POWER March 2022 - 26

NUCLEAR
time, the fleet approach also encourages
friendly competition between decommissioning
sites.
In addition, Holtec selectively retains
site personnel to leverage their site-specific
knowledge and expertise. This practice
also helps assuage the relevant trade
unions and, to a certain extent, minimize
the loss of local skilled jobs. At Pilgrim,
today, former Entergy employees hold all
management positions.
Progress to Date
HDI's physical decommissioning activities
at Pilgrim commenced soon after
the license transfer became official in
August 2019. By July 2020, Holtec had
completed Phase 1 of its spent fuel
transfer campaign having loaded 11 new
casks onto the site's existing ISFSI pad
located near the reactor building.
Since the existing pad did not have
adequate capacity to house all the site's
spent fuel, a new larger ISFSI pad was
constructed (with Fukushima in mind) at
a higher elevation within the site. HDI
began transferring loaded HI-STORM
100 casks to the new pad later in 2020.
A Holtec vertical cask transporter loads
the casks onto a self-propelled Goldhofer
tractor for transfer to the new upper pad.
To meet the NRC's stringent security
requirements, the pad is surrounded by
tall, razor-topped wire fencing; monitored
using high-resolution security cameras;
and patrolled 24/7 by armed militarystyle
security personnel.
On Dec. 9, 2021, when the author visited
Pilgrim for a site tour, 61 HI-STORM
casks had already been loaded with spent
nuclear fuel and transferred to the new
upper pad (Figure 4). The last remaining
cask was moved several days later. Three
cannisters of non-fuel-related Greater Than
Class C (GTCC) waste were also scheduled
to be loaded into Holtec HI-SAFE casks on
the new pad in the first quarter of 2022.
In parallel with its fuel campaigns,
Holtec began segmenting and deconstructing
the reactor. As of this writing,
most of the top two-thirds of the reactor
shroud and internal components had
been segmented with the balance of the
reactor scheduled for completion by thirdquarter
2022. Much of this highly specialized
work utilizes Holtec-developed
tooling. GE, the reactor manufacturer, is
helping develop additional tooling to remove
the in-vessel thermal sleeve.
The contaminated fuel racks are
scheduled to be removed from the spent
fuel pool and transported to a licensed
disposal site later in 2022. Holtec is re26
viewing
several options for disposing of
the facility's treated liquid effluent. While
Pilgrim's National Pollutant Discharge
Elimination System (NPDES) permit issued
by the Environmental Protection
Agency would allow the station to release
this effluent to Cape Cod Bay in
small batches at widely spaced intervals,
Holtec recently received some negative
publicity when it became known that it
was considering this option. The company
has put the matter on hold for now.
Several outbuildings had already been
demolished at the time of my visit. It's
likely that several more will be demolished
by the time this article is published.
Work was also ongoing to characterize
and abate the numerous other auxiliary
buildings on site for asbestos, lead
paint, and other common industrial contaminants
prior to demolition. The main
buildings housing the reactor, spent fuel
pool, and turbine will likely be among the
last to be demolished. Holtec anticipates
that decontamination, abatement, and
dismantling work at the site will continue
through 2026, with site restoration work
completed late in 2027 at which time the
bulk of the site could be returned to unrestricted
use.
In January 2022, with Pilgrim entering
the next phase of its decommissioning
journey, Holtec reduced its site staff. All
permanent employees remaining on site
past Jan. 6, 2022, transitioned from CDI
to HDI. Contract workers brought in for
new projects will also do so under contract
to HDI.
Safety and Environmental
Performance
Holtec has established several industry
records during its decommissioning
activities at Pilgrim, including both
in transferring spent fuel from wet to
dry storage and reactor segmentation.
It also appears to be on track to return
the bulk of the site to unrestricted use in
near-record time.
Significantly, while striving to compress
the decommissioning time envelope,
the company appears to have
maintained a reasonably solid safety and
environmental track record. According
to a senior company spokesperson, Pilgrim's
environmental and safety record
has been very strong, with no recordable
injuries or Occupational Safety and
Health Administration violations in 2021.
Pilgrim reported a single relatively minor
environmental violation on Nov. 9, 2021.
This incident involved pumping approximately
7,250 gallons of non-radiological
www.powermag.com
4. Loaded casks on upper ISFSI pad. Source:
Paul Miller
groundwater (with no visible sheen or
odor) from an underground cable vault to
an adjacent storm sewer.
To reiterate a point previously made,
during its approximately 50-year operational
phase, Pilgrim had a less-thanstellar
performance record. This included
multiple appearances on the NRCs list of
poorest-performing U.S. nuclear power
stations. Speaking as a Plymouth resident
who lives well within Pilgrim's previous
10-mile Emergency Planning Zone,
news that the plant was shutting down
was not entirely unwelcome.
Now that the power station has been
deactivated and the spent fuel moved to
what appears to be relatively safe and
secure dry storage, the general anxiety
level in Plymouth associated with having
an aging nuclear plant in our backyard
has dialed down a bit. However, local
and state legislators, and many others in
the community, remain concerned that
those
large
concrete-and-steel
casks
housing more than 60 cannisters of stillradioactive
nuclear fuel are likely to remain
in Plymouth for years to come.
According to the 2020 Pilgrim Nuclear
Decommissioning Citizens Advisory Panel
(NDCAP) report: " NDCAP and all engaged
parties are keenly aware that the greatest
challenge following the safe decommissioning
of Pilgrim will be the secure confinement
of highly radioactive waste fuel
in Plymouth. " Clearly, to meet this challenge,
for as long as those loaded storage
casks remain in Plymouth, Holtec will have
to rigorously monitor, maintain, and refurbish
them (as needed) under regulatory
oversight, and the on-site security staff will
have to remain ever vigilant. ■
-Paul Miller has been closely following
technology and industry trends in the
power, oil and gas, chemical, and other
process industries for more than 35 years.
This includes almost 24 years on the
technology supplier side with the Foxboro/
Invensys organization (now part of
Schneider Electric) and eight years as the
content director at ARC Advisory Group,
a leading global market research and
technology consulting firm, from
which he recently retired.
POWER | March 2022
http://www.powermag.com
POWER March 2022

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