ML13091A019
| ML13091A019 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/22/2013 |
| From: | Rielly T P Vista 360 |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 78FR11904 00001, NRC-2013-0034 | |
| Download: ML13091A019 (1) | |
Text
nn I)4- Mo~m Pi FROM :FAX NO. :8U4768019i40 Mar-. :J-- .-,,. .RHULES l'I"- DRECTIyES PF,t',lu Lrc IE 6 649 INNSBRUCK a LIBERTYVILLE, ILLINOIS 600481-, Vista 360 TEL: 847-680-o670
-FAX: 847-680-1940 E-MAIL: TR6 4 9 oSBCCLOA I-NET BY FAX 301-492-3446 2013 EIUR 22 Pill 3: 15 Chief, Rules, Announcements and Directives Branch Office of Administration U.S. Nuclear Regulatory CommiSsion Washington, D.C. 20555-0001R ED
Subject:
Docket ID NRC-2013-0034
Dear Chief RADB,
We are a Public Interest Nonprofit Leadership group based in proximity to the Zion facility and have a substantial professional investment of time and involvement in the ongoing Decommissioning
& Site Restoration project since 2008. We are writing you about the U.S. Nuclear Regulatory Commission's pending consideration of issuing an order under section 50.80 of 10 CFR approving the request for an INDIRECT TRANSFER of Facility Operating License Numbers DPR-39 and DPR-48 for Zion Nuclear Power Station Units #1 & #2 and including the General License for the Zion Independent Spent Fuel Storage Installation currently held by Zion Solutions LLC.Pursuant to our chartered capacity and representing at large all contributors to the Zion Decommissioning Trust Fund accounts we are OPPOSED to any INDIRECT TRANSFER of the aforementioned existing Zion facility licenses and find that any transfer of the noted operating licenses will more likely than not disadvantage financial stakeholders of the Zion Facility who have provided substantial monetary Decommissioning Trust Fund proceeds which are being directly employed as project draw downs in the Zion Decommissioning
& Site Restoration Project which will be in excess of $ 800,000,000 during its projected term.Since September 2010 and the previous license transfer, the current licensee, Zion Solutions LLC, has not pursued a policy of open and full disclosure and project transparency on financial matters concerning the project's activities to date which has had an impact on public trust and their credibility.
We understand that there are annual reporting requirements to the NRC but this is of little consequence in considering Zion Solutions LLC past posturing on financial matters with the public.Under the proposed acquisition of Energy Solutions, Inc, a publicly listed & SEC reporting company and the parent company of Zion Solutions LLC, the current licensee, by Rockwell Holdco, Inc, a special purpose privately held Delaware corporation and related affiliated parties, we forecast only further possibilities of financial obfuscation due to reporting standards that will be less stringent and subjectively elective under the proposed capital structure of the acquiring party.Reasonable independent measures of acceptable business practice will not be in place in order to address the public interest during the remaining term of the Zion Decommissioning
& Site Restoration Project. We see the current proposal as being about project finances and capital structures rather than Health and Safety which is the primary Mission of the NRC and we cannot see how the public interest can be served by another 2 nd and unprecedented license transfer Si
- .SSUNSI Review Complete Thomas P. Rielly Template = ADM -013 Executive Principal, E-RIDS= ADM -03 Social Purpose Driven Leadership