The Windham Regional Commission has always maintained a neutral position as to whether or not the Entergy Nuclear Vermont Yankee power station located in Vernon should continue operation. We have taken this position so we could facilitate discussions among those on all sides of the issue. The Commission has, however, been very involved in Vermont Public Service Board dockets since 2007, arguing not for whether or not the plant should continue operation, but rather for what is in the best interest of the region when the plant does eventually cease operation, whenever and for whatever reason that occurs. Our positions seek to mitigate to the greatest extent possible the economic, employment, cultural and social impacts of the closure on the region; advocate for the fiscal well-being of our towns; and advocate for the restoration of the Vermont Yankee site to greenfield status as soon as possible so that it may be reused. These positions were most recently stated in our Initial Brief filed on August 16, 2013 in Public Service Board docket 7862. The following is a summary of those positions excerpted from the brief.
We ask that whether or not a Certificate of Public Good is granted, the Public Service Board consider the following:
· Recognize the value of the Station to the region and state while it is operating, and that the general good would be best served if, upon cessation of operations, the Station is promptly decommissioned with complete site restoration so that the site can be reused and serve the orderly development of the region and state.
· Require that ENVY (Entergy Nuclear Vermont Yankee), ENO (Entergy Nuclear Operations), and Entergy Corporation be held jointly and severally responsible for all costs associated with operations, decommissioning, spent fuel management, and site restoration.
· Require the prompt and complete decommissioning and site restoration of the VY Station after shutdown (whenever that occurs) and prohibit the use of SAFSTOR. The best way to accomplish this is to ensure the decommissioning trust is adequate.
· Recognize the Decommissioning Cost Analysis prepared by TLG is inadequate. The Board should specifically recognize the Decommissioning Cost Analysis and Decommissioning Trust Fund do not adequately account for the costs of removing all structures, reasonable property taxes, and additional elements identified by other parties. The Board should require that Entergy VY fully fund the decommissioning trust to cover all potential costs associated with radiological decommissioning, spent fuel management, and complete site restoration without the use of SAFSTOR.
· Require Entergy VY to meet its MOU (memorandum of understanding) commitment to remove “all structures” as part of site restoration, rather than just removing structures to three feet below grade.
· Require Entergy VY to establish separate and adequate funds to cover radiological decommissioning, spent fuel management, and site restoration, and require substantial additional payments into those funds.
· Require Entergy VY to identify a suitable location for a second ISFSI (independent spent fuel storage installation).
· Require Entergy VY to consider shifting spent fuel from wet to dry storage, or alternatively require a payment-in-kind into the decommissioning trust as if fuel had been moved. Additionally, the Board should require that Entergy VY provide funding to the decommissioning trust to cover all the costs of managing spent fuel derived from any period of extended operations after March 21, 2012.
· Require specific actions from Entergy VY to comply with its commitment to use its “commercial best efforts” to have the spent fuel removed from Vermont.
We feel these positions are in the best interest of the region, and the state. What Entergy Nuclear Vermont Yankee intends to do upon closure is on the record, under oath, before the Public Service Board. Our positions were developed in response to what has been entered into the record. The Public Service Board docket remains open, and we believe that these positions should serve as the primary point of negotiation between the state and Entergy going forward. This filing, and other information related to the Commission’s work on Vermont Yankee, can be found on our website at http://windhamregional.org/vermont-yankee.
Additionally, at the request of the Town of Vernon and using a Municipal Planning Grant, we prepared a study titled Resiliency Action Plan for the Town of Vernon in Preparation for the Eventual Closure of the Vermont Yankee Nuclear Power Station. This plan, completed in June, 2012, explains the closure and decommissioning process, and what actions the town can take to prepare. That plan is available here:
http://windhamregional.org/images/docs/vy/exhibits/wrc-cross-35.pdf.
As we note in the plan, federal law and regulations do not require Entergy Nuclear Vermont Yankee to work with the town or the region as they prepare for closure and decommissioning, but we hope they will voluntarily do so. The WRC is prepared to assist in this effort. We have reached out to our counterparts in New Hampshire and Massachusetts to engage them in preparing for the closure of the plant as well.
We recognize the significant and diverse impacts the closure of the plant will have on our region, our towns, our families, our friends, our neighbors, our businesses, and our economy. Understanding these impacts, and what might be done to mitigate them and make our region more resilient, is the reason we have invested considerable staff and volunteer resources over the last 6 years into planning for the plant’s eventual closure. We stand by to assist our towns with planning for a post-Vermont Yankee future, and to lead a regional resiliency planning effort. Given our experience and background, we also expect to be integral to any statewide response and recovery efforts. Mitigating the impacts on the region’s economy will require region-wide solutions, and we will continue to participate in and support the Southeast Vermont Economic Development Strategy, and the development of a Comprehensive Economic Development Strategy, being led by our regional partner, the Brattleboro Development Credit Corporation. We will also encourage Entergy to voluntarily work with the region and our towns to establish a working group through which there will be clear communication about what the plant intends to do, and what those actions mean for our communities. We all must work together to plan for resiliency as the region loses not only a major employer and economic engine, but also many plant workers and their families that call our region home.
For more information contact Executive Director, Chris Campany at ccampany@windhamregional.org or at 802-257-4547 ext 106.
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Chris Campany, AICP
Executive Director
Windham Regional Commission
139 Main Street, Suite 505
Brattleboro, VT 05301
www.windhamregional.org
office (802) 257-4547 x106
cell (802) 380-3511
pager (802) 250-5115
