Draft Principles for Decommissioning

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  • DRAFT 01-03-14

    DRAFT by the Safe & Green Campaign – Principles for Decommissioning Vt Yankee

    Since Entergy Corporation purchased the Vermont Yankee reactor and the decommissioning fund in 2002, a multi-billion dollar out-of-state corporation has tried to wring every penny it could out of a poor bet, resulting in law suits, leaks, and lies to our legislators and regulators. Now it is asking us to put aside the past and trust it to make a bargain with the state.

    We, the people of Vermont, New Hampshire and Massachusetts living in the evacuation zone, are impacted by every decision Entergy makes. We are between a rock and a hard place: trying to safeguard a legacy of nuclear waste and clean up the site on the Connecticut River, and ensuring that the costs are covered by those responsible.

    Decommissioning and restoring Vermont Yankee’s land will impact our homes and families for many generations. We call for:

    1)         the safe and prompt decontamination and restoration of the site for productive use

    2)         moving all spent fuel from the pool to onsite dry cask storage as soon as is viable

    3)         the long-term containment and safeguarding of all spent radioactive fuel

    4)         an independent assessment of the site

    5)         Entergy Corporation of Louisiana to fulfill its pledge to fully fund the costs of the cleanup and restoration of the Vermont Yankee site.

    Here is why.

    VY WORKERS KNOW BEST

    Begin work on closing the reactor and decontamination promptly, using experienced Yankee employees. The current workers of Vermont Yankee know the site. They know what changes have been made and where. Schematics and blue prints may not have been updated.

    INDEPENDENT SITE SURVEY

    We need an independent survey of the site while experienced Yankee employees are on site, so a thorough and accurate decommissioning plan is written.  Experience shows we cannot trust Entergy to tell the NRC or the State the true condition of the structures and what radiated materials are below the surface of the site. For example, in 2008 the legislature appointed a Public Oversight Panel (POP) to inspect Vermont Yankee. POP oversaw the work of an independent assessment firm which had no ties to Entergy, and 81 corrective actions were identified. Entegy made “incorrect statements” to POP (and to the PSB) about the existence of underground pipes and when the pipes began leaking tritium, the truth was revealed. Entergy can certainly not be trusted to give a thorough report on what is contaminating the soil, the water or the buildings

    Even if management changes have turned its corporate culture to Honest Abes, the decades of cover ups and obfuscation will cast a cloud of suspicion over any self-assessment.

    DIG SAFE

    Entergy must dig safe: remove all irradiated structures and soil, regardless of how deep. For over forty years, the reactor building, cooling towers, turbine building, tunnels and pipes been irradiated.  Much of these are 40 to 50 feet below the surface, not just above it. In addition, tritium was discovered leaking 300 feet below grade.

    When Entergy bought the reactor, Entergy agreed to “remove all structures.” We need to ensure that “structures” is defined to include what is below as well as above the surface – basements, tunnels, pipes, etc. We have not forgotten “underground pipes” versus “buried pipes” and do not want to waste state money and time on symantics.

    FUEL POOL

    Entergy must remove all spent fuel from the pool and reactor core as soon as it is safe to do so. The most dangerous part of the site is spent fuel in the fuel pool.  Yankee was licensed to hold 600 fuel assemblies; as of October 2013, 2,650 assemblies are in the fuel pool, which is located on the top of the reactor building. In addition, there are 370 assemblies still in the reactor core. There is a lot of old fuel in the pool which can be moved into dry casks immediately. Fresher fuel can be moved in five to seven years.

    PAYING FOR DECOMMISSIONING AND RESTORATION

    Entergy Corp., ENVY & ENO must be held jointly responsible for decommissioning and full restoration of the site. From 1982 until Entergy purchased the reactor in 2002, Vermonters’ electric bills included payments into the decommissioning trust fund. Entergy purchased the trust fund along with the rest of the business, and never put another penny into it. The fund’s growth is risked on the stock market.

    The “home office,” Entergy Corp in Louisiana, created limited liability partnerships to protect itself from risk: Entergy Nuclear Vermont Yankee (ENVY) holds the money, and Entergy Nuclear Operations (ENO) runs the reactor. Either could declare bankruptcy and abandon any responsibilities to clean up, and Entergy Corp. would be protected.  Any money needed to clean up the site above what is in the decommissioning trust fund would have to be paid for by the State – we the tax payers.

    Entergy is offering by $60 million to Vermont in economic incentives and $25 million for site restoration – which may look like big bucks in Vermont. But Entergy Corp had revenues of $11 billion and profits of $1.3 billion in 2012, according to Forbes. Entergy Corporation must be held accountable and required to pay full costs of decontamination of the site and restoration.

    Entergy Corp. should put contribute to the fund now. The citizens of Vermont should not pay to clean up its mess, nor should Vernon become another nuclear waste sacrifice zone.

    CITIZENS VOICE

    We must act now. Next year will be too late. Send a message to the PSB and your legislators.  The legislature needs to get a strong message from the people, and they need to get it this year. 2014 is last chance the legislature has to act before Vermont Yankee turns off the power and the state loses any leverage it has. The fate of our region will then be in the hands of Entergy Corporation and the Nuclear Regulatory Commission.

    By NRC rules, the owner of the reactor submits a plan and the NRC approves it. Safe and Green Campaign finds it an affront to democracy that NRC rules do not require any testimony from the state regulators, citizens, neighboring land owners, local residents or other stakeholders on the future of the site.  Our only opportunity, and the state’s, is to speak is during two public comment periods.

    VERMONT’S EXPERIENCE MATTERS

    Vermont Yankee is the first merchant reactor to decommission in a state with a history of activism and an engaged regulatory system. Public utility commissions, governors, and energy and environmental activists around the country are watching to see what precedent is set in this conflict between an energy corporation and the citizens.

    Of the 40+ years of anti-nuclear activism by the people of Vermont, Massachusetts and New Hampshire, this is our most important battle. It is a battle over who controls the legacy of radiated waste and the irradiated land and the river that will impact our region for many generations to come: the citizens who live there, or the corporation?

    Click here for more Resources on Decommissiong Vermont Yankee