Vermont Yankee redux: naturally gas

Vermont Yankee recycled to become a 620-megawatt biomass power plant would be the third-largest on Earth and the third-largest producer of biomass ash and emissions. It also would block the proposed western New England electricity corridor.

How many acres of biomass would be harvested, then delivered daily by how many trucks and trains? Would they also remove the ash for disposal somewhere?

Also burning trash? The Union of Concerned Scientists “does not consider waste-to-energy plants that burn raw municipal waste to be a sustainable form of biomass. Waste-to-energy plants emit high levels of air pollution, including toxic metals, chlorinated compounds and plastics.” Plus toxic ash.

Or natural gas? Crossing northern Massachusetts near potential “anchor tenants” Erving Paper Mills and recycled Vermont Yankee, the proposed Kinder Morgan Northeast Energy Direct Project could include a “lateral” also supplying Brattleboro and Putney, where manufacturers already burn natural gas delivered by trucks.

Yankee should be recycled to burn only natural gas and justify a pipeline serving and spurring the economy of southeast Vermont. Opponents should be asked what they propose instead of prosperity.

Blocking the western New England electricity corridor? Gov. Peter Shumlin has proposed it to deliver Gouvernement du Québec’s Hydro-Québec electricity to southern New England via Vermont (Vermont Public Radio, Sept. 9, 2013).

Already built from Vernon, where VELCO’s switchyard next to Yankee connects it to the New England grid, northward to New Haven, Vermont, it can be extended to Québec via an existing right-of-way.

This switchyard and transmission lines, like all electrical connections, have limited capacity. Closing Yankee, and keeping it closed, frees this capacity so that Hydro-Québec can bypass New Hampshire’s stalled Northern Pass transmission-line project.

False assumptions about SAFSTOR of Vermont Yankee

Entergy implicitly reminded us of our false assumptions about SAFSTOR of Vermont Yankee during the Vermont State Nuclear Advisory Panel (VSNAP) Nov. 14 public hearing at Vernon.

Entergy owns the site and can keep it. The security perimeter around nuclear fuel in dry casks may leave no reusable land.

What if cumulative decommissioning costs exceed the balance of the decommissioning fund due to inflation or deficient investment income?

U.N. International Atomic Energy Agency standards for SAFSTOR (safe enclosure) allow active and passive options (Safe Enclosure of Nuclear Facilities During Deferred Dismantling, 2002, pp. 12-13). “The active option for safe enclosure of the facility is characterized by allowing entry at all times, having dedicated personnel to survey the facility and environmental conditions during the entire storage period and keeping the equipment and systems operational during the safe enclosure period. …The essential feature of the passive option is the fact that the site is not staffed for the majority of the safe enclosure period but only during periods of inspection and maintenance.”

“Significant safety issues arise from: potential failure of barriers used to confine radioactive materials; unidentified areas of significant contamination; new or unrecognized waste streams; …spread of contamination during maintenance and surveillance activities; …deterioration of buildings, structures, systems and components which may have an impact on safe worker access or on final dismantling; potential impacts of non-radiological component failure on overall safety…” (cited above, p. 8).

Can Entergy (and U.S. Nuclear Regulatory Commission resident inspectors) be trusted to safeguard all of the above during decades of SAFSTOR of Vermont Yankee?

In the aftermath of the Fukushima nuclear meltdowns (beginning March 11, 2011), the U.S. Nuclear Regulatory Commission focused on appropriately upgrading safety precautions at American nuclear-power plants, especially those sharing the same design, including Vermont Yankee.

“Potential issues identified include … degraded or missing flood protection features (e.g., seals)” (U.S. NRC Response to Fukushima, April 15, 2013, p. 8).

“On May 24, 2012 [Entergy reported to the U.S. Nuclear Regulatory Commission in its own words], with the plant at 100 percent power, Vermont Yankee (VY) discovered the potential for water intrusion into the Vital Switchgear Rooms via an underground spare conduit that was found to be missing its flood seal. The missing flood seal compromised the interior flood design controls for the Switchgear Rooms. Were flooding of the Switchgear Rooms to occur, the operability of switchgear providing electrical power to Division I and II Engineered Safety Feature systems and Emergency Core Cooling Systems could be affected. This could threaten the capability to shut down the reactor and maintain it in a safe shutdown condition.” (Licensee Event Report 05000271/2012-001-01, Potential to Flood Switchgear Room Due to Missing Conduit Flood Seal, emphasis added).

“On March 19, 2013 [Entergy reported to the U.S. Nuclear Regulatory Commission in its own words], with the plant in the cold shutdown condition during a refueling outage, Vermont Yankee discovered water from dredging operations inside two electrical manholes located in the Vital Switchgear Rooms. On March 23, 2013, it was identified that the water had entered the two manholes through a partially dislodged flood seal in an underground spare conduit that communicates with the Switchgear Room manholes. On March 27, 2013, during an extent of condition review, an additional water intrusion pathway into the Switchgear Rooms via an abandoned sump pump discharge line was discovered. The dislodged flood seal and sump pump discharge line compromised the interior flood design controls for the Switchgear Rooms. The causes of the dislodged flood seal were due to the seal not being conservatively sized or tested for the application it was used in and failure to take timely corrective actions following a similar event reported in LER 2012-001-01 ” [quoted above] (Licensee Event Report 05000271/2013-001-00, Potential to Flood Switchgear Room Due to Missing Conduit Flood Seal, emphasis added).

On November 8, 2013, Entergy again reported to the U.S. Nuclear Regulatory Commission in its own words: “On 11/7/13, it was identified that a missing conduit flood seal between an outside manhole and the West Switchgear Room compromised the flooding design of both the East and West Switchgear Rooms. Compensatory measures were implemented for the flood seal in accordance with the plant’s barrier control process. Repair of the seal is in progress. The event is being reported under 10CFR 50.72(b)(3)(v) as internal flooding of both Switchgear Rooms could affect (a.) safe shutdown, (b.) removal of decay heat, (c.) control of release of radioactive material and (d.) mitigating an accident. (Event Notification Report for November 8, 2013, Event Number 49514, Conduit Flood Seal Missing, emphasis added)

Entergy cannot be trusted to safeguard Vermont Yankee during decades of SAFSTOR, because they do not bother to check their work for mistakes, even when the risk, as they state in the previous paragraph, is nuclear catastrophe. Neither do resident inspectors employed by the U.S. Nuclear Regulatory Commission. That such a risk is unlikely is irrelevant, because it is irrevocable.

I am pronuclear, but such habitual executive, managerial, professional and regulatory inattentive complacency is indefensible.

Employee-owned Vermont Yankee detailed analysis and proposal

Members of the
Vermont House and Senate
Committees on Natural Resources and Energy

Cc: International Brotherhood of Electrical Workers Local 300

FYI: Governor Peter Shumlin
Attorney General William Sorrell
Vermont Public Service Board

With reference to my more widely distributed “Employee-owned Vermont Yankee funds decommissioning & river stewardship,” here is a more detailed analysis and proposal for your further consideration as you please.

The State of Vermont asserts power to close Vermont Yankee, which is manifested only if it is exercised. That the states cannot interfere with interstate commerce, likely including generation and transmission of electricity via the New England grid, seems to be settled law. The Supreme Court of Vermont has clearly stated its criterion for allowing or disallowing legislative encroachment on executive powers. The Supreme Court of the United States (and perhaps of Vermont) likely will decide these issues in due course.

Entergy, however, has forfeited Vermonters’ trust and respect, which anti-nuclear lobbyists naturally are exploiting to realize their clients’ agendas.

The fundamental question remains: What is best for Vermonters?

  • Vigilant operation of Vermont Yankee is best for Vermonters.
  • Timely demolition and “green field” cleanup of Vermont Yankee when the federally extended operating license expires in 2032 is best for Vermonters.
  • Exemplary stewardship of the Connecticut River is best for Vermonters.
  • Removal of all nuclear waste from Vermont is best for Vermonters.
  • Reliable, affordable electricity is best for Vermonters, especially employers and during peak demand.

Employee-owned Vermont Yankee

Long-time employees say that Vermont Yankee was well run before Entergy bought it, because they were a team focusing on vigilant operation, as they would again if given the opportunity.

Vermont Yankee has a consistent, 39-year history of operating revenue and expenses generating and selling electricity profitably in interstate commerce via the New England grid, providing excellent grounds for projecting them 21 years hence until the federally extended operating license expires.

Employee-ownership of Yankee likely would happen in the customary manner and be financed conventionally with 20-year revenue bonds paid off from operating revenue.

The market will determine the bond interest rate, which in turn would determine a purchase price at which operating revenue covers operating expenses, debt repayment and paying up the decommissioning trust fund.

Employee-owned Vermont Yankee funds decommissioning

Relying on investment income from the current balance of the decommissioning trust fund to fund demolition and cleanup of Vermont Yankee someday is a race between cumulative rates of investment appreciation and cost inflation.

While theoretically possible, paying up the decommissioning trust fund in this manner is likely to be practically impossible.

Instead, regular contributions should pay up the decommissioning trust fund while investment appreciation compensates for cost inflation.

Profits from employee-owned Vermont Yankee’s continued operation until 2032 can pay these regular contributions.

Employee-owned Vermont Yankee funds river stewardship

Environmentalists protest the ecological impacts of pumping cooling water from and returning it to the Connecticut River. The “river” is not a real river, but a stair-step series of hydroelectric reservoirs having unnaturally weak currents and high water temperatures. Nevertheless, there is no reason to make matters worse.

Intake suction can be minimized if necessary by widening the river-water intake (narrower currents flow faster; wider currents flow slower). Native aquatic life can be nurtured and returned to the river. Cooling greenhouses can combine thermal and solar energies to grow local flowers, fruits and vegetables year-round while exchanging atmospheric carbon dioxide for oxygen.

Environmentalists who favor nuclear power as a limiter of global warming could work with Vermonters to organize and judge a design competition for the demonstration hatchery, nursery and greenhouses. Design criteria could include minimizing land use and energy wastage. Vermont would demonstrate exemplary stewardship of a working river, possibly obtaining financial grants supplementing Vermont Yankee’s funding.

Removal of all nuclear waste from Vermont

The United States used to recycle nuclear fuel. Fearing proliferation of nuclear weapons, President Carter issued in 1977 an executive order to stop recycling. This executive order has been rescinded, but recycling has not resumed. Instead, we store nuclear fuel forever at the sites of operating, closed and demolished nuclear power plants. Doing nothing to face and solve this problem has not gotten rid of it.

Meanwhile, France and Japan are recycling nuclear fuel successfully without nuclear proliferation. Vermont should take the lead in championing our doing the same.

Reliable, affordable electricity

Electricity is a fundamental economic input for every employer. It must be both reliable and affordable, which will be the sine qua nons of Vermont’s energy future.

Advocates of closing Vermont Yankee state correctly that there is ample surplus electric generating capacity on the New England grid — at typical levels of electric demand.

They overlook that this is not true during peak electric demand throughout New England, when Vermont imports 75 to 90 percent of its electricity, including from Vermont Yankee on the state line.

Existing interconnections with Hydro-Québec have no spare capacity to replace Vermont Yankee’s output before March 2012. Designing, permitting, acquiring rights-of-way, building transmission lines and building converter stations will take several years.

Vermont’s energy future can be innovative, even revolutionary. Requisite technologies are new and evolving rapidly as scientists and engineers ascend the inevitable learning curves perfecting both their knowledge and its application.

For example, existing solar panels inefficiently convert a limited range of hues (wavelengths) of sunlight into electricity. Prototype multi-layer solar panels more efficiently convert more hues of sunlight into more electricity.

If Vermonters commit ourselves too soon to evolving energy technologies, we will be stuck with them or the costs of discarding and replacing them with perfected versions.

Twenty years from now, when Vermont Yankee is closing for good, we will have tried and proven reliable and affordable alternatives.

Thank you for your consideration.

Howard Fairman
Vernon, Vermont, USA

Employee-owned Vermont Yankee funds decommissioning and river stewardship

Governor Peter Shumlin
Attorney General William Sorrell
Vermont House of Representatives
Vermont Public Service Board
Vermont Senate
Vermont news media

A letter to the editor (173 words), open letter, press release and op-ed piece (317 words):

There is an alternative to closing Vermont Yankee: an employee-owned nuclear-power plant funding timely “green field” decommissioning from profits of continued operation until 2032 while demonstrating exemplary stewardship of the Connecticut River.

Finding no other buyer, Entergy may sell Yankee cheaply to get this burden off its books and its shareholders off the hook.

Employees, who say that Yankee was well run before Entergy bought it, could gladly operate it safely and efficiently while contributing the profits to pay up the decommissioning trust fund instead of sending money to Entergy in New Orleans.

When the federally extended operating license expires 21 years from now, demolition and cleanup can begin immediately and be completed as soon as possible. Vermonters will have planned, designed, permitted, built and perfected alternatives to Yankee.

We also can demonstrate environmental innovations protecting the Connecticut River while pumping cooling river water through Yankee. Cool inflow can first circulate through a hatchery and nursery for native aquatic life. Warm outflow can first circulate through greenhouses growing flowers, fruits and vegetables year-round.

Continuing an open letter, press release and op-ed piece (144 additional words):

Entergy can instead operate Yankee while the courts decide the constitutional questions. Can the State of Vermont constitutionally prevent continued operation of a specific business duly licensed by the federal government and engaging in interstate commerce? Can the Vermont Legislature, despite constitutional separation of legislative and executive powers, authorize (or not) the Vermont Public Service Board to issue a certificate of public good to a specific business?

Closing Yankee, Vermont will lose reliable electricity, good jobs and millions in taxes and fees. We will keep a derelict nuclear plant and its radioactive waste and pollution that must be secured and safeguarded until the decommissioning fund grows to pay for demolition and cleanup decades from now. Our grandchildren and great-grandchildren will wonder why we swapped cheap electricity for exempting Entergy from contributing to the decommissioning fund.

If anyone “wins” by closure, what will Vermonters win?

Howard Fairman
Vernon, Vermont, USA