Comments to Mass. DEP on ‘Clean’ Energy Standard

The following comments were sent to the Massachusetts Department of Environmental Protection (before the November 3, 2014 deadline) regarding MA DEP’S DRAFT DISCUSSION REGULATION for the CLEAN ENERGY STANDARD

Comments by:
Duxbury Nuclear Matters Committee
Pilgrim Coalition
Clean Water Action and co-signers
Jones River Watershed Association and Cape Cod Bay Watch 
David Agnew 
John Carlton-Foss

Duxbury Nuclear Matters Committee

The entire fuel chain must be looked at; the planet does not care where the carbon comes from

Nuclear reactors themselves are low carbon-emitters. But when the entire fuel chain is considered, as it should be, nuclear power is carbon-intensive, not to mention harmful to human health and the environment. In total, nuclear power is responsible for about six times the carbon emissions of wind power, and 2-3 times the carbon emissions of various types of solar power technologies.

Age related Degradation could lead to an accident. Pilgrim received its permit for construction in 1967. It was originally licensed for 40 years and began operations in 1972.  How many appliances do you know that are over 40 years old?  Pilgrim was re-licensed in 2012 to operate for an additional 20 years until 2032.

Pilgrim is old and has been headed in a downward spiral. NRC requires licensees to send information to NRC about certain “reportable events” that occur at their facility. Pilgrim had 20 event reports in 2013 – more than any other plant in the country. About half of the reports were due to equipment problems. The shutdowns and required event reports are clear signs that Entergy is not making the necessary investments in personnel (laid off workers) and maintenance that are needed to safely run this old reactor. Why? Because in Massachusetts’ deregulated market, Pilgrim cannot compete with cheaper sources of electricity, mainly natural gas. In 2014 NRC lowered Pilgrim’s performance to DEGRADED. It now joins 7 other U.S. plants ranked at the bottom.  Also, Pilgrim had two near misses in 2011. A “near miss” raises the risk of damage to the reactor core and thus to the safety of workers and the public.

Reactor Core Accident

A reactor core accident at Pilgrim has the potential to release more than twice the amount of Cesium-137 that was released at Chernobyl. The amount of Cs-137 released during the 1986 Chernobyl disaster was 2,403,000 curies.  The amount of Cs-137 in the core of Pilgrim’s reactor, now and until Pilgrim eventually shuts down, is 5,130,000 curies.

When Fukushima failed, three units exploded because the containments surrounding the core were too small to hold in a pressure build-up as the cores began to melt. Pilgrim’s containment shares with Fukushima this critical design flaw.

Natural events that could lead to an accident include: seismic, high wind, snow, ice and extreme cold, and extreme high temperature.

Seismic:  Senators Markey and Warren in a letter to NRC Chair Macfarlane, March 31, 2014, noted that, “The new seismic hazard was found to exceed the safe shutdown earthquake at the ground shaking frequencies that are most likely to threaten the equipment needed to safely shut down the reactor.”


Carbon Dioxide is not the only pollutant on the planet. It is a leading cause of climate change; but that does not mean that carbon dioxide is the only pollutant that matters to the health, safety and economy of our planet.

Radiation is toxic, persistent and a long-lasting pollutant released daily form nuclear reactors.

To conclude, there are alternatives to Pilgrim. We can reduce, and are reducing, our overall power needs by using electricity more efficiently.  Global warming and pollution are similarly being reduced by energy efficiency, and the use of clean renewable energy such as wind, hydro, solar and biomass.  These are the alternatives that will both keep the lights on, and create jobs for Massachusetts. We do not need to subsidize old, expensive, and risky reactors like Pilgrim.  We do not need to replace the poison from one source of energy with another, nuclear. I urge you not to include Pilgrim in the Commonwealth’s Clean Energy Standard.

Respectfully submitted,
Rebecca J. Chin, Co-Chair Duxbury Nuclear Advisory Committee

Pilgrim Coalition

Dear Mr. Space,
I am writing to comment on the the Department of Environmental Protection’s (DEP) proposed Clean Energy Standard for Massachusetts.

The DEP should be commended for its attempt to phase out fossil fuels and promote green energy sources, such as solar and wind. Nuclear energy, however, should not be included in the list of “green” energy sources. To include nuclear power as clean or green, would be counterproductive to the environmental movement, and is short-sighted. Nuclear reactors create radioactive waste, which can contaminates soil – and communities – for thousands of years. No other source of energy can pollute at such a deep and long-lasting level. Additionally, the process of creating nuclear fuel is carbon intensive. Lastly, communities exposed to radiation from nuclear plants face higher levels of disease than non-nuclear communities. Massachusetts would be misguided to include nuclear as a green energy source.

Thank you for strongly considering this perspective as you create new standards for our state.

Anna Baker
Chair, Pilgrim Coalition

John Carlton-Foss
The Massachusetts Department of Environmental Quality recently asked for public comments about whether nuclear energy is a form of clean energy. It is not. A proper accounting of the life cycle for nuclear fuel yields a determination more extreme than the MEOER determination for whether wood pellets constitute a form of “clean energy. It was determined that burning wood did not constitute using clean energy. Wood might be “renewable” but not “clean.” In similar fashion, nuclear energy is not clean because a large amount of fossil fuel energy goes in to the production of small amounts of nuclear fuel.

Although​ th​e​ resulting nuclear fuel does not burn fossil fuels during the time it is in a reactor, it definitely requires the burning of fossil fuels before and after the time it is in a reactor. Thus it is fraudulent and manipulative to assert that nuclear fuel is a “clean fuel” or a “green fuel.”

The following numbers and math will support this statement.

It takes about 11% to 12% of the energy available in nuclear fuel to capture it, refine it, and get it to the reactor. (References from refereed publications will be provided if you request.)

According to James Hansen: “Gen 2 reactors (all those operating in the U.S. today are Gen 2) burn [about] 0.6% of the energy in the original nuclear fuel, i.e., less than 1%. There is no debate about this.”

Doing the math, if 100 units of uranium energy ​are harvest​ed. 11 units​ of fossil fuel energy are used to produce those 100 units. This yields a net of 89 units.* ​Then​ only 0.6 % of th​e original​ 100 units that is usable, is actua​lly​ used. That is about as good as the old Ivory soap claim to be 99 and 44 one hundredths percent pure, except that in the Ivory case that 99.44% is the good stuff. For nuclear the remaining 99.4​​ % is wasted​ and is actually ​a liability for present and future generations. So, even ignoring the risk and cost to deal with spent nuclear fuel, that is a total of about 18 times as much fossil fuel to get a single unit of used nuclear electricity.​

Now having cut through the propaganda, we again see a confirmation of the laws of thermodynamics and entropy. You don’t get something for nothing; nuclear ​energy​ is no exception. If you like warfare you would say that nuclear ​fuel ​is still great for submarines because it enables them to stay underwater for more than a month at a time with a power source that enables creation of oxygen from water rather than consuming it. But the cost to produce that concentration of energy is a​ dramatic polluting of the environment far greater​ than ​the​ burning of fossil fuel. Multiplying forty to a hundred tons per year of long term nuclear waste by 40 years and counting and then by 100 U.S. reactors yields a staggering amount of nuclear waste, much of which still can melt if something goes wrong.

Clearly it is time to reduce this ever present danger, to retire all presently operating nuclear reactors powering public electricity generation. Gen 4 reactors may turn out better in terms of costs and liabilities, but we can address that technology on its own merits when it is actually more ready. It is disturbing that DEP would devote precious resources on​ a stakeholder assessment of this question for which the science and math are so clear. DEP would do well to make its own​ determination based on science, math, and evidence rather than​ inviting word manipulation by the nuclear industry and its supporters.”

David Agnew
Please do not confuse a cesspool with a swimming pool. Nuclear energy has never been clean energy. Show me a single nuclear reactor which has not contaminated it’s environment with radionuclides, some of the most toxic of all proven carcinogens. Is there a nuclear reactor in the nation which has demonstrated the ability to safely isolate it’s high-level waste for the million years that the EPA deems necessary? No. In fact there is no working PLAN to do so, and the federal government’s attempt to do so with weapons waste was successful for just 15 years before contaminating a nearby town with plutonium. Nuclear reactors emit dozens, if not hundreds, of radionuclides routinely, and after 7 decades we don’t know what to do with the waste. Is this what the state means by clean energy?

Hereafter, I focus on the Pilgrim Nuclear Power Station for 2 reasons: I’m most familiar with it (it’s about 30 miles upwind of my home); it’s the sole operating power reactor in Massachusetts. Pilgrim is a , a boiling water reactor, but pressurized water reactors are not much cleaner.

Pilgrim has been leaking tritium for about a dozen years. The operator and the state still don’t know where the leak originates. Tritium is one of the most dangerous radionuclides since: it cannot be removed from water; it can be absorbed through the skin or breathed in; once in the body the alpha-emitter is especially carcinogenic; the body does not distinguish between tritiated water and normal water, so the isotope becomes a part of cells. Is this what the state means by clean energy?

Early in it’s operation, Pilgrim had a batch of ‘failed fuel’ which resulted in replacing a roof due to spewed resin, and repaving a parking lot. Two peer-reviewed studies found a correlation between (considerably) increased cancer rates and proximity to the reactor. Is this what the state means by clean energy?

Pilgrim requires uranium fuel. Our nation is littered with hundreds of small mountains of uranium mill tailings, which will remain carcinogenic for billions of years, and which freely blow about in the wind. Is this what the state means by clean energy?

Pilgrim is a design which is virtually certain to fail to contain a severe accident. Nine percent of such designs have already suffered core melt accidents with breach of containment, as was predicted in 1972. And Pilgrim is older than the average age of the Fukushima reactors when that disaster befell us. Well over three years after those meltdowns, Pilgrim’s sister-designs spew 3,000 tons of radioactive water into the environment daily. Pilgrim’s spent fuel is not inside even that shoddy containment, and a fire in the radwaste pool could contaminate hundreds of miles downwind for centuries. Is this what the state means by clean energy?

Pilgrim also releases chemicals which are introduced into it’s water waste stream as corrosion inhibitors and algae killers. The 510 million gallons that it dumps into Cape Cod Bay, having killed all life in that water, is about 30 degrees warmer than the water that was taken from the Commonwealth. Is this what the state means by clean energy?

Perhaps DEP is looking only at carbon emissions. The Sovacool survey of 103 studies of life-cycle carbon emissions from nuclear reactors found average life cycle emission of 66 g CO2e/kWh. Nuclear emits considerably less carbon than than coal, oil, or even natural gas. But that does not make it clean. Electrical generation by photovoltaics, wind, hydro, geothermal, wave, ocean-swell and biomass are all cleaner than nuclear, and most of these technologies are becoming cheaper with each passing month. Canada has plenty of hydroelectric capacity to provide.

Finally, Mass. DEP has given Pilgrim Nuclear administrative extensions to it’s cooling water intake structure permit, which expired 18 years ago. I believe that permit should be properly reviewed before providing yet another dispensation to this dangerous, polluting electrical generating station. As Albert Einstein said, ““Nuclear power is a hell of a way to boil water.”

David and Mary Agnew

Tagged . Bookmark the permalink.

Comments are closed.