ML20058E998
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| ML20058E998 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/13/2020 |
| From: | - No Known Affiliation |
| To: | |
| SECY/RAS | |
| References | |
| 85FR03947, NRC-2020-0021 | |
| Download: ML20058E998 (2) | |
Text
From:
Riverkeeper on behalf of Edward Brody To:
Docket, Hearing
Subject:
[External_Sender] Docket ID NRC-2020-0021 - Reject Holtec"s PSDAR Date:
Thursday, February 13, 2020 4:34:45 PM Feb 13, 2020 U.S. Nuclear Regulatory Commission, Rulemakings and Adjudications Staff
Dear:
Rulemakings and Adjudications Staff, The NRC should reject Holtec's PSDAR for Indian Point since a cursory overview shows that the Report fails to fulfill its basic objectives.
- 1. A full site characterization has not been completed, which immediately casts a doubt on the entire report.
- 2. The PSDAR does not even mention the Algonquin Pipeline, a giant high-pressured gas pipeline only 105 feet from critical safety infrastructure at the Indian Point nuclear plant and next to two major earthquake fault lines.
- 3. Similarly, the activities that are included within the PSDAR are vague to the point of meaninglessness. Holtec also only proposes removing above ground structures to a depth of 3 feet and proposes abandoning the circulating water intake structures and discharge structure in place as one option.
- 5. 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.
Therefore, as outlined in the PSDAR, Holtec has everything to gain and nothing to lose, by shifting all risk onto the public.
Don't let this plan become reality. I urge you to reject this unacceptable PSDAR.
Sincerely, Edward Brody 66 Pinecrest Dr
Hastings ON Hudson, NY 10706-3702 ebrody52@gmail.com