Write a comment! Support New York Nuclear Plants

Fitzpatrick plant

The Clean Energy Standard

New York State has proposed a Clean Energy Standard which would support not just renewables, but ALL clean energy, including nuclear power.  Implementing this standard would keep the upstate nuclear plants operating.

The comment period on the standard was supposed to close tomorrow.  But, the comment period  has been extended until Friday July 22.  Here's where to comment.

http://documents.dps.ny.gov/public/Comments/PublicComments.aspx?MatterCaseNo=15-E-0302

What is the Clean Energy Standard?

It's a proposal to support all clean energy power plants: both renewable and nuclear.  Here's the staff proposal under current review:

https://www.scribd.com/document/317819837/PSC-staff-proposal#from_embed

And here's one of many newspaper articles on the subject:

http://www.syracuse.com/news/index.ssf/2016/07/nuke_subsidies_ny_extends_comment_period_but_aims_at_aug_1_decision.html

Michael Shellenberger has an excellent article on the subject: http://www.environmentalprogress.org/big-news/2016/7/13/in-wake-of-deal-to-save-fitzpatrick-james-hansen-other-scientists-environmentalists-urge-new-york-to-protect-nuclear-plants

Please comment  and post about it and send links to your friends in New York State!

It is also worthwhile to comment on some of the newspaper articles, but the main thing is: comment to the New York Department of Public Service.   (This is the same link as the first link.  I'm just trying to make it VERY easy to get to the place where you can comment to the New York Department of Public Service.)

The comment extension

Ummm....the people who asked for the comment period to be extended are NOT friends of nuclear energy. You can bet that they are getting their act together  for a major blitz next week.

Send in your pro-nuclear comments!
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Examples and ideas for comments

The  Environmental Progress organization has good information and example comments on this Google Drive.  


https://docs.google.com/document/d/1rp5WnQ2s3BwFYohdJr9Zud2ipLoV6vrHZO4f7TMNYlI/mobilebasic

My own comment is below:

Nuclear is the largest source of zero-emissions energy in New York State.  If we are serious about lowering (or holding steady) on carbon dioxide, we must keep the nuclear plants running.  I live in Vermont, and when Vermont Yankee closed, the carbon emissions on the New England grid rose by 5 to 7% by various calculations. The 7% is from Utility Dive magazine, an industry publication.  It is based on numbers from the New England grid operator.  http://www.utilitydive.com/news/iso-ne-emissions-rose-after-vermont-yankee-nuclear-facility-closed/414404/

All existing zero-emission sources need support!  If people pick and choose: ooh, I don't like nuclear or ooh, I don't like hydro or ooh, wind turbines are terrible, then these existing  zero emission sources WILL be closed.  And they WILL be replaced by fossil.  It is as simple as that, really.

I am in favor of nuclear for the future, but if someone doesn't like to build more nuclear, that is about policy for the future.  For  right now: Keep and Support the Existing Zero Emissions Sources that we have!  Close Fossil First!

Renewables are heavily supported for their zero-emissions qualities, and nuclear deserves some similar support.

Please move forward on the Clean Energy Standard to protect our zero-emission sources.

Comments needed for Diablo Canyon

Diablo Canyon (from Wikipedia)

The California Energy Commission is asking for comments on its Integrated Energy Policy Report.   Somehow, this slipped by me....today is the last day for comments.

I urge you to comment and to defend Diablo Canyon.

 The comment link:

Here's the link for comments:
http://www.energy.ca.gov/2015_energypolicy/

Within the link, you can see the whole report.  Since this is the last day for comments, I will make your life easier by quoting relevant sections.

http://docketpublic.energy.ca.gov/PublicDocuments/15-IEPR-01/TN210069_20160128T104129_Energy_Policy_Report_Proposed_for_Adoption.pdf

 On page 238 of this document, you can see the following few sentences: Diablo Canyon continues to generate power under the current licenses, which are set to expire in 2024 and 2025., even as Pacific Gas and Electric (PG&E) works is working to address several regulatory and policy issues at both the state and federal levels in preparation for a possible relicensing of the plant in the near future. At the state level, the State Water Resources Control Board (SWRCB) and the California State Lands Commission will be making critical decisions regarding Diablo Canyon’s use of once- through cooling and its land leases, respectively.....

 And on page 248, this: In May 2015 CPUC President Michael Picker sent a letter to Christopher Johns, president of PG&E, reminding PG&E that “review and approval of PG&E’s request for ratepayer funding related to license extension of Diablo Canyon at the California Public Utilities Commission...will involve a thorough assessment of the cost-effectiveness of the license extension for Diablo Canyon considering the plant’s reliability and safety especially in light of the plant’s geographic location regarding seismic hazards and vulnerability assessments.”...


What to say?

Oddly, despite the usual endlessly-long-energy-planning report, you can say something simple:

If Diablo Canyon closes, there will be more greenhouse gases in California.


Shellenberger response:

Where to get information for your comment? Michael Shellenberger has submitted an excellent comment on this subject, and you can easily mine his work for information. http://docketpublic.energy.ca.gov/PublicDocuments/15-IEPR-01/TN210106_20160201T072714_Energy__Environmental_Implications_of_Diablo_Canyon_Closure.pdf

You can also see his material at this website, where it is easier to download. http://static1.squarespace.com/static/56a279041a5203ba6b06966e/t/56afdbb186db431e6d55dccb/1454365621994/Diablo+v11.pdf

In his section on Environmental Consequences of Diablo Canyon closure, Shellenberger notes that:

Closing Diablo Canyon would be the equivalent of putting two million more cars on the road.   From the Shellenberger presentation:

Ahem. Do not be intimidated by the depth and quality of this presentation.  Diablo Canyon needs voices in its favor, and short posts are also important!

There are other pro-nuclear comments out there.  I encourage you to find posts by Gene Nelson, for example. In a few minutes, my own post should be up. 

Ah.  Here's my comment. http://docketpublic.energy.ca.gov/PublicDocuments/15-IEPR-12/TN210164_20160205T085145_Meredith_Angwin_Comments_Less_nuclear_means_MORE_natural_gas__K.pdf

However, don't worry.

Just get your post out there.  Select "Nuclear Power Plants" in the select menu at the right, and go forward. Support Diablo Canyon!

My Comment to the NRC in favor of abandoning LNT and ALARA for rule making

Comment on the petition

Recently, three distinguished scientists have filed an NRC petition, asking the NRC to re-visit the radiation protection rule-making which is based on the Linear No Threshold (LNT) assumption, and the consequent ALARA (As Low As Reasonably Achievable) rules.

I posted about this yesterday, also.

Here's the petition in the Federal Register. The comment period is open until September 8, so you have a few days to file your comment.  Please comment.

Update: The comment period is now open until November 19.  (Yes, it surprised me, also.  See the third page of this pdf.)

My Own Comment to the NRC

I support these petitions to base radiation protection on science, not on the assumed linear relationship between harm and dose.

There are very few biological systems that have linear responses between levels of dose.  For example, selenium is both a dreadful poison and an element necessary for life and reproduction.   The effect depends on the dose.  It is not a linear straight-line relationship in which selenium is always harmful but gets more harmful as the dose gets higher.  At low levels selenium is beneficial.  At high doses, it is harmful.

Similarly, the effect of radiation on biological systems is not straightforward.  People living in the mountains, or on granite bedrock, have no more cancer or birth defects than people living with less background radiation.  There is some evidence that radiation is beneficial at low doses: for example, recent experiments in which low doses of radiation extend the life of fruit flies.

(Fruit flies are often used for experiments on genetics.  Example of recent work: http://medicalxpress.com/news/2015-08-weak-doses-prolong-life-female.html   )

Whether or not this type of effect (hormesis) is present for humans is still unclear, in my opinion. But it is clear that, at normal background levels at least, a little more radiation does no harm. The linear-no-threshold hypothesis is unproven, useless, and unreasonable.

What the linear non-threshold assumption (for that is all that it is) has done is simply add to expense and anxiety. It leads to ALARA, which is very bad rule-making.

Imagine that all regulations were based on ALARA.  Let's say my town water supply meets all the criteria for purity that such water supplies must meet.  I could go to my select board and insist that they lower the concentration of a certain contaminant by 50%.  They would say that the town supply met all the requirements for water purity.  I would respond that they are being unREASONABLE.  With an ALARA-regulated water supply, if they CAN lower the concentration REASONABLY (and I get to decide what is reasonable), they are required to do so!  It doesn't matter that the water is already safe to drink.  If they were just willing to spend more money, it could be even…well, not safer, but certainly more expensive water!

In short, ALARA must be rescinded.  The very word "reasonable" is unreasonable.  "Reasonable" according to whom?  How much money is it "reasonable" to spend to achieve yet-lower results? And whose money gets spent this way?

Society has many problems and limited resources to address these problems.  I recently read an article showing that NOx (nitrogen oxides produced in combustion processes, and a precursor of ozone and smog) can hide out in soot deposits and re-emerge later, in a more virulently active form.  Perhaps cleaning the soot from city buildings might make city air more wholesome! http://www.bbc.com/news/science-environment-33970233

We have many real gains in public health available, if we can spend the money.

Spending money on radiation ALARA (make it lower and lower and lower) is completely unreasonable.  Unless you are prepared to decide to evacuate Denver for its high background radiation, I hope you will stop insisting on regulation according to LNT and ALARA.

Write a Note for California

Diablo Canyon from Wikipedia

Citizens For Green Nuclear Power

In California, Californians for Green Nuclear Power is supporting the continued operation of the Diablo Canyon Nuclear plant. This citizen's group is entirely volunteer and self-funded.  Several of them recently carpooled to Sacramento to testify in front of the California Energy Commission.

Now you can help them, help the nuclear industry, and help Diablo Canyon!  But you have to do it by 5 p.m. today. (California time).

A group called Alliance for Nuclear Responsibility has accused Diablo Canyon of not being seismically safe because the plant supposedly did not analyze the effect of a huge earthquake…directly under the plant!  The Alliance does not acknowledge that scientists analyze earthquakes by analyzing the result of earthquakes due to faults, not earthquakes that that they assign to occur at random locations.

Please submit your comments here.  DO IT TODAY!

https://efiling.energy.ca.gov/Ecomment/Ecomment.aspx?docketnumber=15-IEPR-12

You don't have to write anything very lengthy.  Just say that PG&E did an excellent review of seismic safety in the 2012 time-frame, and that the NRC regularly reviews seismic safety in terms of new data.  Or say whatever you want to say, in the words you want to use.  Just do it!

Background

Here's the PG&E report: Central Coast California Seismic Imaging Project. I found the first pages of the Technical Summary the most useful.

Gene Nelson has single-handedly uploaded many comments in response to the Sierra Club and other comments.  Let's help him.  Here's the docket, and you can see his comments.

Update! Send Your Comment to the EPA! Here's Mine.

UPDATE:  Today, December 1, you can still comment on the  EPA rule which gives nuclear power credit for only 6% of the carbon that a nuclear plant mitigates.  

Here's my blog post on the rule: Support Nuclear This Weekend

But more important, here's the link to the American Nuclear Society page about the rule. This page includes explanations and a link to the EPA comment page.
http://www.ans.org/epa/
Here's a direct link to the EPA instead, if you prefer
http://www2.epa.gov/carbon-pollution-standards/how-comment-clean-power-plan-proposed-rule


Below is the comment I sent in.  It's not a perfect comment, but I will say that it meets some of the criteria for a good comment: it includes my name and address, and it is unique to my situation.  Looking at it today, however, it seems a bit wordy.

Write your own comment!  Make it briefer than mine!
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My name is Meredith Joan Angwin. I live in Wilder Vermont. I blog at Yes Vermont Yankee and I am a member the American Nuclear Society.

I want to say that the way the carbon pollution regulations are written now, when Vermont Yankee closes, IF it were to be replaced with gas from Canada supplying a natural-gas fired unit....the rules would say that the carbon dioxide emissions from Vermont would go DOWN, when the actual emissions would go UP.

Now, I am well aware the Vermont doesn't fall under these rules, because we basically only have Vermont Yankee, some hydro and some biomass in-state. So we didn't have to come up with a mitigation plan. However, these rules are backwards. You give nuclear (either existing or being built) credit for about 6% of its emissions reductions. However, any plant (coal or nuclear) that is replaced with a natural gas plant is part of the state's mitigation strategy.

Replacing coal with gas lowers the state's greenhouse gas emissions, replacing nuclear with gas raises the emissions, but it's all the same to the rules as they are formulated now.

I know that people love natural gas plants. "Clean natural gas, lower carbon than coal." But I am on the Coordinating Committee for the ISO-NE (grid operator) Consumer Liaison group, supposed to be the "voice of the consumer" advising the grid operator. I want you to know that consumers suffer when the grid does not have a diversity of supply. In the Northeast, massive price rises of electricity (25%, 40%) are happening this winter, because there's a winter supply crunch on natural gas.

The grid needs diversity so that the lights will stay on even if one type of fuel is unavailable. Yet your current rules would force the grid into renewables-with-natural-gas-backup. Even with different types of renewables, that is NOT diversity. Are you aware that the capacity value for wind in the Northeast is only about 13%? (I've heard lower values at seminars, but I'm going with a EIA report here. http://www.eia.gov/todayinenergy/detail.cfm?id=1370.) The capacity factor for wind in the Northeast is about 25%--that is, the wind blows enough to turn the turbines about 25% of the time. But the grid operators must look at whether the wind will be available when it is needed. That's the capacity value.

Basically, if you don't give nuclear more credit, the grid will inevitably go to renewables for reducing greenhouse gas emissions (but they will have with low capacity values). Then natural gas, with greenhouse gas emissions, will make the inevitable difference. In other words, there will be a nationwide grid that, like the Northeast, is overly dependent on natural gas, with all the price and supply problems that entails.

Originally, I worked in renewables. I was a project manager at the Electric Power Research Institute and I wanted renewables to do it all. Then, painfully, I realized they couldn't. Since I had already worked on the extremely difficult problem of lowering NOx emissions from fossil fuels, I gradually came to realize the virtues of nuclear power. Now I am devoted to it as a substitute for coal. Nuclear power PLUS renewables PLUS some natural gas will help with climate change. But if you don't give nuclear more credit in your calculations, the entire U S grid will be in the same shape as the Northeast grid. Overdependent on natural gas.

And that's not good. Give nuclear plants 100% of the credit for the greenhouse emissions they avoid. It's only fair, after all. I don't know how you got this 6% solution for nuclear, but its wrong. Luckily, there is still time to fix the problem!

Sincerely,
Meredith Angwin

My Comment on the Vermont Total Energy Study

You Can Comment on the Total Energy Study

Comment Period Closing On Wednesday January 22

The Vermont Department of Public Service has written a new planning document for Vermont's future energy use: The Total Energy Study Legislative Report.  You can link to the report and its back-up documentation on the Total Energy Study web page of the Department of Public Service.   You can also link directly to the report and appendixes.

The public comment period on this study is only open through Wednesday, January 22, 2014.  To write a comment,  use this email address: PSD.TotalEnergy@state.vt.us.

I encourage you to comment.

My Comment to the Department of Public Service on the Total Energy Study

Dear DPS

First, a thank-you to Asa Hopkins for sending me information about the RFP for the total energy study.

Second, a comment on the study.  It's a document about setting policy, and most of the policies seem to be financial. There are requirements to use renewable fuels, with financial burdens imposed if you don't (TREES), carbon taxes, etc. 

With this study, the stick is in place to drive the state energy use to 90% renewables, but...where's the road?  We're whipping the horse, but where is the horse heading?  What will 90% renewables look like for the whole economy?  More wind turbines?  Only biodiesel and ethanol fuel sold in Vermont?  A law against private vehicles unless they are electric?  What is the goal here?

In my opinion, by not analyzing actual technologies and how they will be employed, the study is basically a cop-out. I am sorry to say this, because I was hoping for something better in terms of Vermont's future energy use.  Time, energy and intelligence went into this study. In some ways, the study is quite admirable.  It is, however, the wrong study for setting goals for our energy future.

Meredith Angwin
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Background on the Total Energy Study

Basically, the Vermont Comprehensive Energy Plan was put into place in 2011.  This plan mandates  90% of all of Vermont's energy will come from renewables in 2050. Despite its title, however, the Comprehensive Plan does not contain an actual plan for achieving this goal.  (I wrote about this disconnect in an earlier blog post and op-ed.)

By legislative requirement, the Department of Public Service is putting together a Total Energy Study on how to move toward the goal.  To date, in my opinion, the Total Energy Study has focused mostly on financial policy incentives (carbon taxes, fuel switching with targets for renewable content of fuels, cap and trade schemes).  There's also some discussion of methodologies for evaluating technology choices.  

Here's my blog post about the Total Energy Study: Renewables plus Taxes: The Total Energy Study.

Please comment, I think

So, here I am, urging my readers to comment on the study, but frankly, it is difficult to comment on it.  The people at the Department of Public Service have worked hard on the Total Energy Study, but it is not easy to get a handle on the study or recommendations.  To me, reading the study didn't feel like reading an energy article ("how many wind turbines might be built under this scenario?") but instead, it felt like reading something in a political science course.  

Finally, I realized that: my confusion was actually my comment!  So I commented as above.

I urge you to read the study (or at least the executive summary) and write your own comment.

Comments to the Public Service Board by Tomorrow

Important Update

Appeals Court Rules for Vermont Yankee!

In a sixty-page ruling, the federal appeals court upheld the lower court ruling that the state had overstepped its authority in attempting to shut down Vermont Yankee.

Here's a link to the WCAX story on the ruling, which includes a short video.  Here's a link to the ruling itself.  Here's the AP story by Dave Gram, with some excellent quotes from the ruling.

I have not read the entire ruling, but it apparently affirms the role of the state Public Service Board in approving Vermont Yankee.  So comments to the PSB are still VERY useful and important!  So send in your comments!  Here's the link to the comment form for this docket. http://psb.vermont.gov/docketsandprojects/public-comment?docket=7862



Comments in Favor of a Certificate of Public Good

Howard Shaffer
At a Rally for VY

Vermont Yankee requires a Certificate of Public Good from the Vermont Public Service Board  in order to continue to operate.  The Board is still accepting public comments regarding the petition. The Board does read all the comments.

As far as I can tell, comments will be accepted through the end of the month, but it is best if they are sent by Thursday, August 15. That is TOMORROW.  (The PSB schedule is a bit unclear, and comments may be  accepted later than tomorrow, but better to be safe than sorry.)

Send your comments by tomorrow night, if you can.

You can submit a comment by clicking here.

How to Get Started

Use your own perspective in your comments.  For example, if you are concerned with global warming, you might want to comment about Vermont Yankee's low-carbon electricity.  If you are involved in real estate, you could discuss the impacts the closure of the facility would have on property values in the area.

Please share this link with friends and family and encourage them to voice their support as well.

Short Comments are Fine!

Long, thoughtful comments are always very welcome, but one or two sentences in support of the plant are very helpful.  You can write a great letter, or you can write a short postcard!  We have some inspirational comments below. 

Peter Lothes
Speaking at November PSB hearing

Inspiration from Others

Here are links to three (of many) inspiring comments made to the Public Service Board in favor of the Certificate.

Dianne Amme's excellent short comment: Affordable, Reliable Electricity 

Peter Lothes comment on Vermont Yankee versus other sources: Power, Carbon and Costs

Lindsay Rose on economics: Young Workers in Windham County

The Importance of Vermont Yankee

Here are some facts about Vermont Yankee that may be helpful to your writing.

Vermont Yankee is a key component of the area's economy and community.  Here are a few reasons why its operation until 2032 is important for the region:

• Vermont Yankee is a valuable employer. It provides more than 600 jobs in the area, and is a key source of clean and affordable electricity for the region.
• Vermont Yankee provides millions of dollars of revenue for state and local government, as well as donating tens of thousands of dollars to local non-profits.
• Vermont Yankee provides both jobs and critical economic activity for the State of Vermont. Closing the plant would undoubtedly cause many young Vermonters to leave the state in search of jobs.
• Vermont Yankee is a clean, low-carbon manufacturer power source and will be a critical element of Vermont's energy future. The plant's ongoing operation can help incorporate new sources of clean and reliable power while stabilizing electric rates.



Dianne Amme speaking
at November PSB hearing

• Unlike coal and gas plants, Vermont Yankee is a very low-carbon energy source.  It also avoids the many types of air pollution (acid gases, particulates) of most other base-load sources of power.

Just Do It!

Make sure the Public Service Board hears what YOU have to say!

http://psb.vermont.gov/docketsandprojects/public-comment?docket=7862

What Determines the Comment Stream? One Post, Two Sets of Comments

Carbon dioxide and nuclear energy

Recently I wrote a post about carbon dioxide and nuclear energy. Specifically, I posted about why people concerned with climate change seldom talk about nuclear power (though it is a VERY low-carbon source of electricity) and why pro-nuclear people like myself rarely mention climate change.

The simple answer for both groups (climate-change activists and pro-nuclear activists) is that we are both afraid of losing our core supporters.  Pro-nuclear people are often conservative and do not believe climate change is a major issue.  Climate change activists are often liberal and don't approve of nuclear power.  If a speaker crosses the line to say: "we need nuclear" (in front of a climate change group) or "nuclear will help prevent accelerated global warming" (in front of a pro-nuclear group)...well, that speaker will probably lose half of her audience.

My original post appeared in my blog, Carbon Dioxide and Nuclear Energy: The Great Divide and How to Cross It. It was syndicated by The Energy Collective and appeared on their site, also.  The post received a lot of comments both places...as a matter of fact, 34 comments on both sites. The Energy Collective recently sent their contributors an email that contained a  Leaderboard (part of the Leaderboard is at the upper left). From that board, I learned I had written the top-commented post for July.  I decided I would look a little more closely at all the comments.

Before I talking about the comments, however, I want to note that my friend Suzy Hobbs Baker has written an excellent post on the same subject at ANS Nuclear Cafe today. Climate Change and Nuclear Energy: We Need to Talk.

The Comments and the Numbers


The Energy Collective is a much bigger site than Yes Vermont Yankee, and that is reflected in the number of people who read the post on the two sites. As of this writing, 710 people have read my post at The Energy Collective, and 392 have read it at my own blog.

The comment streams on the two posts were so different that they might as well have been about different posts.

The Energy Collective comments started with a discussion of renewables but quickly moved to  the idea that nuclear was not implemented safely, and then went on to a discussion of thermodynamics and Ocean Thermal Energy (OTEC).  Rod Adams, Paul O, Aggie Engineer and I were sticking up for classical thermodynamics and heat transfer, while others argued against what the second law tells us about the requirements of heat engines.  My favorite quote was from Aggie Engineer. He said I should think of myself as "grief counselor"  as people came to terms with the second law.

OTEC Diagram from Wikipedia

The Yes Vermont Yankee comments riffed from my statement that nuclear had many advantages over fossil fuels, besides the global warming argument. The main discussion was about the advantages (or not) of nuclear power.  People quoted article after article, source after source, to make their points.  Kit P has had a guest post on my blog and commented extensively on this post. He had many references about the way fossil fuels have been cleaned up, but Aaron Rizzio and Gwyneth Cravens had rebuttals. Naturally, Kit P had rebuttals to them, also.

The comments also included references to Vermont energy sources and the effects of thermal pollution and pumped storage on the Connecticut River.  In other words, many of the comments on my blog were more detailed and closer to home than the comments on The Energy Collective blog.   I am sorry to say there was also more snideness on my blog, crossing the border to ad hominem attacks.


Vermont is a Small Town,  and so is Yes Vermont Yankee

Most of the posts, on both boards, were about the science: thermodynamics, OTEC, ocean acidification, coal plant clean-up.  There were very few comments about the politics: who speaks about global warming, and in what context.  This is probably because both blogs are technology-oriented.

My blog was more like a small town discussion, getting right down to talking about Connecticut River issues and getting snide.  The Energy Collective comments took a wider view.

I guess that is what would be expected.

I am grateful for everyone who commented on either of the posts!  Thank you all!

PSB Update: Send Your Comments

At this point, Vermont Yankee has asked the Public Service Board for a Certificate of Public Good.

The Public Service Board is accepting comments on the Vermont Yankee docket today (March 6) and tomorrow (March 7). The Public Service Board docket on Vermont Yankee is at http://psb.vermont.gov/docketsandprojects/electric/7440 and the form for sending comments is at http://psb.vermont.gov/docketsandprojects/public-comment?docket=7440

As I wrote in an earlier post, the Board is contemplating a pocket-veto of Vermont Yankee (gosh, we didn't rule by March 21, too bad!). Or possibly, forbidding Vermont Yankee to store more fuel, which would also cause the plant to shut down. You can read the Board's questions to Vermont Yankee at my web site, or within the PSB docket as above.

Send a form

Send a form to them today. I have sent two, and you can use these as a guide for your own letters, if you choose. Let them hear from Vermont Yankee supporters!

It is best to keep your comments short and to the point. If you have several points to make, send several comments.

My pocket-veto comment

As a citizen of Vermont, I urge you to take the high road and NOT attempt to pocket-veto Vermont Yankee's operations. Please obey your own laws, particularly the one that says "3 V.S.A. § 814 ....an existing license does not expire while a timely and sufficient application for renewal is pending relate to these explicit commitments and orders"

Treat the Entergy docket according to the same laws you use for other dockets: a certificate is still good until a new ruling takes place.

My fuel storage comment

It appears that you may be contemplating attempting to limit Vermont Yankee's operations by limiting spent fuel storage at the plant. You claim that "it appears that this (spent fuel) provision has not been pre-empted by the district court."

I urge you to read the entire ruling by the judge, rather than interpret it line-by-line for your own purposes. The major thrust of the ruling is that a state cannot regulate radiological safety. There is no reason to regulate spent fuel storage EXCEPT for concerns with radiological safety. Without radiological concerns, a spent fuel cask can be described as a cylinder of concrete containing ceramic pellets.

Don't regulate on radiological safety. You will be rather quickly overruled by higher courts, and you will waste the taxpayers money.

Send your comments here, too

Send a copy of your comment to this blog to be posted in the comment area. Then others can be inspired, also!

Vermont Yankee: Three Insights from the NRC Review Meeting

Two nights ago, June 22, I went to the NRC meeting reviewing Vermont Yankee's 2010 performance.

About 200 people came to the meeting. The NRC planned to spend half an hour on its own presentations, and two hours "addressing public questions." Here are some insights that I had about the opponents, the meeting and the NRC.

1) Fact: Vermont Yankee opponents do not want to listen to the NRC.

Forty-four people submitted questions or comments to the NRC. Many of the questions were multiple questions, and many of the comments were harangues. The NRC people soldiered on, attempting to explain what they could. NRC staff said things such as: "That's a very good question, about water in the cable pipes, and I made this issue my project for the year. Pipes were drained...."

The crowd was visibly annoyed with the NRC responses. Eventually the crowd had had enough information. One woman told the NRC not to respond to her; she didn't want to hear their answers. After that, a shout came from the audience that they had had enough NRC "tongue-wagging" and it was time to let the audience "have a chance." The audience clapped its approval of this statement.

My Insight: Opponents don't trust the NRC and won't even listen to what the NRC says. The NRC review meeting is just another chance for an anti-nuclear rally.

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2) Fact: According to Vermont Yankee opponents, the non-existent deaths from the nuclear accident are the most important thing that happened in Japan.

At the beginning of the meeting, the NRC asked for a moment of silence for the tens of thousands of people who lost their lives in the earthquake and tsunami in Japan.

Later, one person had her turn to comment: she said was "personally offended" by the silence for the earthquake victims. She was upset that the NRC had forgotten the Fukushima victims. Another comment was: "earthquakes and tsunamis have happened and will happen. The real tragedy is the nuclear tragedy. People will die and the land is ruined forever."

The audience clapped in support of the woman who was offended by the moment of silence. They also clapped and hooted in positive response for anyone who said that they were "very frightened" about nuclear safety, or that their children were not safe, or that the NRC didn't keep people safe, etc.

My Insight: Opponents of nuclear energy are kind people--as individuals. In this audience, they showed themselves cruel and indifferent to other people's suffering (hey, tsunamis happen) but exquisitely attuned to their own fears.

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3) Fact: Signups for speaking were a mess, two years in a row.

Nearly two hundred people came to the Vermont Yankee review meeting this year, and about 45 (including myself) signed up to ask questions. Since there were less than three hours for questions and responses, this was not going to work. Some people were not going to have an opportunity to ask their questions. But which people?

Last year, the NRC had multiple sign-up sheets for questions. You might be the first one to sign up, at the top of a sheet...but be twentieth in line to speak. This made people angry.

This year, you handed in a card. The NRC collected the cards and decided the order in which people spoke. The NRC had elected officials speak first. Next came prominent anti-nuclear activists such as Paul Blanch and Ray Shadis. At that point, one man from Vermont Yankee tried to speak, saying he was an elected union official. The NRC wouldn't let him speak because he wasn't a "real" elected official. The NRC's choices seemed very arbitrary. Not everyone was able to speak.

My Insight:. When running a meeting, you should announce in advance the order in which people will be allowed to speak. The NRC does not do it right. They have lots of practice running meetings so I don't understand the problem. Frustration and anger about speaking must happen at NRC meetings all over the country.

For another overview of the meeting, I recommend this article by Olga Peters of The Commons of Brattleboro.

Dice image from Wikipedia

Inspiring Testimony Sent to the PSB

As I wrote in yesterday's post, there's a meeting tomorrow (Thursday) night at 7 at Brattleboro High School The PSB will meet about Docket 7600, the docket for shutting down Vermont Yankee early. I encourage people to attend this meeting. (There's more information about this docket in my post yesterday's).

However, not everyone can attend such meetings. However, you can submit comments to the PSB by email. File a comment using the PSB general Comment Form. I wrote my comment under "other" ( I could not choose "Docket 7600" from the drop-down list). I put the words "Docket 7600" near the beginning of my comment. It only took a few minutes, and I urge you to do the same.

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Since yesterday, I have received copies of some excellent, inspiring comments which were sent to the PSB by plant supporters. I thank them, and I want to share their comments, in the hopes of inspiring your comments!

• Theresa Derting posted her message on the Facebook Save Vermont Yankee page, and I have copied it here.
• John Ewell sent me a post by Facebook Message, and gave me permission to post it here.

These two comments are great: well-written and full of ideas. One is short and one is long. Both are effective. My own comment emphasized that shutting down Vermont Yankee would be hard on older or low-income people in Vermont.

Be inspired by these comments, steal ideas from them if you want, and file a comment using the PSB general Comment Form. Start your comment with the words Docket 7600.

(John Ewell sent his same post to Docket 7440 when he was finished. That was a very good idea, and takes almost no time. I urge you to do the same. But posting to Docket 7600 is the first order of business today.)

Late News: Nuclear Townhall, a new and influential blog, chose this post as one of their two "best of the blogs" today.

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From Theresa Derting

RE: Docket 7600

I work at Vermont Yankee and I know that it is safe because I do. Entergy has invested enormous amounts of money in updating the facility since it was purchased, and continues to do so now. The tritium leak, even though relatively small by comparable standards, was stopped shortly after it was found, using a careful and methodical process. The company is in the process of implementing further protections to prevent incidents like these. The people who work at VY are committed to the protection of the public AND themselves. I would not work there if there if I was afraid. I would not have my daughter in elementary school directly across the river if I was afraid. Shutting VY down early because of a leak that has already been stopped is a silly notion. Shutting it down early when the effects of the leak are minimal at best is even sillier. Shutting it down early to the detriment of the ratepayers of the state of Vermont would be like the proverbial cutting one's nose off to spite one's face. Please discard this docket as the waste paper it should be.

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From John Ewell

My name is John Ewell. I am a Radiation Protection Technician. I have worked in the nuclear industry for about 30 years, almost 9 years at Vermont Yankee. I am a native New Englander, raised about 15 miles from the Pilgrim Nuclear plant. I now live in Western Mass, having lived in about 20 states. I have worked at 24 different nuclear units, operating and decommissioned. I have also been part of the decommissioning of the Rocky Flats weapons facility in Colorado.

So, I have a lot of experience in varied parts of nuclear power. I have worked as the guy mopping the floors, and supervised 25 people in a hazardous waste environment. Vermont Yankee is the place I chose to be my last nuclear plant. I had opportunities within the region at the time I hired on at VY, but I chose VY. I still believe I made the right choice.

Vermont is in a unique position of being able to predict their energy production for the future. As renewable energy production begins to take off, Vermont has a predictable, reliable energy source for up to 20 years, while green renewable energy production gets established. Rather than shutting down Vermont Yankee, use this time to setup clean, reliable green energy production. Setup the zoning regulations. Determine exactly what infrastructure and tax incentives are needed to support renewable, non-carbon energy production. Don’t go with the “quick fix”, but really set it up right. Vermont has the chance to show the rest of the country how to do it right. From the start, without time pressure or political pressure to “hurry up”.

An early shutdown of VY would be the same as scrapping the family minivan, because it is getting old, and we will have electric cars in the future. But those electric cars aren’t here now. And we still need the minivan to get the kids to baseball practice. If we had a true renewable energy infrastructure in place, shutting down VY may be justified. But we don’t. We still need the power. We can use this time to put it in place. VY will still get us to baseball practice. And to work. And won’t put smog into our air.

Recently in CT, a power plant, using natural gas, blew up. Killed 7 workers that spent years building that plant. Natural gas is highly combustible, and that industry is not as highly regulated as nuclear power. Nuclear power in the United States is not prone to these type accidents. The only accident at a nuclear plant (Three Mile Island) didn’t kill or injure anyone. Large scale energy production has it’s risks. But large scale energy production is needed to help our economy recover and grow. A growing economy will be able to pay for renewable energy. But if the energy isn’t there, the economy will not be able to build it.

The recent tritium leak at VY is one of the issues that has happened at several other nuclear plants in the country. VY identified it, notified the public immediately, and met the challenge head on. The leak was found, the piping replaced, the leak stopped, and we are in the process of removing the tritium water from the ground onsite. It did not spread to the public. It did not get into the groundwater, because of VYs quick action The remediation will be done quicker than about any other site. Just about everyone onsite worked on this project. We took it personal. People worked long hours, different groups worked together, and I am proud to have been part of the team. What we accomplished will be an example to the industry. It should be an example to the public. Find the problem - fix the problem. That is what VY does. That is what my coworkers believe in. That is “how we roll”.

Obviously, I would like for VY to continue to operate. I work there. But also, believe that I work there because I know it is safe. I have worked at other plants. I want to work at VY. I want you to believe in VY the way I do. Look at this as an opportunity to plan for Vermont’s future, instead of a chance to make a “statement” that will be more costly in the long run, both to the industry and workers in the state, and it’s environment.

Thank you,

John I Ewell

Radiation Protection / Industrial Safety

Vermont Yankee