announced it's intention to submit an application in December, 2004 to extend the operating license for the Pilgrim Nuclear Power Station until 2032 (the present 40-year license is due to expire in 2012).
The NRC stated in Boston, July 2003, that they expect 100 reactors to apply for re-licensing in the next two years. A nuclear power reactor licensee may apply to the NRC to renew its license for another 20 years of operations as early as 20 years or as late as five years before expiration of its current license. License renewal is expected to take about 30 months. The license renewal process proceeds along two tracks: one for technical reviews of safety issues (Part 54) and another for environmental issues (Part 51). There is some opportunity for the public to intervene and take action.
Emergency planning, security against terrorist attack, control of routine emissions, containment integrity, spent fuel storage - each of these critical systems was inadequate in the early seventies, and all are far worse now. We have much greater population density, a far greater terrorist risk environment, an allowable radioactive emissions standard greater than the original design specification, an admittedly-inferior reactor containment which has been further compromised by the added direct torus vent, and above-ground fuel storage which exceeds it's maximum design capacity by three times.
Does re-licensing make sense with uninspected safety components which have 3 decades of stress-corrosion cracking and embrittlement, or with once-thru cooling - which would not be allowed in another generating station - harming the marine environment of Cape Cod Bay?
Much has changed in thirty years; there should be a thorough, independent, cost-benefit analysis. And Price-Anderson, originally sold as a temporary subsidy for an industry too new to be insurable, continues today because the marketplace has determined that nuclear energy is too risky to insure.
Cape Downwinders opposes relicensing of any nuclear power station until the following conditions are met:
- Security
- Radwaste
- Age degradation of components
- Radioactive releases
- Marine life
- Emergency planning
- Analysis of costs/benefits and alternatives
- The relicensing application
1. Security must be sufficient to guarantee the successful deterrence of an attack on the reactor building, its support structures and spent fuel storage from the air, land, and water by a dedicated, well-organized team of well-equipped terrorists. The licensee must be required to pass federally administered mock-attack drills designed to simulate today's threat as a condition of continued operation. Drills must be scheduled bi-annually, with a surprise element. [An Oct, 2000 NRC study found that 1/2 of all US commercial aircraft can penetrate 5' of concrete 45% of the time.]
2. Radwaste must be stored in a manner to ensure no risk of fire and attendant catastrophic contamination. Interim on-site storage: transfer all but recently unloaded fuel to hardened dry casks, returning the spent fuel pool to its original and safer design of low-density racks. Long term storage: transfer all waste to demonstrated scientifically-defensible federal repositories able to accommodate all current and projected waste in communities / states willing to host it, with all transportation issues resolved.
3. Age degradation of components must be assessed by federal, on-site, inspection of all safety components, with certification that such components meet design specifications.
4. Radioactive releases to the environment must be markedly reduced. Dose-effects must be re-calculated based upon our specific population profiles (versus current practice of using only a hypothetical healthy young adult male). Verification of compliance by replacing current radiation monitors with the latest, more sensitive technology which reports to the public in real-time; monitoring all egress routes, including the Torus Vent and multiple off-site locations based on population and meteorology. Containment structures must be upgraded as required to provide reliable containment of radioactive material in the event of a core-melt accident.
5. Marine life must be protected and reactors held to the same standards as other individuals and groups impacting aquatic ecology. Once-through cooling of inefficient nuclear technology, with thermal pollution of one billion gallons per day, must be replaced by the best technology available to prevent harm to marine life: cooling towers (see Licensed to Kill).
6. Emergency planning must be upgraded to prepare for a surprise attack or fast breaking event of significant radiological consequence - which would impact an area far beyond the current 10-mile radius. Updated independent studies of worst-case accident consequences must be done at the operator's expense, and "shadow evacuation" must be anticipated. The Emergency Planning Zone should be expanded to a 50-mile radius (already designated as the "ingestion zone") which more closely corresponds to federal studies estimating the consequences of a core melt (Pilgrim and Seabrook's peak first year fatality radius is at 20 miles and peak first year injury radius is at 65 miles). All local plans must be certified as having the full confidence of their local governments. Planning must be realistically and regularly tested.
7. Analysis of costs/benefits and alternatives must be independently performed to demonstrate that: the reactor can compete, without subsidies, with other energy sources; there is a need for its continued operation to meet our projected energy requirements.
8. The relicensing process - an application should not be considered until there is less than 4 years remaining on the current license so that the NRC may consider time-relevant facts, not just information from ten or twenty years before the re-licensing period begins.
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