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.


Vermont Yankee: SAFSTOR & more

Testimony by Vernon resident Howard Fairman to members of the Commerce and Economic Development and the Natural Resources and Energy Committees of the Vermont House of Representatives during their public hearing at Vernon, Vermont, October 28, 2013, regarding impending closure of Entergy Nuclear Vermont Yankee.

Deferred dismantling of a nuclear-power plant, called “SAFSTOR” in the United States, is a United Nations International Atomic Energy Agency (IAEA) radiological safety standard implemented by the United States Nuclear Regulatory Commission (NRC).

Quoting the NRC, “under SAFSTOR, often considered ‘deferred dismantling,’ a nuclear facility is maintained and monitored in a condition that allows the radioactivity to decay; afterwards, it is dismantled and the property decontaminated” (emphasis added). U.S.NRC: Decommissioning Nuclear Power Plants

SAFSTOR does not address or mandate disabling or prevention of future operation.

According to the IAEA: “Deferral of dismantling and demolition may reduce the quantities of radioactive waste produced and reduce radiation exposure to site personnel. In addition, this delay in dismantling may permit technological improvements in the future to be incorporated into the process when decommissioning activities are resumed. However, this option could result in the loss of trained and knowledgeable workers.

“There may be additional disadvantages in delaying dismantling and demolition. If deferred dismantling is being considered for a prolonged period of time, due regard should be given to gradual deterioration of the structures, systems and components designed to act as barriers between the radionuclide inventory and the environment. This deterioration may also apply to systems that could be necessary during plant dismantling.”
UN IAEA: Decommissioning of nuclear power plants & research reactors, p.17

I commend your attention to the IAEA’s active and passive options for SAFSTOR and their obvious further disadvantages.
Safe enclosure of nuclear facilities during deferred dismantling, p.15

Mothballing an operating nuclear-power plant via SAFSTOR can allow it to be restarted afterward, such as when natural-gas prices naturally rise with growing domestic demand and international exports, making Vermont Yankee again profitable to operate.

When electricity generated by burning natural gas, already half of New England’s electricity supply, becomes sufficiently costly, Vermonters and our employers may want Vermont Yankee to be restarted to lower our electricity bills.

Moreover, quoting ISO New England: “Given current and anticipated levels of gas usage, potential gas unavailability threatens the reliability of the electric system due to the limited-capacity pipelines used to transport gas, potential gas supply interruptions, and the ‘just-in-time’ nature of the resource.”
ISO New England: Addressing gas dependence (July 2012), p. 1

Quoting the Boston Business Journal dated yesterday, October 27:
New England’s reliance on natural gas drives power bills up nearly 20% this winter

Vermont Yankee, while in SAFSTOR, can be sold along with its decommissioning fund and liabilities to investors betting that future technological improvements and/or enhanced investment performance will leave unspent millions as windfall profits after successful decommissioning, if Vermont Yankee is not instead profitably restarted.

SAFSTOR benefits Entergy Nuclear and potential buyers of Vermont Yankee.

Vernon and Vermont will benefit when Vermont Yankee has been removed entirely and the site has become a greenfield available for creation of new jobs and tax revenues.

Until then, the Town of Vernon and Vernon Town School District, in compensation for enforced unavailability of the Entergy Nuclear Vermont Yankee site for new economic development, should receive annual hosting payments equal to Entergy Nuclear Vermont Yankee’s current municipal and education property taxes indexed for inflation.