ML20086N080
| ML20086N080 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/25/2020 |
| From: | - No Known Affiliation |
| To: | |
| SECY/RAS | |
| References | |
| 85FR03947, NRC-2020-0021 | |
| Download: ML20086N080 (18) | |
Text
Page 1 of 2 As of: 3/26/20 1:16 PM Received: March 25, 2020 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 1k4-9fr7-ejhm 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-0301 Comment on FR Doc # 2020-03258 Submitter Information Name: Sally Jane Gellert General Comment I am completely opposed to the Indian Point license being transferred to Holtec, which is a poor choice for dismantling and remediating Indian Point and safeguarding its radioactive waste. It is already telegraphing that 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. Its extensive tax credits from my state, New Jersey, were based on out-and-out lies by the company on its application.
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.
Holtec does not engage in constructive dialogue, but lashes out against criticism, and deflects questions (as it did in Lacey Township stakeholder meeting) to the NRC or others, leaving citizens ill-informed about what is https://www.fdms.gov/fdms/getcontent?objectId=0900006484468790&format=xml&showorig=false 03/26/2020
Page 2 of 2 happening in their community.
In a premature and improper report filed with the NRC about its planswhich alone should bring the wisdom of this transaction into questionif they cannot even follow the schedule for such a report, why should we trust Holtec's willingness and capacity to follow other regulations?Holtec low-balled its decommissioning cost estimate, even though there isn't even an assessment of site conditions on which to base an estimate. The company ignored the Algonquin gas pipeline passing near Indian Point's critical components, even though it complicates decommissioning and raises risks of rupture and fire. It plans to do nothing about radioactive contamination of groundwater, which we know is already an issue. It won't remediate contaminated soil at the site any deeper than 3 feet. Holtec stated that it is considering shipping radioactive wastes by barge up or down the Hudson, raising a host of unacceptable risks, including the potential of a radioactive accident in New York harbor.
Holtec has attracted opposition from public officials in New York State and across the country including New York Attorney General Letitia James, who as you know has intervened legally to challenge the license transfer. "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.
With this level of opposition from local government officials, it is critical that this license transfer be stopped as soon as possible. In addition, I am including a letter written by Holtec's president and CEO, Dr. Singh, to the local Citizens' Engagement Panel that I find dismissive and arrogant. Dr. Singh clearly represents the privately-held company, and the tone of the letter is inappropriate and raises questions in my mind as to the ability of this company to coperate with local organizations and governments, to accept any criticism or participate in any discussion the other party kowtowing to Holtec. I actually have worked with members of that CEP, and know that they are thoughtful, concerned individuals who evaluate all information carefully and scientifically, looking for factual answers. If Holtec has such a thin skin that they cannot take questioning, if they instead lash out as this letter shows, they are not qualified to take on any major project in our communities.
I am also attaching information compiled by a colleague about Holtec and its partner, SNC-Lavalin.
Attachments Holtect-Letter-to-David-Victor Holtec SNC-L Profiles 1-15-20 https://www.fdms.gov/fdms/getcontent?objectId=0900006484468790&format=xml&showorig=false 03/26/2020
HOLTEC & SNC-LAVALIN COMPANY PROFILES Legal Issues History Holtec TVA Bribery Conviction & A TVA supervisor pleaded guilty in 2007 to a federal charge of failing to disclose the receipt of Debarring about $55,000 in payments from a Holtec contractor in connection with a contract to build a storage facility for spent nuclear fuel at TVAs Browns Ferry Nuclear Plant in Alabama. The TVA debarred Holtec from doing business with it for 60 days. Holtec was also reportedly forced to agree to pay a $2 million administrative fee and to submit to independent monitoring of its operations for twelve months.
NJ Tax Fraud Issues New Jersey awarded a $260 million Grow NJ tax credit from the states Economic Development Authority (EDA), the second-largest tax break in New Jerseys history. It was put on hold when investigative reporting found Singhs falsely sworn certification in the EDA application claiming Holtec had never been barred from doing business with a state or federal agency Ohio Tax Credits Stripped Just weeks before filing its application in New Jersey Ohio stripped Holtec of state tax credits for failing to create the jobs it had promised as part of a tax break program. According to records, none of the 200 jobs Holtec had pledged to bring to Orrville, a small town outside Akron, Ohio, ever materialized - 2019.
https://www.crainscleveland.com/scott-suttell-blog/new-jersey-learned-too-late-what-ohio-already-knew-about-holtec-international SNC-Lavalin Libyan Bribery Conviction https://www.cbc.ca/news/canada/montreal/snc-lavalin-trading-court-libya-charges-1.5400542 - SNC-Lavalin pleads guilty to fraud for past work in Libya, will pay $280M fine and be placed on probation.
Between 2001 and 2011, the company offered Libyan government officials under the Muammar Gaddafi regime bribes worth $47.7 million to influence decisions and defrauded the Libyan government and other entities of "property, money or valuable security or service" worth approximately $129.8 million.
Former executive Sami Bebawi was found guilty in a separate case of paying off foreign officials as he worked to secure contracts for the firm.
Mexican Conviction SNC-Lavalin consultant who worked to get members of the Gaddafi family into Mexico went to prison there under charges of consorting with organized crime, falsifying documents, and human trafficking World Bank Ban Found SNC-Lavalin was engaged in a pattern of bribery and corruption in several countries, and banned it for ten years from bidding on any contracts funded by the Bank - 2013 McGill University Criminal investigation into fraud and corruption for $1.3 billion contract to design, build and maintain the McGill University Health Centre's Glen Site - 2010 Montreal Hospital Charges SNC-Lavalin is facing criminal charges for its tactics to win a new hospital construction contract in Montreal Montreal Bridge Conviction Canadian federal official pled guilty in 2017 for accepting more than $2.3 million in payments from SNC-Lavalin in connection with the Montreal bridge project, and court documents laid out a $127 million bribery scheme Canadian Political Canadas federal election watchdog reported that in 2018 SNC-Lavalin made more than Contributions $117,000 in illegal political contributions to both parties. A former SNC-Lavalin executive was charged with soliciting employees to make the contributions, conceal their identities, and then get reimbursed by the company through false refunds for personal expenses or payment of fictitious bonuses.
Canadian Ethics Scandal Ethics commissioner Mario Dion found Prime Minister Trudeau violated the Conflict of Interest Act when he tried to pressure Canadas Minister of Justice and Attorney General, Jody Wilson-Raybould to overrule a federal prosecutor's decision to send SNC-Lavalin to trial on corruption charges. She refused and, after four months, she was demoted to veteran affairs minister. If convicted of the charges, SNC-Lavalin could face a decade-long ban from competing for federal government contracts. The scandal threatened to bring down the Trudeau government which narrowly won reelection in 2019
Decommissioning Experience & Qualifications Issues Holtec San Onofre Waste Problems https://www.counterpunch.org/2019/06/07/halting-holtec-a-challenge-for-nuclear-safety-advocates/
At the San Onofre Nuclear Generating Station (SONGS) in southern California, Holtec is contracted to transfer spent fuel into dry storage. A whistleblower revealed a near miss as a 50+-ton Holtec canister was being loaded into an 18-foot concrete silo. It got stuck on a shield ring near the top of the vault and workers didnt realize the slings supporting the canister went slack. It hung there unsupported for close to an hour, in danger of dropping. Holtecs Hi-Storm UMAX system canisters at SONGS are thicker than the ones workers had practiced loading. Thicker canisters mean a tighter fit and less room going into the silos.
[T]he Nuclear Regulatory Commission (NRC) fined Southern California Edison an unprecedented $116,000 for failing to report the near drop . . . delaying giving the go-ahead to further loading operations In 2018 workers were preparing a Holtec canister for loading discovered a loose, stainless-steel bolt inside, about four inches long. An investigation revealed that Holtec had altered the canister design without permission from the NRC. The NRC called the unauthorized changes safety significant.
Oyster Creek Workers Issue Holtec CEO Singh said in a press release, "Many of the excellent plant staff will join our exceptionally qualified engineers.
But since then, multiple unions have objected to Holtec hiring less expensive, lower-skilled workers to do the decommissioning work
Pilgrim lawsuit Attorney General Maura Healeys office filed suit in federal court against the NRC to challenge the decision to approve the sale of the plant to Holtec. The NRC approved a regulatory exemption Holtec had requested to be allowed to use $541 million of the $1.1 billion decommissioning trust fund for spent fuel work that is normally not covered as a decommissioning expense. (see below)
Holtec would be allowed to reimburse itself in advance from the decommissioning fund for what it spends on spent fuel management, then sue the Department of Energy for breach of contract to recover that money, in effect getting paid for twice for the same work. NRC staff confirmed that any funds Holtec recovers from DoE would not go back into the decommissioning trust fund, but to Holtec.
AG Healy also pointed out that Holtec set aside only a very small portion of the decommissioning fund for contingencies.
US Senator Edward Markey also weighed in, saying Holtec's math on how it will pay for decommissioning does not add up Canadian Nuclear Work SNC-Lavalin is part of a consortium to clean up Canadas radioactive waste, as well as all federally owned nuclear facilities. The consortium is paid about a billion dollars in public money each year.
In that role it attracted the opposition of 140 municipalities, NGOs and nuclear experts for its plan to permanently store a million cubic meters of mixed radioactive wastes on the surface next to the Ottawa River at Chalk River National Labs. Opponents of the proposal include former senior Chalk River scientists Industry reputation Holtec was not represented at the industrys 2019 Decommissioning and Waster Forum in Charlotte, NC. May other industry representative were very critical of the company.
Illusive Corporate Organizational Structures Holtec Holtec International (HI) Privately held company founded by CEO Krishna Singh - no public financial disclosure Owned by its shareholders: (i) The Great Banyan Trust, 36.33% ownership interest; and (ii)
Multi-Decades Trust, 63.67% ownership interest. These trusts are controlled by CEO Singh1 Operation centers in the US, Brazil, Dubai, India, South Africa, Spain, UK and Ukraine
Holtec Decommissioning Wholly owned indirect subsidiary of Holtec International1 International (HDI) Formed by Holtec to operate and decommission all Holtec-owned decommissioning nuclear power plant sites 1 Functions as the licensed operator for Holtec owned nuclear power plants Nuclear Consultants Nuclear Consultants International, LLC (NCI) is an autonomously constituted business unit of International, LLC (NCI) Holtec International.
NCIs principal area of concentration is oversight of decommissioning projects to ensure their regulatory and safety. NCI advises the plant owner on licensee requirements and provides oversight activities that meet owner requirements. NCI serves as an agent of the plant owner.
Holtec Power, Inc. (HPI) 1 Subsidiary of Holtec International (HI)
Parent of Nuclear Asset Management Company, LLC Parent of Holtec Decommissioning International, LLC (HDI)
Nuclear Asset Management Indirect Subsidiary of HI through Holtec Power, Inc. (HPI)
Company, LLC (NAMCo) 1 Parent of Holtec Indian Point 2, LLC and Holtec Indian Point 3, LLC SMR-160, LLC Based in Camden, NJ, is a wholly owned subsidiary of Holtec International (United States) https://smrllc.com/2017/07/24/snc-lavalin-and-holtec-formalize-agreement-to-accelerate-the-development-of-smr-160-small-modular-reactor/
SNC-Lavalin and Holtec Formalize Agreement to Accelerate the Development of SMR-160 Small Modular Reactor Ukrainian Module Consortium https://holtecinternational.com/company/divisions/ukrainian-module-consortium/
On June 10, 2019, Holtec, Energoatom and SSTC entered into a Trilateral Consortium Partnership to advance the SMR-160 nuclear reactor for deployment across Ukraine. The Consortiums technology operation center is based in Kiev, Ukraine.
Holtec Orrvilon Limited Private company organized in Hong Kong. Ownership structure is undetermined.
Orrvilon, Inc. Aluminum systems, structures, and components, designing, welding, and engineering services facility located in Orrville, OH
Other Holtec Companies & HI-STORE Consolidated Interim Storage Facility (See Joint Ventures and Issues Regarding Subsidiaries: Other Lines of Business below)
Holtec Government Services Holtec Asia Private Limited Holtec Africa Holtec Manufacturing Division HI-POWER Division Nuclear Power Division Heat Transfer Division Singh Center for Nanotechnology SNC-Lavalin SNC-Lavalin Group Inc. A Canadian company based in Montreal Kentz USA A subsidiary of SNC-Lavalin1 Atkins Energy, Inc. A subsidiary of SNC-Lavalin1 Based in Columbia, South Carolina CANDU Subsidiary: reactor technology and supports plants throughout the world1 Joint Ventures Comprehensive Holtec (through HDI) and SNC-Lavalin (through Kentz USA) jointly owned decommissioning Decommissioning general contractor International LLC (CDI) Actual work is being performed by this joint-venture entity under contractual agreement Conflict of interest as buyer of Holtec dry storage containers, etc.
Subsidiaries Organized for Indian Point Reactors & Fuel Storage IPEC Independent Spent Fuel Current Entergy Dry Storage Facility1 - IPEC Independent Spent Fuel Storage Installation Storage Installation (ISFSI) (ISFSI)
It is unclear exactly which Holtec entity will own the ISFSI Individual Reactor Entities Proposed by Holtec IP1 & IP2 - Holtec Indian Point 2, LLC Indirect Subsidiary of HI through HPI and NAMCo No independent capital, no loans or guarantees from parent companies.
IP3 - Holtec Indian Point 3, LLC Indirect Subsidiary of HI through HPI and NAMCo No independent capital, no loans or guarantees from parent companies.
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML19326B953v None of the subsidiaries have any independent capital. Their only asset is the Decommissioning Trust Fund (DTF). There are no loans from the parent corporations either.
That leads to the exemption request to use the DTF money for waste management work.
This is not the way that operation nuclear plants pay for waste management. Operating plants pay for the waste management work out of their own funds and then are reimbursed by the Department of Energy (DOE). This creates a risk that the DTF will run out of money leaving State and local government on the hook.
Corporate Organizational Bankruptcy risk - https://www.law.nyu.edu/sites/default/files/19-02.20%20-Structures Issues %20NRC%20Petition%20to%20Intervene.pdf The Massachusetts Attorney General had this to say regarding similar structures created by Holtec for the Pilgrim plant decommissioning:
The financial and attendant safety, health, and environmental risks associated with the
[license transfer to Holtec] are further increased by the corporate structure of the proposed transferee and new site operators. Holtec Decommissioning International and Holtec Pilgrim, the proposed licensee and new site operator, respectively, are both structured as Limited Liability Companies (LLCs). . . This raises a significant risk that the owner and operator could at some point have liabilities that outstrip their assets and could therefore choose to file for bankruptcy before site decontamination and restoration are complete.
No parent company responsibility:
https://www.law.nyu.edu/sites/default/files/19-02.20%20-
%20NRC%20Petition%20to%20Intervene.pdf Nor can anyone necessarily assume that Holtec can obtain additional funds from a parent company because, as the NRC has said previously, a parent company is not an NRC licensee and the NRC does not have the authority to require a parent company to pay for the decommissioning expenses of its subsidiary-licensee, except to the extent the parent may voluntarily provide a parent company guarantee.
Holtec Decommissioning Proposals Issues https://www.claimsjournal.com/news/national/2019/05/22/291057.htm Faster fuel transfer approval Under federal protocols, spent fuel rods are typically placed in pools filled with water and requests reinforced with concrete to prevent leakage. Used fuel generally stays in the pool for at least five years, and 10 years is the industry norm, according to the NRC, allowing for enough cooling so it can be safely moved into so-called dry storage casks.
Holtec has designed a cask it says can accept spent fuel after only two years, allowing for a complete transfer from the wet storage pool within three years.
Holtec has also applied to reduce fuel pool cooling times to one (1) year! (See: Attachment 1 to Holtec Letter 5014855 LAR 1014-14 Rev. 0)
Cookie Cutter approach Holtec plans to move crews from plant to plant between six facilities it is trying to decommission. This approach has never been used for decommissioning in the US and ignores the basic differences between the plants.
Applications for https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML19326B953 Decommissioning Trust Fund For Indian Point: The HDI plan is to fund all spent fuel management costs following license exemptions transfer using the NDTs, pursuant to the NRCs approval of an exemption from 10 CFR 50.82(a)(8)(i)(A), which HDI is submitting separately from this Application1 https://www.law.nyu.edu/sites/default/files/19-02.20%20-
%20NRC%20Petition%20to%20Intervene.pdf For Pilgrim: The proposed action would permit Holtec Pilgrim, LLC and HDI to use funds from the Pilgrim decommissioning trust fund (the Trust) for management of spent fuel and site restoration activities.
[W]hen evaluating potential expenses related to the cleanup of other nuclear sites, a decommissioning trust fund shortfall from groundwater contamination is a significant possibility, and a shortfall arising from unexpected spent fuel management expenses is very possible.
https://www.nrc.gov/docs/ML1822/ML18228A498.pdf The exemption from 10 CFR 50.75(h)(1)(iv) would also permit Exelon to make these withdrawals without prior notification of the NRC, similar to withdrawals for decommissioning activities made in accordance with 10 CFR 50.82(a)(8).
Applications for emergency https://www.markey.senate.gov/news/press-releases/senator-markey-blasts-nrc-decision-to-exempt-planning exemptions pilgrim-nuclear-power-plant-from-emergency-planning-requirements Senator Markey Blasts NRC Decision to Exempt Pilgrim Nuclear Power Plant from Emergency Planning Requirements at Entergy & Holtecs request - November 4, 2019 Todays NRC decision means Pilgrim is exempt from regulations that require the maintenance of offsite emergency response capabilities or procedures for public notification, even before all of the spent nuclear fuel is moved into dry cask storage.
Pilgrims nuclear spent radioactive fuel pool was designed to hold 880 fuel assemblies, but today it holds more than 2,300 - more than two and a half times that number.
Indian Point: See letter dated April 15, 2019 Captive Community There are two positions on the Indian Point NDCAP panel for licensee representatives. We Advisory Panel need a truly independent oversight body with the authority and resources required to effectively monitor the decommissioning process.
Worker Retention Incumbent staffing levels will be based on the permanent shutdown and defueled status of the station immediately prior to the license transfer.
Working conditions for Holtec received a significantly lower score than working conditions for competitor Orano.
Holtec - 2.5 Orano - 4.0 Ubiquity of Exemptions https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/decommissioning.html From NRC Website Fact Sheet Backgrounder on Decommissioning Nuclear Power Plants -
Phases of Decommissioning - 1) Transition from Operation to Decommissioning:
Other requirements are currently eased through exemptions and license amendments; several of these transitional changes will be included in the new regulations under development.
Issues Regarding Other Lines of Business Holtec Interim Storage Project Holtec is seeking NRC licenses for an interim storage facility named HI-STOR CISF, located on a 1,000-acre property outside Carlsbad and Hobbs, New Mexico (near the Eddy-Lea county line). It would hold up to 120,000 metric tons of spent nuclear fuel about 40 feet underground in large steel HI-STORM UMAX casks.
The Eddy-Lea Energy Alliance (ELEA), a joint venture with numerous local organizations, owns the surface rights, the New Mexico State Land Office owns the mineral estate beneath the surface in the oil- and gas-rich Permian Basin. Up to 2,500 oil, gas and mineral wells or sites are operated in the area by 54 businesses within a 10-mile radius of the site. Fracking activities can induce significant artificial earthquakes, that can damage CISFs New Mexico State Land Commissioner said that Holtec falsely stated it secured agreements with nearby oil and gas operators to restrict extraction operations near the proposed site and assured the NRC that oil and gas drilling would only occur at depths greater than 5,000 feet But only one such agreements exists https://www.counterpunch.org/2019/06/07/halting-holtec-a-challenge-for-nuclear-safety-advocates/:
In an unusual alliance with environmental groups, extractive industry groups the Texas-based Fasken Land and Minerals Ltd. and Georgia-based NAC International Inc. also filed petitions for a hearing, contending that the nuclear waste storage project threatens lucrative fracking operations in the booming Permian Basin.
The project is also widely opposed by Native American Tribes - already victimized by atom bomb testing and uranium mining - as well as ranchers and growers who fear water contamination and the boycotting of their products Rick Perry, Secretary of the U.S. Department of Energy, admitted a few weeks ago to a congressional committee that there is a distinct possibility that interim storage sites like Holtec could become permanent, de facto spent nuclear fuel repositories for hundreds of years or even forever Suggested viewing: Into Eternity https://www.youtube.com/watch?v=GmWadizC8AQ
Dry Storage Thin Canisters:
https://sanonofresafety.org/holtec-hi-storm-umax-nuclear-waste-dry-storage-system/
Most nuclear waste in the U.S. is stored in thin-wall steel storage canisters like those used by Holtec. These canisters cannot be inspected (inside or out), maintained or monitored to prevent major radioactive releases.
- There is no aging management designed into these thin canisters.
- They cannot be inspected for cracks
- They cannot be repaired once loaded with spent nuclear fuel waste.
- There are numerous concrete aging management problems
- A similar container at the Koeberg, South Africa failed after 17 years Each canister has roughly as much highly radioactive Cesium-137 as was released from the 1986 Chernobyl nuclear disaster.
The current U.S. thin-wall steel storage canisters may start failing in as little as 17 to 20 years with through-wall cracks. Even microscopic scratches, pits or other corrosion, such as from moist salt air, can trigger cracking. According to NRC metallurgist Darrell Dunn once a crack starts it can grow through the wall in only 16 years.
Holtec manufactures the thin-wall dry-storage canisters for both Indian Point and the San Onofre project. They are welded shut, designed for interim storage, and are not approved for shipment off site. It has been revealed that the Holtec canisters are getting scratched and gouged in the loading process. Watchdog groups say they accelerate corrosion in the moist salt air and could lead to early failure. In 2014 Holtecs CEO Kris Singh said publicly he didnt believe it was practical to repair the canisters if they were damaged.
Holtec canisters were the subject of scathing safety reviews by a U.S. quality assurance engineer who was later terminated for suspected whistleblowing. These canisters do not meet ASME requirements for inspection, let alone repair. Only thick-wall casks (such as the Castor) meet ASME N3 requirements The NRC has lowered standards so the utilities can continue using them rather than requiring more robust containers.
Thick Casks:
Thick casks used in most other countries and some U.S. sites have superior features:
- Thicker walls (e.g., 10 to 20 inches thick) vs. 1/2 to 5/8 inch thick.
- Ability to remotely monitor for helium leaks.
- Ability to easily inspect the exterior of the canisters.
- Not subject to stress corrosion cracking.
- Not subject to concrete degradation. Concrete overpacks/casks are not needed.
- Robust radiation protection for both storage and transport.
- Reduced cask drop and handling risks results in fewer opportunities for significant radionuclide releases. SANDIA Human Reliability Analysis Informed Insights on Cask Drops, NUREG/CR-7016, February 2012 (ML110610673), pp 7-1 and 7-2
Dry Storage Downloading Canisters are loaded with the highly radioactive nuclear waste fuel removed from reactor System cores. This requires a downloading system.
All Holtec canisters stored at San Onofre are likely damaged (gouged and scraped) due to Holtec downloading system. There is only 1/4 clearance between the walls of each 54-ton steel canister and a steel 2 thick Guide Ring inside each storage hole.
HI-STORM UMAX System FSAR Revision 3 (ML16193A339), June 29, 2016 (page 3-46) There is no method to prevent or repair the damage.
Facilities with spent fuel pools and ISFSI licenses, are required to be able to unload fuel from canisters back into the pool. San Onofres Chief Nuclear Officer admitted this is not possible to do with the four defective canisters, since they are too hot (200 to 300 degrees C) to unload back into the pool (water boils at 100 degrees C). He referred to this as a reflooding problem.
Even microscopic scratches, pits or other corrosion, such as from moist salt air, can trigger cracking. They admit once a crack starts it can grow through the wall in only 16 years.
Canisters in Use at Indian Holtec canisters are already in use at Indian Point:
Point: As of June 2013, the Indian Point Independent Spent Fuel Storage Installation (ISFSI) contained the following number of canisters loaded between 2008 & 2013:
19 Holtec HI-STORM 218 5 Holtec HI-STORM IP1 Each canister contained 32 fuel assemblies.
Potential Conflict as Canister https://sanonofresafety.org/nuclear-waste/
Buyer & Seller U.S. utility companies choose the inferior steel/concrete canister designs due to cost.
According to the National Research Council of the National Academies (2006), Safety and Security of Commercial Spent Nuclear Fuel Storage, National Academies Press, Washington D.C., page 63.
The vendors informed the committee that cost is the chief consideration for their customers when making purchasing decisions. Cost considerations are driving the cask industry away from all-metal [thick] cask designs and toward [steel/]concrete designs for storage.
Note: Some of the relevant citations are included as links. Other citations are available as links or hardcopies on request.
Information within quotation marks are directly from the sources cited.
KPS Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 - Fax (856) 797-0909 www.holtecinternational.com E-MAIL COMMUNICATION May 4, 2019 Dr. David G. Victor, Chairman Via Email:
SONGS Community Engagement Panel david.victor@ucsd.edu Dr. Victor:
Thank you for forwarding your memo to Messrs. Pedro Pizarro, Kevin Payne, Kevin Walker, Doug Bauder and Tom Palmisano dated April 8, 2019 in which you denigrate Holtec Internationals corporate management without any substantiating basis. We understand that you have not even bothered to read any of our corporate policy documents such as the Corporate Governance Manual and the numerous implementing procedures that undergird our companys operations. Perhaps familiarizing yourself with our companys nuclear program, its global footprint and complex engagements would have given you pause before you launched your wholesale speculative attacks.
In contrast to your memos wholesale disparagement of our company, Edisons response to your memo is thoughtful, measured and focused on looking after the welfare of the community. We should observe that the comments in your memo transgress the charter of CEP and your arrogated role as its chair. It is truly a sad spectacle, because, if led properly, the CEP could play a valuable educational role to help the local people understand the issues. Specifically, the CEP could explain to the activists that a significant reduction in risk from an earthquake will accrue if all the used fuel were expeditiously moved to underground dry storage. Instead, your memo is crafted to sow doubt in the minds of the local people about the competence of the only company that can carry out such work! Given that underground storage in UMAX is the universally-agreed safest solution, do your efforts to undermine Holtec serve public interest or sabotage it?
You should know that our companys operations and governance are subject to review and invigilation by scores of our customers with over a trillion dollars in market value among them. We have 116 nuclear plants as our active dry storage technology customers- ours is the worlds largest dry storage program.
We have business nexus with over 250 customers; we operate in 16 countries and we maintain 15 active nuclear dockets with the NRC and numerous others overseas. Our nuclear program is the envy of the world, your cheap shots notwithstanding.
We note that you have held a string of CEP meetings without Holtecs participation, where the anti-nuclear activists have repeatedly filled the air with irresponsible attacks on our company. You did not see it fit to invite a single Holtec representative to your meetings who could dispassionately explain the material facts to the attendees. Absent a reasoned dialog, your CEP meetings turn into a chorus of baseless attacks on respected individuals and institutions such as Edison, NRC and Holtec. Your memo is 1lPage
KPS Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 - Fax (856) 797-0909 www.holtecinternational.com Dr. David G. Victor, Chairman SONGS Community Engagement Panel May 4, 2019 very much in the tradition of irresponsible claptrap that dominates your CEP meetings. An inflammatory memo unsupported by facts is little more than a hatchet job.
Sincerely, Dr. Kris Singh, President & CEO HOLTEC INTERNATIONAL cc: Pedro Pizarro pedro.pizarro@sce.com EXCOM (Holtec)
Kevin Payne kevin.payne@sce.com Jearl Strickland (j.strickland@holtec.com)
Kevin Walker kevin.e.walker@sce.com Dr. Fred Bidrawn (f.bidrawn@holtec.com)
Doug Bauder Doug.Bauder@sce.com Tom Palmisano tom.Palmisano@sce.com Vince Bilovsky vince.bilovsky@sce.com 2lPage