Opportunity Right Now to Comment on Decommissioning Plan

Time is Short!

In its agreement with the state of Vermont, Entergy promised to prepare several documents outlining decommissioning plans and costs.  Of course, it prepared the documents in a very timely fashion.

The best opportunity to comment on these documents is between now and Tuesday of next week. What's the hurry?  Well, the Bennington Banner explains it:

"Public comments on the draft PSDAR received by Nov. 25 will be considered for inclusion with the Public Service Department’s comments that will be provided to Entergy for incorporation with its PSDAR submittal to the United States Nuclear Regulatory Commission."

The Documents

You can find the links to the documents on the Entergy VYDecommissioning Document Library Page.  The two documents that are most relevant are the Site Assessment Study, and Appendix C: Draft Post Shutdown Decommissioning Activities Report .   Oh right....  I need to tell you that Appendix C is the PSDAR referred to above (Post Shutdown Decommissioning Activities Report). The Site Assessment Study is the SAS, of course.

I hope you will comment.

Comment on what?

Well, yes. What to say? We are talking about two rather dry documents, each about 50 pages each. Reading the documents would be best used as a way to fall asleep without a lullaby or a glass of brandy (depending on your age).  Luckily, however, your comment does not have to be as long as the document.  I have three suggestions for commenting on the PSDAR:

1) The fuel pool:
Not actually in the PSDAR, but the opponents will insist that storing the used fuel rods in the spent fuel pool is very dangerous and the plant must keep all warning and safety and emergency response measures in place. They will claim that all emergency systems must be fully staffed and tested for the entire emergency planning zone, and they must be in place until all fuel rods are removed from the fuel pool after five years.  However, Entergy has calculated the residual heat in the fuel pool and the various accident scenarios, and Entergy plans to shrink the 10-mile planning zone to the plant fence line after about a year. After about a year, the fuel is cool enough for this change.

Opponents oppose this, of course, and Vermont Senator Sanders is particularly incensed at the idea of shrinking the emergency zone.  He seems to think that fuel pools are infinitely dangerous. Meanwhile, at  Fukushima, with fresh fuel in fuel pool 4 and the roof falling in, just about the worst-case-scenario you can imagine....nothing happened.  No melting, no fires, and all the used fuel rods have been removed successfully.

Bottom line: You might want to write a note saying the fuel pool at Fukushima 4 was okay, and the fuel pool at Vermont Yankee will be fine, too.

2) GEIS:
The PSDAR refers many times to the General Environmental Impact Statement (GEIS) issued by NRC about decommissioning. The PSDAR explains how the Vermont Yankee decomm process is governed by that document.  The opponents will undoubtedly attack the GEIS and also attack the idea that Vermont Yankee's situation is covered by the GEIS.  Meanwhile, the PSDAR has elaborate and (sleep-inducing) descriptions of the various parts of the GEIS.

Bottom line: You might want to write a note saying how you found the GEIS to be more comprehensive than you expected (too much information!) and it will be a good guide to the decommissioning process.

3) Timing:

Oh baby. This is a big one.  On page 21 of the PSDAR  there's a time-line for decommissioning.  As Entergy promised, the first part of the decomm (removal of fuel from the fuel pool and into dry casks) goes as fast as possible.  This phase ends in 2021.  But then, the plant is in SAFSTOR as the radiation gets less and the trust fund grows.

In the table on page 21, Decomm is shown as complete in 2073. Site restoration is complete in 2075. It is 59 years (just shy of the 60 allowed by the NRC) between plant shutdown and license termination.  Governor Shumlin initially believed that SAFSTOR was not even allowed in Vermont. You can see chilling footage of Shumlin's statements in my blog post: In Vermont, Our Word is Our Bond, So We Don't Honor Contracts.

Despite Shumlin's odd ideas, SAFSTOR is allowed in Entergy's agreement with Vermont, and it is allowed by the NRC, and Entergy can choose it.

Bottom line: You might want to write something saying acknowledging that SAFSTOR is not the choice that many people in Vermont would have liked, but it is legal and allowed by contract. It is also  safer for the workers and the community allow radiation time to diminish before dis-assembling a plant.

Submitting your remarks:

IMHO, the State of Vermont is not making it easy to make comments. However, you can submit them.  To quote the Bennington Banner again:

Written comments may be mailed electronically to the State Nuclear Engineer at : anthony.leshinskie@state.vt.us. Please include “PSDAR/SAS Comments” in the email subject line. Written comments may also be mailed to the Public Service Department at Vermont Public Service Department, ATTN: PSDAR/SAS Comments, 112 State Street — Drawer 20, Montpelier, VT 05620-2601.

To facilitate the ease of compiling all comments received, please consider emailing comments as an attached MSWord or PDF document. When sending comments via US Mail, please consider using a Compact Disk and either MSWord or PDF format.


Why?

It's all part of the Entergy agreement with the state.  Entergy agreed to consider feedback from state agencies before submitting its documents to the NRC.  The Department of Public Service decided to take comments from the public.  And here we are, commenting...

To quote Chris Campany of the Windham Regional Commission (as quoted by Olga Peters in The Commons)

According to Campany, he asked the DPS to actively seek public comment.
“This is all voluntary on Entergy’s part,” he said of Entergy sending its draft reports to the state agencies for feedback.....
Ultimately, what appears in the PSDAR is “Entergy’s prerogative,” said Campany. “This is not a PSB process.”