Commonwealth of Massachusetts v. NRC

August 12, 2008

Attorney General, Martha Coakley
Office of the Attorney General
One Ashburton  Place
Boston, MA 02108

Re:  Commonwealth of Massachusetts v. NRC

To The Honorable Martha Coakley:

On behalf of Massachusetts citizens who will be directly impacted by the proposed renewed operation of the Pilgrim and Vermont Yankee Nuclear Power Stations, and who live in the area of the Seabrook Nuclear Power Station (for which a license extension application is anticipated), we are writing to thank you for your advocacy on behalf of public health and safety and environmental protection in the U.S. Nuclear Regulatory Commission’s (NRC’s) license renewal proceedings for the Pilgrim and Vermont Yankee plants, including your  appeal to the U.S. Court of Appeals for the First Circuit. 

Last year, the First Circuit ordered the Commonwealth to go back to the NRC and await NRC’s decision on the rulemaking petition before proceeding further.  The Court appeared sympathetic to the safety concerns but first wanted to tidy-up procedural issues. 

Not surprisingly, the NRC continues to blind itself to safety concerns, and last week it denied the Commonwealth’s petition for rulemaking. We hope that we can count on you to take this matter back to the First Circuit so that the NRC will finally be forced to address the significant public health and environmental risks posed by high-density pool storage of spent fuel at plants such as Pilgrim and Vermont Yankee.

We are proud that you have taken a national leadership role on the issue of spent fuel pool safety and security.  Following your example, the State of New York submitted a hearing request in the license renewal proceeding for the Indian Point nuclear power plant, raising the same concerns that you have raised regarding the vulnerability of the spent fuel pools to accidents and terrorist attacks.  The State of California also followed your lead and submitted a rulemaking petition (that the NRC also denied on August 8, 2008) virtually identical to your August 2006 rulemaking petition.
Four days before the NRC’s recent refusal to reconsider its rules, Congressman Ed Markey and Senator Hillary Clinton filed a bill to require that spent fuel from nuclear reactors be stored in the safest manner possible while in the spent fuel pool, that the fuel to be moved to dry storage as soon as possible, and that securing requirements for spent fuel storage facilities be upgraded. On the House side, the legislation has been introduced as H.R. 6816.
Unlike the NRC, you, the Attorney Generals of New York and California, and Congressman Markey and Senator Clinton understand that the NRC has ignored new and significant information regarding the severe consequences and environmental impacts of spent fuel pool accidents, and the increased risks of such an accident. Spent fuel pools like Pilgrim’s and Vermont Yankees are especially vulnerable to attack because they are located in the attic of the reactor, outside primary containment with the thin roof overhead. Moving the spent fuel to an off-site repository such as Yucca Mountain is unlikely to become a viable option anytime in the foreseeable future
We believe your hearing request in the Pilgrim and Vermont Yankee cases constitutes the single most important opportunity to challenge the risks posed by these above-ground pools.  Thus, we commend you for applying the significant legal and expert resources necessary to ensure a full vetting of the spent fuel storage issue, and for your persistence in the Court of Appeals. 

You have assembled a superlative team of environmental lawyers to work on the case, including Assistant Attorney General Matthew Brock and Diane Curran, one of the country’s foremost experts on nuclear safety and security litigation.  On December 6, some of us attended the oral argument in the U.S. Court of Appeals for the First Circuit in Commonwealth of Massachusetts v. NRC.  We thought Mr. Brock did an outstanding job of persuading the Court not to accept the NRC’s attempt to side-line the case through procedural maneuvers.  We trust that the case will now proceed back to the First Circuit Court for consideration of its merits. 

Again, we thank you for protecting the interests of the Commonwealth by vigorously pursuing  this case, and providing national leadership on the critically important issue of spent fuel pool vulnerability to accidents and terrorist attack.  Now that the last procedural hurdle erected by the NRC has been cleared, we look forward to a full airing of the environmental and public health risks posed by high-density pool storage of spent fuel at the Pilgrim and Vermont Yankee nuclear plants.  


Sincerely on behalf of the undersigned,

Mary Lampert
Pilgrim Watch, Director/Town of Duxbury Nuclear Advisory Committee
148 Washington Street
Duxbury, Massachusetts

 Sandra Gavutis, Executive Director
C-10 Research and Education Foundation
44 Merrimac St., Newburyport, MA

Deb Katz
Citizens Awareness Network
Box 83 Shelburne Falls, MA

David Agnew, Coordinator
Cape Downwinders
18 Marthas Lane
Harwich, MA

Cindy Luppi, New England Program Director
Clean Water Action
Boston, MA

Alyssa Schuren, Executive Director
Toxics Action Center
Massachusetts, Connecticut, Rhode Island,
New Hampshire, and Vermont
617-747-4389 (p-MA)
802-223-8422 (p-VT)

David Lochbaum
Director, Nuclear Safety Project
Union of Concerned Scientists
Cambridge, MA

Paul Burns
Executive Director
VPIRG/VPIREF
141 Main Street, Suite 6
Montpelier, VT 05602

Richard Clapp, D.Sc., MPH
Professor, B.U. School of Public Health
Boston, MA

Rebecca J. Chin
Co Chair Town of Duxbury Nuclear Advisory Committee
31 Deerpath Trail North
Duxbury, Massachusetts

Pine duBois, Executive Director
Jones River Watershed Association
Jones River Landing Environmental Heritage Center
55 Landing Road, PO Box 73
Kingston, MA 02364

Richard DiPrima   
31 Cove St.   
Duxbury, MA 02332


Barbara Pye
Church Street
Duxbury, MA

Carol Langford, MD
Box 2895
72 Goose Point Lane
Duxbury, MA

Millie Morrison
83 Bay View Rd.
Duxbury, MA

Wedge Bramhall
Sandwich Road
Ply. Ma 02360   

Ted Bosen, Esq.
69 Janebar Cir,
Plymouth, MA

Heidi Mayo
18 Savery Avenue
Plymouth, MA 02360

Frederick Paris
Rocky Hill Road
Plymouth, MA

Mark Collins 
Russell Mills Rd.
Plymouth, Ma.

Sam Buttlerfield
Plymouth, MA

Charles Bramhall
Sandwich St.
Plymouth Ma

Martha M. Stone
517 Old Sandwich Rd.
Plymouth MA

Margo Culley
32 West Street,
Wendell MA 01379

Jody Shapiro, Ph.D.
Shutesbury, MA

Sanford Lewis, Attorney
Amherst, MA


Ken & Ethel Kipen,
52d John Ford Road
Ashfield, MA



 Thomas Matsuda
888 Shelburne Falls Rd.
Conway, Ma.

William C. Pearson,
New England Coalition Board
Brattleboro, VT

 Arnold Gundersen, BSNE, MENE, RO
Nuclear Safety Expert Witness
Burlington, VT

Jim Warren, Executive Director
NC WARN
North Carolina Waste Awareness & Reduction Network
PO Box 61051, Durham, NC   27715-1051

Eric Epstein, Chairman,
TMI-Alert Inc.
315 Peffer Street
Harrisburg, PA 17112
 North Carolina Waste Awareness & Reduction Network
PO Box 61051, Durham, NC   27715-1051

Connecticut Coalition Against Millstone
Nancy Burton, Esq., Director
147 Cross Highway
Redding Ridge CT 06876

Raymond Shadis
Executive Director
Friends of the Coast
Earth Day Commitment
Post Office Box 98
Edgecomb, Maine 04556

Judith Johnsrud, Ph.D.
State College
State: Pennsylvania

Ben Schreiber
Staff Attorney
Environment America
218 D Street SE, 2nd Fl
Washington DC, 20003