Public Comments to MassDEP Regarding Holtec Due Aug. 31st
Public Hearing to be held at Plymouth Town Hall, at 6 pm on August 24th.
[Readers, though I am a member of the Duxbury Nuclear Advisory Committee and Save Our Bay, the views expressed below are my own.]
Good afternoon, folks. I just wanted to note that public comments to the Mass. Dept. of Environmental Protection (MassDEP) regarding Holtec are due on Aug. 31st at 5 pm.
As you may recall, MassDEP issued a tentative determination on July 24th denying Holtec’s application to modify its permit to allow the discharge of approximately 1.1 million gallons of radioactive wastewater into Cape Cod Bay. The Department correctly determined that the discharge plainly violates the Massachusetts Ocean Sanctuaries Act (M.G.L. c.132A §§12A-16J inclusive and §18), which prohibits the discharge of industrial waste into Cape Cod Bay.
(Clark’s Island and Duxbury Bay, from Saquish Head, in Plymouth; credit — J. Benjamin Cronin.)
MassDEP Director of the Division of Watershed Management Lealdon Langley noted in the July 24th tentative determination that “Section 15 of the [Ocean Sanctuaries] Act prohibits the ‘dumping or discharge of commercial, municipal, domestic or industrial wastes’ into ocean sanctuaries. M.G.L. c. 132A, § 15(4). According to the application to modify the Permit, and the definition of ‘wastes’ at 301 CMR 27.02, the water the Facility proposes to discharge is industrial waste subject to that prohibition. The water is stored in the spent fuel pool, torus, dryer separator, and reactor cavity, was utilized in the Facility’s industrial operations …[and] is contaminated…."
Mr. Langley also noted that “[t]he Act prohibits state agencies from permitting activities contrary to the provisions of the Act. M.G.L. c. 132A, § 18.”
"Since the proposed discharge is prohibited by the Act, MassDEP must deny the requested Surface Water Discharge permit modification in accordance with Section 18 of the Act,” wrote Mr. Langley.
The process is not over, however, and it is important to send public comments to MassDEP, noting why the Department should issue a final determination denying Holtec’s application to modify its permit. I have attached a suggested letter below. These comments are due by 5pm on Aug. 31st, 2023, and MassDEP requests that you send them by email to massdep.npdes@mass.gov.
In addition, the Dept. will hold a public hearing on the matter at 6 pm on Thursday, August 24th, at Plymouth Town Hall.
A suggested simple comment is included below the break.
Cathy Coniaris
Massachusetts Department of Environmental Protection
100 Cambridge Street
Boston, MA 02114
massdep.npdes@mass.gov
Re: Pilgrim Nuclear Power Station
Dear Ms. Coniaris:
I am writing to support the tentative determination by the Massachusetts Department of Environmental Protection (MassDEP) to deny Holtec’s application for a modified Surface Water Discharge Permit that would allow it to discharge radioactive and chemically contaminated wastewater into Cape Cod Bay.
MassDEP’s tentative determination that the requested discharge is prohibited by the Massachusetts Ocean Sanctuaries Act is entirely correct. That act prohibits the “dumping or discharge or commercial, municipal, domestic or industrial waste” into an Ocean Sanctuary. Cape Cod, Plymouth, Kingston, and Duxbury Bays are all protected ocean sanctuaries under the act. The proposed discharge is therefore illegal.
Because Holtec’s proposed discharge is illegal, the Department’s final determination should deny its application.
Thank you,
[Your Name]
[Your Address]