ML15096A429
| ML15096A429 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 03/22/2015 |
| From: | Sachs L S - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 80FR1975 00019, NRC-2015-0004 | |
| Download: ML15096A429 (5) | |
Text
Page 1 of 2 RULES,' L +ECTIVES As of: 3/30/15 3:36 PM Received:
March 22, 2015 Status: Pending_Post PUBLIC SUBM ISSION .,_3 54 Tracking No. ljz-8hv7-yhko Comments Due: March 23, 2015 Submission Type: Web Docket: NRC-2015-0004 2 -_Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report Comment On: NRC-2015-0004-0001 Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report Document:
NRC-2015-0004-DRAFT-0020 Comment on FR Doc # 2015-00450 5 Submitter Information
/Name: Leslie Sullivan Sachs Address: 25 Chestnut Hill #3 Brattleboro, VT, 05301 Email: safeandgreencampaign@gmail.com General Comment EDITED by 1/3 FROM THE UPLOADED FILE I write to comment on Entergy Vermont Yankees Post Shut Down Activities report. Vermont is only the second merchant reactor to decommission.
Entergy must be held accountable.
The NRC needs to send a strong message to reactor owners that local and State hosts -- who will be spending millions of dollars monitoring the site and the river for many decades to come has a meaningful role in decommissioning and site restoration.
- 1. I support comments submitted by the State of Vermont, dated March 6, 2015, including the States request for an adjudicatory hearing as to whether the NRC should allow Entergy to proceed with decommissioning.
I have attended the meetings of the Nuclear Decommissioning Citizen Advisory Panel (NDCAP) and witnessed the behavior of Entergy representatives and presenters.
While in public Entergy personnel have said repeatedly that they are being open and transparent, their actions prove otherwise.
By NRC rules, Entergy has two years after the reactor closed to submit its PSDAR, but Entergy rushed it through a week before closure. Each page is date stamped December 2. State comments were submitted December 13; NDCAP met and made its comments December 18. Entergy submitted it to the NRC December 19. This is insulting.
Entergy clearly did not take NDCAP, State or public comments seriously.
At the February meeting of NDCAP, Joe Lynch, an Entergy VP, gave an update without one word about Entergys reply to the states comments onthe PSDAR. The next day, over Mr. Lynchs signature, Entergy sent the State its reply. Ive read Entergys reply to the states comments.
It is a line-by-line brush off without substance; a https://ww.
fdms.gov/fdms-web-agency/component/contentstreamer?objectld=090000648 1 a57b41 &for... 03/30/2015 Page 2 of 2 less kind critic would call the reply a slap in the States face.2. The PSDAR should be required to include a thorough site characterization.
The NRC should require Entergy to re-submit a PSDAR which is specific to Vermont Yankees location, environment and socio-economic character.
It is 2nd smallest acreage of all US reactors; at most reactor sites the town is buffered by hundreds to a thousand acres. Yankee sits in the middle of a rural village; the reactor is a mere 1500 feet from an elementary school, and across the river from a school in Hinsdale, NH. Entergy should be required to complete a site specific NEPA environmental impact statement.
In addition, because SAFSTOR will have a severe and negative impact on the economics of Windham County and the region, the NRC should require Entergy to go promptly to DECON. DECON will enable our economy to rebound more quickly and make community and economic planning for the future possible.
Under the current scenario, it is impossible.
- 3. Entergy should be required to clean up known contamination now, especially under the AOG building, Waiting under SAFSTOR will risk the spread of contamination into the groundwater, aquifer, and Connecticut River, increasing the cost and environmental harm.4. It is simply absurd that Entergy's PSDAR says the waste will be taken off site by 2052. DOE, with Congress, would have to enact legislation, fund and build a central or interim repository(s) by 2052. Yankee's waste management storage must be based on the likelihood that the radioactive fuel will stay in the village of Vernon for another 100 years.5. Entergy should be required to show, in the PSDAR, how it will comply with State environmental and health regulations; the Settlement Agreement (2014); and the Master Trust Agreement (2002) on the decommissioning trust fund. It wants the NRC to make It wants an environmental impact statement and analysis of what would happen in case of terrorism, and/or zirconium fire without the Emergency Planning Zone in place.6. NRC should deny Entergy the ability to withdraw from the Decommissioning Trust Fund monies for non-decommissioning purposes such as guarding the spent nuclear fuel and Spent Fuel Management; and require that Entergy explain.how it will pay for those non-DTF expenses.
The NRC should also require Entergy to include contingencies that may not be found until end of SAFSTOR.7. Emergency preparedness should remain in place at least until all the radioactive fuel is moved from the fuel pool into dry cask storage. I agree completely with Comments to the NRC 02.27.15 by my VT legislators: "As a community that hosts high level nuclear waste a role we never signed on for we request federal help to cover the cost of expenses we are unprepared to shoulder.
If Entergy can sue the federal government for millions of dollars for not removing the waste in 1998 as scheduled, why can't we access the federal nuclear waste fund to pay for infrastructure, keep us safe and support our emergency personnel?
Major incentives are made available to communities willing to take nuclear waste. So why shouldnt towns like ours that have that job thrust upon us receive such incentives?" Attachments LSS Comments on PSDAR https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=090000648 1 a57b41 &for... 03/30/2015 To: NRC From: Leslie Sullivan Sachs Date: March 22, 2015 Re: Docket ID NRC-2015-0004 I write to comment on Entergy Vermont Yankee's Post Shut Down Activities report.Vermont is only the second merchant reactor to decommission.
Entergy must be held accountable.
The NRC needs to send a strong message to reactor owners that local and State hosts -- who will be spending millions of dollars monitoring the site and the river for many decades to come -has a meaningful role in decommissioning and site restoration.
- 1. I support comments submitted by the State of Vermont, dated March 6, 2015, including the State's request for an adjudicatory hearing as to whether the NRC should allow Entergy to proceed with decommissioning.
I have attended the meetings of the Nuclear Decommissioning Citizen Advisory Panel and have witnessed the behavior of the two Entergy representatives and its presenters.
While in public Entergy personnel have said repeatedly that they are being "open and transparent," their actions prove otherwise.
By NRC rules, Entergy has two years after the reactor closed to submit its Post Shut-Down Activities Report (PSDAR), but Entergy turned its PSDAR over to the NRC on December 19 -- one week before the plant shut down, and one day after the Citizens Advisory Panel (NDCAP) met and commented on the plan. This is an insult to the state and its citizens.
How could it take into account comments given by NDCAP citizen representatives and State representatives the night before? This arrogant behavior is wearily familiar to those of us who have suffered through decades of Entergy manipulation of NDCAP's predecessor, the VT State Nuclear Advisory Panel.To add insult to injury, each page of the PSDAR is date stamped December 2 -well before State comments were submitted December 13 and before the NDCAP meeting December 18. Entergy clearly did not take NDCAP, State or public comments into account.190 comments by three state agencies were submitted to Entergy December 13. Entergy responded February 28 -one day after an NDCAP meeting. Joe Lynch, an Entergy VP, gave an update to the panel on decommissioning (closing with the usual slide about openness and transparency) without one word about Entergy's reply to the state's comments.
The next day, over Mr. Lynch's signature, Entergy sent the State its reply.I've read Entergy's reply to the state's comments.
It is a line-by-line brush off without substance; a less kind critic would call the reply a slap in the State's face.2. The PSDAR lacks a level of detail that should also motivate the NRC to send it back to the drafting table. I agree with the State that Entergy should be required to include site characterization.
Too much data is missing, too may assumptions are made. The PSDAR should be required to include a thorough site characterization to establish fact-based connections between what Entergy plans, how much it will cost to clean it up, based upon what is currently in the water, on and under the land and in the air.3. The NRC should require Entergy to re-submit a PSDAR which is specific to Vermont Yankee's location, environment and socio-economic character.
Yankee is the 2nd smallest sized site of all US reactors, at 125 acres. This is quite different from the average facility, where the towns are buffered by hundreds to a thousand acres or more. Yankee sits in the middle of a rural village;the reactor is a mere 1500 feet from an elementary school, and across the river from a school in Hinsdale, NH.Entergy should be required to complete a site specific NEPA environmental impact statement.
In addition, because SAFSTOR will have a severe and negative impact on the economics of Windham County and the region, the NRC should require Entergy to go promptly to DECON.DECON will enable our economy to rebound more quickly and make community and economic planning for the future possible.
Under the current scenario, it is impossible.
- 4. There is a clear history of contamination on site, including recent evidence of strontium-90.
In Vermont, our groundwater is a public trust. Entergy should be required to clean up known contamination now, especially under the AOG building.
Waiting under SAFSTOR will risk the spread of contamination into the groundwater, aquifer, and Connecticut River, increasing the cost and environmental harm.5. It makes no sense for Entergy to place its faith in the DOE and Congress to enact legislation, assign funding, and build a central or interim repository by 2052. The PSDAR's waste management storage planning should be built on the likelihood that the radioactive fuel will stay in the village of Vernon for another 100 years, in line with the recent NRC decision on waste confidence.
- 6. Entergy should be required to show, in the PSDAR, how it will comply with State environmental and health regulations; the Settlement Agreement (2014); and the Master Trust Agreement (2002) on the decommissioning trust fund. It wants the NRC to make It wants an environmental impact statement and analysis of what would happen in case of terrorism, and/or zirconium fire without the Emergency Planning Zone in place.7. NRC should deny Entergy the ability to withdraw from the Decommissioning Trust Fund monies for non-decommissioning purposes such as guarding the spent nuclear fuel and Spent Fuel Management; and require that Entergy explain how it will pay for those non-DTF expenses.
The NRC should also require Entergy to include contingencies that may not be found until end of SAFSTOR.8. Emergency preparedness should remain in place at least until all the radioactive fuel is moved from the fuel pool into dry cask storage. If the storage pool loses its cooling water supply, as by a sudden drain down (drop of a heavy load punching a hole through the floor, terrorist attack or other hostile action, natural disaster, etc.), or a slower motion boil down (days or even weeks with no electricity from the grid to run the cooling water circulation pumps), the irradiated fuel would only take hours, once exposed to air, to overheat to the ignition temperature of the zirconium metal cladding.
Once the water is low enough, the pool wouldn't be approachable
-- except perhaps by helicopter, attempting to drop water picked up from the Connecticut River from above. Remember the helicopter crews of the Japan Self Defense Forces trying to do just that at Fukushima Daiichi Unit 4, on March 17, 2011? They risked their lives and the efforts failed.I agree completely with the Comments submitted to the NRC February 27, 2015 by my local legislators:
As a community that hosts high level nuclear waste a role we never signed on for we request federal help to cover the cost of expenses we are unprepared to shoulder.
If Entergy can sue the federal government for millions of dollars for not removing the waste in 1998 as scheduled, why can't we access the federal nuclear waste fund to pay for infrastructure, keep us safe and support our emergency personnel?
Major incentives are made available to communities willing to take nuclear waste. So why shouldn't towns like ours that have that job thrust upon us receive such incentives?
Thank you for your consideration of my comments.Leslie Sullivan Sachs 25 Chestnut Hill #3 Brattleboro, VT 05301 safeandgreencampaign@gmail.com