Contact: Clay Turnbull 802-380-4462 or Raymond Shadis 207-380-5994
Intervener asks Vermont Public Service Board to Enforce Its Orders Prohibiting Burial of Demolition Debris at Entergy Vermont Yankee.
Coalition Treads where Angels Fear. Letters to the Editor show Town of Vernon, Local Representative, Vermont Energy Partnership are anxious that nothing be allowed to dissuade NorthStar from prompt decommissioning deal.
In a motion filed today with the Vermont Public Service Board, James Dumont, Attorney for New England Coalition requested affirmation of Board Orders issued in 2002 and 2014, which in effect put judicial teeth into memoranda of understanding signed by the state and Entergy preparatory to Entergy buying the plant and then renewing its operating permits.
Those memoranda contain an agreement to work toward no onsite burial of concrete demolition debris, a practice termed, “rubblization”.
NorthStar, in its VPSB application for a Certificate of Public Good, said that it will not abide by the no rubblization agreement because it does not fit the company’s “business model”
However, Clay Turnbull, NEC representative, points out, NorthStar in its License Transfer Application told NRC something quite different. “They said projected savings from rubblization were not part of their cost estimates.”
“These contradictory statements notwithstanding, NorthStar cannot unilaterally decide which agreements and which Board Orders it will comply with and which ones it will flout” said Turnbull.
For New England Coalition’s Attorney, the issue revolves around whether or not all parties have to respect the law and advance their interests by following the rules
According to Dumont, “The Public Service Board has made clear since the very first case involving Entergy that at the end of the decommissioning process there must be a return to greenfield conditions, which does not include demolishing concrete structures and leaving the rubble on the site.  The Board reiterated this minimum standard in the 2014 license extension case. One of the shortcuts built into the new deal is that NorthStar plans to save money by doing what the Board said in 2003 and 2014 cannot be done. The New England Coalition insists that this fundamental change be addressed pursuant to law — by reopening the two cases, the 2002 sale case and the 2014 license extension case, to lawfully amend those orders if NorthStar and Entergy can satisfy the standards for amending a Board order.” 
NEC Motion for Partial SJ 5 5 17   Attachment 1 7862 MOU   Attachment 2 6545 MOU   Attachment 3 APPENDIX D   Attachment 4 CLF Disc Resp   Attachment 5 DPS Disc Resp   Attachment 6 NEC Disc Resp   List of Attachments
In an essay circulated internally among NEC members and supporters yesterday, May 4, 2017, NEC Senior Technical advisor, Raymond Shadis outlined NEC’s concerns regarding rubblization at Vermont Yankee.
“Simply put, Shadis wrote, NEC objects to rubblization because the site is too precious to besmirch with a granular concrete  landfill.” 
1. It is a vital piece in the mosaic of a restored Connecticut River with both natural preserve and immense recreational value; an important factor in the whole picture of New England and the US clearing up the 19th century vision of industrialized rivers. The site is wholly incompatible with either new industrial development or leaving any more remnants than necessary of nuclear industrial development. 
2. It is a First Peoples heritage site with burial, cultural, and ritual remnants both onsite and in surrounding lands and waters. It would be most disrespectful for our generation to crap it up with radionuclides and industrial trash and leave it that way. 
3. Entergy agreed that it in consultation with Vermont agencies it would establish a “no rubblization” standard for site restoration.  NorthStar is not licensed to establish a landfill dump on the banks of the Connecticut.
As to radiological cleanup, the site is contaminated with the full array of transuranics and fission products produced in the VY Reactor, an array identical to that released by Chernobyl and Fukushima in every way except overall concentration. So, over time the biotic community will be plagued in the same way as the biota of Chernobyl is now plagued and in ways now just emerging at Fukushima. 
One big problem with rubblization is the temptation to mix clean and contaminated concrete so as to bring the radioactive intensity down to clearance levels (while not reducing the overall amount of curie content of the disposed concrete). This can happen purposefully or inadvertently as major radioactive dose contributors such as Strontium-90 (a beta emitter) and Plutonium-239 (an alpha emitter) may be completely shielded from field instrument detection by a cardboard thin layer of concrete. 
Take out the magic of artist’s renderings of the future decommissioned site and Northstar does not leave a very pretty picture.
Read why it is a major issue and the rest of the story at the Reformer’s website  
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