ML20073H003

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Comment from Charlene Woodcock on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
ML20073H003
Person / Time
Site: Indian Point  
Issue date: 03/07/2020
From:
- No Known Affiliation
To:
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML20073H003 (2)


Text

PUBLIC SUBMISSION As of: 3/12/20 2:19 PM Received: March 07, 2020 Status: Pending_Post Tracking No. 1k4-9ff4-pnng 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-0235 Comment on FR Doc # 2020-03258 Submitter Information Name: Charlene Woodcock Address: United States, General Comment It is deeply disturbing that the NRC would consider approving Holtec International for the extremely hazardous work of decommissioning the Indian Point Nuclear Generating plant. There are many public health and safety concerns over the inadequate financial and ethical qualifications of Holtec International and SNCL, as well as their record of financial scandals. SNCL was debarred for "global corruption" by the World Bank.

It is your responsibility to serve the long-term public interests. To approve Holtec and SNCL for this work would fail to do so.

Holtec is not capable of responsibly dismantling and remediating Indian Point and safeguarding its radioactive waste. 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 Page 1 of 2 03/12/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064844020d2&format=xml&showorig=false

trust fund and taxpayer money to maximize its profits.

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.

Page 2 of 2 03/12/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064844020d2&format=xml&showorig=false