ML20058G766
| ML20058G766 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/14/2020 |
| From: | - No Known Affiliation |
| To: | |
| SECY/RAS | |
| References | |
| 85FR03947, NRC-2020-0021 | |
| Download: ML20058G766 (3) | |
Text
From:
Riverkeeper on behalf of Jean Naples To:
Docket, Hearing
Subject:
[External_Sender] Docket ID NRC-2020-0021 - Reject Holtec"s PSDAR Date:
Friday, February 14, 2020 2:35:37 AM Feb 14, 2020 U.S. Nuclear Regulatory Commission, Rulemakings and Adjudications Staff
Dear:
Rulemakings and Adjudications Staff, I am writing as a physician and public health advocate who lives along the banks of the Hudson River, that strongly urges the NRC to cpmpletely reject Holtec's PSDAR for Indian Point since a cursory overview shows that the Report fails to fulfill its basic objectives. A list of its main flaws are as follows:
- 1. A full site characterization has not been completed, which immediately casts a doubt on the entire report. The site characterization provides the foundational information about the site's current situation, including the extent of any contamination, needed to determine what needs to be done to decommission the site. It is highly doubtful that Holtec can accurately gauge the cost of its activities when it does not know what needs to be done.
The NRC should reject this bare bones PSDAR for Indian Point since its cursory overview fails to fulfill its basic objectives. The significant flaws in Holtec's report are as follows. A full site characterization for this Indian Point shutdown project has not been completed, making it impossible to know what needs to be done on the site, let alone to form an accurate cost-estimate.
- 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. Without properly considering the pipeline, Holtec cannot begin to take the necessary precautions to minimize the risk of potential pipeline explosions during the decommissioning process.
It is very important to be aware that a full plan to ensure protection for the Algonquin Pipeline, a giant high-pressured gas pipeline next to Indian Point was not acknowledged, which means there is no plan to prevent pipeline explosions in the PSDAR.
- 3. Similarly, the activities that are included within the PSDAR are vague to the point of meaninglessness. For example, the Report mentions the possibility that large components will be removed by barge and then loaded on rail. However, there is no discussion of possible routes, when barging would be needed, safety precautions to prevent the release of radioactive materials or accidents during the barging process, or the environmental impacts of barging.
Unfortunately, I am writing as a physician and public health advocate, because the activities included within the PSDAR do not include any discussion of precautions and safety concerns for
protection of families that reside near Indian Point and along the shores of the Hudson River. For example, barging large components down the Hudson is mentioned, but essential information such as the route, frequency, and risk of this option is not provided.
The lack of information makes it impossible to figure out what Holtec intends, and as such, it is unfathomable that accurate safety considerations and cost estimate was provided for this option.
- 4. Holtec's minimal effort is further highlighted by its method of choice to address the known radioactive groundwater contamination on-site, monitored natural attenuation -- essentially doing nothing.
Please be aware that doing nothing about radioactive groundwater could lead to it flowing into the Hudson. To cut costs, 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. Simply leaving all the radioactive contamination and structures in place, Holtec is not proposing to fully restore the site for future uses.
Please realize that Holtec's intent to only meet the bare minimum is seen in their proposal to essentially do nothing about the known radioactive groundwater contamination, to remove above ground structures only to a depth of 3 feet, and 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.
The U.S. Regulatory Commission must realize that the cost-estimate for PSDAR appears to be based on the size of the decommissioning trust fund rather than real costs. Holtec plans on using the decommissioning fund for non-decommissioning purposes, and then pocketing any reimbursement it recovers later from the Department of Energy, while limiting its own risk through the use of limited liability subsidiaries with no assets.
Unfortunately, as outlined in the PSDAR, Holtec has everything to gain and nothing to lose, by shifting all risk onto the public.
I am writing as a New York physician and public health advocate, who lives along the banks of the Hudson River. At this time, I thank you for your consideration of my letter and strongly urge the NRC to please not allow this greatly flawed PSDAR to become a reality. Please know that this plan is a clear danger to ensure public health protection for myself and all New York residents that live in proximity to Indian Point or anywhere along the banks of the Hudsoin River. I very much urge you to completely reject this unacceptable PSDAR.
Sincerely, Jean Marie Naples, MD-Ph.D.
Sincerely, Jean Naples 26 Montebello Commons Dr Suffern, NY 10901-4250 jeannaples7@gmail.com