ML20086N077

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

ML20086N077
Person / Time
Site:	Indian Point
Issue date:	03/24/2020
From:	Difrancesco A New York Affordable Reliable Electricity Alliance (NYAREA)
To:
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML20086N077 (3)

Text

Page 1 of 2 As of: 3/26/20 11:19 AM Received: March 24, 2020 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 1k4-9fqk-y5e4 Comments Due: March 25, 2020 Submission Type: API 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-0249 Comment on FR Doc # 2020-03258 Submitter Information Name: Robert DiFrancesco Address:

1177 Avenue of the Americas 5th Floor New York, NY, 10036 Email: difrancesco@nyarea.org Organization: New York Affordable Reliable Electricity, Inc.

General Comment The New York Affordable Reliable Electricity Alliance (New York AREA) is a coalition of member organizations in business, labor, industry, government, and community service advocating for abundant, affordable energy to power our states present and future needs. Since our establishment in 2003, we have been a trusted and recognized voice in our state. Our board chairman, Jerry Kremer, served for 10 years as the chair of the New York State Assembly Ways and Means Committee.

We write in support of the License Transfer Application (LTA) that has been filed with the U.S. Nuclear Regulatory Commission (NRC) by Entergy Corp. and Holtec International, through their affiliates, to transfer Indian Point Nuclear Energy Center (IPEC) and its Nuclear Decommissioning Trust funds to Holtec after the last unit permanently shuts down by April 30, 2021. The companies have asked that the LTA be approved by November, 2020, in order to facilitate timely closing of their transaction by May, 2021.

In addition to their federal filings, Entergy and Holtec have filed a petition with the New York State Public Service Commission (PSC) requesting a ruling disclaiming PSC jurisdiction or abstaining from review of the proposed transfer, or, alternatively, approving the transaction. New York AREA supports this petition as well.

https://www.fdms.gov/fdms/getcontent?objectId=0900006484465059&format=xml&showorig=false 03/26/2020

Page 2 of 2 Holtec is a first-tier global nuclear technology firm whose industry-leading expertise, technical capabilities, innovations, and experience will accelerate decommissioning and site restoration.

Managing complex nuclear projects worldwide in the commercial and government sectors, Holtec has contracted with Comprehensive Decommissioning International, LLC (CDI) to perform the decommissioning, including demolition and site cleanup, at Oyster Creek Nuclear Generating Station in New Jersey and Pilgrim Nuclear Power Station in Massachusetts, in addition to IPEC. CDI is a joint venture company of Holtec International and SNC-Lavalin. Combined, they have more than half a century of experience with such projects.

Note well that the NRC has already approved the applications for license transfer by Entergy to Holtec at both Oyster Creek and Pilgrim, both of which have shut down and commenced decommissioning.

At IPEC, Holtec plans to initiate decommissioning promptly following regulatory approvals and transaction close, and it expects to release the site (with the exception of the ISFSI) for reuse by the 2030sas much as 40 years sooner than if Entergy continued to own the facility. The decommissioning process will also expedite the transfer of all of IPECs spent nuclear fuel to dry cask storage.

Holtec will do its work cost-effectively, with uncompromised safety and under rigorous NRC oversight.

Holtecs expedited redevelopment of the IPEC site will help to assure optimal conditions to reinvigorate the tax base, employment, and overall quality of life in Westchester County and the surrounding community.

During decommissioning, Holtec will work with Entergy to hire existing IPEC workers, and has committed to offer employment to more than 300, who can contribute their expertise. Holtec is also committed to working with the local union halls to provide the skilled labor needed to execute decommissioning safely.

Holtecs core expertise in minimizing disruption of the land, water, and air at and around the IPEC site will help to return it, in an environmentally sound manner, to new productive uses in the shortest time possible.

The assurance of an accelerated timeframe will allow the communities most directly affected by IPECs closure to plan and direct the siting and development of new enterprises more rapidly, efficiently, and effectively.

IPECs transition to closure, and soon to decommissioning, has emphasized responsiveness to the community via regular public meetings of local task forces comprised of citizens and leaders from labor, business, government, and varied interest groups, and via formation of a Citizens Advisory Board.

Because of the conspicuous benefits it offers to our communities, IPECs workforce, local businesses, and our environment, New York AREA endorses the plan that Entergy and Holtec have laid out for the future of IPEC. Thank you for giving it your most thoughtful and favorable consideration.

Attachments image https://www.fdms.gov/fdms/getcontent?objectId=0900006484465059&format=xml&showorig=false 03/26/2020