People Power Wave by March 18

Decommissioning is the nuclear power wave of the future. Stop letting this corrupt industry dominate its captive regulator who should be answerable to the public, not profiteers. Add your voice to change the decommissioning rules. Comment to the NRC by March 18 by going to this link.

Need more info before writing your comments? We sat in on a Webinar hosted by NIRS & CAN. They make 11 recommendations.  You can download the NIRS PDF Powerpoint with more info. Here is a summary:

  1. Require Full Decom Funding Upon Closure

Owners like Entergy exploit SAFSTOR to avoid compliance with regulations and defer cleanup for decades. The result: workers who know the reactor aren’t on the job; the environment is at risk of more contamination over time; economic planning deferred.

  1. Bar Exemptions for Decom Fund Expenses

NRC lets Entergy use Yankee decomm trust funds for nuclear waste management and storage, property taxes, and lobbying, among other things not in the rules.

  1. Restore NEPA Compliance

National Environmental Policy Act was required in the past, which makes decommissioning a Major Federal Action requiring EPA involvement and meaningful oversight.

  1. Restore Public Hearing Rights and Safeguards

Not just one public meeting! We deserve full hearing rights. We who live in the region impacted more than any other stakeholders.

  1. Require FULL Decommissioning Plans

The PSDAR is now rubber stamped by NRC. Require site-specific planning with detailed independent site surveys at the reactor to be decommissioning – not cookie-cutter plans.

  1. Restrict Use of SAFSTOR and DECON

Limit SAFSTOR and require SAFSTOR time period be justified with evidence. Decommissioning should begin at the earliest possible date determined by worker and community safety – NOT by corporate financial manipulation.

  1. Create 4th Decom Option: PDSR

Planned Decom & Site Remediation (PDSR) would limit duration of SAFSTOR to 20 years max, based on safety, not money; include state and community involvement, and retain 50% of current workforce.

  1. Establish Site-Specific Advisory Boards

Independent advisory boards with resources to hire technical consultants with access to information and the NRC.

  1. Permit State Oversight of Decom

States must have resources and authority to regulate pollution within their borders and decommissioning funds that impact taxes and host communities economic development.

  1. Require NRC Inspections and Oversight

The NRC inspectors have left VT Yankee. Who is enforcing even the weak NRC rules? Where is the accountability? Unannounced inspections plus liaison to Community Advisory Board should be mandatory.

  1. Increase License Fees for Decom Reactors

NRC must adapt to industry changes. Operators’ license fees should reflect projected decom costs.


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Busy Week: PSB & NDCAP

The Public Service Board is holding technical hearings in Docket 8300 today and tomorrow. This is Entergy’s application for a Certificate of Public Good (CPG) for a new, second pad for the dry casks which will hold the high level radioactive waste from the fuel pool.

In the past, all VT Yankee cases were accessible via the Board’s website but the Board is not posting documents from this Docket for the public to read.  We have previously postecd on the issue here.

Since we have no idea how long the radioactive waste will sit there, it is important that this be done well. The Nuclear Decommissioning Citizens Advisory Panel (NDCAP) is wrestling with the issue. The panel has been unable to come to consensus on an advisory opinion. It will be discussed Thursday night at their meeting. [6pm, Multi-Purpose Room, Brattleboro Union High School].

Schuyler Gould, a member of VYDA and now a New England Coalition trustee, has done a  Markup – NDCAP Draft Advisory Opinion on the issue here. His Cover Letter, Gould Markup Advisory Opinion is here. In the cover letter, he writes:

With all due respect to the efforts of the Panel on this particularly difficult issue, even the latest draft falls far short of standing up for the interests of the citizens it is commissioned to represent. The entire opinion is based, essentially, upon assertions by Entergy which have yet to be reviewed by the Public Service Board and judged to meet its regulatory obligations with the State of Vermont.

It is unclear to me, and others, why Entergy is even included on a citizens panel, it has been shown repeatedly to be at variance with citizens’ interests. That said, it should not be allowed to direct, certainly not to veto, the will of the majority of the panel.

The latest draft of the Opinion calls for “reliable assurances” from Entergy to “relevant regulatory bodies.” We all know a litany of assurances Entergy has given year after year after year—to the NRC, the Public Service Board, the Department of Public Service, the Department of Health, the Agency of Natural Resources, the Governor, the Legislature—not to mention the public, which have proven, quite simply, false.

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Independent Monitoring Needed

Dr. Bill Irwin, Radiological & Toxicological Sciences Chief at the VT Dept. of Health (VDH), is fighting for Vermont’s ability to retain its independent monitoring of radiation at Vermont Yankee. He writes:

The citizens of Vermont have relied on the independent VDH laboratory analysis of split samples from the VY site and its surrounding public environment which have been published for more than forty years. This independence and ease of access to data is a cornerstone of Vermont’s public health system and it provides Vermonters greater confidence that their land, water, air and health are fully protected.

The above is his conclusion to a Draft Advisory Opinion, under consideration by the Nuclear Decommissioning Citizen Advisory Panel. The State has more stringent air and water radiation regulations than the federal government’s, which Entergy find irksome. We agree with Irwin that the state needs to keep an eye on radiation during decommissioning, “what will be the largest industrial activity in Vermont’s history” .

Entergy doesn’t want to spend the money. They wrote their own Draft Advisory Opinion.

The full panel will meet on Thursday, February 25 at 6pm in the Multi-Purpose room of Brattleboro Union High School. This topic is on the agenda at 6:55 pm. You can read the Drafts and download the Agenda here on NDCAP’s new website:

Public comments on the drafts can be emailed:

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Rad Waste Advisory

Who will pay if the Dept of Energy hasn’t taken away the highly radioactive waste in 68 100+ ton storage containers when it is time to take down the buildings? Some folks who sit on the Nuclear  Decommissioning Citizen Advisory Panel (NDCAP) want assurance from Entergy that the company (or any subsequent owners) — not Vermont taxpayers — will pay for any delay in decommissioning the site. You can imagine what Entergy thinks of that.

onedaysonallthiswillbeyoursTwo Advisory Opinion have been drafted by an NDCAP subcommittee.   Only a few lines in each is different; the emphasis in italics is mine. Draft A reads:

 In the event the presence of the DFS casks will cause an undue delay in the demolition of the reactor building and/or structures, ENVY or any subsequent owner will commit to remedying the delay in a manner that does not encumber the decommissioning trust or site restoration funds, and which will not burden taxpayers beyond recoverable costs from the U. S. Department of Energy.

Draft B, reads:

Under NRC regulations, in the event the presence of the DFS casks will cause an undue delay in the demolition of the Reactor Building and/or structures, ENVY, or any subsequent owner of the property, will be required to update the PSDAR and DCE as well, if there are resulting significant increases in costs. ENVY or any subsequent owner of the property will be responsible for providing any additional funds needed to maintain the site consistent with applicable regulations in effect at the time, including, for example, funds or damages recovered from the U.S. Department of Energy.

We see two main points

  1. Since the Dept. of Energy (DOE) has failed in this effort after 75 years of nuclear waste being created, forgive us if we are skeptical about its potential for success. There is no place for DOE  to put the waste, currently. It is searching the US for communities that will offer their “consent” to  host a site. Even if a community agrees, it will take time to work its way through the legal and regulatory structures — especially if there is local opposition. Then the site design would have to be approved, etc etc etc — then built.
  2. If Entergy is so convinced that it can decommission the entire reactor site safely without the 68 dry casks getting in the way, why is it spending time fighting this purely Advisory opinion from a panel of mostly just plain folks?

The main purpose of the Opinion is to advise the Public Service Board, as that three-person state regulator considers the issue of a new storage pad for the waste. The Board has a history of permitting a project but adding conditions to the permit.

The full panel will meet on Thursday, February 25 at 6pm in the Multi-Purpose room of Brattleboro Union High School. This topic is on the agenda at 6:55 pm. You can read the Drafts and download the Agenda here on NDCAP’s new website:

Public comments on the drafts can be emailed:

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February E-News

Dear Friends of the Safe & Green Campaign,

The 5th anniversary of the beginning of the Fukushima melt-downs, evacuations, contaminations and deaths is approaching, March 11. On Saturday, March 12, we will host a vigil at Pliny Park in Brattleboro. We will honor the 100,000 Japanese people still unable to return to their homes and share what we have learned about Fukushima five years after the disaster began. Please join us from 10am to Noon. Details will be coming soon.

This week, TEPCO’s management claimed Fukushima could be all cleaned up in 40 years. If true, Fukushima will be cleaned up before Vermont Yankee! We wish we could believe TEPCO, but are skeptical. Just look at a single issue, radioactive water: everything TEPCO has tried has failed to keep the water contained.

Speaking of leaking radioactive water: Vermont Yankee and Indian Point are both leaking tritium at a rapid clip. Entergy funds to monitor groundwater at VT Yankee will expire in two months, and Governor Shumlin has put zero dollars in the budget for the state to cover it. Just days after the State and Entergy argued over this at Nuclear Decommissioning Citizens’ Advisory Panel meeting, the news broke that 90,000 gallons of groundwater laced with tritium are approaching the turbine building. NRC thinks the site has more than 1 million gallons of radioactive water and likes Entergy’s plan to ship it all to Idaho. Read more on VtDigger (and check out the Comments section for creative solutions worthy of The Onion.)

NIRS has two fact sheets on tritium: Tritium Basic Info  Tritium natural background

At Indian Point, “One monitoring well showed a nearly 65,000 percent spike in radioactivity, from 12,300 picocuries per liter to more than 8 million picocuries per liter, the governor said.” The NRC and Entergy say there is no threat to the public, but NY Gov. Cuomo said the State will investigate. Edwin Lyman of the Union of Concerned Scientists points the finger at Entergy management.

The State of New York doesn’t think the two Indian Point nukes should get 20-year extensions of their licenses, because the 2.5 billion gallons of water Indian Point uses every day hurts the Hudson River and kills its fish. Entergy claims this is using safety as an excuse and cites the Vermont Yankee federal preemption decision. [ 01.21.2016]

The NRC’s rubber stamp has been getting a lot of Vermont action. Everything is OK!

— VY security is OK: VY Security Endorsed by NRC. It’s all hush hush, because, well, Security. One thing Entergy’s Marty Cohn would say is that people are no longer trespassing because there are signs up saying not to. (Ahem, when did that ever stop us?)

— Entergy’s PSDAR is OKNRC Finds No Issues with VY Clean Up Plan and NRC OKs VY Decomm Plan. Of course, this plan that does not require NRC approval anyway …

–The decommissioning trust fund is OK in Entergy’s hands – NRC: Entergy Complying with Investment Guidelines on Trust Fund (Barre Times-Argus). This comes on the heels of news that Entergy spent down 10% of the fund in the first year of post-closure operations: Entergy Spent 10% of Trust Fund in 2015 (VtDigger) It spent $58 million. (Ironically, Yankee now pays GMP $100,000 a month for electricity and has asked Efficiency VT for help). The State of Vermont disagrees with the NRC that money from the fund should be able to go to spent fuel management, property taxes and other non-decommissioning activities and have filed suit with the NRC. Vermont is joined by the states of Massachusetts, Connecticut and New Hampshire, which are not only worried about the impact of 60 years of Safstor on their own states, but worry about the NRC setting precedent for use of trust funds. Each has their own reactors, and Pilgrim will close in a few years. And all four states are worried about the nuclear waste.

Recently, Arnie Gundersen of Fairewinds Energy Education in Burlington “Decommissioning: Trust Fund or Slush Fund?” Listen to the podcast and or read the transcript. Gundersen stated, “…with the use of exemptions, the Nuclear Regulatory Commission has turned the decommissioning trust fund into a decommissioning slush fund. And now they’re talking about avoiding exemptions entirely by changing the law.”

What Arnie is referring to is the NRC is drafting new rules to decommission reactors. The nuclear industry is promoting its own vision of decomm, and you can bet it’s about money and not public safety or cleaning up a site for productive re-use in the community. Click here to submit your comments. FYI: the comment period was extended to March 18 after public pressure, although NRC’s public comment page has the old date of January 4. Hmmm…. Oversight?

Also happening on the Yankee front: the VT Public Service Board has set February 22 and 23 for arguments on a permit for a new storage pad (ISFSI) for dry casks. The PSB will allow Ray Shadis to testify on behalf of the New England Coalition. (Entergy had fought his testimony). NDCAP has been working the heart of the matter. “… delays or other interference caused by the ISFSI being adjacent to the facility to be dismantled are a public concern, and any associated costs should be borne by the owner and not the public or the Decommissioning Trust Fund.” Entergy insists the Dept. of Energy (DOE) will take away the waste, and if the DOE fails to do so (as it has ever since the first reactor was built), there is sufficient room for the pad and deconstruction of the building near the pad. If Entergy is so sure, why argue so vociferously against a citizen panel’s advisory opinion? As the NDCAP draft advisory opinion states, “If the location is indeed not a problem then this should be a ‘moot point.’”

US Senator Patrick Leahy weighed in on the future of nuclear waste storage with a letter to NDCAP. The Dept. of Energy has begun a “consent based approach” to find a nuclear waste site or sites. Of note: this week, the NH House of Representatives voted down a bill sponsored by Rep. Renny Cushing to prohibit NH from hosting a nuclear waste site.

The “Nuclear Energy Innovation Capabilities Act,” sponsored by Senator Crapo (that’s not a typo), passed the US Senate last week and is on its way to the House. It would give money to develop new nuclear power generation and calls for a four year limit on licensing — which will mean less public participation. VT Senator Patrick Leahy & MA Sen. Elizabeth Warren voted for it – what the hunh? Please contact Leahy & Warren and give them a piece of your mind: Sen Leahy 802-229-0569 Sen. Warren (413) 788-2690

Let’s end with some love, this being Valentine’s Day. We love that Vermont has the 3rd most solar industry jobs, per capita, in the US. [Check it out here.] Look what can happen once a nuke shuts down!

Peace, Leslie Sullivan Sachs


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2015: Year One of Shut Down

Happy Anniversary! And Congratulations! It has been one year since Vermont Yankee stopped producing highly radioactive waste.

It has been a busy year since VY shut down on December 29, 2014, although the “action” has been in meeting rooms rather than marching to the gate. For a bullet list of Yankee-related news, visit our VT Yankee Timeline for 2015 . Review our news posts for the year for opinion. Here are a few highlights:

The best news is the simplest:

The ice returned to the Connecticut River last winter.

The shad returned this spring in record numbers.

2015 has not been kind to the nation’s 2nd largest nuclear corporation. Entergy is closing two more reactors, Pilgrim in Plymouth, MA and Fitzpatrick in NY. Entergy’s profits were down 30% at the end of the 3rd quarter this year; their two Arkansas nukes plus Pilgrim sit dead last on the Nuclear Regulatory Commission’s safety list; and the NRC discovered that Entergy workers had faked 10 years of fire safety records at its Waterford nuke near New Orleans.

In Vermont, Entergy is under constant pressure from the State and from you and me, and we are starting to see some results. Entergy will begin moving the radioactive fuel out of the fuel pool two years earlier than it had planned. It will not use the decommissioning trust fund to move and manage the fuel. It will use a line of credit in anticipation of being reimbursed by the US Dept. of Energy.

The Nuclear Decommissioning Citizen Advisory Panel (NDCAP) got a new chair and co-chair, both citizens, and the neophytes on the panel got educated. The panel has come a long way; a few Entergy stunts woke folks up. NDCAP is now actively advising the State and is working with its counterparts in other states and with the US Congressional delegations from the region to influence the NRC.

There is even good news if you look at the big picture. Despite heavy lobbying by some big names, nuclear power does not appear in the agreement which came out of COP21 in Paris.

On the other hand … there is the NRC.  In an August story on overheating the Cape Cod Bay caused by Pilgrim, the NRC admitted that it had not studied the effect of climate change on nuclear facilities. Since nuclear power (ab)uses more water than any other energy production except hydro, you would think this is something the NRC might want to take a look into.

But denial is the NRC’s best friend.  It cancelled studies of cancer around 7 nuclear reactors in the US, claiming the public health data would not be worth the price of $8 million. Sound like a lot to you? Compare it the NRC’s nuclear reactor research & development budget. Last week, Congress approved “$986 million in fiscal 2016, an increase of $80 million, or 9 percent, over the requested budget.”

What will 2016 bring?

Citizens across the US and the world will continue to fight for their voices to be heard in the face of extreme energy projects built (and later abandoned) by corporations which put profits first.

The town of Vernon is desperate for tax money now that Yankee has shut down. This March, the town will vote on whether to host a new gas plant. It would hook up to the Kinder Morgan pipeline and compressor station proposed for neighboring Northfield, MA.

VT’s Public Service Board will act on Entergy’s application for a new dry cask storage pad. The fight is on: Entergy wants the PSB to ignore any testimony by the New England Coalition’s Ray Shadis, a twenty–year veteran of Yankee cases before the PSB. Windham Regional Commission thinks the pad is in the wrong place, and a lot of us agree with them that the DOE can’t be trusted to take away the waste in a timely manner.

The NRC is drafting new rules for decommissioning nuclear power plants. Bowing to pressure from all sides, it has extended the public comment period to March 18, 2016. [More on our website with a link to the NRC comment page.]

A Final 2015 Memory

One of the most difficult, but certainly memorable events of 2015 for me was when the NRC came to Brattleboro in February to get feedback from the public on Entergy’s decommissioning plan.

Bert Picard to the NRC: “So what are you? You are a government of occupation, right?”

Betsy Williams’ indignation: “When you tell me the casks will be adequate, that does not give me great assurance. I’m looking for a hell of a lot more than adequate.”

Kevin Kamps’ comments to the NRC are a fitting close to 2015.

“The folks in this room, educated citizens fighting Yankee for four decades, shut it down. You have to use your same courage and vision and creativity to make decommissioning happen.”

Peace, and No Nukes,

Leslie Sullivan Sachs

For the Safe & Green Campaign

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Xmas Gifts

We found a few holiday gifts under our tree this season:

  1. Under pressure from regional nuclear activists, NDCAP, and our Congressional delegations, on December 24th the Nuclear Regulatory Commission extended the deadline to comment on nuclear reactor decommissioning rules. The new deadline is March 18. We will share our comments here at a future date.
  2. Entergy announced that it will move the radioactive fuel out of the fuel pool and into dry casks two years earlier than planned. The new target date is 2017. Dry-Load-Entergy News-Release-FINAL
  3. Entergy says it will use $145 million line of credit to move the fuel, rather than drawing down the decommissioning fund.

There is one drawback of Entergy’s announcement about moving fuel. It puts pressure on VT’s Public Service Board to give a Certificate of Public Good to the dry cask location by this spring. The PSB will have to come up with some creative solution to make this work for Vermont. In Entergy’s application to the PSB, the casks are close to the reactor building. Before decommissioning the reactor can begin, the Dept. of Energy would need to take all the fuel away. We don’t trust that the DOE will have can do all that is necessary to take the fuel away.

A senior staffer from the pro-nuke trade group, Nuclear Energy Institute, came to the Vernon nuke recently to promote their spin on dry cask storage — “one of the great industrial success stories of our time. We did not envision dry cask storage when we built any of these plants.” Mike Faher’s interview is here.

As to the Christmas eve gift of an extended comment period on new rules: The NRC gets a lump of coal for not adding any public hearings in states that are currently or will soon undergo decommissioning. As it now stands, only one public meeting will be held. Read all about it, and comment, on the NRC website here.

The decomm rules won’t take effect until 2019 or later, says the NRC, so new rules will probably not affect the decommissioning of VT Yankee. But other host states and communities can learn from our experience. The decommissioning of merchant reactors is a whole new ball game, and we are the among first to go through the process.

VtDigger covers the story in more depth here.


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VT & MA Congressional Delegations Tell NRC to Let the People Speak

US Rep. Peter Welch (VT), US Rep. Keating (MA), US Senators Bernie Sanders, Pat Leahy, Ed Markey and Elizabeth Warren are calling for an extension of the public comment period on new decommissioning rules. The current deadline is January 4th. See our post here for how to comment to the NRC.

“[“[W]e believe the short public comment period and the plan to have a single public meeting will not give local and state stakeholders sufficient opportunities to participate meaningfully in the rulemaking process,” their letter to the NRC states. The letter asks that the deadline be extended to February 4.

They point out that scheduling the comment period between Thanksgiving and New Year’s “falls short of providing satisfactory time to comment.” The also ask that “a public meeting be held in each of the states in which a plant is currently being decommissioned, or will be decommissioned int he next four years”



You can Congress decommissioning-nuclear-plants-letter 12.7.15.

Please email your thanks to and


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12/12 Rally & March in Boston

800 people so far have RSVPed to head to Boston this coming Saturday to make their voices heard on climate justice. Please join Safe & Green and 130+ other environmental, labor, social justice, and climate action groups co-sponsors. The action marks the end of the Paris climate talks.

Why go ?

  • The end is not in sight for climate change, nor for the talks in Paris. It is likely the close of the climate talks will be extended past Saturday.
  • Multiple reports say Nuclear power is a big player this year – hidden beneath the “clean energy” slogan (Take a look at the three articles at the end of this email). Bring your own graphics, or look for the No Nukes flags and get one of your own.
  • 350VT and 350Mass have made it easy for you. They have extended the bus RSVP so may still be time to catch a ride there & back for only $37.50. Tickets are here.
  • Our New England climate is obviously warming – it’s still protest ‘season’ for fair weather activists 🙂
  • Shela Linton, an ally, single mom & Brattleboro native, writes from Paris with a convincing argument for joining together with others who share our values: “Through my work with the Vermont Workers’ Center and our national allies, I’ve come to see the interconnections between environmental and social justice issues and the need to build unity between our movements.” You can read her Sunday OpEd from Paris here.

Following the official rally on the Boston Common at 1 and March to the State House at 2:30, other groups will engage in separate direct actions. One action at Fanieul Hall Marketplace is looking for non-arrest supporters. In another action, “Dressed as official MBTA employees, we will “officially” announce and hand out Change of Service maps due to massive flooding to people entering and exiting the subway system. The maps showcase the imminent devastation that sea level rise is going have on our coastal infrastructure if we cross the climate line and fail to keep 80% of our fossil fuel reserves in the ground.”
The latest official schedule is below and here:


1 PM: Rally at Parkman Band Stand

Derek Pellotte, 350 Mass for a Better Future

Sherri Mitchell, Maine Penobscot Tribe

Karen Higgins, Registered Nurse and National Co-President of National Nurses United

1:30 PM: March Begins

Stop 1: Fast food worker speaks in front of McDonalds
Stop 2: United Food and Commercial Workers worker speaks at Primark location
Stop 3: Jane Palmer, VT landowner & pipeline fighter, speaks in front of Kinder Morgan Office

2:30 PM: Rally at State House

John Robbins of Council of American Islamic Relations, Massachusetts

Rev. Margaret Bullitt-Jonas Missioner for Creation Care, of Western MA Episcopal Church and founding member of MA Interfaith Climate Coalition

John Harrity, President of Connecticut State Council of Machinists

Adrian Ventura, Executive Director of New Bedford Worker Center

YouTube Inspirational Invite Here

12/12 Rally & March Facebook Page here

And here we’ve selected three articles about nukes & Paris, as promised above:
The View from New England on HuffPo how the Paris talks are like New England’s current energy “quandries”

China’s awful env. record – and it wants to build 110 new nukes by 2030? Washington Post
Linda Gunter’s Counter-Punch article here: who are the billionaires behind the Breakthrough?


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NDCAP: 12/10 Meeting on 3 Draft Advisory Opinions

At the November Nuclear Decommissioning Citizen Advisory Panel (NDCAP) meeting, the panel passed an Advisory Opinion on the role of host communities in decommissioning: NDCAP Advisory Opinion – Engaging Host Communities – Adopted 11.12.15

Three more draft advisory opinions will be under discussion at the next NDCAP meeting December 10 [6pm, Brattleboro Area Middle School Multi-Purpose Room, 109 Sunny Acres Drive, Brattleboro, VT. (Sunny Acres Dr. is on the right just before the High School).

The more citizens at the meeting commenting the better! At a minimum, please email comments to

  1. We support the draft opinion addressing the re-location of the dry cask storage pad which will house 900+ tons of radioactive waste.   PDF of the  Advisory Opinion -DRAFT ISFSI-CPG – Submitted 10.15.15(1)

Here’s our take: Entergy proposes to build the second pad next to the existing pad. Both are within the “protected area” (near the reactor building).  Entergy’s plans are based on the false hope that the Dept of Energy will take the radioactive waste away by 2052, before it starts taking down the reactor building. Looking at the long history of Yucca Mtn. and other proposals for long term storage, there is no reason to believe Congress, the NRC, DOE and all the other players will find a site or sites, pass a law, enable regulations, build the facility, and license it —  by 2052.

We support the position of the Windham Regional Commission (WRC), which wants the PSB to make Entergy build the new pad further away from the reactor, in case the waste still there when the time comes for decommissioning the reactor. This Advisory Opinion also supports finding a location on site but far enough away from the reactor building such that it will be able to be decommissioned even if the DOE does not remove the waste in time.

VT’s NDCAP joined community advisory boards in MA, Maine and CT  which wrote “to federal lawmakers, urging approval of an interim, centralized storage facility so that nuclear waste won’t be stashed long-term at four shuttered plants – Vermont Yankee, Maine Yankee, Connecticut Yankee and Yankee Rowe.” [VtDigger 11.27.15]

2. We support continued funding of the emergency response plan. Advisory Opinion – DRAFT RERP – Submitted 10.15.15

This opinion was drafted by Dr. Bill Irwin of the VT Dept. of Health. It recommends funding emergency response planning for the state and towns as appropriate for the levels of risk at the different stages of decommissioning. Which makes a lot of sense to us. The level of risk which radioactive fuel is being moved from the fuel pool is different from the risk while it is stored in dry casks. The level of risk during so-called SAFSTOR (moth ball period) is different from the risk we will face when the radioactive buildings and the soil below are being decontaminated.

Currently, the NRC and Entergy operate under the delusion that any radioactive releases – whether in air, water or in the earth – will stop at the boundary of the site. Such wishful thinking does not protect the school 1500 feet from the site, nor those of us living downwind.

3. Groundwater monitoring. To be honest, your loyal scribe could not understand the 7-page proposal. At November’s NDCAP meeting we learned that it was written by Entergy staff. Nuclear Decommissioning Citizens Advisory Panel Advisory Opinion – Groundwater Monitoring Nuclear Decommissioning Citizens Advisory Panel Advisory Opinion – Groundwater Monitoring

After the November NDCAP meeting, Dr. Irwin drafted a counter proposal. DRAFT – NDCAP Groundwater Advisory Opinion Counter-Proposal – Submitted 11.23.15 (Bill Irwin)

We support Dr Irwin’s counter-proposal, that the Dept of Health be funded to monitor groundwater. In the past, VT Dept of Health found tritium and/or strontium 90 in the groundwater when Yankee staff did not report finding any. “Split samples” we take to mean that both VY and the Dept of Health analyze the same samples/

“The citizens of Vermont have relied on the independent VDH laboratory analysis of split samples from the VY site and its surrounding public environment which have been published for more than forty years. This independence and ease of access to data is a cornerstone of Vermont’s public health system and it provides Vermonters greater confidence that their land, water, air and health are fully protected.”

The NDCAP subcommittee on issues to take on as future advisory opinions will be meeting Friday, December 4th, 2015 from 12:00 PM to 1:00 PM at the Windham Regional Commission (WRC), 139 Main Street, Brattleboro, Vermont. The meeting will be held in the WRC conference room. Like all NDCAP meetings, it will be open to the public. Remote access locations are listed on the NDCAP webage.

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