But when the time came to weigh in on Entergy’s attempts to build a second spent fuel storage facility at the Vernon property, it wasn’t the state raising the most ruckus — it was the local planning commission.
The Windham Regional Commission last week aired detailed concerns about how the company chose the proposed site for long-term storage of spent nuclear fuel. Planners also say the site location could affect the cost and schedule for the decommissioning of the nuclear power plant.
“It is our position that alternative sites should be identified and assessed or, alternatively, (Entergy) must guarantee that the spent fuel will be removed in a timely manner such that decommissioning will not be delayed and that the costs associated with doing so will not be taken from funding intended for decommissioning and/or site restoration,” Chris Campany, Windham Regional’s executive director, testified before the Vermont Public Service Board.
An Entergy spokesman said the company still is evaluating the testimony. But in previously filed documents, a company administrator contended that Entergy had examined and ruled out other storage possibilities – including moving the spent fuel off site.
“There are no off-site storage options available at this time or that are likely to be licensed and constructed within a timeframe that would allow Entergy VY to move all of its spent fuel out of the spent fuel pool by 2020 as it now plans,” testified George Thomas, a senior project manager with Entergy Nuclear Operations, in June 2014.
The date Thomas mentions is a major benchmark in the early stages of cleaning up Vermont Yankee, where decommissioning work will take decades. The plant is entering an extended period of dormancy called SAFSTOR, and the exact time frame for decommissioning will depend on the growth of a decommissioning trust fund.
Vermont Yankee ceased power production in late December and, not long after that, Entergy announced that all spent nuclear fuel had been moved into a spent-fuel pool – what’s known as “wet storage.” Entergy, its regulators and its detractors disagree on a lot, but they tend to agree that the spent-fuel pool is not an appropriate, long-term storage option. Rather, the plan is to move all remaining fuel into “dry storage” via specially designed, heavily reinforced casks.
That’s supposed to happen, as Thomas noted, by the end of 2020. But Entergy – which already maintains one pad loaded with dry casks at the Yankee site – needs the state’s permission to build another pad adjacent to the first. There are 13 dry casks loaded with spent fuel in Vernon; eventually, Entergy says there will be 58 casks on the two pads.
Citizens and advocates are concerned about the safety of those casks. At recent meetings of the Vermont Nuclear Decommissioning Citizens Advisory Panel, an industry consultant and the CEO of Holtec International – maker of the casks at Yankee – have sought to rebut those concerns by detailing the strength and extensive testing of the containers.
The Vermont Public Service Board is considering Entergy’s spent-fuel pad application, but state officials have relatively little to say about safety issues.
There is testimony, for instance, about a stormwater permit and a floodplain permit. There is talk of the need to test for and properly handle non-radiological waste that might be contaminating the pad site (possibilities include waste oil, lead and PCBs).
But when Public Service Department Commissioner Chris Recchia is asked whether the spent-fuel project is for the “general good” of the state, he says, “In general, yes.”
Recchia notes that the federal government has not yet made good on its promise of providing a long-term storage facility for spent nuclear fuel. So, “in the interim, the department believes that the common-sense approach of transferring spent nuclear fuel to dry cask storage is cost effective and provides Entergy the option, consistent with (Nuclear Regulatory Commission) regulations, to decommission and greenfield the site sooner, to the economic benefit of Vermonters,” Recchia said in documents released by the state.
He mentions Vermont’s pending legal challenge to some of Entergy’s proposed withdrawals from the Yankee decommissioning trust fund, including use of the fund “to provide financial assurance for spent-fuel management.” But Recchia also reiterates that, in financial terms, dry casks are “the desirable outcome” when compared with leaving the fuel in wet storage – which would be more costly in the long term.
Campany said Windham Regional also favors the transition to dry cask storage as soon as possible. But he says the commission can’t yet reach a “final conclusion” on Entergy’s plans because of concerns about where the new spent fuel pad will be built.
Citing earlier testimony, Campany says Windham Regional “remains concerned that a pair of spent fuel storage pads adjacent to the power block structures will either delay the point at which the station can be decommissioned and the site restored, or could increase the costs of decommissioning.”
“Entergy VY apparently intends to pay these costs from the decommissioning trust fund and the site restoration fund and then hope for reimbursement from (the U.S. Department of Energy), which is not assured,” according to the Windham Regional’s testimony. “Likewise, we are concerned that spent fuel located in the center of the site could have profound impacts upon redevelopment after the reactor complex has been decommissioned and restored.”
Campany says Entergy, in seeking to construct its first spent fuel pad, had indicated that the company eventually would build one larger pad farther away from the reactor complex. Instead, Campany testified, “nine years later, we find ourselves reviewing a petition that does what the petitioner had previously said should not be done; specifically siting a second (spent fuel pad) close to the power block in a manner that would inhibit eventual decommissioning or otherwise make decommissioning more expensive or difficult.”
“It is our recommendation that the (Public Service Board) should require consideration of a single consolidated pad far removed from the reactor complex, and if accepted as an alternative, should hold Entergy VY responsible for all costs associated with constructing this pad and moving fuel from the original pad (rather than impose those costs on the decommissioning trust fund),” Campany testified.
In response, Entergy spokesman Martin Cohn said the company is “evaluating all the pre-filed testimony to ensure that it is within the parameters set by the PSB.”
Entergy has staunchly defended selection of both the Holtec dry casks and the location for the casks. In Thomas’ 2014 testimony to the Public Service Board, he said Entergy considered placing the dry casks underground, but “it would be extremely difficult and expensive to excavate to the depths required to build the underground facility within the (plant’s) existing protected area.”
Such a project would mean more money taken out of the decommissioning trust fund, “slowing the growth of the trust balance and delaying the time when major decommissioning activities could begin,” Thomas warned.
In addition to considering placing the dry casks underground and off site, Entergy thought about building the second spent fuel pad elsewhere on site – outside the plant’s protected area. But that would “require new security facilities at additional costs” as well as additional facility upgrades, Thomas said – not to mention making “transfers of casks between the two … pads more difficult and costly.”
The state is expected to rule on Entergy’s spent fuel pad application in spring 2016.
The Brattleboro-based New England Coalition via Raymond Shadis, a Maine-based technical consultant for the group, also filed testimony. Shadis said decisions about spent-fuel storage casks at the Maine Yankee plant was more public and transparent than the Vermont Yankee process has been. He also points to the possibility that spent nuclear fuel will be stored in Vernon for a long time.
Shadis says he wanted “to underscore the likelihood that high level nuclear waste will not be removed from Vermont Yankee or Vermont in our lifetime and thus to help ensure that, because of vast uncertainties as to how long the negative impacts of the proposed project will play out, the board and the parties will give the proposal a most scrupulous and searching review,” he said.
Vermont has just “one chance” to get the siting of the casks right.
“Unlike permission to operate a generating station, once permission, a certificate of public good, is given to set up a host site for sealed canisters of high level nuclear waste, the permission cannot be withdrawn and its effects undone,” Shadis says.