Urgent Action on unreliable Mark I and Mark II containments: Request Commissioners to support the installation of filtered vents

Chairwoman Allison M. Macfarlane

Commissioner Kristine L. Svinicki

Commissioner William D. Magwood, IV

Commissioner William C. Ostendorf

Commissioner George Apostolakis,

United States Nuclear Regulatory Commission

Washington, DC 20555-0001

By email: Secretary Annette Vietti-Cook NRCExecSec@nrc.gov

I write to you in an appeal to promote the protection of the public health and safety in communities surrounding the thirty-one (31) General Electric Mark I and Mark II Boiling Water Reactors similar to those that exploded and melted down at Fukushima Daiichi, Japan on March 11, 2011.

In the coming weeks, the Commission will be voting on whether or not to affirm the NRC staff’s professional judgment (SECY 2012-0157) to require by Order that the operators of these vulnerable reactors install on their containment structures a severe accident capable hardened vent with a high-capacity radiation filter.

I urge you to support the installation of the filtered vent on all Mark I and Mark II reactor containments.

Thank you

Entergy Watch: Vermont Yankee argues it is simply "above the law" in the State of Vermont

As listed in Beyond Nuclear's "Freeze Our Fukushimas" pamphlet, Entergy Nuclear's Vermont Yankee atomic reactor is a GE BWR Mark I, just like Fukushima Daiichi Units 1-4.

Entergy Nuclear's latest argument before the State of Vermont Public Service Board -- regarding Vermont Yankee atomic reactor's ongoing operation -- beggars belief. Entergy argues it is above State of Vermont law, even though it agreed to abide by State of Vermont law a decade ago. As reported by the Associated Press, Entergy's lawyers and hired experts are now arguing that because radiological safety is exclusively U.S. Nuclear Regulatory Commission jurisdiction by settled law, the State of Vermont must simply get out of the way -- even though that same U.S. Supreme Court decision in 1983 in the Pacific Gas & Electric case recognized that states retained authority over most other aspects of nucelar power besides radiological safety.

The article reported: '...At Monday's hearing on Entergy's request for a new state permit, company lawyers sought to take that idea of federal pre-emption and run with it, telling the board that it should avoid considering not just the economic impact of a possible nuclear accident, but that the board also should not consider the impact that hosting a nuclear plant might be having on the state's tourism industry.

Burlington lawyer Robert Hemley told the three-member board the only reason the presence of a nuclear plant might harm tourism is if the public develops fears about nuclear safety — a subject Vermont is barred from considering.

"Discussion about tourism is a pre-empted area. ... We feel the entire area is off-limits for this board," Hemley said.

Entergy's push for pre-emption appeared to run counter to an agreement it entered with the state when it bought Vermont Yankee in 2002 from the group of New England utilities that had owned it previously.

Under that memorandum of understanding, Entergy and the state agreed "to waive any claim each may have that federal law pre-empts the jurisdiction of the board" to decide Vermont Yankee's post-2012 future.

Entergy lawyer Sanford Weisburst argued later that the board would be hard-pressed to find a plausible, non-safety reason to deny Vermont Yankee a new permit...'

Entergy Nuclear has named the three commissioners of Vermont's Public Service Board, as well as Governor Peter Shumlin and Attorney General William Sorrell -- by name -- in its lawsuits seeking to overturn Vermont state laws, to which it had previously committed to abide, which now call for Vermont Yankee's permanent shutdown.

The Vermont Yankee Decommissioning Alliance and Citizens Awareness Network have called for grassroots comments to bolster the Vermont Public Service Board's resolve against issuing a renewed Certificate of Public Good to Entergy. Without it, Vermont Yankee's continued operation is illegal under State of Vermont law.

Vermont Digger has reported on this story. Frances Crowe, a nonagenarian member of the Shut It Down! Affinity Group, responded to the article by stating: "Every day that plant operates it is endangering the health and safety
of the people in Vermont, New Hampshire and Massachusetts. Shut it down and start the clean up and put the spent fuel rods in dry caskets and bury them deep underground." Shut It Down! has has organized some two-dozen civil resistance direct actions protesting against Vermont Yankee. When asked by AP on March 22, 2012 -- amidst 1,500 protestors gathered on the first day of VY's NRC-rubberstamped 20-year license extension -- how many times she had been arrested protesting VY, Frances Crowe answered "Not enough!"

Entergy admits its faulty equipment caused 35 minute Super Bowl "lights out"

As listed in Beyond Nuclear's "Freeze Our Fukushimas" pamphlet, Entergy owns the GE BWR Mark Is -- identical in design to Fukushima Daiichi 1-4 -- at Vermont Yankee, Pilgrim near Boston, and FitzPatrick in Upstate NY. Entergy also operates the Cooper Mark I on behalf of Nebraska Public Power District. Of course, it was a Station Black Out that led to the triple meltdowns at Fukushima Daiichi...

First, Entergy denied any responsibility, instead pointing fingers at the Superdome. Then, Entergy agreed to the need for an investigation. And now, five days later, Entergy admits that its faulty equipment was the culprit that plunged the Super Bowl -- and 75,000 in-stadium fans -- into darkness for 35 long minutes. 108.4 million others watched the darkness on television.

It's not unlike that time in Vermont, when Entergy officials testified, under oath, to state officials, that no underground piping existed at Vermont Yankee which could possibly be conducting radioactive materials. Only to have to admit a short time later, that those very pipes which it had denied even existed, were leaking tritium and other radioactive contaminants into soil, groundwater, and the Connecticut River.

Or that time, when it took over at the Palisades atomic reactor in Michigan, when it promised it would replace the corroded reactor lid and degraded steam generators, as well as deal with the worst embrittled reactor pressure vessel in the U.S. -- but never did.

The Chicago Tribune has reported on Entergy's mea culpa for causing the Super Bowl lights out. USA Today reports that Entergy stocks took a hit upon the admission. CBS Sports has reported that documents revealed concerns about electrical failures in the months leading up to the game. More.

Entergy Watch: Pilgrim Coalition urges NRC to require Mark I atomic reactor to shutdown during historic winter storm

Beyond Nuclear's "Freeze Our Fukushimas" pamphlet lists the 31 GE BWR Mark Is and IIs in the U.S. Entergy Nuclear's Pilgrim atomic reactor near Boston is a Mark I, identical in design to Fukushima Daiichi Units 1-4.

As reported by Wicked Local Plymouth, in the lead up to what is being reported as an historic winter storm about to hit the Northeast, Pilgrim Coalition and Cape Cod Bay Watch are calling on the U.S. Nuclear Regulatory Commission (NRC) to order Entergy's Pilgrim atomic reactor shutdown, "arguing that a prolonged power outage, flooding, high winds, and snow and ice could cause several serious problems at Pilgrim."

However, as of 2:30 PM, NRC's "Current Power Reactor Status" report shows that Pilgrim is operating at 83% power. All other reactors in the Northeast are also operating, either at, or very close to, 100% power levels.

In a press release, Pilgrim Coalition spokespeople stated:

“This is predicted to be a historic storm with severe consequences,” said Pine DuBois, Executive Director of Jones River Watershed Association. “Winds are supposed to pick up Friday night during high tide and continue through the even higher tide Saturday morning. Near hurricane gusts will be out of the east, hitting Pilgrim head-­‐on. At other times during high winds, Pilgrim’s water intake pumps have failed.”

“Entergy could not keep the lights on during the Super Bowl -­‐ can we be sure they’ll provide enough power to Pilgrim during the storm?” duBois added.

According to Karen Vale, Campaign Manager at Cape Cod Bay Watch, “This historic storm emphasizes that rising sea levels and frequent, more severe storms make Pilgrim’s continued operations increasing risky. We hope that the NRC will close Pilgrim until the threat of the storm passes.”

As Beyond Nuclear's Freeze Our Fukushimas campaign has warned, no matter the cause (earthquake and tsunami, or historic winter storm at high tide), any prolonged loss of power to atomic reactors can lead to meltdown and catastrophic radioactivity releases. Entergy's Pilgrim is an identical twin design to Fukushima Daiichi Units 1 to 4, a General Electric Mark I Boiling Water Reactor.

Update on February 9, 2013 by admin

Reuters has reported that Pilgrim did automatically shutdown after a loss of offsite power last night. AP has reported that Pilgrim lost offsite power at 9:15 PM last night (as did several hundred thousands Massachusetts residents) due to the storm, and has been running cooling and safety systems with emergency back up generators since. AP has also reported that Seabrook, NH, "hometown" to a full-scale atomic reactor, was blanketed with 26 inches of snow. Despite the risk of power outages, NRC's Power Reactor Status Report showed that, as of yesterday (the most recent report available), all reactors in the Northeast were still operating at or near full power.

Even when reactors automatically shutdown, as happened last night at Pilgrim, their hot core still needs to be actively cooled for days, or a meltdown can occur. If primary offsite power is lost, but emergency diesel generators function as designed, cooling to the reactor core can be maintained. But, as revealed by U.S. Congressman Ed Markey (D-MA), there is a long history of diesels not working when called upon in the U.S.

On 3/11/11, when the 9.0 earthquake struck off the northeast coast of Japan, the three reactors operating at Fukushima Daiichi automatically shutdown. But the quake had also destroyed primary offsite power, leaving the emergency backup diesel generators as a last line of defense to cool the still-hot reactor cores. An hour later, the 45-foot tall tsunami also destroyed the diesel generators, plunging reactors there onto the inescapable path towards meltdown. (There is strong evidence that the quake alone, prior to the tsunami, had plunged Unit 1 into meltdown mode.)

Thus, shutting reactors down ahead of predicted natural disasters, such as this current blizzard or the recent Hurrican Sandy, would allow the core to cool, decreasing the risks of overheating and meltdown if offsite power is lost and emergency diesels don't work. However, the nuclear power industry and NRC rarely take such a basic safety precaution.

Update on February 11, 2013 by admin

Reuters has reported that on Sunday, off-site electricity was restored to Pilgrim. The blizzard knocked out Pilgrim's three connections to the off-site electrical grid, but emergency diesel generators continued supplying the power needed to run safety and cooling systems on the reactor, the NRC has reported.

However, not mentioned by news media coverage, and little known, is the fact that NRC does not require emergency back up power on the high-level radioactive waste storage pools. Under NRC's lax regulations, pools can rely entirely, and exclusively, on the electrical grid for the running of cooling water circulation pumps. Thus, when the grid goes down, the pool begins to heat up. After enough hours or days without water circulation, the pool can begin to boil. If the evaporation goes on long enough, the pool water can boil away the water cover over the stored irradiated fuel. If the high-level radioactive waste is exposed to air, it can quickly catch fire. As pools are not required to be located within primary radiological containment structures, either (see graphic, above left), this means that catastrophic radioactivity releases into the environment could result from a pool fire, as Alvarez et al. warned in Jan. 2003, in the aftermath of the 9/11 attacks.

Pilgrim's pool contains all the high-level radioactive waste ever generated there. None has yet been moved to dry cask storage, a very rare exception in the U.S. nuclear power industry. After more than four decades of exclusively pool storage, however, Entergy has applied to NRC for permission to begin moving some fraction of the pool's inventory into dry casks.

Entergy Watch: New CEO admits times are tough at Entergy's merchant reactors

As reported by Reuters, Entergy Nuclear's new CEO and Chairman of the Board, Leo P. Denault (pictured left), has admitted "its merchant nuclear power plants are in 'challenging economic situations,'" and "'[n]ear-term power prices are challenging for some merchant nuclear generating units in certain competitive markets.'" The admission came during a fourth-quarter earnings call.

The article continues:

"He said some plants are in the more challenging economic situations for a variety of reasons, including 'the market for both energy and capacity, their size, their contracting positions and the investment required to maintain the safety and integrity of the plants.' (emphasis added)

He would not name the plants but said, 'There are years when certain plants' cash flows can be negative at today's forward price curve.'"

UBS has concluded that the financial pressures could force Entergy to close Vermont Yankee, FitzPatrick in New York, and even Pilgrim near Boston yet this year. Entergy owns and operates those three GE BWR Mark Is, identical in design to Fukushima Daiichi Units 1-4. Entergy also operates the Cooper Mark I in Nebraska, owned by Nebraska Public Power District. A full listing of GE BWR Mark Is and IIs across the U.S. can be found in Beyond Nuclear's "Freeze Our Fukushimas" pamphlet.

A Dominion spokesman admitted last October that the high cost of making needed safety repairs was a major factor in the nuclear utility's decision to close Kewaunee in Wisconsin by mid-2013. It was the first announced closure of an atomic reactor in the U.S. in 15 years.