It’s only good business. So don’t wait, Entergy.

Veteran employees in decommissioning know where the metaphorical bodies are buried. Expert analysts note that waiting to fully decontaminate Vermont Yankee will only increase the costs.

It's a kind of inside joke, and a not-very-funny one at that.

Archer Mayor's latest police procedural novel, Presumption of Guilt, is set at Vermont Yankee. A decommissioning crew finds a body buried in a cement slab beneath a warehouse set for demolition.

Tres cool, though Entergy Nuclear Vermont Yankee would likely argue - as company officials did with buried pipes carrying radioactive material, notably tritium - that a body is not actually “buried” if it is encased in concrete (or a coffin) and not in direct contact with the soil.

In the real world of decommissioning, the “buried bodies” are areas of radiologically contaminated soil, concrete, or other objects, up to and including nuclear-fuel particles that were spilled, dumped, or otherwise released to the open environment sometime in the reactor's operating history.

As shown in Entergy VY's 2014 site assessment study, reliance on written records - a paper chase - will yield less than a complete picture.

When it comes to releases of radiological materials, what surfaces in the record is often the tip of the iceberg, not the bulk. That remains submerged, buried.

* * *

At Maine Yankee, we decided on prompt rather than delayed decommissioning in part because we would be able to involve veteran employees who had witnessed the various spills, releases, and inventory gone astray over the plant's 26-year operating history.

History keepers, we reasoned, know best where the bodies are buried. Their firsthand recollections and knowledgeable scouting for hot spots proved valuable in avoiding radiological surprises that otherwise would have proven costly in worker exposures and dollars.

Today, at Vermont Yankee, Entergy can similarly involve veteran employees in decommissioning - employees who will be gone in 20, 30, 40, or 50 years.

When referencing Maine Yankee, I say “we” because, unlike Entergy VY, Maine Yankee Atomic Power Company sought stakeholders' informed input and agreement from the get-go. The result was state and community satisfaction and a decommissioning with record cleanup and minimal worker exposure, coming in on budget and almost on schedule (seven years, five months).

But that was another company in another time.

This is Entergy VY.

Nothing if not smug, Entergy VY remains committed to the safstor delayed decommissioning model (see me Thursday, half a century from now), as opposed to the more-immediate decon.

Why? It could be because during its 14-year tenure at Vermont Yankee, Entergy set aside absolutely no money - zero - for decommissioning and it doesn't intend to start contributing now.

But wait - there's more.

Thomas LaGuardia, whose company, LaGuardia & Associates, now owned by Entergy, performed decommissioning cost studies for more than 90 percent of U.S. reactors (including Vermont Yankee), told the website Nuclear Energy Insider that “project management costs can represent as much as 55 percent of total decommissioning costs, with 20-25 percent allocated for dismantling and around 25-30 percent for waste disposal.”

So with virtually no corporate investment, Entergy stands to reap more than half of the projected $1.24 billion trust fund in decommissioning and spent-fuel-management fees.

“While most operators have chosen to defer D&D [decontamination and dismantlement] activities by using safstor, operators can benefit from using the alternative decon approach as it allows them to shift the financial liability for decommissioning activities to a contract company,” LaGuardia said.

“Although safstor requires a minimal initial outlay and delays spending on the main expenses, licensees need to manage [Nuclear Regulatory Commission] regulations and the site's nuclear liability over several decades.”

* * *

Shifting financial liability to a decommissioning contract company is exactly what Exelon did for its two Zion, Illinois, reactors, going to decon after a decade or more of costly safstor. Savings brought decommissioning of the two reactors down to around $900 million. At least two other plants are following the Zion example.

In the same Nuclear Energy Insider piece, Geoffrey Rothwell, principal economist at the Organization for Economic Cooperation and Development's Nuclear Energy Agency, said operators should start decommissioning activities as early as possible, as the deferral of D&D exposes operators to delay-related costs, investment risks, and loss of crucial expertise as workers leave the industry.

According to the article, “A major advantage of carrying out D&D activities immediately is that current operations staff have in-depth knowledge of plant specifics, including previous incidents and undocumented facility detail, which avoids unnecessary work-arounds, Rothwell said.”

In another article, the publication concluded that “by deferring D&D activities, operators raise the chance of chemical or radiation leaks spreading and the introduction of stiffer regulation.”

“While decommissioning cost estimates have risen, rates of return for [decommissioning trust funds] have been lower than expectations, and operators which have accelerated closure plans should leverage current staff expertise and optimize decommissioning schedules to allocate decommission fund portfolios so the 'liquidity matches your plans,' [Rothwell] said."

A big plus at Vermont Yankee is that Entergy has recently shown signs that it cares what stakeholders think by consulting on tritium-contaminated water disposal and funding for emergency planning.

It's only good business.

Entergy Nuclear Vermont Yankee should borrow the up-front money from its parent company to go to decon now and repay the loan from the decommissioning trust fund when it matures.

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