ML20058E969
| ML20058E969 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/13/2020 |
| From: | - No Known Affiliation |
| To: | |
| SECY/RAS | |
| References | |
| 85FR03947, NRC-2020-0021 | |
| Download: ML20058E969 (2) | |
Text
From:
Riverkeeper on behalf of Stan Jacobs To:
Docket, Hearing
Subject:
[External_Sender] Docket ID NRC-2020-0021 - Reject Holtec"s PSDAR Date:
Thursday, February 13, 2020 7:34:12 PM Feb 13, 2020 U.S. Nuclear Regulatory Commission, Rulemakings and Adjudications Staff
Dear:
Rulemakings and Adjudications Staff, I live on the Tappan Zee, a short distance downstream of the Indian Point nuclear plant, and agree with the majority that NRC should reject Holtec's PSDAR for Indian Point, based on an overview showing that the Report fails to fulfill the dost basic requirements. Its main flaws include:
- 1. A full site characterization has not been completed, casting doubt on the entire report. A proper site characterization provides information about the site's current situation and contamination, essential to a decommissioning. How can Holtec accurately gauge the cost of its activities without knowing what needs to be done?
- 2. The PSDAR does not mention the Algonquin Pipeline, a giant high-pressured gas pipeline 105 feet from critical safety infrastructure and next to major earthquake fault lines. Without properly considering that pipeline, how can Holtec minimize the risk of potential pipeline explosions during the decommissioning?.
- 3. PSDAR activities are meaninglessly vague, e.g, in noting that large components will be removed by barge and rail. However, there is no discussion of probable barge routes, timing, safety precautions or other environmental impacts. How can one thus determine Holtec intentions, or have any faith in the safety considerations and cost estimates provided?
- 4. Minimal effort is further highlighted by Holtec's aversion to doing anything beyond monitoring natural attenuation (i.e., flow into the Hudson) to address known radioactive groundwater contamination. Doing nothing about radioactive groundwater could lead to it flowing into the Hudson. To cut costs, Holtec would only remove above ground structures to a depth of 3 feet, and abandon the circulating water intake and discharge structure. How does that fully restore the site for future uses?
- 5. The PSDAR also reveals that Holtec's true intentions are to drain the decommissioning trust fund. Since IP Units 2 and 3 are functionally similar, why should decommissioning Unit 3 cost nearly $200 million more? Anticipating that exemptions will be available to use the decom fund for other purposes such as spent fuel management and site restoration would not only divert funds from their intended purpose, but allow Holtec to pocket any later reimbursement for spent fuel management from the Department of Energy. Coincidentally, Holtec would
be limiting its own risk via the use of asset-free limited liability subsidiaries, make it nearly impossible to collect any shortfalls from the company.
Why contract with a disreputable company that has everything to gain, nothing to lose, and shifts all risk onto the public? I urge you to reject this unacceptable PSDAR.
Sincerely, Stan Jacobs 869 Piermont Ave Piermont, NY 10968-1050 sjacobs@ldeo.columbia.edu