Holtec No! Cape Cod Bay, Yes!

Peace Advocate July 2022

Cartoon created by Joe K

by Diane Turco

When the Pilgrim Nuclear Power Station in Plymouth shut down for good in June, 2019, we all breathed a sigh of relief. Finally, we thought, the risk of a serious nuclear accident was in the past! But the reprieve came to a nerve-wracking end when Holtec International stepped in to take over decommissioning from Pilgrim owner, Entergy. For about $1,000, Holtec obtained the license from the inept federal regulator, the Nuclear Regulatory Commission [NRC], to dismantle and “clean up” the site with the Pilgrim $1.3 billion Decommissioning Trust Fund (DTF). That fund consists of taxpayers’ monies accrued from 1972-1998 (when the utility was regulated) to pay for the clean-up. This resulted in Holtec, a company with no experience decommissioning nuclear reactors, taking up the dirty job, determined to find the cheapest, fastest, and most profitable form of decommissioning, come hell or deadly water. They are now raiding the DTF, buying up old reactors to make huge profits while generating great risks to communities and the environment. 

The spent fuel pool at Pilgrim cooled over 4,000 highly radioactive fuel assemblies during the 47 years of its operation. During the planned process of removing the reactor building, which includes the spent fuel pool, Holtec plans to discharge over a million gallons of radioactive water from the pool into Cape Cod Bay. This water is full of dangerous radiological contaminants that cannot be filtered out.  Because the dismantling process cannot continue until the water is moved, Holtec has presented three options approved by the NRC–dumping the radioactive water into the bay, evaporating it, and trucking it to a licensed facility off-site just as Vermont Yankee nuclear facility plans to do. Holtec also presented a supporting argument for the dumping and arguments against evaporation and trucking. Just recently, Holtec offered another option, which is to contain the water onsite. Holtec representatives have not been forthright about how that option would be achieved. The primary plan remains to dump into the Bay.

Why should we all be concerned? One reason is that the water is contaminated with long-lived radionuclides that would be incorporated into the bay water, salt spray, beaches, and marine life. In the Pilgrim water, one particular radionuclide, Tritium, cannot be separated or treated. It bonds with water and becomes even more dangerous when organically bound to materials such as sediment and grasses. It bioaccumulates in orders of magnitudes up the food chain to your plate. Tritium can pass through the placenta and cause genetic damage. It can attach to organs and tissue, causing cancers and other illnesses. Tritium also can impact marine life like the endangered right whale that inhabits Cape Cod Bay Ocean Sanctuary.  

In addition, Holtec cannot meet the NRC ALARA [As Low As Reasonably Achievable Requirement] which would entail reducing the amount of radioactivity in Pilgrim’s contaminated water before it is dumped into the bay or by evaporating it on-site. NRC’s Backgrounder on Tritium states that “In principle, no dose should be acceptable if it can be avoided.”  In addition, an NRC regulation states, “Maintaining radiation doses from radioactive effluents ‘as low as reasonably achievable” is an NRC requirement. NRC also states it supports no threshold-no safe dose as does the National Academies of Science in their Biological Effects of Ionizing Radiation VII report. The science tells us and we all can agree, there is no safe dose, particularly for the fetus, infant, child, and females.  However, the NRC “allows” this contaminated dumping because their “safety standards” are not safe and only protect Holtec’s purse. Holtec must avoid any doses and meet the ALARA requirement by not dumping, period.

Like the tobacco industry’s misinformation campaign of the past, Holtec uses junk science to justify the dumping. They say radionuclides will dilute in the bay but, in fact, radionuclides don’t dilute, but disperse. They still remain dangerous. And according to Woods Hole Oceanographic scientist Dr. Irina Rypina, the contaminated water discharged right at the shore of Cape Cod Bay shows that circulation patterns will hold the contaminated water in the bay for a long time. Even beyond the immediate health and environmental issues, the livelihood of the fishing industry, tourism, real estate values, and coastal communities’ economy would be damaged. 

Both the NRC and Holtec see no problem dumping this radioactive garbage into our bay. But a fisherman would be fined if a gum wrapper was thrown into the water. There are state regulations against dumping hazardous waste, yet Holtec hangs its hat on the NRC to protect its interests. While the NRC has given Holtec the green light to dump anytime, the state has the authority to stop it. Holtec agreed to follow all Massachusetts regulations when they signed the 2020 Settlement Agreement through Attorney General Maura Healey’s office. There are current state laws and regulations, including those that specifically prohibit disposing radioactive waste into our bay, which is a protected ocean sanctuary. In the agreement, Holtec explicitly agreed to “comply with all applicable environmental and human-health based standard and regulations of the Commonwealth,” yet dumping is still their plan. They have shown no inclination to comply with local and state regulations, even though federal preemption of state law does not apply in this case.  

Senator Edward Markey, Senator Elizabeth Warren, and Representative Bill Keating, along with our state and local representatives, town boards, and citizen petition initiatives from towns on the South Shore, Cape Cod, and Martha’s Vineyard have called on Holtec to terminate their plans to dump any radioactive water into our bay.  Attorney General Maura Healey has pledged to block Holtec from dumping. The Conservation Law Foundation recently sent a letter to call on Holtec to immediately remove dumping from their plan. There is a huge public outcry to halt Holtec’s plan. Yet today, Holtec holds onto their grievous plan to dump. They will make a decision by September/October. We say NO NOW!

Holtec knows dumping would harm our families, damage the local fishing and shellfish industry, hurt the coastal real estate and tourism industries, harm the habitat of marine life, particularly the endangered right whale, and violate our right to safety. Local economies would be devastated as would our environment. But Holtec appears to be too corrupt to follow any rules for the common good.  As is so often the case, business decisions come down to money and we, the people, need to be out front to protect our interests as stakeholders and community.  We must be ever vigilant because our government fails to protect us and because corporate capitalism has no respect for life. We must hold Holtec’s feet to the fire, insisting that they immediately remove dumping of waste as an option. Emergency legislation filed by Senator Susan Moran, S.2719, which prohibits dumping, is now in Senate Ways and Means. Similar legislation filed by Rep. Josh Cutler and Rep. Kathleen LaNatra, H.4444, is in the Judiciary Committee. Call your state legislator to move both emergency bills forward for a full vote this legislative session.

Also please contact Governor Baker and Attorney Health and ask them to ensure Holtec “complies with all applicable environmental and human-health based standards and regulations of the Commonwealth” per the Settlement Agreement and call on Holtec to be environmentally responsible and immediately remove dumping into Cape Cod Bay from their plan.

Governor Charlie Baker

Massachusetts State House

Office of the Governor

24 Beacon Street, Room 280

Boston, MA 02133  


Tel. (617) 725-4005 (Boston)

Email Form:


General Maura Healey Attorney

Office of Attorney General

One Ashburton Place

Boston, MA 02108

(617) 727-2200 (Boston)

email for constituents, policy comments:


CC Seth Schofield 

Senior Appellate Counsel Assistant Attorney General Energy and Environment Bureau



Together, our voices are strong and will be heard! No Way in OUR BAY!


For more information and updates, go to www.SaveOurBayMA.com

JOIN US FOR THE NEXT EVENT: Monday, July 25 for a rally 5:15-6:15 at Plymouth Town Hall green before the Nuclear Decommissioning Citizens Advisory Panel meeting at 6:30.


Diane Turco has been working on nuclear weapons/nuclear power issues since 1982. She is also Director of Cape Downwinders, a grassroots organization working on closing the Pilgrim Nuclear Power Station in Plymouth.