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Cape Cod National Seashore NPS gov 100 yrs
Part of the National Seashore faces Cape Cod Bay: https://en.wikipedia.org/wiki/Cape_Cod_National_Seashore , as does Pilgrim Nuclear Power Station.
Pilgrim NPS Cape Cod map
Pilgrim Nuclear Outfall
Pilgrim Nuclear Power Station showing outfall
Location exported from: https://en.wikipedia.org/wiki/Pilgrim_Nuclear_Generating_Station
Cape Cod National Seashore doesn’t look like much of a beach, but historically this region was associated with wealthy people. No place is safe, it seems, and especially a park or so-called nature preserve. The fact that people aren’t supposed to be in a park, green spaces, beaches, etc., for long is often used as an excuse to avoid proper remediation of nuclear waste, uranium mining waste, and accidents. Animals and plant lives don’t count at all for them. This is true in the UK and European continent too. Do research before you go. Consider carrying a Geiger Counter with you.
Cape Cod Highland Lighthouse NPS gov
NPS photo of Highland Lighthouse at the National Seashore

Apparently Entergy says that they will shut down Pilgrim Nuclear Power Station on Cape Cod by mid 2019. And, it has been operating without a water permit for around 20 years. It has been predicted that it will shut-down before the water rule passes all of the bureaucratic hurdles. Still, many people seem interested in the hearing today. Perhaps they hope to shut it down now. 2019 could be too late. And, 2019 means almost 3 more years of radioactive discharges into air and water. This case makes a good exercise in nuclear water rules. It seems a good exercise in bureaucratic nonsense.

The two most important observations are that they messed up the Plymouth Public Library address, suggesting that they don’t check their work, and don’t have anyone to double check for them; and that they intentionally or unintentionally mislead people regarding the Clean Water Standard for radionuclides.

If you type into Google Earth you even get the right address for the library. Are they lazy? Was it a typo? Why does it matter? Sometimes this is done intentionally to keep unwanted people (i.e. environmentalists) from attending public hearings. Companies have been known to pack hearings with “models” from unemployment agencies, as well.

Above all what the incorrect hearing address shows is that you can’t trust the US EPA with critical safety calculations regarding health and the environment. This is particularly true of radionuclides in the environment.

To err is human. And, that’s the reason that the nuclear industry must be promptly shut down and conscientious people put in charge of monitoring waste and clean-up for perpetuity. People responsible for such important tasks must check their work, and have at least one other person to double check it for them. These are life and death matters. If they can’t get a library address right, then they certainly can’t be trusted to do meticulous calculations involving radionuclides. Nuclear waste is not a job for investment bankers, such as EnergySolutions, either.

Additionally, the EPA or MA DEP author(s) of this water discharge permit either don’t know what the clean water rule says, or are pretending not to. They pretend that the EPA standard is 20,000 pCi (740 Bq) per liter for tritium. However, this is only true if it is the only [Beta-photon emitter] radionuclide present. And, 168 other Beta-photon emitters are supposed to be checked, as well as gross alpha, radium, and uranium, once pre-screening shows at least 50 pCi/L (less than 2 Bq (1.85 Bq) of Beta emitters. 20,000 pCi is certainly much greater than 50 pCi! And other radionuclides have been found present in the soil, such as Cesium, so tritium isn’t alone – radionuclides occur together.

US EPA chief Gina McCarthy (U. Mass Boston; Tufts) and this document by the US EPA-Mass DEP, not to mention the head of the US NRC, Ernest Moniz (Boston College; MIT), Calabrese at U. Mass Amherst, raise questions about quality of Massachusett’s educational system. Whatever happened? This is shameful, and it is revolting. Boston, at least, used to produce well-educated people. Didn’t it? Or were Martin Luther King, Jr., Bishop Oxnam and some other well-known and unknown Boston U. grads anomalies? When did people cease to read books from the wonderful bookstores which Boston had? Perhaps reading is insufficient? Don’t look for Massachusetts born and educated Gina McCarthy at the public hearing, either. She is reportedly in Vienna pretending to care about the environment. Perhaps she is really there pretending to be Marie Antoinette for a summer festival? She bears a remarkable likeness. Hopefully Nuclear-Free Austria will call Gina for the fake she is, but they are probably too mannerly. Don’t be looking for former Massachusetts Senator John Kerry to be there, either, even though he descends, in part, from Massachusetts blue bloods. He will be in Vienna too.

For those who missed it, nuclear reactors legally discharge lethal radionuclides into the environment, including waterways, on a routine basis. They are only required to dilute the radionuclides adequately before discharge. Dilution is even put forth as an obviously false solution

According to the draft water discharge permit:
Recent studies regarding groundwater onsite have indicated low levels of tritium ranging from 1,000-3,100 picocuries/liter (pCi/L). EPA’s drinking water standard for tritium is 20,000 pCi/L – the average annual amount assumed to produce a dose of 4 mrem/year.” (USEPA- Mass DEP, NPDES Permit No. MA0003557 “DRAFT AUTHORIZATION TO DISCHARGE UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM“)

The US EPA drinking water standard allows 20,000 pCi (740 Bq) per liter if and only if tritium is the only radionuclide. However, other radionuclides have been found onsite. Additionally, the US NRC has recently reported higher levels of tritium (4,530 pCi/L and historically much higher levels (69,000 pCi/L). 69,000 pCi/L is 2,553 Bq/L. A Bq is one radioactive disintegration (shot) per second.

According to the US EPA: “Radionuclides Rule: A Quick Reference Guide“:
Beta/photon emitters* 4 mrem/yr, Gross alpha particle 15 pCi/L, Combined radium-226/228 5 pCi/L, Uranium 30 µg/L
*A total of 168 individual beta particle and photon emitters may be used to calculate compliance with the MCL…. Vulnerable CWSs
” [Community Water Systems] “(2) must sample for: • Gross beta: quarterly samples. • Tritium and Strontium-90: annual samplesIf gross beta particle activity minus the naturally occurring potassium-40 activity exceeds 50 pCi/L, the system must: • Speciate as required by the State. • Sample at the initial monitoring frequency.” http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=30006644.txt (What if the State doesn’t require testing? Apparently if it’s not classified as vulnerable the Community Water Service escapes testing).
Note that this is the rule. It is separate from the so-called PAG recommendations to make people drink highly radioactive water subsequent to a nuclear accident. Multiply by 0.037 to get Becquerels (Bq). Note that uranium is in micrograms per liter.

The maximum amount of Cesium 137 (Cs-137) allowed per liter of drinking water if there were no other radionuclides is 200 pCi/L (7.4 Bq/L – That is Seven point four Radioactive disintegrations per second.). According to the “Pilgrim Nuclear Power Station (PNPS): Tritium in Groundwater Monitoring Wells“, Updates as of May 12, 2015, “Cesium-137 was detected in the vicinities of both catch basins (i.e. approximately 10-15 feet bgs) at concentrations ranging from non-detect to 2,400 pCi/kg” (CB-10) It appears that this is soil. If it were water then it would be roughly 2,400 pCi/L. In the same place (CB-10): “Tritium was detected in the soil proximate to CB-10 at concentrations ranging from non-detect to 175 pCi/kg” See: http://web.archive.org/web/20160315124228/http://www.mass.gov/eohhs/docs/dph/environmental/radiationcontrol/tritium/2015-updates/pnps-update-05-12-15.pdf

From the US NRC’s summary of Leaks and Spills At U.S. Commercial Nuclear Power Plants, December, 2015 “After a radioactive leak or spill, tritium is generally the first radionuclide to be identified in groundwater. This is because tritium travels through the soil faster than other radionuclides. Leaks and spills at some sites (e.g., Indian Point, Braidwood) involved nuclides other than tritium (e.g., Cobalt-60, Cobalt-58, Cesium-134, Cesium-137, Strontium-90, Nickel-63)” Historically Pilgrim has had as much as 69,000 pCi/L of tritium (December, 2013) and as of December 2015, 4,530 pCi/L of tritium, according to the US NRC: http://www.nrc.gov/docs/ML1532/ML15322A312.pdf

In his 2007 testimony regarding relicensing of Pilgrim, nuclear engineer Arnold Gundersen stated:
17.4.3. The release of Tritium indicates a leak in a system that in the past was radioactive.
17.4.4. I believe such a leak means that testing should immediately be undertaken that searches for Cesium 134 and Cesium 137, Cobalt 60, and other gamma emitters as well as Strontium 90.
” (“ENTERGY NUCLEAR GENERATION CO., LLC and ENTERGY NUCLEAR OPERATIONS, INC. (Pilgrim Nuclear Power Station), License Renewal Application, Dec. 2007http://static1.squarespace.com/static/54aac5e4e4b0b6dc3e1f6866/t/56bb5a6dc2ea51c64311e706/1455118957188/Gundersen+Pilgrim+Declaration+12-07.pdf )

JOINT CORRECTION TO PUBLIC HEARING INFORMATION PERTAINING TO THE ISSUANCE OF A DRAFT NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT TO DISCHARGE INTO THE WATERS OF THE UNITED STATES UNDER SECTIONS 301 AND 402 OF THE CLEAN WATER ACT, AS AMENDED, AND UNDER SECTIONS 27 AND 43 OF THE MASSACHUSETTS CLEAN WATERS ACT, AS AMENDED. REASON FOR CORRECTION: Original public notice of public hearing listed the incorrect street address for the Plymouth Public Library (public hearing location). A public hearing and meeting (information session) will be held on the following date and time:
DATE: Thursday, July 21, 2016
MEETING TIME: 6:15 p.m. – 7:00p.m.
LOCATION: Plymouth Public Library (side door entrance) 132 South Street Plymouth, MA 02360, MEETING ROOM: Otto Fehlow Meeting Room


Non-anonymous public comment is allowed, due on the 25th, specifically for this Pilgrim Nuclear discharge draft. On the same day (25 July) anonymous comment is allowed on the Environmental Protection Agency (EPA) Notice: [Nonprotective Inaction ] “Guide for Drinking Water after a Radiological Incident” here: https://www.regulations.gov/docket?D=EPA-HQ-OAR-2007-0268 Comment Deadline by 11.59 pm on 25 July 2016.

Some excerpts dealing with radioactive materials from the 300 plus page Pilgrim Water Discharge document:
Due to detected levels of tritium in groundwater samples in the vicinity of Outfall 005, the permittee conducted an investigation to determine its source and concluded that water from the waste neutralizing sump that was being discharged through the storm drain at Outfall 005 was the likely source of this tritium. The permittee believes that the storm drain associated with Outfall 005 is not watertight and leaks water from the Outfall 011 discharges. In order to avoid groundwater contamination from this discharge through this storm drain, the permittee has rerouted the flow from the waste neutralizing sump only, directly to the discharge canal with a hose, thereby bypassing the storm drain associated with Outfall 005 (See Figure 4). Since this is a discrete outfall to the discharge canal, it has been designated in this permit as a new Outfall, #014. The other discharges from Outfall 011, including demineralized water, service water, and station heating water will not need to bypass the storm drain and will continue to be discharged through the storm drain at Outfall 005. (12/17/15 email from J. Egan to G. Papadopoulos)”

The low level radioactive effluent associated with Outfalls 011 and 014 shall continue to meet all the Nuclear Regulatory Commission (NRC) requirements as specified in 10 C.F.R. Part 20“. [Apparently they mean that they are diluting it to a certain concentration.] “These limits are detailed in the PNPS Technical Specifications which define facility operational conditions. EPA and the NRC, in the past, have signed a Memorandum of Understanding (MOU) which specifies that EPA will be responsible for the water quality aspects of the discharge in concert with the State, and the NRC will be responsible for the levels of radioactivity in the discharge“. [Radiation in water has nothing to do with water quality?] “Thus, the draft permit addresses only the chemical aspects of water quality and does not regulate radioactive materials encompassed within the Atomic Energy Act’s definitions of source, byproduct, or special nuclear materials. See Train v. Colorado Public Interest Research Group, 426 U.S. 1, 25 (1976) (holding that “the ‘pollutants’ subject to regulation under the [CWA] do not include source, byproduct, and special nuclear material.”). All NRC radioactive discharge requirements will continue to be in effect, as required, in 10 C.F.R. Part 20 and plant technical specifications.” (p. 37)
6.8.1 Radiological Wastewater (“radwaste”) Effluents

The discharge of radiological waste water (“Radwaste Effluents”) directly into the discharge canal occurs via a diffuser pipe submerged at the upstream (proximal) end of the canal, adjacent to the discharge structure. It consists of demineralized water contaminated with radioactive species [plant makeup water (contact cooling water)] which is normally recycled within the radwaste processing system. In the event of a discharge, it is sampled, analyzed and pumped to the diffuser pipe in the discharge canal. Radioactive materials that fall within the Atomic Energy Act’s definitions of source, byproduct, or special nuclear materials are not subject to regulation under the CWA. Train v. Colorado Public Interest Research Group, 426 U.S. 1, 25 (1976); see also 40 C.F.R. § 122.2 (defining “pollutant”). Thus, the NRC, not EPA, regulates this discharge, which typically occurs 1-2 times per year, usually during refueling outages.

6.8.2 Groundwater

Recent studies regarding groundwater onsite have indicated low levels of tritium ranging from 1,000-3,100 picocuries/liter (pCi/L). EPA’s drinking water standard for tritium is 20,000 pCi/L – the average annual amount assumed to produce a dose of 4 mrem/year. From 2007 to 2013, PNPS worked with the Massachusetts Department of Public Health (DPH) to resolve the issue, citing weekly phone calls and quarterly meetings to determine the source of contamination. The permittee has determined that the storm line draining to Outfall 005 likely is not watertight and is a source of ongoing contamination of the groundwater from the demineralizer waste associated with internal Outfall 011. See discussion for Outfalls 011 and 014 in Section 6.7 above for the remedy that the permittee is proposing to implement.” (pp. 44 -45)

Regarding testing – this is of Outfall 1 but gives an idea:
All samples shall be representative of the effluent that is discharged through Outfall 001, taken at a location between the point of discharge from the condensers and the outfall channel discharge to Cape Cod Bay. This sampling point shall also include flows from Outfalls 004, 005, 010, 011, and 014 when discharging. A routine sampling program shall be developed in which samples are taken at the same location, same time and same days of the month. Any deviations from the routine sampling program shall be documented in correspondence appended to the applicable discharge monitoring report (DMR) submitted to EPA. In addition, all samples shall be analyzed using the analytical methods found in 40 Code of Federal Regulations (CFR) §136, or alternative methods approved by EPA in accordance with the procedures in 40 CFR §136. Any change in sampling location must be reviewed and approved in writing by EPA and MassDEP. 2. Sampling frequency of 1/week is defined as the sampling of one (1) discharge event during each calendar week, when discharge occurs. Sampling frequency of 1/month is defined as the sampling of one (1) discharge event during each calendar month, when discharge occurs. For those months when there are no discharges, the Permittee must report a No Data Indicator (NODI) Code (e.g., “C” for “No Discharge”) on the DMR. In Attachment E of NPDES Permit Program Instructions for the DMRs, a list of NODI codes are included at http://www.epa.gov/region1/enforcement/water/dmr.html. The results of sampling for any parameter above its required frequency must also be reported. 3. Continuous monitoring shall be defined as monitoring at a minimum of fifteen (15) minute intervals during discharge. The results shall be recorded with the time and date on a chart, and shall be made available upon request by EPA or MassDEP. If continuous monitoring equipment at the outfall is unavailable, a minimum of four (4) manual grab samples taken at least fifteen (15) minutes apart each day is acceptable in lieu of continuous monitoring data. The permittee shall provide an explanation of why continuous monitoring was not available and when continuous monitoring would be expected to be resumed. The flow rate may be estimated from pump capacity curves and operational hours. The daily maximum discharge temperature and delta T shall be the highest level recorded during the month.” (p. 4) https://www.epa.gov/sites/production/files/2016-05/documents/draftma0003557permit.pdf (Emphasis added)

Two Effluent Release Reports for Pilgrim:

About Drinking Water Compliance:
The MCL for beta particle and photon radioactivity did not change in the revised rule from the current level of 4 millirem per year (mrem/year). A millirem is a dose of energy to the body. EPA regulates 179 man-made nuclides, and each of them has a concentration of radiation (measured in picoCuries per liter [pCi/L]) which produces the 4 millirem (mrem) dose. These concentrations are listed on a conversion table that the State will use to determine if you are in compliance.

Each nuclide has a different concentration that produces a 4 mrem dose because different radionuclides have different energy levels.

Some nuclides need to be in a higher concentration to give the same 4 mrem dose.

The laboratory will measure the nuclide concentration in the water, and the State will compare this result to the concentration allowed for that particular nuclide (see table on page 13). The comparison results in a fraction
If your water contains several man-made radionuclides, the State will add all the fractions together

The State of Washington environmental agency makes this even more clear:
EPA has established a maximum contaminant level of 4 millirem per year for beta particle and photon radioactivity from man-made radionuclide’s in drinking water. Tritium would be covered under this MCL. The average concentration of tritium which is assumed to yield 4 mrem/year is 20,000 picocuries per liter. If other radionuclide’s which emit beta particles and photon radioactivity are present, the sum of the annual dose from all the radionuclide’s must not exceed 4 mrem/year.

US EPA Normal Drinking Rules, NOT Proposed PAG Rule, which show how many radionuclides are supposed to be considered is found below. As seen above, they often pretend that there is only one, when giving the amount allowed. In the PAG recommendations for an emergency it is mentioned that “In situations where multiple radionuclides are present, DRLs should be combined using a sum of fractions approach to ensure that the projected dose does not exceed the PAG…” (p. 17) and yet they list only three!

Excerpts from:”Radionuclides in Drinking Water: A Small Entity Compliance Guidehttps://web.archive.org/web/20151014190302/http://www2.epa.gov/sites/production/files/2015-06/documents/compliance-radionuclidesindw.pdf
Radionuclides in Drinking Water: A Small Entity Compliance Guide p. 4 Rad Max Contam
Radionuclides in Drinking Water: A Small Entity Compliance Guide Requirements for Beta-Photon
Radionuclides in Drinking Water: A Small Entity Compliance Guide  Beta and Photon Derived concentrations drinking water, p. 11
Radionuclides in Drinking Water: A Small Entity Compliance Guidep. How to Meet the MCL p. 19

John Fitzgerald Kennedy, Born May 29, 1917
Brookline, Massachusetts
, U.S. https://en.wikipedia.org/wiki/John_F._Kennedy
Nuclear Power Nuclear War Everyday JFK quote

Comments due date

Extension date

How to comment
You may comment on the proposed Draft Permit in Writing. Email, Fax or Mail your comments to:
George Papadopoulos(papadopoulos.george@epa.gov)
EPA Office of Ecosystem Protection
5 Post Office Square, Suite 100 (OEP06-1)
Boston, MA 02109-3912
Telephone: (617) 918-1579
Fax: (617) 918-0579
Public Notice / Draft Permit: Pilgrim Nuclear Power Station, Plymouth, MA, MA0003557


We couldn’t find a bio or cv for the contact person. This is apparently as close as we will get, unless he sees fit to post his qualifications: https://en.wikipedia.org/wiki/Georgios_Papadopoulos

It seems impossible by Gina McCarthy has this grad degree, but both she and Tufts claim she does: http://web.archive.org/web/20160425044517/http://engineering.tufts.edu/cee/graduate/mengEnvironHealth.htm An undergrad degree in anthropology would appear to make her poorly suited for the grad program and she appears to have learned nothing. Anthropology focuses on qualitative analysis, not the sort of stats required for her supposed grad degree.

Archive of quick reference guide: http://web.archive.org/web/20160422014854/http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=30006644.txt
Archive of hearing address newspaper correction: