Editor’s note: This commentary is by Raymond Shadis, a trustee of the Brattleboro-based New England Coalition since 1982. He served as staff technical advisor to the coalition from 1997 to 2006 and as a consulting technical advisor from 2006 to the present. He is the coalition vice president for legal initiatives, often representing the coalition on Vermont Yankee matters before the Vermont Public Service Board and the U.S. Nuclear Regulatory Commission.
[I]t’s a kind of inside joke, and a not very funny one at that. Archer Mayor’s latest police procedural novel “Presumption of Guilt” is set at Vermont Yankee. A decommissioning crew finds a body buried in a cement slab beneath a warehouse set for demolition.
Tres cool. Though Entergy Vermont Yankee would likely argue, as it did with buried pipes carrying radioactive material, notably tritium, that a body is not actually “buried” if it is encased in concrete (or a coffin) and not in direct contact with the soil.
In the real world of decommissioning the “buried bodies” are areas of radiologically contaminated soil, concrete, or other objects, up to and including nuclear fuel particles that were spilled, dumped or otherwise released to the open environment sometime in the reactor’s operating history. As shown in Entergy Vermont Yankee’s 2014 site assessment study, reliance on written records, a paper chase, will yield less than a complete picture. When it comes to releases of radiological materials, what surfaces in the record is often the tip of the iceberg, not the bulk which remains submerged, buried.
At Maine Yankee, we decided on prompt rather than delayed decommissioning in part because we would be able to involve veteran employees who had witnessed the various spills, releases, inventory gone astray over the plant’s 26-year operating history. History keepers, we reasoned, know best where the bodies are buried. Their firsthand recollections and knowledgeable scouting for hotspots proved valuable in avoiding radiological surprises; otherwise costly in worker exposures and dollars. Today, Entergy Vermont Yankee can involve veteran employees in decommissioning who will be gone in 20, 30, 40 or 50 years.
When referencing Maine Yankee, I say “we” because, unlike Entergy Vermont Yankee, Maine Yankee Atomic Power Co. sought stakeholder’s informed input and agreement from the get-go. The result was state and community satisfaction and a decommissioning with record cleanup, minimal worker exposure, coming in on budget and almost on schedule (seven years, five months).
But that was another company in another time.
This is Entergy Vermont Yankee.
Nothing if not smug, Entergy Vermont Yankee remains committed to “Safstor” (see me Thursday, half a century from now).
Why? It could be because during its 14-year tenure at Vermont Yankee, Entergy set aside absolutely nothing (zero) for decommissioning and it doesn’t intend to start contributing now.
But wait, there’s more.
At Maine Yankee, we decided on prompt rather than delayed decommissioning in part because we would be able to involve veteran employees who had witnessed the various spills, releases, inventory gone astray over the plant’s 26-year operating history.
According to Thomas LaGuardia, whose company, TLG Associates, now owned by Entergy, performed decommissioning cost studies for more than 90 percent of U.S. reactors (including Vermont Yankee), “Project management costs can represent as much as 55% of total decommissioning costs, with 20-25% allocated for dismantling and around 25-30% for waste disposal” (Nuclear Energy Insider, 9/21/2016). So with virtually no corporate investment, Entergy stands to reap more than half of the projected $1.24 billion trust fund in decommissioning and spent fuel management fees.
“While most operators have chosen to defer D&D activities by using SAFSTOR, operators can benefit from using the alternative DECON (prompt) approach as it allows them to shift the financial liability for decommissioning activities to a contract company,” La Guardia said. “Although SAFSTOR requires a minimal initial outlay and delays spending on the main expenses, licensees need to manage NRC regulations and the site’s nuclear liability over several decades.”
Shifting financial liability to a decommissioning contract company is exactly what Exelon did for its two Zion, Illinois, reactors, going to DECON after a decade or more of costly Safstor. Savings brought decommissioning of the two reactors down to around $900 million. At least two other plants are following the Zion example.
In a separate interview with Nuclear Energy Insider (9/23/2016), Geoffrey Rothwell, principal economist at the Organization for Economic Cooperation and Development’s Nuclear Energy Agency, said operators should start decommissioning activities as early as possible as the deferral of D&D exposes operators to delay-related costs, investment risks and loss of crucial expertise as workers leave the industry.
“A major advantage of carrying out D&D activities immediately is that current operations staff have in-depth knowledge of plant specifics which avoids unnecessary work-arounds,” Rothwell said.
“By deferring D&D activities, operators raise the chance of chemical or radiation leaks spreading and the introduction of stiffer regulation,” he said.
“While decommissioning cost estimates have risen, rates of return for DTFs have been lower than expectations, and operators which have accelerated closure plans should leverage current staff expertise and optimize decommissioning schedules to allocate decommission fund portfolios so the “liquidity matches your plans,” Rothwell said.
A big plus at Vermont Yankee is that Entergy has recently shown signs that it cares what stakeholders think, by consulting on tritium-contaminated water disposal and funding for emergency planning.
It’s only good business.
Entergy Vermont Yankee should borrow the upfront money from Entergy Louisiana to go to DECON now, repaying the loan from the decommissioning trust fund when it matures.
