Anonymous Whistleblower Raises Worker Safety Concerns at Pilgrim

May 14th Letter Comes as a Follow-Up to an August, 2023, Whistleblower Letter

(PLYMOUTH) — Another anonymous whistleblower letter regarding conditions at Pilgrim Nuclear Power Station in Plymouth, and the conduct of Holtec, the company which owns and is decommissioning the plant, was sent last month to the Massachusetts Department of Public Health’s Radiation Control Program Director Jack Priest, and to the Cape Cod Downwinders environmental and nuclear safety organization.

The letter, which makes serious allegations regarding worker safety, was sent on May 14th, and because Diane Turco, of Harwich, the Director of Cape Cod Downwinders, was traveling, she did not open this third [CORRECTION: I initially described the May 14th letter as the second whistleblower letter; it is the third. I regret the error] whistleblower letter until June 6th, after which she shared it with me (Note: I work with members of the Cape Cod Downwinders in the Save Our Bay MA coalition, including Mrs. Turco).

The letter’s other recipient, Mr. Priest, of the Department of Public Health’s Radiation Control Program, is a member of the Massachusetts Nuclear Decommissioning Citizens Advisory Panel (NDCAP). Despite receipt of the letter on the 14th, he neither raised its contents nor noted its existence at the May 20th NDCAP meeting.¹

“I am writing this letter as a followup to my letter dated August-2023, regarding issues of trust with Pilgrim Station Management's stated intent to safely dispose of radioactively contaminated water, and to safely decommission the remainder of the facility,” wrote the anonymous whistleblower (I covered the earlier whistleblower letter last August.)

Longtime observers of the nuclear industry have expressed the view that the whistleblower would likely be permanently blacklisted from any future employment in the industry if their name became known.

(Pilgrim Nuclear Power Station, in Manomet, taken from The Gurnet, October, 2023; credit — Ben Cronin.)

“I still believe that Pilgrim's management was somewhat 'misleading' in their assertion that the evaporative heaters installed in the Spent Fuel Pool (SFP) were for the purpose of providing a source of radiant heat, for the 'benefit' of plant workers during cold weather months. This belief, and recent incidents at the plant involving the radioactive exposures of plant workers, suggest that Pilgrim Management's commitment to worker safety and well-being may not be as 'sincere' as they claim,” the anonymous author of the letter wrote.

“Specifically, plant personnel working on the Refuel Floor who are exposed to the airborne contamination resulting from the evaporative water 'disposal' process, have repeatedly asked the HOLTEC Radiation Protection (RP) Manager and Supervisor, how much internal radiation exposure they are receiving. Radiation Protection (RP) Technicians assigned to the Refuel Floor, have stated that the RP Technical Staff that were responsible for safely planning work and determining the radiation exposure of Plant workers, had their positions eliminated due to cost-cutting efforts. Consequently, the RP Technicians stated that no one in the RP Department knows how to determine airborne radioactivity level and the resultant exposure to workers, nor do they have the experience necessary to devise work plans for mitigating the radiation exposures received by workers,” the author alleged.

“Furthermore, RP Technicians stated that they do not even possess the detection and measurement equipment necessary to determine airborne radioactivity levels on the Refuel Floor. However, Plant Managements on-going lack of commitment to worker safety is best exemplified by a recent exposure event that occurred on the Refuel Floor involving an RP Technician. Work controls intended to minimize worker radiation exposure were revised by the HOLTEC RP Supervisor, presumably, for being too much of a hindrance to the conduct/progress of work,” the author continued.

“As a result of the relaxed work controls, an RP Technician was exposed to airborne radioactive contamination, and received a burden of radioactive material in his body. The amount of radioactive material in his body has been causing the RP Technician to alarm radiation detection monitors at the Plant access/egress point for the past several weeks. Thus, through no fault of his own, this RP Technician is unavailable to perform work inside the plant, and so, is essentially 'unemployable' in the nuclear power field,” alleged the whistleblower.

“An 'investigation' of cause of the exposure incident was conducted by the HOLTEC RP Supervisor. However, this HOLTEC RP Supervisor was the person who relaxed the work controls that were specified in the original draft of the work plan. Not surprisingly, the HOLTEC RP Supervisor lay 'blame' for the incident on the Contractor RP Planner who developed the original work control plan. The Contractor RP Planner protested this conclusion, citing the work controls that she had prescribed that would have prevented the incident from occurring. The Contractor RP Planner eventually resigned under duress,” the author alleged.

“Following the resignation of the Contractor RP Planner, several individuals approached the exposed RP Technician, and alerted him that his position at the plant may also be 'at risk'. The implication is that anyone involved with, or who has detailed knowledge of the incident, may be 'discharged' prior to the incident being reviewed by either auditors or regulators. This would leave HOLTEC RP Management to dictate the narrative of the exposure event. This post-event 'tactic' was successfully employed to deflect, reassign, or otherwise 'disguise' the cause or blame for a litany of other, radiological and non-radiological safety events dating back to the time HOLTEC acquired Pilgrim Station,” the author alleged.

These safety events included “Electrical Safety Events such as when the Refuel Bridge severed its own 480V power cable, then tore the same cable out of its power box several weeks later, almost electrocuting several workers. (incidents captured on video camera),” alleged the whistleblower, as well as “Rigging Events such as a lifting rig swinging and almost knocking the Refuel Floor 'Sky Box' office off its pedestal, and into the Dryer-Separator Pit, and when the Refuel Floor Overhead Crane almost knocked a worker off the top of a cask. (incidents captured on video camera and anonymously distributed site-wide).”

In addition, “the Thermex Fire Event, which was initially reported to the USNRC and Plymouth Fire Department as a 'heat event', and subsequently reclassified as a 'fire' after an investigation by the USNRC. (incident captured in photographs),” the whistleblower added.

The whistleblower also shared their thoughts “regarding the recent radiation exposure event,” stating that “although Pilgrim Station Management is not required to provide notification of such events to the USNRC, the USNRC is expected to review incidents involving 'unintended' exposure of personnel to radioactive material upon their next routine inspection. Thus, given the USNRC's comments and critique of Pilgrim Station Management's commitment to the safe conduct of work thus far in the decommissioning process, they can be expected to be particularly critical of Pilgrim Management's cause analysis of this radiation exposure event.”

Given the allegations, the whistleblower told the recipients of the letter that “your attention to this personnel radiation exposure investigation matter is appreciated.”

I asked Patrick O’Brien, Director of Government Affairs and Communications for Holtec International, whether he wished to offer any comment upon the letter.

“A plant individual received internal radiation exposure that was promptly reported and entered into the facility Corrective Action Program.  The individual was exposed to airborne contamination when they inadvertently contacted a contaminated work surface, which was the reactor vessel head when they were performing surveys of the head and inadvertently contacted it causing airborne particles. The individual was appropriately monitored at all times for their personal exposure.  They alarmed a portal monitor when exiting the radiologically controlled area of the reactor building. The dose received by the individual did not approach allowed exposure levels established to ensure worker protection,” said Mr. O’Brien.

“Plant investigation into the cause of the event is on-going[,] including analysis independent of the supervisor involved in the activity.  As with any activity at the facility that does not go as planned, corrective actions are expected to address both any identified worker performance and program related deficiencies.  With the exception of the above personnel contamination event, these assertions in the letter do not provide any new information or concerns that have not been fully addressed previously,” Mr. O’Brien said. 

As noted above, Mr. Priest never noted the letter’s existence or his receipt of it at the May 20th NDCAP meeting in Plymouth. I wrote to him, as one of the two recipients of the letter, asking if he had any comment upon it. While Mr. Priest did not reply directly, I did hear from the Department of Public Health, an official of which told me that the letter had been referred to the Nuclear Regulatory Commission (NRC) as the appropriate regulatory agency.

I wrote to the NRC, asking if it had any comment upon the anonymous May 14th letter. 

“We are aware of the recent anonymous letter and we are reviewing it,” Neil Sheehan, NRC Public Affairs Officer for NRC Region I (Ed. – the Northeast, from Maine to Washington, D.C.), told The Plymouth County Observer. 

 Since the incidents alleged are still being reviewed by the NRC, they have not been covered in any existing NRC report or notification, Mr. Sheehan confirmed. “We would cover any findings associated with the issue in a forthcoming inspection report,” he said.

Diane Turco, the Director of Cape Cod Downwinders, said that the letter raised serious concerns.

“Obviously, this person is an insider and risking their livelihood by sending two anonymous letters to the state and CDW [Cape Cod Downwinders] to expose negligence by Holtec regarding worker and public health and safety. The Nuclear Regulatory Commission is complicit with Holtec as worker concerns are brushed under the rug,” said Mrs. Turco.

 “The lack of transparency from Holtec and the state to the public is disconcerting. In order to regain public trust, the state must now initiate an independent investigation into the serious whistleblower allegations,” she said.

 Meanwhile, it was revealed at the last NDCAP meeting on May 20th at Plymouth Town Hall that Holtec had, in a letter to the US EPA dated April 23rd, 2024, revised its application to modify its permit which it submitted on March 31st, 2023, and which MassDEP tentatively denied on July 24th, 2023 (MassDEP has yet to issue its final determination). Holtec has now changed its characterization of the proposed discharge of the radioactively and chemically contaminated wastewater, asserting that it is not “new”, as Holtec had previously characterized the proposed discharge, but is rather “existing”.

I hope to show in a future article why the proposed discharge would in fact be “new” — as Holtec originally and correctly characterized it — rather than “existing”, for the simple reason that in order to be “existing”, it would have to actually exist, which it does not and has not. Doing so, however, will require a full essay, so I will leave the subject for an upcoming article.

In addition, Holtec’s evaporation of the contaminated industrial wastewater in question continues; given prevailing wind directions, some portion of this will necessarily settle into Cape Cod Bay. There is therefore good reason to believe that this violates both the Massachusetts Ocean Sanctuaries Act and the Massachusetts Endangered Species Act, both of which prohibit the discharge of industrial waste into Cape Cod Bay. This, too, I hope to discuss in greater detail in the future.

The next NDCAP meeting will be on July 22nd, 2024, at Plymouth Town Hall, at 6:30 p.m.

1. Though Mr. Priest did not raise the issue of the whistleblower letter — relating in significant part to allegations of grave radiological safety failures at Pilgrim — at the May 20th NDCAP meeting, he did take time at that meeting to minimize the threat posed by Holtec’s present course of evaporating the chemically and radioactively contaminated wastewater in question:

“We’re spending a lot of time, and I think we could be scaring members of the general public, with discussions on numbers that are extremely small, less than a thousand times the regulatory limit,” Mr. Priest, who prior to working for the Commonwealth worked in the nuclear industry, said (starting at approximately minute 59:35 of the meeting).

Notably, Mr. Priest’s sanguine view of evaporation is not shared by scholars of public health and physicians, such as Petros Koutrakis, Ph.D., Professor of Environmental Sciences at the T.H Chan School of Public Health at Harvard University, and Brita Lundberg, M.D., of the Greater Boston Physicians for Social Responsibility, who have expressed their grave and continuing concerns around evaporation.

Indeed, such a sanguine view of evaporation contrasts markedly with Mr. Priest’s own prior statements on the subject. At the January 31st, 2022, NDCAP meeting, as reported by David R. Smith of The Old Colony Memorial at the time, Mr. Priest said that both discharging the wastewater into the bay or evaporating it were bad options. From Smith’s article: 

“‘The effect (of evaporation) might be higher than putting it into the bay,’ NDCAP member Jack Priest said. ‘Both are lousy choices.’”

See David R. Smith, “No decision reached on wastewater disposal at shuttered Pilgrim Nuclear Power Station,” The Old Colony Memorial, Feb. 1st, 2022.