ML20066H356

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Comment from Vincent Ferri on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
ML20066H356
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 02/23/2020
From:
- No Known Affiliation
To:
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML20066H356 (2)


Text

Page 1 of 2 As of: 3/5/20 2:56 PM Received: February 23, 2020 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 1k4-9f6m-93ov Comments Due: February 24, 2020 Submission Type: Web Docket: NRC-2020-0021 Indian Point Nuclear Generating Unit Nos. 1, 2, and 3; Transfer of Control of Licenses and Approval of Conforming License Amendments Comment On: NRC-2020-0021-0001 Indian Point Nuclear Generating Unit Nos. 1, 2, and 3; Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments Document: NRC-2020-0021-DRAFT-0117 Comment on FR Doc # 2020-00824 Submitter Information Name: Vincent Ferri Address:

555 Scotchtown-Collabar Road Middletown, 10941-3634 Email: advocate@wallkillwideawake.org General Comment Holtec is a poor choice for dismantling and remediating Indian Point and safeguarding its radioactive waste, and it's already telegraphing it will do a bad job. Among Holtec's many disqualifying problems:

Holtec lacks experience in nuclear plant decommissioning.

Holtec's record is full of malfeasance bribery, fraud, getting barred from doing business with entities like the TVA and the World Bank, lying to public officials, risk-taking, dangerous incompetence and contempt for public concern or input.

Holtec's complex subsidiary structure of siloed, undercapitalized LLCs shields it from liability and accountability. Its side businesses pose serious conflicts of interest.

Holtec is privately held and secretive about its finances. It hasn't demonstrated the capitalization required to complete the estimated $1.3 billion decommissioning, as opposed to walking away and sticking taxpayers with the consequences and costs. Its business model is about using the ratepayer financed decommissioning trust fund and taxpayer money to maximize its profits.

https://www.fdms.gov/fdms/getcontent?objectId=09000064843a100e&format=xml&showorig=false 03/05/2020

Page 2 of 2 In a premature and improper report filed with the NRC about its plans, Holtec lowballed its decommissioning cost estimate, even though there isn't even an assessment of site conditions to base an estimate on.

The company ignored the Algonquin gas pipeline passing near Indian Point's critical components, even though that complicates decommissioning and raises risks of rupture and fire.

It plans to do nothing about radioactive contamination of groundwater.

It won't remediate contaminated soil at the site any deeper than 3 feet.

It stated it is considering shipping radioactive wastes by barge down the Hudson, raising a host of unacceptable risks.

Holtec has attracted opposition from public officials in New York State and across the country including New York Attorney General Letitia James, who intervened legally to challenge Indian Point license transfer to Holtec. "Putting the decommissioning of Indian Point in the hands of a company with no experience and uncertain financial resources is very risky," she said.

Elected officials who support the AG's effort and have echoed her concerns about Holtec include U.S.

Representatives Eliot Engel and Sean Patrick Maloney; State Senators David Carlucci, Peter Harckham, Shelley B. Mayer and Jen Metzger, and State Assembly Members David Buchwald and Ellen Jaffee, among others.

In addition, nine Rockland County Legislators, including Legislative Chairman Alden Wolfe, Vice Chair Aney Paul, Majority Leader Jay Hood, Deputy Majority Leader Phil Soskin and Legislators Michael Grant, Itamar Yeger, Toney Earl, Harriet Cornell, and Aron Wieder, have urged the NRC to reject the sale of the plant to Holtec and to ensure proper decommissioning and site restoration.

Holtec must be disqualified.

https://www.fdms.gov/fdms/getcontent?objectId=09000064843a100e&format=xml&showorig=false 03/05/2020