Attn: Kristin Wood
Economic Development Specialist for
Congressman John Olver
Re: Constituent Concerns About Entergy Vermont Yankee Nuclear Power Station
Issues: Public Safety, Terrorism Susceptibility, Reliability, Inadequate Engineering Analysis
Dear Congressman Olver,
We need high-level leadership such as yours to represent the concerns and interests of our region with regard to threat to public safety and to the local economy represented by the power uprate of Entergy Vermont Yankee Nuclear Power Station.
This is a real threat to the region, not simply a typical political concern. To make a difference is a challenge, but to have a chance of making a difference, we need your involvement.
As an energy engineer who has personally reviewed the limited inspection report provided on the Vermont Yankee Nuclear Reactor and as a citizen living in the 10 mile evacuation zone of the reactor, I and my family are very concerned about the changes that are proposed at the reactor.
There are a host of concerns with the proposed uprate. It is our understanding that:
• A 20% power increase, even accomplished in two steps, is an extreme uprate. Most uprates have been accomplished in smaller steps and been for a smaller increase.
• An increase in power output requires more steam/water to be passed through the system at a faster rate; this subjects all components to greatly increased stresses and vibrations. These effects can lead to making parts break off or to breaking of pipes which can cause major malfunctions in the rest of the power station.
• Operation under uprate shortens time available for operator response and increases the likelihood of a malfunction due to operator error.
• The limited inspection review provided by the Nuclear Regulatory Commission was inadequate. Information and analyses provided by Entergy were incomplete and inadequate. Vermont state legislator Steve Darrow said that Entergy gave evasive answers to questions asked. He testified at Vermont Public Service Board hearing that Entergy is gaming the process.
• The recent fueling of the nuclear reactor with more highly enriched uranium in advance of completion of the uprate approval process and prior to a ruling by the Vermont Public Service Board on the acceptability of the inspection report is unacceptable.
• Instead of providing a comprehensive analysis of the ability of components to handle the increased stresses, the NRC is proposing to allow Entergy to stress test components during the process of ramping up the power level. We hold that such an experimental approach to assessing the operation represents an irresponsible approach and an unacceptable risk.
• David Lochbaum of the Union of Concerned Scientists said that such experiments belong in a laboratory, not in communities.
• We are aware that similar uprates at other reactors of this type have caused costly shutdowns due to potentially dangerous steam dryer cracking and valve jamming. Cracks are known to exist in VY’s steam dryers, which are identical to the Quad Cities unit that failed in Illinois.
• In addition, the Entergy request to run the ENVY reactor at containment overpressure is a potentially dangerous and operationally confusing condition that puts the public at risk.
• It may be seen that in addition to safety concerns, the power uprate will reduce the reliability of existing power production at the reactor.
• We are concerned to read in the March 22, 2005 Federal Register that Entergy is no longer reequired to report annual occupational radiation exposure for its workers. This suggests relaxation of safety standards for public and workers alike at a time when risks of harm are heightened by the uprate..
We call on Congressman Olver:
• To call on the NRC to require a comprehensive Independent Safety Assessment (ISA) using the same methodology and scope as that applied to Maine Yankee Reactor. I call on the Congressman to enlist the Vermont congressional delegation (Jeffords, Sanders, Leahy) to stop the uprate until such a study is completed and to assert the inadequacy of the inspection report that the NRC provided.
• To request the GAO (General Accounting Office) to investigate the adequacy of the NRC’s streamlined inspection which they substituted for a safety assessment. We question whether the NRC in, using the streamlined inspection process in this case, is meeting its responsibility to protect the public from unnecessary radiation exposure. The Independent Safety Assessment process as used at the Maine Yankee reactor uncovered many deficiencies that the NRC’s current process would never address or reveal. We feel our children deserve the same protections as Maine’s children.
• We call on the Congressman to work with the Vermont delegation to make the Entergy parent company financially responsible for the on-site storage nuclear waste expenses for as long as the waste remains on the site.
We further call on Congressman Olver to write to the Vermont Public Service Board and deliver the following message:
1. We call on the Vermont Public Service Board to reject the NRC’s inspection report as inadequate to meet the VPSB’s requirement for an independent engineering assessment.
2. We urge the Vermont Public Service Board to rescind its conditional approval of the power increase until an adequate report is provided and its results are evaluated and subjected to public scrutiny.
3. If added on-site storage is to be allowed at all, we make a call on the Vermont Public Service Board to require hardened on-site storage (using concrete and steel structures around each waste module, enclosing them in protective mounds, and with waste modules spread further apart). If this storage system is inadequately designed and constructed, then future generations may end up bearing the economic and societal burden associated with protecting the site and preventing any malfunction while reaping none of the benefits.
4. We call on the PSB to consider health concerns and related costs to the state, local agriculture and business economies which would be adversely affected by an accident or technical problem leading to added releases of radiation to the area. We also perceive the power uprate as reducing the reliability of existing power production at the reactor.
5. We call on the Vermont Public Service Board to make the Entergy parent company financially responsible for the on-site storage nuclear waste expenses for as long as the waste remains on the site.
The address for the Vermont Public Service Board is:
Vermont Public Service Board
Chittenden Bank Building
112 State Street
Montpelier, VT 05620-2701
Please write to the Vermont Public Service Board to emphasize our continued concerns about the Entergy-VT Yankee nuclear power reactor. As citizens living within the 10-mile evacuation zone, we write to express our concerns.