1. Pilgrim Power Plant: Beyond Design Basis External Event Plan
Emily Tompkins
Corporate Communications and Social Responsibility: W01
Professor Yongjun Shin
Bridgewater State University
December 10, 2014

2. Executive Summary
The purpose of this community development project is to mitigate the concerns of non-
government organizations and the concerned residents around the Plymouth Pilgrim power plant,
owned by Entergy. The concern addressed in this plan is about what will happen in a beyond
design basis external event (BDBEE). The Nuclear Regulatory Commission (NRC) recently
posed a new regulation to ensure safety in these cases, like severe hurricanes and snow storms
that could cause the power plant to lose electricity. The nuclear accident in Fukushima in 2011 is
what sparked these new regulations. To prevent such meltdowns from occurring in the United
States, NRC is calling for each facility to have a personalized FLEX plan; a portable system to
keep the power plant from nuclear accidents in the event of BDBEE. There are many concerned
citizens in the area as well as large non-government organizations that fear for their safety over
Entergy's proposed FLEX plan. The three main concerns are: 1.) restricted access to FLEX
equipment during BDBEE, 2.) ocean and groundwater pollution due to the proposed FLEX plan
and 3.) that this is a cheap and ineffective solution only for the purpose of meeting NRC
minimum requirements for BDBEE plans. I recommend utilizing corporate social responsibility
(CSR) to ensure the safety of facility employees and residents in the surrounding communities.
My community development plan involves: 1.) moving spent nuclear fuel rods from wet pool
storage to safer dry cask storage, 2.) engage in research and development of the best BDBEE
tactics and 3.) to not just communicate CSR, but to implement it in Entergy's business practices.
There are many benefits to accepting and enacting my proposed plan, including ensuring the
safety of facility employees and residents within communities in the surrounding area, create
more job positions and to begin to accumulate public trust. Pilgrim's nuclear operations are
highly debated in the South Shore; many are concerned over radioactivity and pollution while
others only focus on their employment, disregarding safety for financial security. But, the issue

3. at hand is not whether the plant should remain active or be shut down, the issue is with the
proposed FLEX strategy and if it is really the best solution in case of BDBEE.
Introduction
Explored in this project is Entergy applying for a license to build their FLEX equipment
in Plymouth Bay. This license is needed because the FLEX plan utilizes Plymouth Bay and must
adhere to the Chapter 91 Public Waterways Act. The plan must be accepted by the Department
of Environmental Protection (MA DEP). The main site of inquiry was attending the public
hearing in Plymouth Town Hall on November 18, 2014. This allowed me to gain a better
understanding of the issue, including the concerns of the public. Because of the nature of this
project being community development, it was important to know the concerns of the community.
While not all residents of the community are aware of the issue, over 80 community members
attended the hearing to voice their concerns. Entergy has a license to operate their business in our
community, but unless they show a higher concern for safety, they may not have their license
renewed in 2032. Entergy's presence in Plymouth is debated throughout the South Shore; some
feel threatened by nuclear activity so close to home, others defend it because Entergy is the
largest employer in Plymouth. This larger issue is a touchy subject in our community. I expect
the safety of the public and Entergy workers to be top priority to Entergy; this project hopes to
ensure this prioritization.
Preliminary Research
After the Fukushima accident, the NRC is requiring all power plants in the United States
to comply with a three step program for BDBEE. As outlined by the NRC:
The initial phase requires the use of installed equipment and resources to maintain
or restore core cooling, containment and spent fuel pool (SFP) cooling

4. capabilities. The transition phase requires providing sufficient, portable, onsite
equipment and consumables to maintain or restore these functions until they can
be accomplished with resources brought from off site. The final phase requires
obtaining sufficient offsite resources to sustain those functions indefinitely (U.S.
NRC March 12, 2012, 35)
Entergy’s proposed FLEX plan involves creating an outhaul and mooring system in the case of a
BDBEE. The Nuclear Energy Institute explains that FLEX is a "flexible" system that is facility-
specific which uses portable equipment to maintain adequate temperatures of the facility and to
regain electrical power after a BDBEE (NEI 2011). In Pilgrim's case, the outhaul and mooring
system is their personalized FLEX strategy.
To gain a full understanding of the situation, I attended the public hearing regarding the
issue. Eric Glass, a professional engineer, spoke for Entergy about the proposed plan. He
explains the system as two auger-driven helical pile moorings connected to landside outhaul
anchors by a pulley system using a 1 inch mooring line. The project will be located in the
existing embayment and has minimal environmental impact. The system will only be used in
cases of training exercises and BDBEE's. This situation has been brought to Plymouth Town
Hall because in order for the system to be utilized, a Chapter 91 Waterways license must be
acquired due to the significant use of Plymouth Bay. Entergy is seeking the license but citizens
and non-government organizations are trying to appeal because they argue that this plan does
more harm than good.
Cape Cod Bay Watch and Pilgrim Watch, two anti-nuclear groups, created an easy to
follow outline of Entergy's emergency plan. They explain that two anchored moorings would be
installed in the embayment with a pulley system and water lines connected to the shore by an
outhaul system, with a truck on the shore line with a generator to pump the ocean water for use
(Pilgrim Watch, July 12, 2014). These two groups propose possible flaws in this FLEX plan:

5. lines can be disconnected or clogged in extreme weather events, the supplies to enact the system
are in storage units and may be inaccessible due to storm debris, the pathway for the truck with
the pump may also be blocked by debris and the plan does not specify if there will be more than
one hose to use incase one's integrity is lost (Pilgrim Watch, July 12, 2014).
To further examine the concerns of the citizens, attending the public hearing in Plymouth
was very useful. I recorded these concerns, and more, that were expressed to the Massachusetts
Department of Environmental Protection (Mass DEP) on November 18, 2014. Bill Maurer, a
Cape Downwinders and Cape Cod Bay Watch volunteer, explained that there doesn't seem to be
a plan for the ocean water after use; the water will be contaminated with radioactive materials
and if not controlled, will go back into the ocean or into the ground/drinking water of community
residents. Maurer is also concerned that the pump intended to be used in BDBEE is meant for
still water conditions, an obvious flaw for extreme weather conditions in New England. Meg
Sheehan, a Pilgrim Coalition member, agrees that water run-off after use violates the Clean
Water Act, but also, will the ocean water go to cooling the reactor itself, or the wet pool storage
that can combust if the spent fuel rods become too hot? North Falmouth resident Lillian Frantin
argues that there are no actual pictures of this plan in action, she questions if this plan has even
been practiced by the facility. Manoment resident and a woman with a history of boating,
Christine Bostick, notes that the thickness intended for the lines are thinner than used on boats;
they can easily be broken in strong currents. Bostick also demonstrated that because of its
manual nature, power plant workers will have to be outside fighting waves and harsh conditions
to implement the plan. Nancy Noak of Duxbury poses questions for Entergy: what are the best
practices used for BDBEE, what information is the NRC using to determine the best emergency
response, why haven't spent fuel rods in wet storage been moved to safer, dry cask storage?

6. Plymouth resident, Dustin Taylor urges Entergy to learn from Fukushima; not only were citizens
in the surrounding area of the plant suffering death and radiation sickness, but the workers who
cleaned up after the event suffered from radiation sickness as well, while also taking much time
and money to clean up. Another Plymouth resident, Charlotte Heller brought up an additional
point, that terrorist attacks can easily disrupt the power grid, and because the facility uses energy
from off-site sources, terrorists can easily cause an emergency situation by knocking out power
to the plant, creating a need for the BDBEE FLEX plan to be implemented. Elaine Dickerson,
Cape Cod resident and Robert Miles of Hingham both felt as though Entergy is putting profits
over people; this plan is a cheap way to adhere to the NRC's response to the Fukushima disaster,
and does not show concern for the citizens in the surrounding area. While many commenters
diverged from the issue at hand and expressing their desire for the facility to be shut down all
together, they did raise important concerns for the proposed plan; Entergy had a chance for
rebuttal after the hearing but declined.
Stakeholder Analysis
The relevant market stakeholders in this situation are Entergy management and
customers. Entergy management’s interest is to maintain their job status and promote safety.
They have the power to strike and can fire employees, within reason. Customers are interested in
receiving electricity but do have the power to take their business elsewhere. Key non-market
stakeholders are the NRC, MA DEP, concerned citizens within a 50 mile radius of the facility
and coalitions such as the Cape Downwinders, Pilgrim Watch, Concerned Neighbors of Pilgrim,
Cape Cod Bay Watch, Jones River Association and Pilgrim Coalition; all of which are anti-
nuclear organizations. The NRC and MA DEP's interests are to ensure public and environmental
safety and have the power to regulate the nuclear industry. The various anti-nuclear groups form

7. a coalition of shared ideologies about the facility itself; the concerned residents and the NGO’s
have the power to question, appeal and contest Entergy's actions in the community.
Implications
There are two contrasting views on this issue. Entergy believes they are fulfilling the
obligations set by the NRC, but the citizens and NGO’s don't feel as though their safety is being
ensured through this FLEX strategy. Entergy states they are complying with NRC requirements
but the three main concerns of their opponents are important, which are: 1.) equipment being
inaccessible in a BDBEE, 2.) cheap and untested tactics, and 3.) contaminated water runoff after
the ocean water is used to cool the plant. Figure 1 shows the locations of the storage of FLEX
equipment, locations of pumps for the plan, and the connection stations. Lochbaum (July 31,
2014) outlines possible problems with the proposed plan. The storage sheds are 2,400 feet apart,
which doesn't account for widespread debris. Also, the connection stations won't work unless the
reactor vessel pressure is lowered, because the FLEX plan uses cheaper, low pressure pumps.
The Union of Concerned Scientists argue that building a better facility (instead of buying cheap
portable equipment) would reduce negative impacts of a BDBEE, but nuclear facilities do not
want to put the money needed into those projects because the probability of a BDBEE occurring
are so small. The concerns of the citizens are justified, as outlined by the Union of Concerned
Scientists.

8. Figure 1 (Lochbaum July 31, 2014)
Community Development CSR Plan
Corporate social responsibility (CSR) is the idea that corporations should enhance society
and its community and be held accountable for its actions that affect the people, the community
and the environment (Lawrence and Weber 2014, 49). The benefits of CSR, as outlined in
Business and Society, are: balancing power and responsibility, self-regulation of the industry,
improving stakeholder relations and positively effecting the business's reputation. The drawbacks
include negatively effecting profits, placing more economic burden on CSR implementing
businesses, passing costs onto stakeholders, requiring skills the facility may lack and putting
responsibility onto the business itself rather than individual decision makers (Lawrence and
Weber 2014, 49). There are other complications with CSR. Schmeltz (2014) examined

9. implementation of CSR in businesses and found that while companies value CSR, it is difficult
to enact when it contradicts other business practices. As stated in the text: "there is a conflict
between the observations that the companies are exposed to pressures of being politically correct
and engaging in CSR and their inherent ability to grasp the concept and translate it into
something that can be both realized and applied in a beneficial manner to benefit the company"
(Schmeltz 2014, 18). As outlined here, it is difficult for companies to apply CSR that also
immediately benefits the company and does not infringe on their prioritized goals, i.e. profits.
Entergy suffers from this problem: the company claims safety and focus on customer satisfaction
but plans to use cheap and unproven ways of protecting the community against BDBEE
emergencies. While the company understands the values of the community, they have not
successfully implemented CSR. In the nuclear energy industry, adhering to NRC regulations is
not enough to appease the community; community stakeholders want to see CRS being
accurately applied to the facility's practices. Entergy's goal of maintaining or increasing profits
does not align with their written concern for safety. But the value of building public trust is
integral to this industry. There is much debate on the acceptance of a nuclear facility in
America's hometown, Plymouth. So to help gain public trust of the operations at Pilgrim, CSR
does need to be addressed and implemented at the facility. It seems as though citizens and
NGO’s try to deter any motions made by Pilgrim and want the facility shut down all together, but
by applying CSR tactics in a realistic way, perhaps this resistance would weaken and the
concerned communities would be more accepting of Pilgrim's presence in Plymouth.
I propose three main developments for Entergy to implement in order to successfully use
CSR for the benefit of the community and its business: 1.) moving spent fuel to dry cask storage,
2.) research and development of a safe and effective BDBEE plan and 3.) to accurately

10. communicate concerns for public safety and civic engagement. First, there are over 3,000 spent
fuel rods in wet pool storage at Pilgrim; the wet pools originally intended for only 800 rods to be
stored (Corcoran November 22, 2011). By moving the excess spent fuel rods into safer dry cask
storage, the probability of combustion and radioactive emissions would be reduced in the case of
a BDBEE. Using safer nuclear waste practices, although costly, would help to ensure the safety
of not only the community, but the workers who would be executing the FLEX strategy. Second,
there is little information online about other FLEX strategies used by U.S. facilities. Entergy
could become a leader in safety practices if they dedicate themselves to public and facility safety.
Improved FLEX strategy technology would not only make for a safer facility, but make Entergy
an industry leader. Finally, implementing and communicating CSR and the goal of public safety
is vital to this plan. As seen earlier, claiming CSR and enacting CSR are two very different
things. On a main page of the Entergy website, the values and ethics are listed: "create and
sustain a safe and healthy life, cultivate a diverse and inclusive work culture, possess a winning
spirit, focus on our customers, grow the business, be active team players, treat people with
respect, aggressively look for better ways, take actions to achieve results and above all, act with
integrity" (Entergy 2014). As highlighted earlier, CSR and ethics may contradict the goals of the
business. Safety and health, focusing on customers and looking for better ways contrast with the
growing the business aspect. These first three ethics are communicated, but in this case of FLEX
strategy, they are not being practiced. Safety is not being ensured, concerned citizens are not
being heard and better business practices are being ignored for the sake of profits. It is as Elaine
Dickerson and Robert Mills expressed at the November 18th hearing; profits over people. But by
actually applying CSR, and not just claiming it, public trust can begin to accumulate.

11. This plan has many benefits, but of course, at a cost. Customers would benefit from this
community development plan because, although some are unconcerned over this issue, they
would be better protected in the case of a BDBEE which could lead to a nuclear meltdown if not
handled in the safest manner. This benefit would also positively affect the various anti-nuclear
NGO’s by being shown that public safety is integral for Entergy. The NRC and MA DEP would
benefit because they would be performing their job of protecting public health and the
environment. These two agencies can assist Entergy in this process by aiding Entergy with
research and development as well as accumulating funding for this CSR project. They may gain
this aid because in this increasingly capitalist society, CSR is becoming more and more
important to consumers. Entergy management should take interest in this project because in the
case of a BDBEE, it is their employees who will be executing the FLEX plan, and management
is in charge of directing them. The health and safety of employees must be a top priority in such
a dangerous field of work. While it will take much time and money to enact this plan, another
benefit is job creation. Constructing dry cask storage and developing the best FLEX plan would
open up more jobs to be filled by the many citizens who are eager to work. The recent economic
downturn has hurt many families, but this plan would create more opportunities for employment.
If implemented, such a positive change of heart should be communicated by Entergy to show
progress to the public.
There are a few channels worth exploring to spread the word of progress made by
executing this community development plan. For instance, social media is increasingly used by
businesses to promote their commodity. This channel can be utilized to communicate the actual
implementation of CSR, not just its written form. Pictures and videos of progress can be
uploaded and shared, giving the development of CSR real world value. Another medium is local

12. news. By starting with local news stories, through the Old Colony Memorial or Wicked Local, in
combination with social media, this story could be picked up by larger news sources. Another
way to inform citizens of their progress is through a newsletter, which can also be given to the
anti-nuclear groups. By keeping the anti-nuclear groups informed about Entergy's new business
practices, this negative relationship can begin to be repaired. Perhaps not just informing these
groups, but working together with these groups to find the best solution through compromise
would benefit both parties. Entergy’s license to operate in the community does not expire until
2032; removing Entergy from Plymouth is not an option until then, so collaborating on safety
practices is the next best solution to appease the anti-nuclear groups and concerned residents.
Conclusion
As outlined in this project, the proposed FLEX strategy of Entergy in BDBEE
circumstances is being debated. The main concerns over this plan from community members, are
a lack of accessibility to FLEX equipment during BDBEE, questioning what will happen to
ocean water after it is used and the belief that this is a cheap way to reach the minimum
requirement by the NRC, with little concern for public safety. My proposal to alleviate these
concerns are to move spent fuel to dry cask storage, create a better FLEX strategy for the plant
and to accurately implement CSR to regain public trust. The benefits to this proposal are placing
facility and public safety as top priority, becoming a leader in safety practices, job creation in
these tough times and to improve the reputation of the nuclear power plant. Because of the
dangerous nature of this type of energy generation, safety needs to become the most important
aspect integrated into this plan; Fukushima proves to be an example of what can happen in a
BDBEE. Entergy must understand; if there is no community left to do business in, you have no
business.

13. Bibliography
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http://www.wgbh.org/articles/index.cfm?tempid=4869
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nuclear.com/plant_information/pilgrim.aspx
Lawrence, A. T., & Weber, J. (2014). The Corporation's Social Responsibilities. Business and
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Mc-Graw-Hill Irwin.
Lochbaum, D. (July 31, 2014). Status of Fukushima lessons. Union of Concerned Scientists.
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Nuclear Energy Institute (2011). FAQ: Nuclear energy industry develops FLEX Strategy to
increase safety, address NRC's Post-Fukushima recommendations. NEI.
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