ML20069F124

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Comment from Tracy Feldman on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
ML20069F124
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 03/05/2020
From:
- No Known Affiliation
To:
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML20069F124 (2)


Text

Page 1 of 2 As of: 3/6/20 2:31 PM Received: March 05, 2020 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 1k4-9fdw-46yr Comments Due: March 25, 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-2020-0021-0002 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-0213 Comment on FR Doc # 2020-03258 Submitter Information Name: Tracy Feldman General Comment Please do not hand over decommissioning of the Indian Point Power Plant to Holtec International.

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:

1. Holtec lacks experience in nuclear plant decommissioning.
2. 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.
3. Holtec's complex subsidiary structure of siloed, undercapitalized LLCs shields it from liability and accountability. Its side businesses pose serious conflicts of interest.
4. 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.
5. 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 https://www.fdms.gov/fdms/getcontent?objectId=09000064843f2500&format=xml&showorig=false 03/06/2020

Page 2 of 2 host of unacceptable risks.

Thank you for considering these comments.

https://www.fdms.gov/fdms/getcontent?objectId=09000064843f2500&format=xml&showorig=false 03/06/2020