ML20058E974

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

ML20058E974
Person / Time
Site:	Indian Point
Issue date:	02/13/2020
From:	- No Known Affiliation
To:
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML20058E974 (2)

Text

From: Riverkeeper on behalf of Wendy Fast To: Docket, Hearing

Subject:

[External_Sender] Docket ID NRC-2020-0021 - Reject Holtec"s PSDAR Date: Thursday, February 13, 2020 9:04:49 PM Feb 13, 2020 U.S. Nuclear Regulatory Commission, Rulemakings and Adjudications Staff

Dear:

Rulemakings and Adjudications Staff, Why would the NRC accept a report that doesn't even fulfill very basic objectives. Instead it is a corporate effort by Holtec to obtain a huge decommissioning fee freely while shifting on to the public all the risk. This is sad and tragic.

How can any cost be determined without a true site characterization?

This would give information about the depth of contamination. When you don't know what needs to be done, how can you possibly be accurate in estimating the cost?

Holtec has not considered the giant, high-pressure gas pipeline adjacent to the "safety" infrastructure of the Indian Point Nuclear Plant and also adjacent to not one, but 2 earthquake fault lines. Precautions to keep the risk of explosions of the pipeline to a minimum are necessary. They do not disappear because they are not mentioned in the PSDAR!

Safe decommissioning requires that radioactive waste not be released.

This needs to be planned for. It's not planned for, nor are routes detailed for possible rail or barge removal of "large components" There's no environmental impact statement included-which is, of course, another violation.

Holtec also has no planned action for dealing with radioactive groundwater. " Monitored natural attenuation" includes noticing a problem after it occurs-a problem such as radioactive groundwater flowing into the Hudson River Leaving radioactive contamination and structures in place means that the site has not been restore for future use-it has only been abandoned..

Finally, the PSDAR cannot be clearer in showing Holtec's true intentions of draining the decommissioning trust fund. Though Indian Point Units 2 and 3 are functionally similar other than the size of their decommissioning fund, the PSDAR projects that decommissioning Unit 3 will cost almost $200 million more. The PSDAR also notes that Holtec anticipates that it will get exemptions to use the decommissioning fund 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 recovers later from the Department of Energy. In conjunction to draining the funds, Holtec limits its own risk if funding runs out through the use of limited

liability subsidiaries with no assets, which would make it nearly impossible to collect shortfalls from Holtec.

Don't let this plan become reality. I urge you to reject this unacceptable PSDAR.

Sincerely, Wendy Fast 8406 Green Rd Dansville, NY 14437-9140 ttouch22@me.com