Markey, Warren, and Keating Write to Holtec's Singh on Evaporation
Federal Delegation Asks for Holtec's Answers in Writing by May 31st
(WASHINGTON, D.C.) — United States Senators Edward J. Markey and Elizabeth Warren and United States Representative William R. Keating wrote a letter to Holtec International President and CEO Dr. Kris Singh, dated April 30th, 2024, urging Holtec — the company which owns and is decommissioning Pilgrim Nuclear Power Station in Plymouth — to honor the commitments to transparency and community consent it made at Sen. Markey and Rep. Keating’s May 2022 Congressional field hearing in Plymouth.
“Scientists, public health officials, elected leaders, and residents of the communities surrounding the Pilgrim Nuclear Power Station have raised concerns that Holtec’s plan for dispositioning radioactive wastewater stored at the plant poses a threat to the health and safety of the public and the environment. That plan, which initially called for a discharge of wastewater into Cape Cod Bay, now apparently includes dispositioning through evaporation,” wrote Sens. Markey and Warren and Rep. Keating.
“In light of the harm that either form of wastewater release may have on public health, ecosystems, and the blue economy, we urge Holtec to heed those concerns and to develop a transparent, community involved approach for dispositioning the wastewater, especially as legitimate public concerns over wastewater evaporation and airborne releases have heightened in recent months,” the legislators wrote.
In addition, the Federal delegation requested the answers from Holtec, in writing, to 13 questions relating to evaporative release of the wastewater in question.
(Pilgrim Nuclear Power Station from Gurnet Point; photo credit — J. Benjamin Cronin.)
Sens. Markey and Warren and Rep. Keating pointedly noted Dr. Singh’s own statements at the May 6th, 2022, Congressional field hearing held by Sen. Markey and Rep. Keating in Plymouth.
“During the 2022 field hearing held by the U.S. Senate Environment and Public Works Subcommittee on Clean Air, Climate, and Nuclear Safety in Plymouth, Massachusetts, you committed Holtec to not discharging Pilgrim’s wastewater into Cape Cod Bay without the consent of local, state, and federal stakeholders,” they wrote.
The delegation also noted the extremely significant legal fact of the Settlement Agreement with the Commonwealth that Holtec signed in June of 2020.
“That commitment [at the May 6th, 2022, Congressional Field Hearing] expanded on Holtec’s earlier promises in the 2020 Pilgrim decommissioning settlement agreement with the Commonwealth of Massachusetts to (1) ‘comply with all applicable environmental and human-health based standards and regulations of the Commonwealth’ and (2) to not assert that any commitment made under the settlement agreement ‘is invalid under federal law or the U.S. Constitution.’”1
The legislators went on to note that on July 24th, 2024, the Massachusetts Department of Environmental Protection (MassDEP) issued a tentative denial of Holtec’s application to modify its existing NPDES (National Pollutant Discharge Elimination System) Permit to allow discharge of the radioactively- and chemically-contaminated wastewater in question, on the grounds that such a discharge would violate the Massachusetts Ocean Sanctuaries Act, which was among the numerous laws that Holtec agreed to follow in the Settlement Agreement.2
“With the final NPDES permit decision pending, Holtec has informed the Nuclear Decommissioning Citizens Advisory Panel (NDCAP) that Pilgrim’s wastewater is being heated in the winter months with submerged electric heaters to increase the plant’s ambient temperature to both promote worker comfort and expedite the drying of plant components. While those are both laudable goals, a consequence of the heating — confirmed by Holtec — is an increased rate of wastewater evaporation above the pace at which it occurs naturally. According to Holtec’s initial estimates, in 2021, Pilgrim had 1.1 million gallons of wastewater. Now, Holtec reports only 880,000 gallons remain. Despite this significant reduction, Holtec has yet to provide an estimate of the amount of wastewater evaporation associated with the heaters versus that which occurs naturally,” wrote Sens. Markey and Warren and Rep. Keating.
The Federal delegation underlined the significant risks of evaporative release of the wastewater.
“There is no question that evaporating wastewater from Pilgrim poses potential health and environmental risks. During the 2022 U.S. Senate field hearing, you identified evaporation with electric heaters as an alternative to discharging the wastewater into Cape Cod Bay. But you also acknowledged that evaporation would cause environmental damage. After all, evaporated wastewater released into the air will not permanently remain in the sky; eventually it will return to sensitive areas such as Plymouth’s residential neighborhoods and Cape Cod Bay. Public health organizations—including the Greater Boston Physicians for Social Responsibility and the Town of Plymouth’s Board of Health—scientists, local officials, and community members, have all raised concerns about the environmental risks of airborne releases of wastewater through evaporation and confirmed their potential risks to human health and marine ecosystems,” wrote Sens. Markey and Warren and Rep. Keating.
“Given these public health concerns, the Massachusetts Medical Society has urged that proactive steps be taken to assess the safety of airborne releases. These include evaluating the health effects of radioactive releases; collecting biometric data; and putting in place radiation monitors before any releases. Holtec’s response to repeated concerns about airborne releases has been to point to historical releases from Pilgrim as evidence the practice is safe. But the mere fact of a historical release does nothing to prove that such a release was safe or that future releases will be safe,” they continued.
Senators Markey and Warren and Representative Keating asked Dr. Singh and Holtec 13 specific questions, for which they requested answers by May 31st. Some of the questions include:
No. 1: “Will Holtec commit to engaging with community stakeholders prior to any action on dispositioning wastewater, forgoing any current plans for discharge into Cape Cod Bay or intentional evaporation?”
No. 2: “Beyond the stated benefits for heating the plant and drying components, is Holtec also heating and evaporating the water for the purpose of reducing the remaining water volumes?”
No. 9: “Before operationalizing the submersion electric heaters, did Holtec conduct a study or analysis to determine:
a. Potential environmental and public health risks for the community and Cape Cod Bay from increasing the rate of evaporation and associated discharge considering the specific radionuclides and non-radiological pollutants presents in the current water?
b. Where the evaporated water would migrate following the release?
c. The costs of heating the plant with the submersion heaters relative to the costs of alternative heating strategies and the estimated costs associated with the risks to the environment or public health due to evaporative discharges of the wastewater?
If so, please share the results of that study or analysis. If no such study or analysis was completed, why not?”
No. 11: “What specific measures is Holtec taking to ensure the safety of plant workers exposed to the evaporated water, including through the use of safety equipment and monitoring?”
No. 12: “What specific measures, if any, is Holtec taking to protect the surrounding neighborhoods and wider community from increased exposure to evaporated wastewater associated with the submersion heaters?”
No. 13: “Are you actively taking or considering any steps (beyond the activation of electronic submersion heaters) that would hasten the evaporation rate? If so, please identify them.”
The legislators closed by urging Holtec to demonstrate the transparency which it so frequently professes.
“Through the decommissioning process, Holtec routinely celebrates its transparency and community engagement efforts. With those values in mind, we urge Holtec to meaningfully engage with and center local stakeholders and experts to develop a community-driven approach for dispositioning Pilgrim’s wastewater in a manner that respects input from residents, state and local officials, marine scientists, and public health experts, upholds prior commitments, and complies with the law,” wrote Sens. Markey and Warren and Rep. Keating.
The full letter can be read here:
https://www.markey.senate.gov/news/press-releases/markey-warren-keating-urge-holtec-to-heed-community-concerns-over-evaporation-and-discharge-of-radioactive-wastewater-from-nuclear-plant
See Massachusetts-Holtec Settlement Agreement, III (10)(l) and VI (48).
M.G.L. Ch. 132A Secs. 12A through 16J and Sec. 18; the tentative denial from MassDEP can be found here: https://www.mass.gov/doc/tentative-determination-to-deny-holtecs-surface-water-discharge-permit-modification-request/download.