ML20058H117

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

ML20058H117
Person / Time
Site:	Indian Point
Issue date:	02/15/2020
From:	- No Known Affiliation
To:
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML20058H117 (2)

Text

From: Riverkeeper on behalf of Leslie English To: Docket, Hearing

Subject:

[External_Sender] Docket ID NRC-2020-0021 - Reject Holtec"s PSDAR Date: Saturday, February 15, 2020 10:57:41 AM Feb 15, 2020 U.S. Nuclear Regulatory Commission, Rulemakings and Adjudications Staff

Dear:

Rulemakings and Adjudications Staff, I hope the NRC will reject Holtec's PSDAR for Indian Point. It has major inadequacies, among them:

1. There has been no full site description, such as any contamination remediation or projected cost.

2. There is no mention the Algonquin Pipeline, a giant high-pressured gas pipeline only 105 feet from critical safety infrastructure at the nuclear plant and next to two major earthquake fault lines. Without considering this, Holtec cannot take precautions to minimize the risk of potential pipeline explosions during the decommissioning.

3. Similarly, the activities included within the report are vague.

Large components may be removed by barge and loaded on rail, but there is no mention of possible barging routes, when barging would be needed, precautions to prevent release of radioactive materials or accidents or the environmental impacts. There is insufficient information to figure out what Holtec intends.

4. Holtec's minimal effort is highlighted by its method to address the known radioactive groundwater contamination on-site, monitored natural attenuation -- completely inadequate. This could cause radioactive groundwater to enter 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.

5. The PSDAR clearly shows 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, Leslie English 398 Mossybrook Rd High Falls, NY 12440-5304 lbenglish.mes@gmail.com