ML20050N670
| ML20050N670 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/31/2020 |
| From: | - No Known Affiliation |
| To: | |
| SECY/RAS | |
| References | |
| 85FR03947, NRC-2020-0021 | |
| Download: ML20050N670 (4) | |
Text
PUBLIC SUBMISSION As of: 2/5/20 10:00 AM Received: January 31, 2020 Status: Pending_Post Tracking No. 1k4-9er8-j6yv Comments Due: February 24, 2020 Submission Type: API Docket: NRC-2020-0021 Indian Point Nuclear Generating Unit Nos. 1, 2, and 3; Transfer of Control of Licenses and Approval of Conforming License Amendments Comment On: NRC-2020-0021-0001 Indian Point Nuclear Generating Unit Nos. 1, 2, and 3; Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments Document: NRC-2020-0021-DRAFT-0001 Comment on FR Doc # 2020-00824 Submitter Information Name: Joel Gingold Address:
55 Nordica Drive Croton on Hudson, NY, 10520 Email: jegconsult@optonline.net Organization: CCoHOPE Indivisible General Comment I strongly urge the Nuclear Regulatory Commission to deny the application for the transfer of ownership of Indian Point (IP) to Holtec. As a practicing nuclear engineer for nearly sixty years, I fully appreciate the complexities of decommissioning and harbor grave doubts over whether it can be safely and efficiently completed by Holtec.
There are serious questions regarding Holtecs business ethics, whether they be bribery at the TVA, failed promises at its Orrville facility in OH, or misrepresentations in its application for tax benefits in NJ. This situation alone disqualifies Holtec from acquiring IP.
At San Onofre in CA, where Holtec has been managing the spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such operations simultaneously, including, not only IP, but also Pilgrim in MA, Oyster Creek Page 1 of 3 02/05/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648431a14f&format=xml&showorig=false
in NJ, and Palisades in MI. It would clearly be prudent to wait until Holtec has successfully decommissioned a single plant before authorizing it to undertake additional projects. The potential risks in decommissioning are too great to rely on other than successful performance in one project before authorizing additional endeavors.
It is not clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained workers who will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated then that at other reactors because of the absence of a rail spur at IP.
But my principal concerns are financial. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every completed decommissioning, unanticipated circumstances arose that increased the cost above the initial estimate. So today, we cannot accurately know what the final cost of this project will be.
The decommissioning fund contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference, and any additional unforeseen expenses. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI),
a joint venture with SNC-Lavalin. Through this device, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of NY will be forced to pay for the balance of the effort.
Thus, if NRC does approve the transfer, Holtec should not be absolved of financial responsibility and should be compelled to provide any additional monies, beyond those in the decommissioning fund, needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is depleted.
Holtec has requested permission to use monies from the decommissioning fund for spent fuel management.
This should be denied regardless of what other rulings are made by NRC. The decommissioning fund was established for decommissioning alone, and with grave concerns already existing over the adequacy of that fund, any use of it for any other purpose will only exacerbate the fiscal concerns already expressed.
Finally, NY intends to establish a Community Oversight Board (COB) to monitor the contractors performance. Should NRC agree to the transfer, Holtec must be required to cooperate fully with the COB. As a minimum, Holtec should be compelled to share, plans, procedures, documents, etc. associated with the decommissioning process, fully answer all reasonable questions raised by the board, conduct periodic site visits to view the progress of the work and any problem areas, and guarantee that any expert consultants retained by the board will have equivalent access.
The case against Holtec is strong, whether the considerations are technical, fiscal, or ethical. The NRC will best fulfill its obligations to the citizens of our area by denying the application for the transfer.
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