ML20058E956

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Comment from Monika Half on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
ML20058E956
Person / Time
Site: Indian Point  
Issue date: 02/13/2020
From:
- No Known Affiliation
To:
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML20058E956 (2)


Text

From:

Riverkeeper on behalf of Monika Half To:

Docket, Hearing

Subject:

[External_Sender] Docket ID NRC-2020-0021 - Reject Holtec"s PSDAR Date:

Thursday, February 13, 2020 8:41:17 PM Feb 13, 2020 U.S. Nuclear Regulatory Commission, Rulemakings and Adjudications Staff

Dear:

Rulemakings and Adjudications Staff, I live approximately 27 miles down the Hudson River from Indian Point, not a safe enough distance if a nuclear reactor melted down. The NRC should reject Holtec's PSDAR for Indian Point since the Report fails to fulfill its basic objectives. Its main flaws include:

1. The lack of a full-site characterization has not been completed, but merely provides only the foundational information about the site's current situation that omits the extent of any contamination to determine what needs to be done prior to the decommission of the site.

How can we accept the costs Holtec anticipates to decommission the site if they have not outlined what they intend to do?.

2. The PSDAR avoids any mention of the Algonquin Pipeline, whose high-pressured gas pipeline is situated a mere 105 feet from critical safety infrastructure at the Indian Point nuclear plant and adjacent to two major earthquake fault lines. Holtec cannot take necessary precautions to minimize the risk of pipeline explosions during the decommissioning process without addressing the dangers inherent in the pipeline's footprint,.
3. Although the Report mentions the possibility that large components of the reactors will be moved by barge and then rail, no time frame, route maps or safety precautions against the release of radioactive materials, the issues surrounding radioactive groundwater which was not taken into account, and other environmental impacts. This has left the citizens of this State and the people's legislators in the dark.
4. Holtec's nominal effort and opacity regarding recovery plans for future usage of the site is irresponsible and dangerous. Abandoning structures or partial structures is a cost-cutting mechanism without regard for the long-term effects.to the surrounding communities and those further from the site but still in harm's way.
5. Holtec's true intentions of draining the decommissioning trust fund by applying for exemptions for non-decommissioning purposes, such as spent fuel management and site restoration. This not only diverts funds away from its intended purpose, but also allows Holtec to pocket any reimbursement for spent fuel management it later recovers from the Department of Energy. If funding runs out, Holtec limits its risk by the use of limited liability subsidiaries retaining no assets, that would render it impossible for the state to collect shortfalls..

By shifting all the risk onto the public, Holtec has engineered the PSDAR in such a way as to gain everything and lose nothing.

You can stop this. I urge you to reject this PSDAR for what it is, an unfair reckoning of Holtec's responsibility to the people of New York and a further assault on the state of the Environment.

Sincerely, Monika Half 1077 Warburton Ave Apt 607 Yonkers, NY 10701-1178 monikah@optonline.net