COVID-19 has reduced the hustle and bustle, letting us think about what is important — or, more correctly, reset our priorities. This is no small thing; in fact, a culture-quake may be necessary before we can adopt the entirely new relationship with nature that must happen if we are to stave off climate change.
To go from environmental thinking globally to acting locally, let’s consider that one of Vermont’s natural, historical treasures — 130 acres of Connecticut River waterfront in the little town of Vernon — is being scarified, dug up, and heaped with demolition debris.
The demolition of Vermont Yankee is being done on schedule and on budget by a subsidiary of NorthStar, a demolition company noted for speed and precision in taking down large buildings, two recently in midtown Manhattan.
But NorthStar and most stakeholders seem to forget that decommissioning is not primarily about how fast and how cheap you can tear down buildings.
It is about the safe, careful, detailed removal of enough carcinogenic, mutagenic, and teratogenic radioactive contaminants to the point that agreed-upon residual radiation levels will allow open, worry-free access to the site.
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The way the U.S. Nuclear Regulatory Commission puts it in its federal regulations (posted at nrc.gov), decommissioning is “the safe removal of a facility from service and reduction of residual radioactivity to a level that permits termination of the NRC license.”
“As one of the conditions for an operating license, the NRC requires the licensee to decommission the nuclear plant after it ceases power operations,” the regulations say. “This requirement is based on the need to reduce the amount of radioactive material at the site to ensure public health and safety as well as protection of the environment.”
Two important things to note: The NRC talks about reducing the amount of radioactive material at the site and protecting the environment. These objectives are the drivetrain of decommissioning, not added extras like floor mats and turbo wheel covers.
At the end of the day, the first determines proportionately the second.
That is why New England Coalition advocated and won NorthStar’s binding agreement to at least try to reach a residual radiation dose equivalent that matches that already achieved at the other defunct “Yankee” plants — Connecticut Yankee, Maine Yankee, and Yankee Rowe.
NorthStar’s CEO, Scott State, cannot say why Vermont deserves a radiologically dirtier site, but he hesitates to commit to what NEC has been calling the “New England standard” because, despite Entergy’s much-ballyhooed and little probing or detailed feather-duster surveys, he doesn’t know just how badly the site is contaminated.
This is not, financially, a secure position in which to be. And NorthStar’s impromptu decision to ship yet another few million gallons of tritium-contaminated water for out-of-state disposal doesn’t bode well for early cost estimates.
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Mr. State is not alone in his concerns about undisclosed radioactive pollutants. An NRC paper offering guidance to the federal agency staff cites established policy to define a “legacy site” as “a facility that is decommissioning and has an owner who cannot complete the decommissioning work for technical or financial reasons.”
“Legacy sites have two common characteristics: subsurface residual radioactivity in amounts greater than anticipated, and insufficient funds to remediate the radiological contamination to levels that will meet the NRC’s license termination criteria.
“In 2005, NRC staff conducted an evaluation of 82 active and completed decommissioning sites to identify the key operational and technical issues that underlie legacy sites.
“The evaluation concluded that low-level specific-activity radioactive-process leaks, spills, and controlled and uncontrolled effluents were common to legacy sites.
“Over the short term, these are below the threshold for reportable effluent release. Over the long term, these chronic releases accumulate in the subsurface environment and are often not considered for remediation in the decommissioning cost estimate, upon which decommissioning financial assurance is based.”
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Our concern is not about running out of money — some 38 percent of the decommissioning funds are earmarked to pay NorthStar for oversight of contractors doing the actual work of dismantling and decontamination.
Rather, our concern is that decommissioning is a one-time opportunity to remove as much man-made radioactive material as possible.
The beneficiaries would be those at risk of exposure or of incorporating radioactive particles by a myriad of pathways. The children, and the children of the next several generations, will benefit, as will the community of life that surrounds us.
Justices of the U.S. Supreme Court make note in Sierra Club v. Morton that the ordinary corporation is a “person” for purposes of the adjudicatory processes, whether it represents proprietary, spiritual, aesthetic, or charitable causes.
“So it should be,” the Justices say, ”as respects valleys, alpine meadows, rivers, lakes, estuaries, beaches, ridges, groves of trees, swampland, or even air that feels the destructive pressures of modern technology and modern life.
“The river, for example, is the living symbol of all the life it sustains or nourishes — fish, aquatic insects, water ouzels, otter, fisher, deer, elk, bear, and all other animals, including man, who are dependent on it or who enjoy it for its sight, its sound, or its life.
“The river as plaintiff speaks for the ecological unit of life that is part of it. Those people who have a meaningful relation to that body of water — whether it be a fisherman, a canoeist, a zoologist, or a logger — must be able to speak for the values which the river represents and which are threatened with destruction.
“A teaspoon of living earth contains 5 million bacteria, 20 million fungi, one million protozoa, and 200,000 algae. No living human can predict what vital miracles may be locked in this dab of life, this stupendous reservoir of genetic materials that have evolved continuously since the dawn of the earth.”
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The justices’ view is pretty far removed from the notion that the industrialized portion of Governor Hunt’s pasture — having been in the construction of Vermont Yankee razed, graded with rocky fill, paved, poured chockablock full of concrete foundations, and routinely contaminated — is no longer among the living and fit only to walk the streets of commerce.
All in all, the 130-acre site not only has the potential to be rehabilitated as a natural gem, it is a historical treasure as well. The Vernon area hosted one of only two significant settlements in what is now Vermont when Europeans first arrived. In 1676, King Philip or Metacomet gathered 3,000 Native warriors (and how many families and camp followers) at Vernon.
Natives and immigrants bloodily contested the fields around Vernon for the next century and a half.
Governor Jonathan Hunt, whose wife named Vernon “Vernon,” died in 1823. The house, barn, and many acres remained in the Hunt family until prior to the Civil War. It was then bought by Marshal Reed and his half brother, Ed Heard.
Ardent abolitionists, they ran an underground railway station in the Hunt House. It is likely, then, that men and women escaping slavery tilled the fields and ran cattle to pasture where nuclear waste fuel canisters now stand.
So life and history of the Vernon site run deeper than the foundations of Vermont Yankee. The legacy of radioactive contamination, being permanent and wholly undeserved, should be minimized. All that is lacking is an awakening and resolve.