Critique of Holtec’s Dry Casks

Oscar Shirani worked for Commonwealth Edison & Excelon. He blew the whistle on the defects of Holtec’s dry casks. He was blacklisted by the industry. (He died in 2008.) Here is a summary of Oscar Shirani’s allegations against the Holtec dry cask, and support from Dr. Ross Landsman, NRC’s Region 3 dry cask inspector (the hand written notes are Shirani’s own):

Donna Gilmore has done a lot of research on dry cask storage of high level radioactive waste. Her research is posted on her webpage You can listen to a podcast of an interview with Donna on Vermont Yankee, released July 1, 2014 on Nuclear Hotseat podcast Donna’s interview begins almost half-way through. Host Libbe Libbe HaLevy runs through this week’s nuclear news first. If you are short on time, scroll ahead to under the S in the red LISTEN above it.

She looked at the power point by Holtec International’s CEO Dr. Kris Singh, presented at the last NDCAP meeting, and wrote us this email:

I found a lot of holes in Holtec’s slide presentation.

Holtec: A leak-tight confinement that renders the likelihood of radiation leakage in long term storage non-credible.
DG: ignores stress corrosion cracking of the thin canister.  Ignore there are air vents in the concrete overpack.

Holtec: No loaded canister of Holtec’s has ever leaked in long term storage
DG: There has never any in long term storage; notice he doesn’t mention whether any of them have cracks, since he cannot inspect them. And he doesn’t mention they cannot be repaired, even if they could find the cracks.

Holtec: As the pie chart shows, the HI-STORM MPC System is the most widely used canister system in the world.
DG: But not the most widely used storage system — thick metal casks up to 20″ thick are — not the Holtec thin (1/2″) canisters.

Holtec: In addition to the US, countries with active terrorist cells, such as Spain and Ukraine, have selected Holtec’s HI-STORM for their spent fuel storage needs.
DG: The system has not yet been installed in the Ukraine and they are using a different design, but one that is still inferior. Holtec has sold them a double wall thin canister system.  Outer is 3/8″ and inner is 1/2″ thick stainless steel.  They are still subject to stress corrosion cracks, so are not designed for long term use and are not inspectable or maintainable. And just because they are using them doesn’t make it a good decision or prove it will be good protection from terrorists.

Additional DG comments:
Not designed for inspection or maintenance of the concrete or the thin steel canister.No seismic rating for cracked canisters.No early warning monitoring system.  Will only know AFTER leaks radiation.Bolted lid thick casks have pressure monitoring system and double seals, so if there is any change in pressure there is instant notification, so the problem can be dealt with (e.g., change seals).  The ductile cast iron casks have two independent bolted lids, each with double seals.  If one seal or lid fails, the other is fully functional.  This is true defense in depth.  The Holtec thin systems do not have this.No mention that the Holtec thick over pack has air vents (needed for cooling the thin canister), so the single point of failure is the thin canisters.Regarding the concrete, I haven’t researched using concrete without rebar. According the the tech specs the concrete doesn’t provide structural support.

By enclosing the concrete in steel, you cannot inspect the concrete for degradation.   There are numerous degradations mechanisms for concrete.  The key is to be able to inspect the concrete.  The Holtec design makes that impossible.  I have a section on the nuclear waste page of my website that addresses concrete degradation of spent fuel storage systems.

A news article said there was 2″ thick steel.  Not sure what this applies to.  It doesn’t apply to the 1/2″ thin canister.  The Overpack has a 3/4″ steel exterior and a 1 1/4″ steel interior. Is this what they were referring to? See FSAR (PDF page 156).

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The NRC’s Magic Wand

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Dear Friends of the Safe and Green Campaign,

The last weekend in June has provided an opportunity to write to you without distraction. It was a powerful week of change in the US. Here’s what’s going on in our little corner of the world.

The NRC Magic Wand of Exemption

If you’ve been following along, you know that there aren’t any rules for decommissioning. Instead, the NRC waves its magic wand and lets reactors stop following the rules for operating. This is pretty dern frustrating for citizens and the State. At a May pubic meeting, Commissioner Chris Recchia called the NRC decommissioning process “stupid, stupid, stupid.”

At this week’s NDCAP meeting (below), Commissioner Chris Recchia said, “There is a blatant inconsistency between what the regulations say the Decommissioning Trust Fund can be, and what the NRC is actually allowing” such as using the fund for emergency planning, taxes, and now spent fuel. While the NRC’s waiver of its own regs is consistent with what is being done at other closed reactors, Recchia said “it’s unbelievable what the NRC is doing.” He’s working with the Attorney General and “fully expects that Vermont will lead the charge, with other states” in taking on the NRC’s decommissioning rules. “The NRC process is broken and needs to be fixed.”

Why is the State of Vermont spitting mad? This week, the NRC took out its Super Magic Wand and waived one of the few rules on its decommissioning books: use of the Decommissioning Trust Fund.

The NRC rules defines decommissioning as the “safely removing a facility or site from service and reducing residual radioactivity to a level that permits” either unlimited or limited use of the site. Small problem: there is nowhere to move the radioactive waste to. 70 years of nuclear technology and there is still no solution to what to do with the waste. So, last year the NRC decided, in its Waste Confidence decision (aka ‘Waste Con’ as in con job), that highly radioactive nuclear waste can safely live at nuclear power sites for 100 years. This leaves 900 plus tons of waste here in Vernon, Vermont. How is storing, monitoring and guarding it paid for?

By waiving the NRC’s Super Magic Wand, Entergy can use the decommissioning trust fund for all those expenses. Entergy has a $145 million line of credit to move the fuel (which it will recover from the DOE). Once that’s gone, the NRC will let Entergy take up to $223 million from the DTF to manage the fuel. That $223 is about 1/3 of the entire DTF as it now stands.

To add insult to injury, the NRC said Entergy could take it out of the fund without the usual 30-day notice to the NRC. So get ready for a RAID on the DTF you and I built with our electric rates until Entergy came along.

Now, with only 2/3 of the funds (left to its chances on the stock market), when will the actual decommissioning of Yankee happen? Entergy swears it will do it as soon as there is enough money … until then, its putting the reactor in mothballs and leaving a skeleton crew to guard the waste.

(Here’s a scary scenario: Entergy builds the storage, moves all the fuel into the dry casks, then declares bankruptcy. With all the levels of LLCs between Vermont Yankee Nuclear and the mothership in New Orleans, no one knows what would happen.)

Green Mtn. Daily 06.22.15: NRC Never Fails to Disappoint Vermonters

Reformer 06.26.15: VT Official: Yankee Trust Fund Process is Broken

Rutland Herald 06.19.15: NRC Sides with Entergy on Yankee Trust Fund

Rutland Herald 06.20.15: Vt Seeks Regional Support to Challenge the NRC

Vt Digger 06.18.15: NRC says Entergy can use DTF for Spent Fuel

Nuclear Decommissioning Citizen Advisory Panel (NDCAP)

This past Thursday the Nuclear Decommissioning Citizen Advisory Panel met in Brattleboro. 30 citizens showed up. So did the CEO and President of Holtec International, Dr. Krishna Singh and his entourage. [Read more about him here.] The meeting facilitation was good, with ample time for questions from the public.

The two Entergy VPs aren’t talking much (methinks their lawyers have told them to lay low while Entergy is before the Public Service Board).The other members are feeling more confident about making their voices heard. They grilled Joe Lynch, Entergy’s presenter, on its latest (unannounced, June 10) hostile action drill. (NDCAP Final Presentation June 25 2015 power point under the NDCAP tab).

State Rep. David Deen was frustrated. “We have no clue what went on, and what people did. Did you drill the emergency alert system? Did the sirens go off? I haven’t heard anything about it.” Commish Recchia is “growing less and less patient with the NRC’s approach to spent fuel – it’s as safe in the pool as in dry cask storage, but you need to do two hostile action drills?”

Chris Campany of Windham Regional Commission said that on August 13, some towns in the EPZ will come together to talk about how to operate without radiological alert funding.

Dr. Singh’s presentation was what one would expect from a well-paid CEO of a huge international corporation. He was a salesman: slick, quick and dismissive of any danger. You can download his powerpoint from Entergy’s page under the NDCAP tab, here: HI-STORM-MPC-Storage-System-for-Vermont-Yankee-R4

  • These Holtec 100 Storm casks will never Look, welds not gaskets! They are the most robust in the industry. (I counted 5 uses of the word Robust in the power point but may have missed one or two).
  • They are good for 300 years! (“You can’t reassure me until you’ve lived that long, said Deb Katz. She pointed out that Holtec casks have only been in service for 15 years.
  • High burn up fuel? None at Yankee … oops, oh, you do use HBF? Ah well, no problem. Our casks can handle it.
  • Singh was so glad we asked about the shipment of casks in 2006 which had not undergone helium leak rate tests required by the NRC. Singh said, essentially, our tests are better than the NRCs, the NRC doesn’t require those tests anymore. (According to the Reformer 08.13.09: “Holtec’s decision to eliminate the test was a violation of NRC regulations … We required that they take immediate corrective actions.” The AP did a good analysis and also noted that Entergy “was not doing as much radiological monitoring of the dry casks as was required by an agreement with the state…the failure to establish a radiation monitoring process was due to ‘a lack of formal tracking of such state commitments,’ according to Vermont Yankee.”
  • Speaking of which, Nancy Braus grilled him on radiological monitoring. Singh said that’s not Holtec’s job. They make recommendations, but it is up to Entergy and the NRC.
  • It was reassuring to hear him say that Vermont’s radiological levels are the lowest he’s encountered, lower even than European limits. (According to Holtec, the casks will emit 5 ML of radiation – lower even than terrestrial background radiation.)

You can read press coverage about the meeting by the Keene Sentinel and in some of the articles above.

At the Diablo Canyon reactor in California, the owners violated NRC specifications for loading dry casks for SIX YEARS before the owners or NRC noticed. They loaded casks 19 times before somebody caught on. [06.24.15: Read more about it here and in their local newspaper here.] “PG&E did not load 19 of its 34 used fuel dry storage casks according to a technical specification made by the casks’ manufacturer, Holtec International, regarding the proper mixture of older and newer spent fuel to ensure proper heat dissipation.” This included high burnup fuel.

The owners, PG&E, said the problem was “administrative in nature, not safety related… The specification was outdated and has been removed.”

This is the same line Dr. Singh gave about the missed helium test for Yankee’s casks. As Ray Shadis said back then, there is “a trend in the nuclear industry to operate on the belief that safety margins are excessive and that one can reduce them or take chances in not going the full distance.”

The NRC and the industry have become so used to handling ‘SNF’ that it has become just another ‘product.’ For our safety and worker safety, we need oversight that is conscious that this is 900+ tons of highly radioactive waste. We are obviously not going to get that from Holtec, Entergy or the NRC.

 Advisory Panel Preparing to Advise

Following the Holtec presentation and Q&A, the panel took on discussion about how to advise the state, what process to use, and what topics to cover. Dr. Bill Irwin, VT Dept. of Health, summed up our thoughts: “We’ve been reacting, going through growing pains for the first six months. Now we are at a great point to do our core mission, advising the state.” Irwin submitted a list of topics the panel could consider for the PSB case. Kate O’Connor, the chair, spoke with the state’s attorney on the PSB case on the pad, Aaron Kisicki, who said comments from the panel would be given significant weight by the PSB. David Mears, Commissioner of the VT Dept. of Environmental Conservation, said that the panel needs to hear from independent experts; only industry experts have spoken. The panel renewed its contract with consultant Catherine Morris, who may be able to help with process. Kate O’Connor, David Deen, Chris Campany, and Jim Matteau volunteered to form a committee.

The panel then heard more comments from the public, including Susan Lantz, Peter Vanderdoes, Amy Shollenberg, Frances Crowe, Howard Shaefer, Bert Picard, and Clay Turnbull. Clay suggested that the panel think from a new perspective: “what is the ultimate best use of the site? Actions we take now will affect that. Is the best and highest use to have a high level radioactive waste site on that beautiful site in Vernon, on the banks of the river? Or is there a better piece of property for the waste?”

After taking the summer off, the next NDCAP meeting will be September 24. The Massachusetts Dept. of Environmental Protection will make a presentation on the decommissioning of Rowe Yankee.

Safe and Green Campaign is not taking the summer off. Our next steering committee meeting is Monday, July 6 at 5:30pm, starting with a pot luck supper. Email for directions if you would like to join us.

Since we last wrote two weeks ago, we:

– Joined Rising Tide & on June 22 for their demo at the Public Service Board. 100+ folks marched and rallied, and a bunch of hardy young folks camped out overnight next to the PSB office. We were calling on the PSB to not allow a gas pipeline planned to run down the western corridor of Vermont. The project is not safe, overbudget, and the company is taking land by eminent domain. Safe & Green and Post-Oil Solutions members traveled up from Windham County in solidarity. It was great to march with fellow Safe & Green activists from central Vermont, Vt Yankee Decommissioning Alliance (VYDA) and Nuclear Info Research Service (NIRS). You can see photos and read about it on our Facebook page here (even if you are not a Facebook member).

– Joined the New England Coalition and other allies for our third meeting on decommissioning. The next meeting is scheduled for Wednesday, July 1 at the Brattleboro Food Coop Community Room 6:30-8:30pm.

– Updated our website’s Decommissioning Resources page, and our Action Center page with CAN’s list of bills before the Mass. Legislature on nuclear energy issues. Please also check our website regularly for posts on the homepage. . For daily posts on Yankee, nuclear power in the US and the world, and the latest good news on renewables, Like & Follow our Facebook page


Leslie Sullivan Sachs for the Safe & Green Campaign

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NDCAP: CEO of Holtec Coming to Town

Nuclear Decommissioning Citizens Advisory Panel (NDCAP) will meet 6-9pm on June 25 at Brattleboro Area HIGH SCHOOL Multi-Purpose Room (usual location – not previously stated Middle School), Fairgrounds Road, Brattleboro, VT 05301. Open to the public.  There is time on the agenda for public comment.

Primary topics: (1) Presentation by CEO &  of HOLTEC International (dry cask manufacturers);  (2) Potential Issues for NDCAP Advisory Opinions The NDCAP  webpage is here. 

NDCAP Agenda 06.25.15 Meeting Agenda – FINAL(1)

NDCAP Advisory Opinions Potential Issues- as of 6.15.15(1)

The CEO of Holtec, Dr. Singh makes $200 million a year and has made a sweet [yet suspicious] deal with NJ Gov. Chris Christie. [Read about that in the Guardian here.]  Dr. Singh made a presentation to the San Onofre citizen advisory panel. You can watch a clip on YouTube here, in which he states:

“…It is not practical to repair a canister if it were damaged… if that canister were to develop a leak, let’s be realistic; you have to find it, that crack,  where it might be, and then find the means to repair it. You will have, in the face of millions of curies of radioactivity coming out of canister; we think it’s not a path forward…

A canister that develops a microscopic crack (all it takes is a microscopic crack to get the release), to precisely locate it… And then if you try to repair it (remotely by welding)…the problem with that is you create a rough surface which becomes a new creation site for corrosion down the road.  ASME Sec 3. Class 1 has some very significant requirements for making repairs of Class 1 structures like the canisters, so I, as a pragmatic technical solution, I don’t advocate repairing the canister.”

Instead Dr. Singh states

…you can easily isolate that canister in a cask that keeps it cool and basically you have provided the next confinement boundary, you’re not relying on the canister. So that is the practical way to deal with it and that’s the way we advocate for our clients.

Donna Gilmore of San Onofre Safety offers this critique of his remarks:

“However, there are many problems with Dr. Singh’s solution of putting cracked and leaking canisters inside [transport] casks.

  • There are no NRC approved Holtec specifications that address Dr. Singh’s solution of using the “Russian doll” approach of putting a cracked canister inside a [transport] cask.
  • NRC requirements for transport casks require the interior canister to be intact for transport.  This NRC requirement provides some level of redundancy in case the outer cask fails. Does this mean this leaking canister can never safely be moved?  Who will allow this to be transported through their communities? How stable is the fuel inside a cracked canister?
  • What is the seismic rating of a cracked canister (even if it has not yet cracked all the way through)? The NRC has no seismic rating for a cracked canister, but plans to allow up to a 75% crack. There is no existing technology that can currently inspect for corrosion or cracks. The NRC is allowing the nuclear industry 5 years to develop it. It is likely to be inadequate due to the requirement the canisters must be inspected while in the concrete overpacks.
  • What is the cost for the transport casks that will be needed for storage?  Will they be on-site? Where is this addressed? Transport casks are intended to be reusable because of their higher cost. How and where will they be stored and secured on-site?
  • How will the leaking canisters be handled by the Department of Energy at the receiving end of the transport?  The DOE currently requires fuel to be retrievable from the canister.”

End of SONGS critique.

Kevin Kamps of Beyond Nuclear had this to share about Dr. Singh:

Over a decade ago, Oscar Shirani, the Commonwealth Edison/Exelon whistleblower on Holtec’s dry storage casks for high-level radioactive waste, told me that Dr. Kris Singh, CEO of Holtec, offered him a bribe, if he would shut up about the problems with Holtec dry casks. Shirani said that Singh said to him that Shirani could decide his own salary, and come to work at Holtec. Shirani refused the offer. Shirani was then run out of his own company, and blacklisted altogether from the U.S. nuclear power industry for the rest of his life. Shirani passed away, in his early 50s, in late 2008, just six days after being diagnosed with brain cancer.

Here is a summary of Shirani’s allegations against the Holtec dry cask, and support from Dr. Ross Landsman, NRC’s Region 3 dry cask inspector (the hand written notes are Shirani’s own):

—Kevin Kamps, Beyond Nuclear




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Pilgrim: Work Together to Shut It Down

Yesterday, we joined the MA Downwinders and Cape Downwinders for the last leg of the March for the Children, from Dewey Square to the Statehouse in Boston. As we marched, I was reminded of how far the fight to shut down Vermont Yankee has come since our own Step It Up to Shut it Down walk from Brattleboro to Montpelier in January of 2010. When 300 walkers presented a petition at the VT Statehouse on that snowy day, we did not know that one month later the VT Senate would vote not to extend Yankee’s license by a vote of 26-4.  We did not know that Yankee would continue to run past March 21, 2012 without its state permit, nor that the next day 1,500 citizens would take a day off from work to march  to Occupy Entergy HQ. Nor that a few weeks later, Gov. Peter Shumlin and US Senator Bernie Sanders tell a crowd of 1,000 “SHUT IT DOWN“.  And we certainly did not know that two weeks after winning its lawsuit to overturn the state legislatures’ right to vote on relicensing, Entergy would announce it would shut it down.

Our efforts from the January 2010 walk through the closure announcement in August 2013 were successful in part because citizens groups, large and small, worked together and presented a unified message: SHUT IT DOWN. Our messages to the legislature, in the streets, in direct action, at local town meetings, in OpEds, in public testimony, and in educational workshops was consistent.

Pilgrim crowd

100 Pilgrim protestors wearing neon green tees filled the Gardener Auditorium in Boston yesterday.

There are many citizens’ groups on the mainland and on Cape Cod working on Entergy’s Pilgrim reactor.  Some of them vow to shut it down while others say they work to “make it safer.” For example, from the Pilgrim Coalition:

dedicated to raising awareness of – and reducing – significant risks to public safety, health and our environment arising from the continued operation of Pilgrim

The Pilgrim reactor is on the NRC’s list of worst performing reactors. Its Clean Water Act permit expired 19 YEARS ago. Its emergency planning is a farce: when an accident occurs, both bridges to Cape Cod will be closed, trapping residents in a radiation zone while Plymouth residents flee. As former Gov. Michael Dukakis said yesterday, “But the fact of the matter, folks, is that it’s impossible to meet the federal standards for evacuation plans for any of these locations. It’s simply impossible.”

Nancy Braus of Safe & Green Campaign

Nancy Braus of Safe & Green Campaign

Yesterday, a dozen speakers give evidence that Pilgrim must shut down. Then Nancy Braus of Safe & Green got up to speak and the crowd went nuts. Nancy walked all four days with the Pilgrim activists. As she shared Yankee victory stories, one lesson was clear: to succeed, the citizens of Massachusetts must come together with one voice to shout from every town: Shut Pilgrim Down.

Just IMHO, by Leslie Sullivan Sachs, Safe & Green Campaign

Wicked Local 06.17.15

MetroBoston 06.16.15

WGBH Radio Boston

the Rally’s Speakers on our Facebook page



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June 4: Public Hearing on Entergy’s radioactive waste storage pad

On Thursday June 4 please come and speak to the Public Service Board at its Public Hearing. This could be the ONE public hearing on Entergy’s plan to store 900+ tons of highly radioactive fuel in the village of Vernon … perhaps forever. 7:00 pm Thursday, June 4, Vernon Elementary School, Governor Hunt Road, Vernon, VT.

Entergy needs to build a new pad on the 127-acre Vermont Yankee site, upon which 22 casks of high level radioactive fuel will sit. To do so, it needs a Certificate of Public Good from the Public Service Board (PSB). This permit application is Docket 8300. We and others have identified issues which need to be brought to the PSB’s notice. Below are a few.

Accessing the May 2015 version of Entergy’s “Spent Fuel Management Plan for VT Yankee”: ain’t easy. Go to – click State, and then download “Supplemental Pre-Filed Testimony of George Thomas.” Scroll down to page 10, at the end of Thomas’ testimony.

(1) Calling it “Spent Fuel” makes it sound benign. It is not. It is highly radioactive nuclear waste. Let’s not allow nuke-speak to hide the truth behind acronyms. SNF = spent nuclear fuel = highly radioactive nuclear waste. Here’s another: Independent Spent Fuel Storage Installation = ISFSI = a concrete pad with casks of highly radioactive nuclear waste sitting on it.

onedaysonallthiswillbeyours (2) The school, where the hearing is being held, is right across the street from Vermont Yankee’s gate and just about 1,500 feet from the reactor. There is danger of accident and radiation releases while they move the fuel from the pool to the pad. Entergy should schedule movement only when school is not in session to reduce the risk and protect the children.
(3) The benign-sounding “North Warehouse” will be torn down and the pad built in its place. But it is not so benign: the warehouse is a “radiologically controlled area,” meaning it contains radioactive material, and probably hazardous and non-radioactive waste which concerns Vermont’s Agency of Natural Resources and Health Department. If what is under the warehouse is not cleaned up properly, and instead is buried under the concrete pad, it could spread.

(4) A “line of sight barrier” – basically a wooden screen – will make the view of the storage less ugly, but will do nothing to protect the casks themselves. The first pad is ‘protected’ by an earthern berm but that is not in the plan for the second pad. (A new diesel generator will be protected by a wall 8 foot thick).

(5) Entergy’s talk and filings repeatedly say “just like the first pad.” Same elevation (127 feet above Connecticut River high water mark), same 1,000 year flood plain, same earthquake safety analysis. The approach is: if it was good enough for the PSB in 2006, it must be good enough for the PSB now. But we know that is simply not the case, for at least two reasons.

Fukushima storage of radioactive waste before 2011

Fukushima storage of radioactive waste before 2011

#1: It’s a post-Yucca scenario. In 2006, it was assumed the highly radioactive waste would be taken away by the department of Energy and sent to Yucca Mountain. The PSB assumed the latest it would be on site would be until 2082. But last year the NRC decided that highly radioactive waste could stay in host communities … forever. The NRC calls it “waste confidence.” In reality it is a Waste Con Game.

 #2: it’s a post-Fukushima scenario. Pro-nukers say the dry cask storage survived tsunami and earthquake unharmed. True. What they do not say: Radioactive waste at Fukushima was stored in a concrete building, not on an open pad. The Fukushima casks themselves were 20” thick forged steel, not 5/8” thin canisters Holtec casks which Entergy is buying.


Dry cask storage pad with casks (Connecticut Yankee)

Dry cask storage pad with casks (Connecticut Yankee)

About those Holtec casks: The 5/8” thin canisters are encased in a concrete “overpack” that is 19 feet high and weighs 200 tons — not sophisticated engineering, instead good old USA “bigger is better” engineering. There is no real-time radiation monitoring like there is in Europe and Japan. A canister is passively air cooled with a vent at top and bottom of each cask. For an examination of what the US uses, versus the rest of the world, go to waste/

The NRC ignored documented claims by whistle blower Oscar Shiranti and others that Holtec casks flagrantly violate engineering standards. The Holtecs are not approved by the American Society of Mechanical Engineers. To read more about flaws detected by Shirant, go here:

(6) Entergy’s back-up mantra: the NRC doesn’t make us do that. Why protect school children? Why share information with the state? Why protect the river? (Gee, we don’t know, ethics?)

(7) Entergy’s ultimatum, heard repeatedly since 2002: play our way or it will cost you. This time, Entergy is saying if the PSB does not grant their wishes with a CPG by May 2017, it will cost the Decommissioning Trust Fund $1.7 million every MONTH the radioactive waste remains in the fuel pool. The PSB, as the state regulator, should be setting the ultimatums. We will be hosting most toxic substance known to humankind, not the neighborhoods of the corporate executives outside the corporate headquarters in New Orleans.

Here are some numbers, if you are into that:

There will be a total of 58 casks when both pads are full.

They need to buy 45 more than are now on site.

The first pad can hold 36 casks. There are already 13 casks on it, loaded.

On the second pad (proposed), will hold 22 casks. There is room for 25.

There will be one cask filled with radioactive “debris.”

The pool now has 2,996 highly radioactive nuclear fuel rods in it.

Entergy’s proposed construction schedule:

May 2016: Get PSB Approval of the CPG in early.

June 2016 – remove North Warehouse and underground utilities, relocate diesel generator.

2017: Pour concrete pad.

November 2017: Start moving fuel

2020: All 900+ tons of highly radioactive nuclear fuel rods moved onto the banks of the Connecticut River

NOTE: 2020 was the negotiated date from the negotiated agreement with the State of Vermont in December 2013. By NRC “rules,” Entergy could have waited until the 60 year SAFSTOR period was up. Moving the highly radioactive nuclear fuel rods out of the spent fuel pool was the #1 priority of citizens, activists and the State of Vermont.




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Juanita’s Memorial Parade & Service

This Saturday, May 30, activists from around the country will gather in Greenfield to honor Juanita Nelson. Juanita and her husband, Woody Nelson, helped organize the first Freedom Rides in the 1940s and became war tax resisters at that time. They moved to Woolman Hill in Deerfield a few decades ago.

Safe & Green members  Randy Kehler and Bob Bady are organizing the day. Juanita loved music and marches, so we’ll begin at 12:30pm with a New Orleans-style jazz procession from Court Square, Federal & Main Streets, in Greenfield. The Expandable Brass Band will lead the way.

Amandla Chorus, Eventide Singers, and former Sweet Honey in the Rock singer Evelyn Harris will join in. The service will be at the Greenfield Middle School on Federal Street at 2:00pm.

Randy reflects on Juanita’s lively life in the Greenfield Recorder, here: 

Details and a flyer are on our Events calendar here.

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May 28 NDCAP – June 1 NRC – June 4 PSB

UPCOMING … details below

May 28: NDCAP Meeting — PSB & dry cask storage pad on the agenda

June 1: NRC public comment period on EPZ ends

June 4: Public hearing on PSB & dry cask storage pad

June 13-16: March with Pilgrim Downwinders from Plymouth to Boston


May 28: The Nuclear Decommissioning Citizens Advisory Panel (NDCAP) will meet on Thursday, May 28 from 6-9pm in the Multi-Purpose Room, Brattleboro Union High School, Fairground Road. It is open to the public — please attend! Let’s show the state that citizens care, let’s do what we can to keep the panel on time, and let’s ask the difficult questions. This is the only public opportunity we have to learn what’s going on prior to a public hearing on the main agenda topic – the new dry cask storage pad – one week later.

Let’s hope this NDCAP meeting includes a designated Time Keeper. The May agenda includes 45 minutes for public comment at the end of the meeting.  Agenda: download NDCAP Agenda 05.28.15

After updates from Entergy and the State on the current status of decommissioning, the main topic of discussion will be the Public Service Board’s Certificate of Public Good process for a new dry cask storage pad at the site (a.k.a. Docket 8300. It is limited to the pad that dry casks will sit on — not the casks themselves or any other decommissioning topic). Entergy, VT Public Service Dept., and VT Agency of Natural Resources will give presentations. Chris Campney of Windham Regional Commission with present on “Stakeholder Interest in the CPG Process.” Here’s press coverage of PSB schedule for Docket 8300  Here is the full Docket 8300 schedule. 

There will be a Public Service Board (PSB) PUBLIC HEARING on JUNE 4th — time and place TBA. The New England Coalition, which has argued before the PSB in countless VT Yankee dockets, hopes to be a party to the proceedings and may be the only citizen group there.

 Entergy has managed to insult, ignore and generally piss off the Public Service Board for a dozen years. We need to take advantage, wiggle our way into any cracks in the corporate armor, find loopholes, and keep the pressure on the State to do the same. Citizen reps on NDCAP can benefit from our experience and knowledge of the PSB process — the 2002 sale to Entergy, the uprate, (first) dry cask pad, and license extension.

 “Hostile Action” Drill?

We sure hope NDCAP updates include Yankee’s first-ever “hostile action drill.” Coincidentally (not?), the potential for a hostile action is one of the reasons the State appealed of NRC’s decision to allow Entergy to eliminate the 10-mile evacuation planning zone.

We don’t know much about what went down, because “Entergy broke with decades of tradition and banned the press from its Joint Information Center, where details of previous multi-state drills were routinely made public.” Marty Cohn blamed the black out on FEMA and the NRC. But they said having the press present was up to Entergy. (Whose cheeks are red?)  Read the story here RH 05.14.15

It took Entergy one year to plan the hostile action evacuation drill. It took FEMA and the NRC two days to proclaim the drill a success.

EPZ Update?

The same day as the NRC gave glowing reviews to the evacuation drill, the State lost its appeal for a hearing on the EPZ. Coincidence? The Atomic Safety & Licensing Board, with 1 member dissenting, said NRC should be able to do whatever it wants because (1) it always has, and (2) there are no rules. Honest. Read the appeal decision  here. [RH 5.19.15] and about the quickie thumbs-up on the hostile action drill here.

The NRC has let owners off the hook for evacuation planning 17 times — every time it was asked for it. Why should we be any different? Well, there are a whole lot of reasons why Vermont Yankee is different — its location in the middle of a village, across from an elementary school, for starters. It’s tiny footprint — 124 acres compared to the average 700-1,200 acres. It is hard to believe that high level radioactive waste that is so hot that it must be kept in cement encased steel canisters will be cool enough in a year to drop the emergency alert system and EPZ.  Yet the NRC and Entergy want us to believe if there is an “event,” radiation will stop at Yankee’s fence line.

Comment to the NRC BY JUNE 1!documentDetail;D=NRC-2015-0111-0001 or snail mail Mail comments to: Cindy Bladey, Office of Administration, Mail Stop: OWFN-12-H08, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 Be sure to include: Docket ID NRC-2015-0111

The Keene Sentinel wrote a clear explanation of the issues.

“In its ruling, the licensing board noted: ‘the NRC Staff has determined that permanently shut down reactors face a smaller number of potentially severe accident scenarios.’ A smaller number sure, but any number greater than zero when you’re talking about ‘potentially severe accident scenarios’ strikes us as warranting safety measures for all those potentially affected… As long as high-level radioactive waste remains in Vernon, especially in the spent-fuel pool, the danger is obvious.” Sentinel OpEd is here.

Money Update?

At the last NDCAP meeting, we heard from three state agencies — health, environment, and public service — that there is no state money to support state government oversight of any decommissioning activities. In a Brattleboro Reformer OpEd 05.21.15, the writer calls $5 million “shakedown money.” These are funds the state negotiated in its settlement agreement with Entergy. (Windham County will get separate economic development funds – $2 million a year for 5 years.) We look forward to hearing more about this $5 million.

Nuke News of Note

March for DownindersMarch for Our Children — Join the Downwinders in Massachusetts walking 54 miles from Entergy’s Pilgrim nuke in Plymouth to the Boston State House June 13-16. Join for the full four days or just part of the march. Housing has been set up. For full details, go here:  We’ve been invited to speak at the State House. Safe & Green members will be walking — some for all, some for part, a bunch for the last leg. Email us and let’s make some plans.

Reports of a drone flying over Maine Yankee “turned out to be a pilot from Canada who stopped to get gas and was not aware when leaving the airport that planes are supposed to bank right. The pilot banked left. FAA was advised.”

2004 Yankee Transformer Fire

2004 Yankee Transformer Fire

Entergy’s Indian Point, 30 miles from NYC, had a transformer fire. Like our’s in 2004, a silver lining is that it drew attention to the bad condition of the reactor, and in IP’s case, the crazy plan to build a gas pipeline next door. Read about it on Ecowatch. We first heard about the pipeline plan from whistle blower Paul Blanch at a New England Coalition meeting in Brattleboro in 2008 or 2009. FYI: IP’s NRC license for Unit 2 expired two years ago, but the NRC is letting it chug along anyway. Unit 3’s license will expire at the end of 2015.


Speaking of pipelines, Rising Tide Vermont is organizing a Rally & All Night Vigil to Stop the Fracked Gas Pipeline starting on Monday, June 22, 4 pm at the Public Service Board, 112 State St., Montpelier, VT. “Defend communities from Alberta to Vermont and make sure hard-working ratepayers aren’t forced to fund this dangerous fracked gas pipeline.” Contact Rising Tide: or email Safe & Green about car pooling. FYI: if you don’t have time but have a few extra dollars, Just Power is looking for help paying for legal assistance at the Public Service Board technical hearing for Jane and Nate Palmer and other landowners faced with eminent domain actions by VtGas/GazMetro. Watch their video, give $ here.

Leslie Sullivan Sachs
Safe and Green Campaign


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The Nuclear Decommissioning Citizens Advisory Panel will meet on Thursday, May 28 from 6-9pm in the Multi-Purpose Room, Brattleboro Union High School, Fairgrounds Road, Brattleboro. It is open to the public — please attend! The State of Vermont is representing our interests and share many of our goals. But the only way the state will continue to put the pressure on is if they think citizens care.

At the March meeting, citizen comment was very limited because speakers ran over their times. Let’s hope future meetings include a designated Time Keeper! The good news for May is that the agenda includes 45 minutes for public comment at the end of the meeting.

Agenda: download NDCAP Agenda 05.28.15   After updates from Entergy and the State on the current status of decommissioning, the main topic of discussion will be the Public Service Board’s Certificate of Public Good process for a new dry cask storage pad at the site. Entergy, VT Public Service Dept., and VT Agency of Natural Resources will give presentations. Chris Campney of Windham Regional Commission with present on “Stakeholder Interest in the CPG Process.”

Why is this important? This CPG is limited to approving the pad that dry casks will sit on — not the casks themselves or any other decommissioning topic. But it is important. The Public Service Board is the one place where Vermont has a chance to be heard.

Entergy has managed to insult, ignore and generally piss off the Public Service Board for a dozen years. We need to take advantage, wiggle our way into any cracks in the corporate armor, find loopholes, and keep the pressure on the State to do the same.

The decommissioning deck is stacked to favor the corporate owner, Entergy. The NRC has a hands-off attitude: it does not approve decommissioning plans. The NRC does not even have rules specific to decommissioning. There is no role in decommissioning for state or local input.


By the way, the technical term for a “pad” is Independent Spent Fuel Storage Installation,” or ISFSI. Say that three times fast. Former NRC Chair Alison McFarland had advice for the new NRC Chair: get rid of the acronyms. She also warned that the NRC is not prepared for decommissioning. it was too busy ramping up for the nuclear renaissance that never came.



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May Update

There are a full slate of events on decommissioning issues scheduled for May and June.

May 13 6-8:30pm: Let’s Talk, Let’s Do: Community Decommissioning Meeting sponsored by New England Coalition on Nuclear Pollution (NEC). Wednesday, May 13, 2015 from 6pm to 8:30pm. This meeting will be at the Brattleboro Food Coop Community Room, which is accessible through #7 Canal Street, Brattleboro.  This meeting is open to all.  A continued dialog from the April 8 meeting is scheduled with individuals from all viewpoints on what the community can do to expedite Entergy Vermont Yankee decommissioning to standards most protective of people and the environment. NEC will also share a brief update on our attendance at the status conference last week in Montpelier before the Public Service Board regarding Docket 8300 (Entergy’s application for certificate of public good for the 2nd dry cask storage pad, in lay terms).  Note to date we are the only public interest group to apply for party status. For additional information, contact Clay Turnbull @ 802-257-0336 or

Evacuation Planning Zone

June 1: NRC Deadline for comments on NRC’s finding that there are no environmental impacts from Entergy’s request to eliminate the evacuation planning zone.

The State of Vermont wants the EPZ to be maintained until 2020, and said Entergy had not “done adequate analysis about the potential for ‘hostile action’ on the now-closed plant, a plane crashing into the spent fuel pool in the reactor building, and other potential scenarios, including a fuel handling mishap.” RH 04.09.15 State Fights to Continue EPZ. This week, according to MassLive on-line, “The state of Vermont is weighing its options in responding to a request by Entergy Nuclear to eliminate the ten-mile evacuation zone around the decommissioned Vermont Yankee nuclear power plant.” Opposes Requests. For Entergy’s point of view, an article by Bob Audette of the Brattleboro Reformer was posted in VtDigger 04.28.15 NRC Says No Significant Env. Impacts in Reducing EPZ.

On April 12th, MA Rep. Paul Marks sponsored a decommissioning forum in Greenfield. 50 citizens attended. Much of the public comments and questionswere  focused on the EPZ


Vermont’s Public Service Board (PSB) will decide whether or not to grant Entergy a permit to build a new storage pad at Vermont Yankee. A site visit and public hearing will be held June 4th (time and location to be set). Note that this is Docket 8300; here is the PSB Pad schedule for the next year. Over the next year, the PSB will hear from Entergy, the State of Vermont, the New England Coalition on Nuclear Pollution and others as to the merits of Entergy’s application. The Brattleboro Reformer has an article here.

There is already one storage pad on the Vermont Yankee site, which was approved with conditions by the PSB in 2008. There are 8 casks currently on that pad. This is an application to build a second pad. The technical term for a pad is ISFSI (Independent Spent Fuel Storage Installation). We use the term “high level radioactive waste” — rather than the industry’s term “spent fuel.” People use the word “spent” when they feel exhausted, that they have no energy left. But this is highly radioactive material that can still do a lot of damage. Otherwise, why spend hundreds of millions of dollars to store the stuff? Plus, there is a lot of it: 2,996 fuel rods, over 900 tons. Nuclear engineer Arnie Gundersen says this is “the equivalent of radiation from 700 atomic bombs.”

By 2020, Entergy is committed to move it all from the fuel pool above the reactor into dry casks located on the first and second pads. It will sit there until the industry or the federal government come up with a solution as to what to do with the radioactive waste currently sitting on-site of 104 nuclear reactors in the US.

OpEd on Oyster Creek decommissioning: This is an excellent op-ed about a New Jersey nuclear reactor due to close in a few years. Details aside, the entire thing could be about Yankee (like Yankee it is a Fukushima twin). 5 bullet points at the end suggest actions the state could take which we should consider, including “an aggressive independent advocate should be hired full time to protect” the states’ and citizens’ interests. But one thing we have learned, which New Jersey has not, is that all the money is in the hands of the owner of the reactor. There is no decommissioning trust fund money for the state – or in our case, states – for environmental and other state oversight, to pick up the cost of emergency planning, or to advocate for our needs.

Arnie Gundersen of Fairewinds Energy testified about Vermont Yankee decommissioning before the Vermont Senate’s Natural Resources and Energy Committee on April 22. You can watch the video and read his report here. One of his points is about the EPZ. If Entegy and the NRC say that radiation will not leave the site and the surrounding towns are safe, then Entergy should give up the liability protection it gets from the Price-Anderson Act, which limits the amount of money a reactor owner has to pay if there is an accident. Senator Bernie Sanders agrees: [great photo]. He offered this suggestion to Republicans who say there is too much regulation of the nuclear industry:

“I wonder if any of my conservative friends would co-sponsor with me legislation to repeal Price Anderson so that we can leave the nuclear power industry alone and not get involved with government,” Sanders said. “I look forward to working with Senator [David] Vitter [R-La.] or Senator Inhofe on getting the government out of the nuclear power industry. Any volunteers at this point?”

Speaking of Bernie, in the GOOD NEWS column this month:

Finally, a presidential candidate who opposes nuclear power, Sen. Bernie Sanders of VT! Here’s a video clip of Bernie speaking at the “Defend Democracy: Shut Down VT Yankee” Rally in April 2012. He is on the US Senate Env & Public Works Committee, which oversees the NRC, where he has reminded the NRC Commissioners that they work for citizens, not the industry. He hosted a Town Meeting to a packed house at the Latchis when Yankee was up for sale which brought our issues to the NY Times. This April, he co-sponsored three bills on EPZs, state participation in decommissioning, and dry cask storage. Safe & Green members have met with his energy staff and found them to be on top of current issues in Vermont and nationally. (For a brief description of the bills, go to Green Mtn Daily here.

And more good news: * Tesla’s new $3,500 battery could be “the final nail in the coffin of nuclear power.”

If you enjoy fantasy rather than reality TV, watch “SAFSTOR Matters” on YouTube or BCTV. Marty Cohn, communications shill for Vermont Yankee, hosted this first in a series touting the glories of “Safe-Store.” The next in the series will be on the changes in emergency response.



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April Update

Well, that was a wicked winter. Now that Spring has reached our valleys and hills, let’s get together soon. Join us on Monday April 6, with Kevin Kamps, “Safeguarding Radioactive Waste at VT Yankee.” 7pm, Centre Congregational Church, in the Parlor. 193 Main Street, Brattleboro, VT.  Ample time for Q&A and discussion on one of the most important issues facing us: what to do with the high-level nuclear waste sitting on the banks of the Connecticut River. As the Nuclear Waste Watchdog for Beyond Nuclear, Kevin is one of the nation’s experts and has traveled the country educating local communities and their elected officials at all levels of government. Read more about him on our website here.

April 14, 6:30pm, Informational Forum with a presentation by Entergy reps on decomm process and end of the EPZ. Greenfield Community College Downtown Center, 270 Main St., Greenfield, MA. Scheduled by MA Rep Paul Mark (D-Peru), who said, “It’s really for people of the region to have their say and to have a more interactive forum with Entergy. Even at the panel meetings we have, a lot of time is spent on presentation and not public discussion. I really want Massachusetts to have a chance to get a little more information and have more of a say.” The Greenfield Recorder has an article here.


Support for nuclear power is at 51%, its lowest level since 2001, an 11 point drop since 2010. Even “70% of Republicans for solar and 63% for wind”

The NRC ruled against citizens again this week. For three years, citizen groups have been asking the NRC to take a close look at Entergy’s weak finances, which have been widely reported, to determine if the company can maintain its leaky old reactors in the Northeast properly, and decommission Yankee. Predictably, NRC trusts Entergy’s financial reporting and said that there’s nothing to worry about.

On the other hand … in a phone conference a few days earlier, the NRC “at first glance” thinks Entergy plans to use of the decommissioning funds improperly for things such as “using the $660 million fund for Yankee’s property taxes, Entergy Nuclear’s membership dues in the Nuclear Energy Institute, insurance, security staffing costs and shipping nonradioactive asbestos waste.” The NRC will investigate 5 other recently closed nukes as well to make sure they’re following trust fund rules.

Vermont Yankee will hold an “Emergency Plan Full Participation Exercise Scenario” on Wednesday, May 13. Details of the drill are confidential; the NRC defines one as “appropriate offsite local and State authorities and licensee personnel physically and actively take part in testing their integrated capability to adequately assess and respond to an accident at a commercial nuclear power plant.” We wonder: will it be the last drill before Entergy quits the emergency plan?

Speaking of security: Entergy made a stink about two recent trespassing incidents at Yankee. There is no longer any security at the gate, and it looks like folks just kind of wandered onto the site. One took a stroll through the dry casks and the other took photos out her car window.

Public comments on Entergy’s decommissioning plan (the PSDAR) have come to a close. But only 2 of the 41 public comments submitted to the NRC via its on-line comment page are available for the public to read. You can download a bunch from our website. CLICK HERE FOR: PSDAR Comments to the NRC including State of Vermont, area legislators, Town of Brattleboro, Fairewinds Energy Education, Shut It Down affinity group, yours truly and others.

Fairewinds has released a report, Vermont Yankee’s Decommissioning As An Example of Nationwide Failures of Decommissioning Regulation. It outlines changes that need to take place in the NRC’s approach to decommissioning, with an eye to the wave of reactor closures that are to come.

Entergy’s Southeast region was in the news this week. In Mississippi, Entergy will now benefit from ” pure corporate socialism.” Passed without one dissenting vote, and masked as economic development, the new law will allow Entergy ratepayers to pay for “speculative buildouts of infrastructure, whether or not the industry or business to be served becomes a reality and buys electricity from the utility.” Entergy “can go build a shoe factory and put the cost of building a shoe factory in the rate base and never give an electric power customer a pair of shoes,” [one critic] Blanton said. “It’s the most un-American bill I can imagine.”


April 1-12 Pipeline Pilgrimage — on the proposed route of the Kinder-Morgan pipeline, 143 miles from Pittsfield, MA to Dracut, MA. Led by the New England Young Adult Friends (Quaker) Climate Worker Group. Most nights at 6:30pm: Pipeline Pilgrimage Community Pot Lucks. Sunday April 5 at 5:00pm: Passover Seder potluck, All Souls Unitarian Church, Greenfield, MA.

April 7 – Stand Up for Solar! Lobby Day at the MA State House. 10am-2pm. Sign up at MA legislation on nuclear as green – or not. One House bill, “An Act to Repower Massachusetts,” includes nuclear as “clean” power. Another states that nuclear is not a renewable energy source, and two others expand the EPZ. Learn more on our website, then contact your legislators and let them know your thoughts.

April 15 Book Signing with Frances Crowe, “Finding My Radical Soul,” Solar Store of Greenfield, 2 Fiske Ave., Greenfield MA 6-7:30pm

May 10 Cape Downwinders “We’re Mad as Hell Mother’s Day Rumble” 11am-2pm, St. Catherine’s Chapel Park, Plymouth, MA. to close Entergy’s Pilgrim reactor. If you would like to be part of the rumble program at the park-music, song, poetry, personal reflection, or other, please contact Susan at If you would like to be part of the Grandmother’s Affinity Group to plan a creative action, please contact Sarah at (508)385-2316 or Elaine at before April 25th.

We hope to see you all this Monday to join us in discussing nuclear waste with Kevin Kamps. We’ll close with his words after our January VY UnPlugged party:

I can point out to people that shutting down Vermont Yankee was a miracle, right? We weren’t, as the people, supposed to have that power. And people did it anyway. They insisted on it and they saw it through and made it happen. And so the same kind of courage and vision will have to be applied now to the decommissioning process. People have to stay in there, attend all the meetings, read all the documents. It’s a Herculean task and if anybody can do it, it’s the folks who have already forced the shutdown of Vermont Yankee. [Nuclear Free Future Yankee Post-Mortem 01.06.15]


Leslie Sullivan Sachs

for the Safe and Green Campaign


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