BVY 08-077, State of Vermont Comment on the Revised Spent Fuel Management Plan Filed on October 14, 2008 by Entergy Nuclear Operations, Inc., Pursuant to 10 CFR 50.54(bb)

State of Vermont Comment on the Revised Spent Fuel Management Plan Filed on October 14, 2008 by Entergy Nuclear Operations, Inc., Pursuant to 10 CFR 50.54(bb)

ML083440317
Person / Time
Site:	Vermont Yankee
Issue date:	12/01/2008
From:	O'Brien D State of VT, Dept of Public Service
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 08-077, FOIA/PA-2009-0094
Download: ML083440317 (2)

Text

,o#%\VERMONT State of Vermont FAX: 802-828-2342 Department of Public Service TTY VT: 800-734-8390 112 State Street email: vtdps@state.vt.us Drawer 20 http://publicservice.vermont.gov/

Montpelier, VT o5620-26Ol TEL: 802-828-2811 December 1, 2008 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

References:

(1) Letter, Entergy to USNRC, Report re Vermont Yankee Revised Spent Fuel Management Plan Pursuant to IOCFR50.54(bb), BVY 08-077, dated October 14, 2008.

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket 50-271)

Revised Spent Fuel Management Plan Pursuant to 10CFR50.54(bb)

Vermont Comment on Revised Spent Fuel Management Plan

Dear Sir or Madam:

On October 14, 2008, Entergy Nuclear Operations, Inc. filed a Revised Spent Fuel Management Plan Pursuant'to 10 C.F.R. 50.54(bb). It is unusual for a State to comment on a filing such ais this bifttwo assumptionrs in Entergy'*fiIih -caused significant concern for Vermont.

1) Table.2, column F,..shows the escalation of the6dciommissioning trust fund at 2% per year. Thetotal for 2007 is.based on historic data. However, the sum for 2008 shows an escalation by 2% to$448.358. Because of theýturmoil in the markets, the Vermont Yankee Decommissioni'.ig Trust Fund has not escalated but has declined in value from the 2007 value to $397.036 as of.

September 30, 2008. It only seems prudent to use the historical value for 2008 since we knovW thefuind'did not actually escalate by 2/. It certainly would be the more accurate portrayal of the fund.

2) The assumption used in the Revised Spent Fuel Management Plan assumes a 2017 date for Yucca.Mountainto begin acceptiing spent fuel. Altihough,that date is still listed as the official opening date fo6 Yucca Mountain'by the U.S.

Department oifEný'ergy, even Edward F. Sproat, Director of the Office of Civilian Radioactive Waste Management for U.S. DOE regularly admits that the opening date is likely to be in 2020. Using the 2017 date does not give an accurate picture of Entergy's spent fuel manage.ent stri*tegy. or the relative health of the decommissioning fund: .

I*.,.

Page Two The State of Vermont hopes the NRC Staff reviewing the Entergy Revised Spent Fuel Management Plan will take these comments into consideration when reviewing the Entergy plan. Using realistic information in formulating and reviewing a spent fuel plan seems crucial to its success.

Very truly yours, David O'Brien, Commissioner Vermont Department of Public Service.

cc: Michael Colomb, Site Vice President at the VYNPS Samual Collins, Regional Administrator, NRC Region 1 James Kim, Project Manager U.S. NRC USNRC Resident Inspector at the VYNPS