ML20052E506

Comment from Courtney Williams on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)

ML20052E506
Person / Time
Site:	Plum Brook, Indian Point
Issue date:	02/11/2020
From:	Safe Energy Rights Group
To:
References
85FR03947, NRC-2020-0021
Download: ML20052E506 (3)

Text

PUBLIC SUBMISSION As of: 2/14/20 7:46 AM Received: February 11, 2020 Status: Pending_Post Tracking No. 1k4-9eyk-jxu0 Comments Due: February 24, 2020 Submission Type: Web 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-0004 Comment on FR Doc # 2020-00824 Submitter Information Name: Courtney Williams Submitter's Representative: Courtney M. Williams Organization: Safe Energy Rights Group General Comment I am writing on behalf of Safe Energy Rights Group, Inc. (SEnRG) and the 20 million people living and working within the 50 mile radius around Indian Point Nuclear Power Plant to request the NRC deny the application for license transfer from Entergy to Holtec.

The communities around Indian Point and others in the region, have grave concerns about Holtec's ability to successfully complete the decommissioning of Indian Point Units 1, 2, and 3.

The Post-Shut Down Decommissioning Activities Report (PSDAR) filed by Holtec Decommissioning International, LLC ("HDI") was woefully inadequate:

It failed to include a single mention of the "Algonquin" Pipeline system that runs under Indian Point Energy Center, including one pipeline that runs 400 feet from the control room. New York State conducted a risk assessment of the co-location of these pipelines with Indian Point and identified decommissioning activities as posing an increased risk of rupture and fire. That Holtec was seemingly unaware of these pipelines and did not include a plan to address the increased risk is unacceptable.

It failed to include a plan to remediate the significant amount of radioactive water already beneath the site and currently being monitored by wells around the Indian Point property. The presence of old water mains under the site and the leaks from the spent fuel pools are likely to be exacerbated by the use of heavy equipment to Page 1 of 2 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064843532f5&format=xml&showorig=false

deconstruct the reactors and other structures.

HDI set up a series of "shell" companies to own and manage the decommissioning process. None of these companies appear to have any 'seed capital' or any guarantees on the part of HDI that would ensure their ability to complete this project.

Because the 'shell' companies lack capital, Holtec has requested an exemption to use the Decommissioning Trust Fund to pay for waste handling. It plans to then request reimbursement from the Treasury for those expenses - which amounts to double payment for activities that are not even among the allowed

'decommissioning activities' under the applicable Federal legislation.

Our community and our elected officials share these concerns. We therefore request the application for license transfer be denied.

Attachments SEnRG public comment on license transfer Page 2 of 2 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064843532f5&format=xml&showorig=false

Empowering Communities to Power the Future Courtney M. Williams, PhD Safe Energy Rights Group, Inc.

92 McGuire Avenue Peekskill, NY 10566 February 10, 2020 US Nuclear Regulatory Commission By Electronic Transmission:

Hearing.Docket@nrc.gov Washington, DC 20555-0001 RE: Comment on Indian Point License Transfer, NRC-2020-0021 To Whom It May Concern:

I am writing on behalf of Safe Energy Rights Group, Inc. (SEnRG) and the 20 million people living and working within the 50 mile radius around Indian Point Nuclear Power Plant to request the NRC deny the application for license transfer from Entergy to Holtec..

The communities around Indian Point and others in the region, have grave concerns about Holtecs ability to successfully complete the decommissioning of Indian Point Units 1, 2, and 3.

The Post-Shut Down Decommissioning Activities Report (PSDAR) filed by Holtec Decommissioning International, LLC (HDI) was woefully inadequate:

It failed to include a single mention of the Algonquin Pipeline system that runs under Indian Point Energy Center, including one pipeline that runs 400 feet from the control room. New York State conducted a risk assessment of the co-location of these pipelines with Indian Point and identified decommissioning activities as posing an increased risk of rupture and fire. That Holtec was seemingly unaware of these pipelines and did not include a plan to address the increased risk is unacceptable.

It failed to include a plan to remediate the significant amount of radioactive water already beneath the site and currently being monitored by wells around the Indian Point property. The presence of old water mains under the site and the leaks from the spent fuel pools are likely to be exacerbated by the use of heavy equipment to deconstruct the reactors and other structures.

HDI set up a series of shell companies to own and manage the decommissioning process.

None of these companies appear to have any seed capital or any guarantees on the part of HDI that would ensure their ability to complete this project.

Because the shell companies lack capital, Holtec has requested an exemption to use the Decommissioning Trust Fund to pay for waste handling. It plans to then request reimbursement from the Treasury for those expenses - which amounts to double payment for activities that are not even among the allowed decommissioning activities under the applicable Federal legislation.

Our community and our elected officials share these concerns. We therefore request the application for license transfer be denied.

Sincerely, Courtney M. Williams, PhD Cofounder, Safe Energy Rights Group, Inc.