My Public Comment for Mass. NDCAP

Including a Reminder of Statements by Holtec CEO Dr. Kris Singh at the US Senate Hearing in Plymouth in May, 2022

[Dear Readers: tonight is the meeting of the Massachusetts Nuclear Decommissioning Citizens Advisory Panel, at 6:30 p.m. in Plymouth Town Hall. We covered a recent letter by Sens. Markey and Warren and Rep. Keating to Holtec, the corporation which owns and is decommissioning Pilgrim Nuclear Power Station in Plymouth, regarding its apparent plan to dispose of the radioactively- and chemically-contaminated wastewater contained at the plant using evaporation, rather than discharging it into the bay, or shipping it — at slightly greater expense to Holtec than otherwise — to a licensed waste storage facility (discharge into the bay was tentatively denied by the Massachusetts Dept. of Environmental Protection in July, 2023).

It’s important to note that the environmental health effects of evaporation have been decried by figures such as Dr. Petros Koutrakis, Ph.D., Professor of Environmental Sciences at the Harvard T.H Chan School of Public Health, and Dr. Brita Lundberg, M.D., of the Greater Boston Physicians for Social Responsibility.

I submitted the following remarks as public comment. Thanks, as always, for reading.]

Massachusetts Nuclear Decommissioning Citizens Advisory Panel – Plymouth Town Hall — May 20, 2024

Chair Lampert and Vice Chair Gatslick, Members of NDCAP:

Thank you for hearing my comments this evening. My name is Dr. Benjamin Cronin, I'm a member of the Town of Duxbury Nuclear Advisory Committee, but I speak tonight only for myself as an individual citizen.

(Plymouth Town Hall. Credit — Ben Cronin.)

I just wanted to note for the record some of the comments made by Holtec President and CEO Dr. Kris Singh at the May 6th, 2022, hearing of the Subcommittee on Clean Air, Climate, and Nuclear Safety of the U.S. Senate Committee on Environment and Public Works in Plymouth, italicized below, with emphases added in bold by me (the transcript may be found here:

https://www.epw.senate.gov/public/_cache/files/7/d/7df3f36e-4441-4fbb-b4b7-17c486e1b8b0/E79494CD3D5B107B30617B24FFF09EF6.field-spw-05062022.pdf ):

a) Dr. Singh to Sen. Markey, p. 92 of the field hearing transcript:  

"But we would not discharge it [i.e., the contaminated wastewater] until we have consent from our stakeholders. We would not discharge it because we do not want to upset anyone."

     b) Markey-Singh exchange, pp. 93-94: 

"Senator Markey. So I think for everyone here today you have just said something very important to them, which is that you said, you will not discharge the water unless you have the consent of the stakeholders. Is that what you just said, Doctor? 

Dr. Singh. Yes, I said the stakeholders, and then the State, you know, the State, the NRC, the people who we have, we routinely, with EPA, we consult with to do anything. Because this item has become one of political, taken a political dimension, no, we will not discharge without [indiscernible]. 

Senator Markey. So when you say stakeholders, do you mean the State of Massachusetts, the Attorney General’s office? 

Dr. Singh. Yes, your office, Senator. Yes. 

Senator Markey. And my office? 

Dr. Singh. Any organization, any organized group. 

Senator Markey. And the people of Plymouth? 

Dr. Singh. We will consult. We participate in NDCAP meetings, as you know, routinely. We try to be as transparent as possible. I really don’t understand why people say we keep information. We put information on our website, we publish it routinely, we publish bulletins. You can go on our website and see questions and answers to the decommissioning [indiscernible]. We are not a closed company."

[CRONIN -- Note that Dr. Singh does not acknowledge the people of Plymouth or her sister towns as "stakeholder[s]" in his answer, despite being given the opportunity to do so.]

c) Dr. Singh to Sen. Markey, p. 95: 

"If we let it [i.e., the contaminated wastewater] sit, which we will, if that is what the stakeholders tell us, don’t discharge water, I don’t like the term dump, because it is not a dump, it is discharging it to the bay with, under prescribed conditions in a controlled way. But if the decision is to leave the facility standing and leave the water there, we will do that."

d) Dr. Singh exchange with Rep. Keating, p. 99: 

[Keating]: "On March 14th of this year, the Environmental Protection Agency sent a response to that letter, outlining their concerns with the discharge of fluid from the spent fuel cooling pool, which states unequivocally that your company must seek clearance, must, from the EPA for any discharge into Cape Cod Bay from the spent fuel coolant pool. Has your company responded to the EPA’s letter? 

Dr. Singh. Congressman Keating, I don’t have personal knowledge whether we have answered or not. 

Representative Keating. You are the CEO. [Simultaneous conversations.] 

Dr. Singh. Let me answer your question. I will get that information for you. The bigger question that you said is that we have, we are not communicating with your office and other major stakeholders in the process. I will rectify that problem immediately. There is no agenda here to hold back any information. We will fix that. We will fix that.”

Recalling Dr. Singh’s words two years ago, I am left with a number of questions for Holtec’s representatives here tonight. 

The first is: Does evaporation of the wastewater in question constitute “discharge”?

The second is: Are the people of Plymouth and her sister towns stakeholders in the decommissioning process?

The third question is: Dr. Singh says in one of his answers that “we will consult”; can you describe the efforts Holtec has made to consult with the people of Plymouth and her sister towns on the issue of evaporation of the wastewater in question?

I’d like to note one more thing that Dr. Singh said in his testimony at the Senate Hearing. He states, on p. 103 of the transcript, that “we can locally evaporate the water using electric heaters. That will environmentally damage as well.”

My question for Holtec is: was Dr. Singh correct in his testimony at the Senate hearing that evaporation “will environmentally damage as well”?

Thank you for your time and attention.

Sincerely,

J. Benjamin Cronin, Ph.D.
Duxbury, Massachusetts