Given the overwhelming vote by the Vermont Senate to reject Vermont Yankee's continued operation after its license expires in 2012, it's confounding that you, Chairman, chose this moment to visit VY and offer this meeting. Why not last January when the ongoing leaks as well as Entergy's misrepresentations became apparent?
I assume, Chairman, that you are not here to undermine this vote that expressed the will of the people of Vermont to pursue a state energy policy that does not include Vermont Yankee.
I can only assume the reason for the visit involves the continued problems that manifest at this troubled reactor and how the NRC intends to deal with Entergy and VY during this important transition period.
Entergy's systemic mismanagement and its delayed maintenance program - coupled with its repeated misrepresentation to state officials - are of great concern as Entergy prepares to close Vermont Yankee in 2012.
We are also concerned with the NRC's actions during this period.
We are concerned that Entergy will continue to delay maintenance and repairs since it will have little incentive with closure looming. We are concerned that both safety-related and non-safety-related (from NRC point of view) systems will be neglected and that problems will escalate. We have experienced repeated mishaps with the cooling tower collapse and the unending repairs to this deteriorating system, the transformer fire, endless leaks from nonexistent pipes, groundwater contamination, and refusal to implement state commitments in a timely manner.
We are also concerned that with closure, a number of issues will manifest.
Given the fact that upon closure there is no longer any NRC resident inspector required to work on site, how can we be assured that Entergy will do an adequate job of decommissioning when with a resident inspector it has fallen far short?
How will Entergy deal with the high-level radioactive waste remaining in its fuel pool? The National Academy of Sciences acknowledged that Mark I reactor fuel pools are most vulnerable to terrorism. VY's pool is located outside of containment, seven stories in the air, with a metal roof. It is essential that the fuel be moved as quickly as possible to on-site dry storage.
But we're also concerned with dry-cask storage.
With over 50 million curies of high-level waste in its fuel pool and no repository available for the foreseeable future, waste - upwards of 40 casks - will remain in dry storage for decades, if not centuries. Besides its vulnerability to terrorism and the need for hardening, it is “across the street” from two elementary schools on either side of the Connecticut River.
Even with Entergy buying up residential houses in close proximity to VY, there are concerns that the shine from these casks located so close to schools as well as residences compromises health and safety.
We believe that the creation of a Citizen Advisory Board to oversee the transition, closure, and decommissioning of VY is an important component of community outreach. The board would be a formal mechanism for community participation.
It should be organized by the licensee and NRC in conjunction with local government and community representatives. The board would meet regularly to give meaningful input into decisions concerning health and safety. It would function to educate the community to the issues involved in decommissioning.
Then there is your agency.
When NRC staff began holding meetings on Entergy's application for relicensing of Vermont Yankee and the repeated failure of its maintenance programs, 800 people attended the first meeting. The last I heard was attended by 10.
The community does not have confidence in the NRC as a regulator with a mission to protect its health and safety; NRC has frequently been experienced as an extension of Entergy. These concerns preceded relicensing and increased substantially with the uprate proceeding.
The leaking of tritium into the groundwater - whether it left the site or not - is a violation of the public trust. NRC is experienced as being nonchalant in response to this violation and the corporate culture that allowed these nonexistent pipes to leak for months on end unabated.
No one came to the community while the pipes were leaking; no meetings by Entergy or NRC were held to update the community and answer questions. Only months later, when the leaks was found, pipes were repaired, and a contamination cleanup plan was in place did Entergy, NRC, and the state show up. This was too little, too late.
And I am concerned that your decision to visit Vermont Yankee and our community may well add to that perception. There is a great opportunity to create a successful model for reactor closure that includes meaningful public participation. We hope that you choose to make this a reality.