Last night, we drove up to Brattleboro, Vermont, to testify before the Vermont Public Service Board, which is taking input on whether Entergy, the Louisiana-based owner of the severely troubled Vermont Yankee nuclear power plant.

We didn’t get to testify; I was something like #78 on the list, across about eleven sites around the state, all televised live. But perhaps that’s just as well, because I’ve spent much of the day going into a lot more detail than I would have had in a two-minute live statement.

I’m going to share the testimony with you. If you’re inspired to give your input to the PSB, you can do so by e-mailing psb.clerk AT state.vt.us, or writing to Vermont Public Service Board, 112 State Street—Drawer 20, Montpelier, VT 05620-2701. You will want to include the docket number. I suggest you use this subject line:

Comment on PSB Docket No. 7862 (Entergy application for Certificate of Public Good)

This is what I submitted. Yes, I know it’s long. But this is one of the most important struggles of our time. If you’re not already familiar with the issues around nuclear power, this will give you some of the basics, as slanted toward an audience of government officials in the US who already know, for example, about the insurance exemption for nuclear power under the Price-Anderson Act that basically means if there’s a problem, the plant owner is not liable.

Dear members of the Vermont Public Service Board,

My name is Shel Horowitz. I am the author of one book on nuclear power and two award-winning books on business ethics and the environment. Like the majority of people who have come before you to testify, I ask that you deny the Certificate of Public Good for Entergy for the continued operation of the Vermont Yankee nuclear power plant.

Dictionary.com provides two definitions for “public good”:

• 1) a good or service that is provided without profit for society collectively
• 2) the well-being of the general public

According to both definitions, Vermont Yankee and Entergy fail the test.

Definition #1 has three components:

a. a good or service is provided

b. without profit

c. for society as a whole.

Yes, Vermont Yankee provides electricity and jobs (though, as we will see later, less efficiently than its alternatives). But it fails utterly on the other two components. Entergy’s whole reason for existence is to provide profits for its shareholders and executives (as opposed to the whole society), and the callous way the company has disregarded both public safety and the truth is directly related to valuing short-term profit instead of the public good.

As to the second definition—I submit that Vermont Yankee not only does not support the well-being of the general public, it puts that well-being at severe risk. Vermont Yankee’s continued operation actively threatens the well-being of residents of three states.

I will elaborate several ways in which Entergy fails to achieve these standards. While I recognize that the federal government has preempted the safety discussion, I submit that you, the board members of the PSB, have an obligation to look at the economic consequences of the safety issues, as they apply to the question of whether Entergy is in fact providing a public good. For that reason, some (not all) of my arguments do include safety concerns, because every safety issue has an economic consequence.

Specific points:

1. Vermont Yankee has a troubling history of severe problems. As far back as 1973 (the last year that full reporting was required), when the plant was only a year old, Vermont Yankee reported 39 Abnormal Occurrences to the Atomic Energy Commission (predecessor to the NRC). A single page of the printout lists six incidents, four of which are potentially significant threats: component failures in both Emergency Core Cooling System and radiation monitoring, and two explosions in the off-gas system within six days of each other. I am enclosing a copy of that printout, along with the descriptive text noting the 39 incidents at Vermont Yankee and 850 AOs nationally when the fleet was only 30 reactors (source: Gyorgy, Anna et al.: No Nukes: Everyone’s Guide to Nuclear Power. Boston: South End Press, 1979). [Click twice on the picture to read the printout (it’s the right-hand side of the graphic)]

2. 

   Other well-documented problems include the collapse of the cooling tower on August 22, 2007, and the more recent discovery that not only was Vermont Yankee polluting the Connecticut River with radioactive tritium, but Entergy lied about the very existence of the pipes conveying the tritium. All of these problems are expensive to fix, impacting ratepayers and residents.

3. Embrittlement and corrosion are severe problems for the nuclear energy generally. Years and years of bombardment by high doses of radiation, the ongoing trauma of New England’s severe winters, and exposure to corrosive chemicals weaken the structural integrity of metal and concrete—aging of the materials was cited as the cause of the cooling tower collapse, in fact. Should these issues start to affect the containment vessel or other key structural components, the results could be catastrophic to the local economy. And the likelihood of deep stress within the plant is high, because this plant was only designed to last 40 years and is now past its life expectancy. It is the height of irresponsibility to continue operating under these circumstances, and PSB’s mandate is to maintain the public good by denying the certificate.
4. While Vermont Yankee’s supporters cite the “public good” of Vermont Yankee in supplying jobs and baseload energy while not generating greenhouse gasses, none of these claims hold up to scrutiny. Clean, renewable energy provides far more jobs per megawatt. Vermont Yankee’s power is currently spread out over the grid and not part of the Vermont baseload, and in any case is frequently unavailable due to both planed and unplanned shutdowns and power reductions.
   To accurately examine the issue of greenhouse gases, and, for that matter, net power generation, we have to remember that nuclear plants themselves are only one small part of the nuclear fuel cycle. The fuel cycle includes mining, milling, processing, assembly into fuel rods, transportation of the fuel, loading them into the reactor, running the reactor, sending electricity along the grid to remote locations (with severe transmission losses in the process), removing the spent fuel, storing it temporarily, and storing longer-term (though, as noted above, reliable permanent storage does not yet exist). Most of these processes are large-scale consumers of energy and emitters of greenhouse gases.
   Like fossil fuels, uranium is a finite substance, and it requires extensive work to create usable fuel. Nuclear expert John J. Berger estimated that once the best quality uranium had been mined (by the 1970s), the remainder is of such low yield that a ton of rock yields only 44 ten-thousandths of an ounce of fissionable U-235. Berger also noted that as of 1977, the nuclear industry had consumed five times as much energy as it produced (source: Berger, John J. The Unviable Option. New York: Dell, 1977, pp. 115-116 and 150-151, as cited in Curtis, Richard, Elizabeth Hogan, and Shel Horowitz. Nuclear Lessons. Harrisburg: Stackpole Books, 1980, p. 222 and p. 90).
5. Routine operation of Vermont Yankee creates harmful radioactive waste that puts its workers and neighbors at risk of health problems (which in turn have a negative economic impact), and that must be isolated from the environment for 250,000 years. Humans have no track record in preserving anything for more than about 30,000 years; we have a few arrowheads and pottery shards from that era. Entergy employs enormous hubris to suggest that when we have no computer data even 100 years old, no languages even 5000 years old, and no artifacts even 50,000 years old, that we will somehow be able to instruct people 10,000 generations into the future on how to maintain the safe and complete isolation of these poisons, even though we don’t yet have any idea how to do this. Obviously, even assuming the language and communication issues can be surmounted, going back in every 50 or 100 years to inspect and rebuild the barriers between these toxic poisons and the environment will be a massively expensive financial burden to future generations of Vermonters—but not to Entergy, which will in all probability not last as long as the problem it is creating.
6. Vermont Yankee shares its reactor design (GE Mark I) with the discredited design of Fukushima-Daiichi. Fukushima has already contaminated a large swath of Japan, resulting in destruction of crops and livestock and severe losses to farmers and residents—and the potential still exists for a secondary accident that could cause far worse damage (see “Estimating the Potential Impact of Failure of the Fukushima Daiichi Unit 4 Spent Fuel Pool” by Dr. Paul Gailey, produced more than a year after the accident <https://www.washingtonsblog.com/2012/06/estimating-the-potential-impact-of-failure-of-the-fukushima-daiichi-unit-4-spent-fuel-pool.html>—as well as this New York Times report in the immediate aftermath: < https://www.nytimes.com/2011/03/18/world/asia/18spent.html?pagewanted=all>
7. Like Fukushima, Vermont Yankee is at risk of catastrophe during severe weather events. Hurricane Irene proved that southern Vermont is not immune to weather catastrophe; last year’s tornado devastated Hampden County, Massachusetts, only about an hour away. And of course, just last month, Superstorm Sandy caused major damage not very far away. These damaging weather events will only increase (see, for instance, NASA climatologist James Hansen, writing in the Washington Post: “This is the world we have changed, and now we have to live in it — the world that caused the 2003 heat wave in Europe that killed more than 50,000 people and the 2011 drought in Texas that caused more than $5 billion in damage. Such events, our data show, will become even more frequent and more severe.” <https://www.washingtonpost.com/opinions/climate-change-is-here–and-worse-than-we-thought/2012/08/03/6ae604c2-dd90-11e1-8e43-4a3c4375504a_story.html>, emphasis added).
8. Items #5 and #6 point to the grave threat in the event of accident (or sabotage). More than 25 years after the Chernobyl accident, large areas in the Ukraine are still uninhabitable, and their land removed from agricultural production. This kind of ecological devastation should be unacceptable anywhere; in an area as dependent on agriculture and tourism as Vermont, it is especially troublesome; it would cause billions of dollars in damage and basically eliminate the local economy.
   Once again, the definition of pubic good requires benefits “for society collectively, and not for profit.” However, should there be a major accident at Vermont Yankee, what gets shared collectively is not the benefit, but the risk. As you know, nuclear power plant owners and operators are protected from the financial consequences of accidents by the Price-Anderson Act—a threat to every American’s economic well-being. Entergy takes the profits—but the citizens of Vermont and neighboring states take the risk. And this risks are real; as I wrote in the 2011 post-Fukushima update to my book Nuclear Lessons (published in Japan by Kinokuniya), there have been at least 101 accidents causing loss of life or at least $50,000 in property damage, including not only the 2011 Fukushima accident but also a lesser-known accident there in 2010.
9. It is hard to make a claim that a company as consistently disingenuous as Entergy can in any way be a partner in the public good. Two among many examples: Entergy accepted a set of conditions giving the State of Vermont power to decide whether the plant should be allowed to continue operating past the original March 2012 expiration date. However, when the state legislature chose not to allow a renewal, Entergy has refused to obey the law and continues to operate while suing the state. Then there were the lies about the tritium leaks. As an expert in business ethics, I see that these two instances demonstrate that this company does not follow accepted standards of business ethics, and should not be trusted to responsibly operate this highly dangerous apparatus.
10. My final point addresses whether nuclear power is the best way to achieve (public good definition #2) “the well-being of the general public.” Nuclear power is, inevitably, a high-risk proposition involving concentrating centralized resources, combining numerous complex processes, and wasting much of both the natural resources and energy required to produce this power. I suggest that first of all, as a society, we can easily slash our energy use by 50 to 80 percent, using deep conservation and better design. Germany uses about half as much energy per capita as the United States, to achieve a comparable quality of life. Here in the U.S., we have the technology to do even better. We can design buildings that are so in tune with their environment, they don’t need furnaces or air conditioning. We can follow the example of the Empire State Building, which is saving more than $4 million per year following a deep energy retrofit. We can use small-scale solar and wind, in-stream (non-dammed) hydro, geothermal, and other truly clean and renewable technologies to generate the energy we need right where it will be used, eliminating the colossal waste of energy lost in transmission. This is the way to a sustainable future for our children and future generations. This is the REAL public good.

Respectfully submitted,

Shel Horowitz

Hadley, MA

Author, Guerrilla Marketing Goes Green, Nuclear Lessons, and six other books.