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08-30-17 Arnold Gundersen Prefiled Testimony STATE OF VERMONT PUBLIC UTILITIES COMMISSION Joint Petition of NorthStar Decommissioning Holdings, LLC, NorthStar Nuclear Decommissioning August 30, 2017 Company, LLC, NorthStar Group Services, Inc., LVI Parent Corp., NorthStar Group Holdings, LLC, Docket No. 8880 Entergy Nuclear Vermont Investment Company, LLC, and Entergy Nuclear Operations, Inc., any other necessary affiliated entities to transfer ownership of Entergy Nuclear Vermont Yankee, LLC, and certain ancillary approvals pursuant to 30 V.S.A. Sections 107, 231, and 232. PREFILED REBUTTAL TESTIMONY OF ARNOLD GUNDERSEN ON BEHALF OF NEW ENGLAND COALITION Mr. Gundersen outlines his professional opinions regarding the proposed ownership transfer and decommissioning plans for the Vermont Yankee Atomic Power Reactor. He further provides informed perspectives on the presence of radioactive contamination on the Vermont Yankee (VY) site, the use of rubblization rather than removal of radioactivity from the VY site, comparisons of contamination between Boiling Water Reactor (BWR) and Pressurized Water Reactor (PWR) decommissioning. In addition, Mr. Gundersen opines on the financial risks to the State of Vermont by the proposed NorthStar LLC purchase of Vermont Yankee from Entergy LLC, funding of the actual Vermont Yankee decommissioning project and a separately funded Department of Energy Interim Spent Fuel Storage Installation, and the overall lack of corporate experience and capabilities of NorthStar as the proposed prime decommissioning contractor. Mr. Gundersen’s analysis indicates that granting the Petition as it stands would not on balance serve the public good. Docket 8880 1 Joint Petition of NorthStar Decommissioning Holdings, LLC 2 3 4 STATE OF VERMONT 5 PUBLIC UTILITIES COMMISSION 6 7 In the matter of 8 9 Joint Petition of NorthStar Decommissioning 10 Holdings, LLC, NorthStar Nuclear Decommissioning August 30, 2017 11 Company, LLC, NorthStar Group Services, Inc., LVI 12 Parent Corp., NorthStar Group Holdings, LLC, Docket No. 8880 13 Entergy Nuclear Vermont Investment Company, LLC, 14 and Entergy Nuclear Operations, Inc., any other 15 necessary affiliated entities to transfer ownership of 16 Entergy Nuclear Vermont Yankee, LLC, and certain 17 ancillary approvals pursuant to 30 V.S.A. Sections 18 107, 231, and 232. 19 20 21 TESTIMONY OF ARNOLD GUNDERSEN SUPPORTING 22 THE NEW ENGLAND COALTION: 23 AN EVALUATION OF THE FINANCIAL RISKS TO VERMONT 24 IN THE PROPOSED SALE OF 25 THE ENTERGY NUCLEAR VERMONT YANKEE POWER PLANT SITE 26 TO NORTHSTAR DECOMMISSIONING HOLDINGS, LLC 27 28 29 WITNESS BACKGROUND 30 Q1. Please state your name and residence. 31 A. My name is Arnold Gundersen, and I live in Burlington, Vermont 32 Q2. What is the purpose of your testimony? 33 A. The New England Coalition has retained Fairewinds Associates, Inc to evaluate 34 the financial risks associated with the proposed sale of the Entergy Nuclear Vermont 35 Yankee (ENVY) Power Plant to NorthStar, LLC for the proposed purpose of 36 decommissioning Vermont Yankee. As an employee of Fairewinds Associates, and 37 its chief engineer, I performed this risk assessment for New England Coalition. 38 Q3. Please summarize your educational and professional experience. 39 A. I earned my Bachelor Degree in Nuclear Engineering from Rensselaer 40 Polytechnic Institute (RPI) cum laude. I earned my Master Degree in Nuclear 41 Page 2 of 24 Engineering from RPI via an Atomic Energy Commission Fellowship. Cooling 1 tower operation and cooling tower plume theory were my area of study for my 2 Master Degree. 3 I began my career as a reactor operator and instructor in 1971 and progressed to 4 the position of Senior Vice President for a nuclear licensee prior to becoming a 5 nuclear engineering consultant and expert witness. An updated Curriculum Vitae 6 is attached as Exhibit 1. 7 I have testified as a nuclear engineering expert witness before the Nuclear 8 Regulatory Commission (NRC) Atomic Safety and Licensing Board (ASLB) and 9 Advisory Committee on Reactor Safeguards (ACRS), in Federal Court, the State 10 of Vermont Public Service Board, the State of Vermont Environmental Court, and 11 the Florida Public Service Commission. 12 I am an author of the first edition of the Department of Energy (DOE) 13 Decommissioning Handbook. I was a member of an NRC Licensee’s Radiation 14 Safety Committee responsible for decommissioning nuclear facilities throughout 15 the United States. I am the author of a peer reviewed scientific paper entitled 16 Radioactively-hot particles detected in dusts and soils from Northern Japan by 17 combination of gamma spectrometry, autoradiography, and SEM/EDS analysis 18 and implications in radiation risk assessment published in the Journal (STOTEN) 19 Science of the Total Environment. 20 As an appointee of Vermont State Legislature for two years, I was charged with 21 serving in an oversight role of Entergy Nuclear Vermont Yankee and an advisory 22 role on nuclear reliability issues to the Vermont State Legislature. 23 I have more than 45-years of professional atomic power engineering experience 24 as delineated in my attached CV. 25 26 Q4. Have you ever testified before the Vermont Public Utility Commission 27 Page 3 of 24 (VTPUC) or Vermont Public Service Board (VTPSB)? 1 A. Yes, I have testified in several Vermont Yankee Dockets heard before the 2 VTPSB. 3 4 Q5. Have you read the Application and Prefiled Testimony of Entergy and 5 NorthStar? 6 A. Yes. 7 8 Q6. What are your preliminary observations and conclusions? 9 A. NorthStar’s lack of experience in decommissioning boiling water reactors 10 (BWRs) has led me to conclude that there is a significant financial risk to the 11 State of Vermont and its citizens if Vermont Yankee were to be decommissioned 12 and dismantled with the petitioners’ approach. 13 14 Q7. Did you review NorthStar’s claimed proprietary material? 15 A. Yes, but I found none of the material was useful in reaching any conclusions, so it 16 is not incorporated into this report. 17 18 Q8. According to prefiled testimony by petitioners NorthStar and Entergy, both 19 petitioners claim that the proposed change in ownership of the shutdown 20 Entergy Vermont Yankee (ENVY) atomic power reactor will allow its 21 decommissioning to move forward more quickly following the transfer of 22 ownership. Furthermore, the parties claim that the transfer of ownership of 23 ENVY from Entergy to NorthStar will reduce decommissioning costs by 24 hundreds of millions of dollars and also reduce the length of time required to 25 dismantle Vermont Yankee by approximately 30 years. Does the proposed sale 26 of ENVY from Entergy to NorthStar provide these claimed benefits? 27 A. No, selling Vermont Yankee to NorthStar, a corporation that is inexperienced in 28 atomic power reactor and nuclear power plant decommissioning does not produce 29 Page 4 of 24 any of the claimed financial or schedule benefits. Entergy’s TLG subsidiary or 1 any one of many newly formed decommissioning competitors all are capable of 2 hiring a team of subcontractors to completely dismantle VY by the early 2030’s 3 within the funds available in the Decommissioning trust. In fact, Entergy has 4 acknowledged that its TLG subsidiary is a highly experienced nuclear industry 5 leader in decommissioning. 6 JACKSON, Miss., Sept. 7 /PRNewswire/ -- Entergy Corporation 7 (NYSE: ETR) has agreed to buy TLG Services Inc. of Bridgewater, 8 Conn., in a deal that will make Entergy one of the most experienced 9 companies in decommissioning in the U.S. nuclear industry, the 10 two companies jointly announced today. 11 "TLG Services is a globally recognized expert in decommissioning 12 engineering, related cost estimation, and field services. Their 13 expertise strengthens Entergy's capabilities as one of the nation's 14 premier nuclear operators," said Jerry Yelverton, chief executive 15 officer of Entergy Nuclear. 16 "We already are doing decommissioning work in the utility industry, 17 and acquiring TLG solidifies our position as an industry leader. 18 "Yelverton pointed out the expertise of TLG Services will reduce 19 the decommissioning risk, a potentially significant liability, at 20 Entergy Nuclear's existing nuclear plants and the additional plants it 21 buys as Entergy pursues its principal growth strategy of acquiring 22 more nuclear generation. 23 "TLG's knowledge is necessary for a national nuclear company 24 and fits well with our growth strategy," he said. (emphasis added) 25 26 Q9. Entergy and NorthStar have claimed a series financial and schedule savings 27 due to NorthStar’s proposed plan. Are the claimed Entergy and NorthStar 28 savings correct? Are the presumptions and cost analysis delineated by Entergy 29 and NorthStar and that underlie the claimed savings correct? 30 A. No, both the claimed financial savings and schedule reduction and the underlying 31 presumptions and cost analysis being used to justify the proposed sale of VY are 32 incorrect. 33 34 In 2012, Entergy provided the State of Vermont with a Yankee decommissioning 35 Page 5 of 24 planning document entitled Decommissioning Cost Analysis for the Vermont 1 1 Yankee Nuclear Power Station , written by TLG Services. A literal reading of this 2 Entergy document led Vermont State policymakers to reach erroneous 3 conclusions regarding the timing of Entergy’s program for decommissioning 4 Vermont Yankee. Decommissioning Cost Analysis for the Vermont Yankee 5 Nuclear Power Station speculates that the costs associated with decommissioning 6 Vermont Yankee are so excessive and exorbitant that it will take at least 60-years 7 for the underfunded trust fund to finally accumulate adequate funds to address the 8 excessive cost estimates of decommissioning the 40-year-old plant. 9 10 Formerly an independent decommissioning services company, TLG Services is 11 now a wholly- owned subsidiary of Entergy Corporation. Beginning in 2012, 12 TLG Services created a series of spurious financial premises released in its 2012 13 VY report that allowed Entergy to reach its erroneous financial and schedule 14 conclusions.
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