We write today to urge the Nuclear Regulatory Commission (NRC) to ensure a safe and expeditious decommissioning process at the Vermont Yankee nuclear plant at the time the plant ceases operations. Immediate decommissioning will assure Vermonters that the plant is being disassembled safely, and will provide an opportunity for current plant employees who are most knowledgeable about the facility to work to safely decommission it. The idea that Entergy, the owner of Vermont Yankee, will seek decades of delay before fulfilling their commitment to cleaning up Vermont Yankee is unacceptable.
Entergy has several times publicly indicated its preference for the use of the so-called “SAFSTOR” method of decommissioning. SAFSTOR would let Entergy off the hook for cleanup, waste disposal, and remediation of the plant site in Vernon, Vt., for years or even decades. Entergy Vice President Jay Thayer testified to the Vermont Senate Finance Committee that if the plant closes in 2012, [Yankee] would remain in SAFSTOR for a period of time most likely, most likely in a 15- to 20- year time frame."
While Entergy may prefer leaving the plant to sit like an abandoned factory because it has not saved the necessary funds to fully decommission the plant, this is not the safest option for Vermonters.
Unfortunately despite its name, the SAFSTOR option does not guarantee safe maintenance. The Dresden One facility in Illinois, while it was in SAFSTOR, had a frozen pipe burst when the heat in the building was shut off. This leaked 55,000 gallons of radioactive water in the containment building. According to reports, had the leak not been discovered by a night watchman after several days, additional frozen pipes could have burst and caused a serious radiation release.
All of this happened at a plant that still had other operating reactors and a full complement of engineers and personnel on site to address the situation.
* * *
The use of SAFSTOR at Vermont Yankee, if approved by the NRC, would be a rare and unwelcome exception. SAFSTOR may be more commonly used at sites with multiple reactors, where there would remain a full complement of site personnel. Vermont Yankee is a single-reactor site, and similar sites, including Maine Yankee and the Connecticut Yankee plant, were approved for the “DECON” option. This meant immediate decommissioning activities took place after operations ceased.
It is important to note that under the DECON option there remains significant flexibility, and according to NRC regulations, the decommissioning schedule and activities can be changed as necessary to respond to conditions and to protect the health and safety of workers and the public. The Connecticut Yankee plant selected “immediate dismantlement because it was the most practical and environmentally responsible option.”
As you know, the Vermont Senate, in an overwhelming bipartisan vote, has declined to authorize the issuance of a Certificate of Public Good for continued operation of Vermont Yankee beyond its sunset date in 2012. Immediate decommissioning at the time the plant ceases operations would allow Vermont Yankee to utilize its current employees' knowledge of the plant and their technical skills. According to Connecticut Yankee, immediate dismantlement was selected in part because it allowed for use of “current plant employees who were trained and knowledgeable about the facility.” Connecticut Yankee found that among the disadvantages of SAFSTOR is the fact that “few, if any, personnel familiar with the facility are available at the time of decontamination (up to 60 years after plant shutdown).”
The safe decommissioning of Vermont Yankee is an issue of enormous consequence for Vermont. Therefore, we request a meeting with the entire commission, as soon as possible, to discuss the NRC's oversight of Vermont Yankee and the decommissioning process. We will also invite Governor Peter Shumlin to join this meeting, because the state has a vital interest in the safe and immediate decommissioning of the plant.
For all of the reasons stated, we respectfully request that the NRC require immediate dismantlement of Vermont Yankee at the time its operations cease, and look forward to discussing this with the commission soon.