Entergy decommissioning team executes proactive labor strategy ahead of US closure surge

Entergy's newly-created Nuclear Decommissioning Organisation will apply recent learnings on labor placement and regulatory efficiency to the group’s upcoming reactor closures in order to optimize pre-shutdown activities and cut transition phase costs, company executives told Nuclear Energy Insider.

Entergy's decommissioning strategy builds on lessons learned at the Vermont Yankee decommissioning project. (Image credit: Entergy)

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There are currently 18 U.S. nuclear power plants being decommissioned and sustained low power prices have prompted six plant closure announcements in the last seven years. Sufficient planning pre-shutdown can significantly shorten the transition period into decommissioning activities and minimize labor costs.

Staffing costs account for around 43.5% of total decommissioning costs and this portion does not include the labor workforce performing the dismantling, the Electric Power Research Institute (EPRI) said in a recent report. Staffing costs during the transition phase have been estimated at around $25 million per year equating to $70,000 per day, but some utilities have reported costs of up to $300,000 per day, it said.

The EPRI has urged U.S. utilities to start decommissioning work at least three years before shutdown as longer planning timelines have been shown to shorten transition phases.

The transition period for the 582 MW Connecticut Yankee plant was 2.8 years after a swift shut down in 1996 and no prior decommissioning preparation, EPRI data shows.

In contrast, the transition period for Entergy's 620 MW Vermont Yankee plant, shut down in December 2014, was just 1.3 years following around 1.3 years of decommissioning planning. In November 2016, Entergy agreed to transfer Vermont Yankee licences to decommissioning group NorthStar, in a deal which will accelerate decommissioning and restore the Vermont Yankee site by 2030.

Entergy also plans to close its 811 MW Palisades nuclear power plant in October 2018 followed by the (695) 688 MW Pilgrim plant in 2019 and the 2 GW Indian Point nuclear plant in 2020-2021. Following the closure of the Vermont Yankee plant, Entergy set up an internal Nuclear Decommissioning Organisation (NDO) to synergize fleet decommissioning strategy and coordinate on-site work including human resource planning.

The NDO, in place since January 2017, will allow Entergy to optimize labor placement across multiple sites and perform proactive regulatory and administrative tasks which can save time and reduce spending during transition phases, company executives told Nuclear Energy Insider.

              US planned nuclear plant shutdowns

Planning pays

Operators have applied proactive staff planning and communication approaches at several recent or upcoming plant closures, including Vermont Yankee, Dominion's 1,772 MW PWR Kewaunee plant and Exelon's 1,930MW BWR Oyster Creek plant (due to shut down at the end of 2019), Richard Reid, Technical Executive EPRI Decommissioning Technology Program, said.

“The feedback has been quite positive…it is reasonable to assume this played into the success in the transition process at Kewaunee and Vermont Yankee,” he said.

A number of post-shutdown safety regulation submissions can be prepared during the operational phase and some regulatory submissions are not strictly required but can reduce costs, according to the EPRI. These include licence amendment requests for emergency plan reductions, security plan exemptions, decommissioning trust fund (DTF) exemptions and insurance exemptions.

Other key activities utilities can perform during operations phases include:

• Revision of the Safety Analysis Report, technical specifications, procedures and processes to reflect the defueled/non-operational condition.

• Completion of engineering evaluations to reclassify systems, so immediate action plans can be developed for each system and component (e.g. de-energize, drain, declare abandoned).

• Detailed planning and contracting for major post shutdown activities (e.g. site characterization, asbestos abatement, management of operational waste, chemical decontamination).

• Completion of the Historical Site Assessment.

• Development of Human Resources and Communication plans and a Community Engagement Panel.

Staff deployment

Entergy's new NDO team is built around the expertise gained from the Vermont Yankee decommissioning project, Paul Paradis, Director Nuclear Decommissioning at Entergy, told Nuclear Energy Insider.

The NDO coordinates on-site work as well as human resource planning and prioritises frequent and open communications with employees during the operations phase, he said.

“You need to get instilled in the organisation, even the oversight organisation, that eventually every job goes away, so our job is to safely, prudently from a financial standpoint, shut down the plants and get them ready for decommissioning,” Paradis said.

Nuclear operators must provide staff with regular updates on labor milestones early in the planning stages, Joseph Lynch, Senior Government Affairs Manager Decommissioning at Entergy, said.

“Everybody’s situation is different; some people are very late in their career and are trying to get to retirement and other people are young and are looking for a future. At the same time, we need to maintain this very skilled and dedicated staff, so we need to make sure that they realize they’re the most important part of this whole process,” he said.

Vermont Yankee staff numbers were cut from 650 during operations to around 315 in the first quarter of 2015 and then reduced to 150 by the second quarter of 2016, according to a presentation by Entergy and Northstar, published in December 2016.

A key challenge was identifying the skills needed for decommissioning while finding staff alternative positions within the company, Lynch said. Entergy has been able to transfer 95% of plant staff into a new career at another operational Entergy plant or to a Vermont Yankee decommissioning role, he said.

One essential staff retention area is security, as regulations stipulate licensees provide continuous security for onsite fuel, Lynch said. Vermont Yankee personnel employed during operations were kept informed of post shutdown security requirements and security staff were transferred to roles outsourced to a private contractor when the plant began decommissioning.

Lessons learned from Vermont Yankee will be applied to future decommissioning projects and the NDO team is already planning for the decommissioning of its Pilgrim 688 MW plant due to transition in 2019, Lynch said.

Community engagement

The Vermont Yankee project has shown that operators can leverage local support for the plant during the operations phase to encourage the community to contribute towards efficient decommissioning operations, Lynch said.

Entergy and the state of Vermont invited local representatives, including members of the public, local officials and labor union officials, onto a Nuclear Decommissioning Citizens Advisory Panel (NDCAP). Early engagement and regular meetings allowed the local community to make preparations to minimize the economic impact of the closure and built local support to move ahead with decommissioning activities.

Entergy is currently building a similar citizens advisory panel for the Pilgrim plant ahead of its closure in 2019, to mitigate the impact on the host community, Lynch said.

“[Citizens advisory panels] are a very good way of getting information out and asking questions, educating them and essentially putting to rest all of their fears associated with that transition to decommissioning and then the work that we’re doing at the site,” he said.

By Karen Thomas