Vermont Yankee Whats Next? Safe and Green Campaign December 3, 2013 - - PowerPoint PPT Presentation

Vermont Yankee What’s Next?

Presented by Tom Buchanan

Safe and Green Campaign December 3, 2013

DRAFT 12/02/13

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Tom Buchanan

• Windham Regional Commission (WRC)
• Commissioner representing Town of Londonderry
• Chair VY Study Committee/Member Ex. Board
• Responsible for making policy recommendations
• Party in Certificate of Public Good (CPG) docket
• Speaking today as an individual
• Began work on the VY project in October, 2007

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Overview Virtual Tour Standards Timing Trust Fund Options Influence

• Virtual Tour of Vermont Yankee
• Standards of Decommissioning

and Site Restoration

• Timing of Decommissioning Process
• The Decommissioning Trust Fund
• Options: DECON vs. SAFSTOR
• Influencing the Process

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Overview Virtual Tour Standards Timing Trust Fund Options Influence

Virtual Tour

• f

Vermont Yankee

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Vermont Yankee Property (~148 acres)

Connecticut River Governor Hunt Road

Main Entrance

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Vermont Yankee Property (~148 acres)

Connecticut River Governor Hunt Road

Cooling Towers Switchyard Main Facility

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Vermont Yankee Property (~148 acres)

Connecticut River

Reactor Building Turbine Building

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Vermont Yankee Property (~148 acres)

Connecticut River

Intake Structure Discharge Structure

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Vermont Yankee Property (~148 acres)

Connecticut River

ISFSI Spent Fuel Storage

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important take-away…

The VY site is not very large, but if the decommissioning is managed well, much of the site can eventually be returned to productive economic use.

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Overview Virtual Tour Standards Timing Trust Fund Options Influence

Standards of Decommissioning and Site Restoration

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Decommissioning & Site Restoration

NRC Regulates Radiological Decommissioning Only: 25 millirem + ALARA

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Vermont Standard

“Site restoration shall mean that, once the VYNPS site is no longer used for nuclear purposes or non-nuclear commercial, industrial, or similar uses consistent with the

• rderly development of the property, the site

will be restored by removal of all structures and, if appropriate, regarding and reseeding the land.”

Source: Docket 6545 MOU, paragraph 3 (2002 sale from VYNPC to ENVY)

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important take-away…

The NRC only requires radiological

• decommissioning. The “greenfielding” of the

site is a state requirement, and the specific terms are in dispute.

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Overview Virtual Tour Standards Timing Trust Fund Options Influence

Timing of the Decommissioning Process

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Timing

• The NRC requires that radiological

decommissioning be completed within 60 years.* This part of the process is called DECON.

• The NRC allows a licensee wide latitude to delay

radiological decommissioning. The period of delay is called SAFSTOR.

• The most recently discharged fuel must remain

in the spent fuel pool for at least five years before being moved to casks.

*The 2012 Vermont Yankee PSDAR assumes a 54 year period of SAFSTOR

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Timing

Entergy must submit several reports to the NRC within two years of shutdown (by December 2016):

• Post Shutdown Decommissioning Activities

Report (PSDAR).

• Site Specific Decommissioning Cost

Estimate

• Updated Spent Fuel Management Plan

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Timing

• The reports must define the planned approach

to decommissioning and timing, and show how it will be funded.

• The NRC will hold public meetings on the plan.

The NRC is generally deferential to the licensee, but can be influenced by public comments and governmental policy.

2014 2074 60 Years

DECON

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Timing

• The reports must define the planned approach

to decommissioning and timing, and show how it will be funded.

• The NRC will hold public meetings on the plan.

The NRC is generally deferential to the licensee, but can be influenced by public comments and governmental policy.

2014 2074 60 Years

DECON SAFSTOR

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Timing

• The reports must define the planned approach

to decommissioning and timing, and show how it will be funded.

• The NRC will hold public meetings on the plan.

The NRC is generally deferential to the licensee, but can be influenced by public comments and governmental policy.

2014 2074 60 Years

DECON SAFSTOR

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Timing

• The reports must define the planned approach

to decommissioning and timing, and show how it will be funded.

• The NRC will hold public meetings on the plan.

The NRC is generally deferential to the licensee, but can be influenced by public comments and governmental policy.

2014 2074 60 Years

DECON SAFSTOR DECON

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Timing

2014 2074 60 Years

DECON SAFSTOR A period of SAFSTOR appears inevitable… The best we can hope for is probably a short period of SAFSTOR followed promptly by complete decommissioning.

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important take-away…

Entergy will file a decommissioning plan with the NRC within two years of shutdown, and the public will be given an opportunity to comment.

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Overview Virtual Tour Standards Timing Trust Fund Options Influence

The Decommissioning Trust Fund

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Trust Fund

The value of the Decommissioning Trust Fund on October 31, 2013 was:

Source: Entergy advisory email to DPS, 11/7/13 (Malmquist to Commons)

$598 Million

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Trust Fund

Source: Various filings, dockets 7440 &7862

Value dropped to $359 million on 3/31/09 $0 $100,000,000 $200,000,000 $300,000,000 $400,000,000 $500,000,000 $600,000,000 $700,000,000 07/01/02 05/01/03 03/01/04 01/01/05 11/01/05 09/01/06 07/01/07 05/01/08 03/01/09 01/01/10 11/01/10 09/01/11 07/01/12 05/01/13 Value (millions of dollars) 2002-2013 Amount

• When Entergy bought VY in 2002 the

Decommissioning Trust Fund was valued at approximately $310 million.

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Trust Fund

Source: Various filings, dockets 7440 &7862

$0 $100,000,000 $200,000,000 $300,000,000 $400,000,000 $500,000,000 $600,000,000 $700,000,000 07/01/02 05/01/03 03/01/04 01/01/05 11/01/05 09/01/06 07/01/07 05/01/08 03/01/09 01/01/10 11/01/10 09/01/11 07/01/12 05/01/13 Value (millions of dollars) 2002-2013 Amount

• The fund must grow faster than inflation, and

when in SAFSTOR it must grow faster than inflation plus the cost of site maintenance.

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Trust Fund

Example: Shutdown in 2032, all fuel off site in 2082 DECON SAFSTOR License Termination (DECON) $566.7m $622.5m Spent Fuel Management $365.3m $397.2m Site Restoration $ 47.8m $ 47.7m Total Cost $979.9m $1.06b

Source: Decommissioning Cost Analysis, February 2012, scenarios 4/6, 2011 dollars, truncated (Other SAFSTOR scenario maximums: Total $1.159b, Lic termination $653.1m, SF Mgt $502.9m)

• The fund must cover costs of decontaminating the

site, managing the fuel (with some reimbursement from DOE), and restoring the site.

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Trust Fund

Entergy Corporation Entergy Nuclear Vermont Yankee (ENVY) Entergy Nuclear Operations (ENO) The Decommissioning Trust Fund and the VY Station are owned by and Entergy subsidiary called Entergy Nuclear Vermont Yankee (ENVY)

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Trust Fund

Entergy Corporation Entergy Nuclear Vermont Yankee (ENVY) Entergy Nuclear Operations (ENO) The Decommissioning Trust Fund and the VY Station are owned by and Entergy subsidiary called Entergy Nuclear Vermont Yankee (ENVY)

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important take-away…

The decommissioning trust fund has performed well in real terms and relative to inflation, but it may never be sufficient to fully restore the site. Unless additional funding sources are secured, any additional costs charged to the decommissioning fund will delay the point at which the site can be decommissioned and restored.

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Overview Virtual Tour Standards Timing Trust Fund Options Influence

DECON vs. SAFSTOR

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DECON vs. SAFSTOR

• Prompt decommissioning returns the land to

productive economic use sooner than if decommissioning is delayed.

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DECON vs. SAFSTOR

• Prompt decommissioning provides a better

economic and employment profile.

Source: Docket 7862, A.WRC:EN.1-27.1 and A.WRC:EN.1-27.2, graphics provided by Entergy

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DECON vs. SAFSTOR

• Prompt decommissioning provides access to a

workforce with legacy knowledge.

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DECON vs. SAFSTOR

• Prompt decommissioning eliminates market

uncertainties associated with the Decommissioning Trust Fund, and the risk of inflation.

Source: Various filings, dockets 7440 &7862

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DECON vs. SAFSTOR

Example: Shutdown in 2032, all fuel off site in 2082 DECON SAFSTOR License Termination (DECON) $566.7m $622.5m Spent Fuel Management $365.3m $397.2m Site Restoration $ 47.8m $ 47.7m Total Cost $979.9m $1.06b

Source: Decommissioning Cost Analysis, February 2012, scenarios 4/6, 2011 dollars, truncated (Value of Decommissioning Fund on 7/31/13~$582 million, source: Entergy press release, WRC-X)

• Prompt decommissioning is less expensive than

SAFSTOR under every scenario pairing.

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DECON vs. SAFSTOR

Entergy Corporation Entergy Nuclear Vermont Yankee (ENVY) Entergy Nuclear Operations (ENO)

• Prompt decommissioning Provides greater

assurance of corporate responsibility.

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DECON vs. SAFSTOR

• Prompt decommissioning may produce less

nuclear waste (or the same amount of waste).

“Given the levels of radioactivity and spectrum of radionuclides expected from thirty to forty years of plant

• peration, no plant process system identified as being

contaminated upon final shutdown will become releasable due to the decay period alone, i.e., there is no significant reduction in waste volume in delaying decommissioning. In fact, SAFSTOR estimates can show a slight increase in the total projected waste volume, due primarily to initial preparation activities for placing the unit in safe-storage, as well as from follow-up housekeeping tasks over the caretaking period for the station.”

Source: DCA, 2001, section 2, page 16

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DECON vs. SAFSTOR

• Texas Compact

provides for disposal

• f low level waste at

a facility in Andrews, Texas.

• Texas has licensed

the Andrews facility for 15 years, expires in 2024. Extensions are possible in 10 year increments.

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DECON vs. SAFSTOR

• Vermont rail and road

facilities exist now for transport of low level

• waste. Not guaranteed

in the future.

• Prompt

decommissioning provides greater assurance of low level waste disposal.

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DECON vs. SAFSTOR

• Prompt decommissioning reduces Vermont

state regulatory and oversight costs (taxes):

• Public Service Board
• Department of Public Service
• Department of Health
• Agency of Natural Resources
• Representation before the NRC
• etc.

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DECON vs. SAFSTOR

• Prompt

decommissioning eases the burden of

• ngoing emergency

management throughout the tri-state region.

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DECON vs. SAFSTOR

• Prompt

decommissioning allows the state, region, and municipality to put distance between the contentious protests of present day, and the future redevelopment of the property.

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DECON vs. SAFSTOR

The Kindergarten Rule: Clean up your own mess…before nap time.

• As the generation that benefited from the
• peration of the plant, we should be responsible

for remediation, and not leave that task to our grandchildren’s generation.

Intergenerational Equity

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important take-away…

The best available option is prompt and complete decommissioning without the use of SAFSTOR, or alternatively the shortest period

• f SAFSTOR possible.

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Overview Virtual Tour Standards Timing Trust Fund Options Influence

Influencing The Process

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Influencing the Process

• Require immediate full funding of all

reasonably expected decommissioning expenses. …and then

• Prompt and complete decommissioning

without the use of SAFSTOR, or alternatively, with the shortest period of SAFSTOR possible.

Work Together Define the Objective

Thank You

Tom Buchanan

PO Box 261, Londonderry, VT., 05148 802.824.4243 email.tom.buchanan@gmail.com