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BRATTLEBORO – An important part of Vermont Yankee’s decommissioning process – moving the plant’s spent nuclear fuel into more-stable storage – could begin two years earlier than originally planned.

In new filings with the Vermont Public Service Board, an Entergy executive says administrators may start to move the fuel into dry cask storage in “as early as 2017.” The company previously has said it would transfer the fuel in 2019 and 2020.

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The schedule shift apparently would give Entergy more time to undertake the slow, highly regulated transfer of thousands of radioactive spent fuel assemblies from a pool of water at the nuclear plant compound into casks on the site.

George Thomas, a senior project manager with Entergy VY, said the accelerated schedule won’t increase the cost or change the projected completion date.

“The reason for considering the change is to provide an even higher level of confidence that the transfer of all of the spent nuclear fuel that is in the spent fuel pool to dry cask storage … will be complete during 2020,” Thomas said.

The disclosure with the state is part of the latest round of paperwork filed in Entergy’s quest to obtain state approval to build a second concrete pad for storage of Vermont Yankee’s spent fuel. The Vernon plant stopped producing power Dec. 29, but most of its spent fuel – 2,996 assemblies – remains in so-called “wet storage” in a pool inside the plant’s reactor building.

Entergy already maintains one fuel pad at the site; it holds 13 dry casks containing 884 spent fuel assemblies. Eventually, there will be 58 casks needed to hold all of the plant’s spent fuel.

While there is general agreement that dry casks represent a safer method of storing that fuel, Entergy’s plans have attracted scrutiny and spurred concern. Among the issues raised at public meetings has been the safety of the transfer process, in which the fuel is pulled from the pool, placed in casks, loaded onto a large, tracked vehicle nicknamed “Cletus” and moved slowly to the spent fuel pad.

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In new testimony filed Wednesday, Thomas said Entergy’s original schedule called for “the loading and transfer of 32 casks during 2019.” Now, administrators are making arrangements to start that process far earlier.

“Our dry storage system vendor (Holtec) has indicated that it will be able to accelerate the delivery schedule of dry fuel storage equipment, and we are working with Holtec to ensure availability of qualified personnel to load and transport the casks,” Thomas said.

Given that Entergy has not yet built the second pad, “we are evaluating the feasibility of loading and moving spent nuclear fuel casks to the existing (spent fuel) storage pad during construction of the project and believe that it can be accomplished safely and efficiently,” Thomas added.

He told the board that a final decision on the project’s schedule is expected in December. He also said Entergy would not, in the end, pay more for an expedited fuel move. “Certain costs would be incurred earlier than originally planned, but the overall cost of the project would remain the same,” Thomas said.

Thomas offered two other notes on the planned construction of a second spent fuel pad at Yankee: First, he said Entergy now plans to leave a portion of a wall in place during demolition for the new pad; doing so, he said, “will provide additional assurance that the existing (spent fuel) pad has adequate lateral support during excavation.”

Second, Thomas said the federal Nuclear Regulatory Commission has “completed its review of the engineering design calculations for the second (spent fuel) pad and had identified no issues with the calculations.”

Otherwise, Entergy’s latest filings are meant as a response to concerns that had been expressed by state officials and by Windham Regional Commission. In particular, regional commission Executive Director Chris Campany had said alternative sites within the Yankee property should be considered for a spent-fuel pad, and he had raised questions about the project’s financing and its impact on the timeframe for decommissioning.

In their latest testimony, both Thomas and Mike Twomey, Entergy’s external affairs vice president, attempt to rebut testimony filed by the state and by Windham Regional. They raise the following points:

• Thomas said there has been radioactivity detected at the North Warehouse – the structure that will be razed to make way for the second storage pad. This is not surprising, he said, because the warehouse had been used to burn radiologically contaminated oil.

While the state had demanded proper management of non-radiological waste associated with the warehouse, Thomas said the area actually is regulated by the NRC. He said warehouse waste, as well as the building’s oil burner, will be disposed of outside the state as “low-level mixed waste.”

• Thomas said there has been no radioactivity detected in soil around the North Warehouse. If any is found after demolition, that soil will be stored on-site and disposed of per NRC rules. Thomas also pledged that Entergy would continue talking with the state Agency of Natural Resources about Entergy’s testing and waste-disposal plans.

• On the siting question, Thomas offered another detailed defense of Entergy’s decision to build the second spent fuel pad adjacent to the first – and to place both pads near the plant’s reactor building. In ruling out several other locations, he cited factors such as aesthetic problems, right-of-way agreements, limited real estate and radiation dose limits.

Furthermore, he said finding a new site for the second pad at this point would lead to additional costs and would “significantly delay” transferring spent fuel into dry casks.

“Completely new geological analyses would have to be performed, and new engineering designs would have to be developed and analyzed based on those geological analyses,” Thomas said. “A new haul path to a more distant location would have to be engineered, designed and constructed. I estimate that such activities would take several years.”

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• Twomey reiterated that Entergy expects to pay for spent fuel management in two ways.

Building the second pad, buying dry casks and transferring fuel into those casks will be funded via a $145 million line of credit. Entergy expects to repay that line of credit by suing the U.S. Department of Energy “for breach of its contract to remove spent nuclear fuel from the VY station” – a tactic that has worked before.

Entergy wants to pay for long-term spent fuel management by using the plant’s decommissioning trust fund. The NRC has approved that use, though the state has challenged it in federal appeals court.

Twomey said Windham Regional’s financial concerns are “misplaced,” and he said “adequate financial assurances are provided” by Entergy’s spent fuel financing plans. He added that the NRC requires an annual report on the status of Vermont Yankee’s spent fuel funding.

“I should note that the NRC’s standards for evaluating the ability to cover spent fuel management costs are quite conservative because they do not take into account any recovery of these costs from DOE,” Twomey said.

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