ML20091J918
| ML20091J918 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/31/2020 |
| From: | - No Known Affiliation |
| To: | |
| SECY/RAS | |
| References | |
| 85FR03947, NRC-2012-0021 | |
| Download: ML20091J918 (81) | |
Text
From:
David Feldman To:
Borges Roman, Jennifer
Subject:
[External_Sender] Decommssioning at Indian Point Plant Date:
Thursday, February 13, 2020 7:59:54 AM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
To Whom it May Concern,
As a resident that lives in close proximity to Indian Point (less than 10 miles away), I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But
there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Sincerely,
David Feldman 3 Robbie Rd.
Corltandt Manor, NY 10567
U.S. Nuclear Regulatory Commission Washington, DC 20555-000 I ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering teclmical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Te1messee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate.
We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the
difference. But there is no guarantee that such earnings wiJJ be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CD1.
The intended financial an-angements also offer precisely the wrong incentives. As proposed, Holtec's profits wi ll be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take very seriously its obligation to keep our community safe through the decommissioning process. lf the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Thank you, ~
Susan Riordan 3 5 Ferris Place Ossining NY 10562
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate.
We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the
difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was w1derstaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its 01Tville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate.
We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the
difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perfo1m the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtec's profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Sincerely, Lynne Teplin 846 Palmer Road # 1 A Bronxville, New York 10708
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled
and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtec 's profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut comers, employ less-qualified
staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
I £ & Campbell 185 Frederick St
- Cortlandt Manor, NY 10567
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, 241 Nimham Road Kent Lakes, NY 10512 February 12, 2020 As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership oflndian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
~
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate.
We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtec' s profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut comers, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Sincerely, Martha G. Collins
PUBLIC SUBMISSION As of: 2/20/20 8:55 AM Received: February 14, 2020 Status: Pending_Post Tracking No. 1k4-9f0n-pjmp 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-0023 Comment on FR Doc # 2020-00824 Submitter Information Name: Elizabeth Peterson Address:
Cortlandt Manor, NY, 10567 General Comment U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Page 1 of 2 02/20/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648436eb83&format=xml&showorig=false
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion.
However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI),
a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtec's profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Page 2 of 2 02/20/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648436eb83&format=xml&showorig=false
PUBLIC SUBMISSION As of: 2/14/20 10:12 AM Received: February 12, 2020 Status: Pending_Post Tracking No. 1k4-9ezc-86sp 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-0015 Comment on FR Doc # 2020-00824 Submitter Information Name: Ellen Heidelberger Address:
7 Stephen Lane Cortlandt Manor, NY, 10567 Email: eheidelberger@hotmail.com General Comment U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an Page 1 of 3 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484360b1d&format=xml&showorig=false
apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion.
However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI),
a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtec's profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask Page 2 of 3 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484360b1d&format=xml&showorig=false
that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Page 3 of 3 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484360b1d&format=xml&showorig=false
PUBLIC SUBMISSION As of: 2/14/20 10:25 AM Received: February 13, 2020 Status: Pending_Post Tracking No. 1k4-9ezn-oel2 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-0017 Comment on FR Doc # 2020-00824 Submitter Information Name: Kale Roberts Address:
195 Old Albany Post Road Garrison, 10524 Email: buffalokale@gmail.com General Comment U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent Page 1 of 3 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648436299e&format=xml&showorig=false
assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtec's profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel Page 2 of 3 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648436299e&format=xml&showorig=false
management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Page 3 of 3 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648436299e&format=xml&showorig=false
PUBLIC SUBMISSION As of: 2/14/20 10:27 AM Received: February 13, 2020 Status: Pending_Post Tracking No. 1k4-9ezq-25n6 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-0018 Comment on FR Doc # 2020-00824 Submitter Information Name: Anonymous Anonymous Address:
39 Wells Avenue Croton on Hudson, NY, 10520 Email: ricki.rusting@gmail.com General Comment As a resident who lives close to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before Page 1 of 2 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484363ed3&format=xml&showorig=false
authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion.
However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI),
a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtec's profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Page 2 of 2 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484363ed3&format=xml&showorig=false
PUBLIC SUBMISSION As of: 2/14/20 10:36 AM Received: February 13, 2020 Status: Pending_Post Tracking No. 1k4-9ezr-a1q2 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-0019 Comment on FR Doc # 2020-00824 Submitter Information Name: George Fouhy Address:
POB22 Crompond crompond, NY, 10517 Email: georgef@bestweb.net Organization: Castle Oil Corp General Comment U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site Page 1 of 3 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064843640ef&format=xml&showorig=false
was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion.
However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI),
a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtec's profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Page 2 of 3 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064843640ef&format=xml&showorig=false
George Fouhy 41 Baron De Hirsch Rd.
Crompond, NY 10517 Page 3 of 3 02/14/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064843640ef&format=xml&showorig=false
PUBLIC SUBMISSION As of: 2/20/20 9:05 AM Received: February 15, 2020 Status: Pending_Post Tracking No. 1k4-9f14-febz 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-0024 Comment on FR Doc # 2020-00824 Submitter Information Name: My Nguyen Address:
28 N 1st St Cortlandt Manor, NY, 10567 Email: vitvuvo@yahoo.com General Comment See attached file(s)
Attachments Comments on Indian Point Decommissioning Transfer Page 1 of 1 02/20/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484374d0d&format=xml&showorig=false
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate.
We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the
difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
PUBLIC SUBMISSION As of: 2/20/20 9:20 AM Received: February 15, 2020 Status: Pending_Post Tracking No. 1k4-9f1a-f34l 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-0027 Comment on FR Doc # 2020-00824 Submitter Information Name: Enid Breisblatt Address:
47 Sunset Lane Croton on Hudson, 10520 Email: breiscom2@gmail.com General Comment U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate Page 1 of 2 02/20/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484375a2d&format=xml&showorig=false
confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion.
However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI),
a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtec's profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Page 2 of 2 02/20/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484375a2d&format=xml&showorig=false
PUBLIC SUBMISSION As of: 2/20/20 9:47 AM Received: February 18, 2020 Status: Pending_Post Tracking No. 1k4-9f35-a08v 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-0033 Comment on FR Doc # 2020-00824 Submitter Information Name: Eliza Dean Address:
117 S Highland Ave Ossining, NY, 10562 Email: eliza.dean61@gmail.com General Comment See attached file(s)
Attachments Comments on Indian Point Decommissioning Transfer Page 1 of 1 02/20/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648437ec3c&format=xml&showorig=false
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical,
- fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Eliza Dean Resident of Ossining NY
PUBLIC SUBMISSION As of: 3/6/20 7:49 AM Received: February 24, 2020 Status: Pending_Post Tracking No. 1k4-9f7e-8dvs 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-0130 Comment on FR Doc # 2020-00824 Submitter Information Name: Anna Drabek General Comment U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Page 1 of 2 03/06/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064843ac030&format=xml&showorig=false
Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion.
However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI),
a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtec's profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Page 2 of 2 03/06/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064843ac030&format=xml&showorig=false
From:
Calypsidog To:
Docket, Hearing
Subject:
[External_Sender] closing of Indian Point, New York Date:
Monday, February 24, 2020 9:49:28 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
To Whom it May Concern,
As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required.
The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives.As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Respectfully Joan Mullee
From:
A Drabek To:
Docket, Hearing
Subject:
[External_Sender] Indian Point Public Comment Date:
Monday, February 24, 2020 9:27:57 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But
there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
- Best, Anna Drabek
From:
Tom Warner To:
Docket, Hearing
Subject:
[External_Sender] I have concerns about Indian Point Nuclear reactor Date:
Friday, February 14, 2020 6:37:20 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
To Whom it May Concern,
As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
From:
lmiranda@cognizantcommunication.com To:
Docket, Hearing
Subject:
[External_Sender] Indian Point Concerns Date:
Thursday, February 13, 2020 1:05:01 PM To Whom it May Concern,
As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project.
Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Thank you for your time and consideration.
Lori Miranda
From:
Stephanie To:
Docket, Hearing
Subject:
[External_Sender] Concerned Citizen Date:
Thursday, February 13, 2020 12:38:02 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec
claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Stephanie Marie Hickey
From:
George Fouhy To:
Docket, Hearing
Subject:
[External_Sender] Docket ID NRC-2020-0021 Date:
Thursday, February 13, 2020 10:30:50 AM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
To Whom it May Concern,
As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
George Fouhy 41 Baron De Hirsch Rd.
Crompond, NY 10517
From:
Ricki Rusting To:
Docket, Hearing
Subject:
[External_Sender] Indian Point Decommissioning concern Date:
Thursday, February 13, 2020 9:54:23 AM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident who lives close to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But
there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Sincerely, Ricki Rusting
From:
Gary Abrams To:
Docket, Hearing
Subject:
[External_Sender] Indian Point decommissioning Date:
Wednesday, February 12, 2020 9:57:41 PM To Whom it May Concern,
As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning
International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Sincerely yours, Gary Abrams
From:
Amy Hersh To:
Docket, Hearing
Subject:
[External_Sender] Indian Point de-commissioning Date:
Wednesday, February 12, 2020 7:59:45 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
To Whom it May Concern,
As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Sincerely, Amy Hersh 982 Lester Road Yorktown Heights, NY 10598
From:
Elizabeth Brown, CPA To:
Docket, Hearing
Subject:
[External_Sender] Indian Point and NRC Date:
Wednesday, February 12, 2020 6:41:56 PM Attachments:
image001.png Importance:
High To Whom it May Concern,
As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no
guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Thank you.
Elizabeth Brown, CPA 26 Dawning Lane Ossining, NY 10562 914-345-1040
From:
Elizabeth Terbrock To:
Docket, Hearing
Subject:
[External_Sender] The Upcoming Decommissioning of Indian Point Energy Center Date:
Wednesday, February 12, 2020 6:29:57 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Thank you for your attention to this matter.
Sincerely, Elizabeth Terbrock P.O. Box 311 Maryknoll, NY 10545-0311
From:
Tom Berta To:
Docket, Hearing
Subject:
[External_Sender] Decommissioning of Indian Point Date:
Wednesday, February 12, 2020 6:01:05 PM To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC takeseriously the myriad concerns about Holtecs decommissioning plan that have beenpresented by professionals in the field, the media, and community members, and requestthat you deny their application for the transfer of ownership of Indian Point EnergyCenter. Secondly, I am requesting that the NRC hold a public meeting to answer some of thelingering technical, fiscal, and ethical concerns surrounding Indian Pointdecommissioning and Holtec. At San Onofre in California, where Holtec has been retained to manage spent fuel, acontractor reported an apparent near accident involving a dry cask filled with spentassemblies.
The contractor also alleged the site was understaffed and its supervisors oftenreplaced with less experienced managers. This does not generate confidence that Holtecis capable of safely executing major decommissioning work.Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously,including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in NewJersey, and Palisades in Michigan. The potential risks in decommissioning are too greatto rely on other than successful performance in an initial project before authorizing additional endeavors. It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely beperformed by such skilled and experienced specialists. And the work will be morecomplicated than that at other reactors because of the absence of a rail spur at IndianPoint.There are also serious questions regarding Holtecs business ethics. When looking intotheir history you will find a proven track record of dishonesty and corruption, whether itbe bribery at the Tennessee Valley Authority, failed promises at its Orrville facility inOhio, or misrepresentations in its application for tax benefits in New Jersey.I also have grave financial concerns. Holtec has estimated the total cost ofdecommissioning at $2.3 billion. However, in essentially every nuclear plantdecommissioning, unanticipated circumstances increase the cost above the initialestimate. We therefore cannot accurately know what the ultimate cost of this project willbe.
The fund established for decommissioning Indian Point contains about $2.1 billion andHoltec claims that earnings achieved through investing the fund will make up thedifference. But there is no guarantee that such earnings will be adequate to complete theoperation.To perform the decommissioning, Holtec has formed Comprehensive DecommissioningInternational (CDI), a joint venture with SNC-Lavalin.
Through the CDI, the parentcompanies are insulated from financial responsibility for the project. Thus, should fundsprove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinishedand the taxpayers of New York will be forced to pay for the balance. Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent companyshould not be absolved of financial responsibility and Holtec should be compelled toprovide any additional monies beyond those in the decommissioning fund needed tocomplete the work, independent of the status of CDI.The intended financial arrangements also offer precisely the wrong incentives. Asproposed, Holtecs profits will be enhanced by any money remaining in thedecommissioning fund when the work is completed.
Thus, there is every incentive forHoltec to cut corners, employ less-qualified staff, and rush through various phases of thework in order to complete it before the decommissioning fund is completely depleted.Holtec has requested permission to use decommissioning funds for spent fuelmanagement. This should be denied regardless of what other rulings are made by NRC.The NRC must take seriously its obligation to keep our community safe through thedecommissioning process. If the NRC grants this license transfer to Holtec I fear therewill be grave consequences for residents living along the lower Hudson Valley, and thegreater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Pointdecommissioning.
Tom Berta 38 Hudson Point Lane Ossining, NY 10562 Tom Berta 914.762-4883 914.261.3395 - cell
From:
Susan Kassouf To:
Docket, Hearing
Subject:
[External_Sender] Concerns about Holtec Decommissioning Indian Point Date:
Wednesday, February 12, 2020 5:48:59 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
To Whom it May Concern,
As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be
grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Sincerely, Susan Kassouf
From:
Thomas Comiskey To:
Docket, Hearing
Subject:
[External_Sender] Indian Point Decommissioning Date:
Wednesday, February 12, 2020 4:09:18 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
To Whom it May Concern,
As a resident that livesin close proximity toIndian Point,I am asking thatthe NRCtake seriouslythe myriadconcernsabout Holtecs decommissioning plan that have beenpresented by professionals in the field, the media, and community members, andrequestthat you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly,I am requestingthatthe NRChold a public meeting to answersome of the lingering technical, fiscal, and ethical concerns surroundingIndian Point decommissioning andHoltec.
At San Onofre in California,where Holtec has beenretainedto managespent fuel,a contractor reportedan apparent near accident involving a dry cask filled withspentassemblies. Thecontractoralso alleged the site was understaffed and its supervisors often replaced with less experienced managers.This does not generate confidence that Holtec is capable ofsafely executingmajor decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposesto perform several such decommissioningoperations simultaneously, including, not only Indian Point, butalsoPilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other thansuccessfulperformance in an initialproject before authorizing additional endeavors.
It is far from clear that Holtecemployssufficientqualified senior staff to supervisesuchsimultaneousefforts, much less the large number of specially trained technical workers whose services will berequired. The nature of the work is such that it can only safely beperformedby suchskilledand experiencedspecialists.And the work will be more complicatedthan that at other reactors because of the absence of a rail spur at Indian Point.
There arealsoserious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also havegravefinancialconcerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning,unanticipatedcircumstances increase the cost above the initial estimate.Wethereforecannot accuratelyknow what the ultimate cost of thisproject will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make upthedifference.But there is no guarantee that such earningswill be adequate to complete the operation.
To perform the decommissioning, Holtec has formedComprehensive Decommissioning International(CDI),a jointventure with SNC-Lavalin.Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDIfile forbankruptcy, the decommissioning will lie unfinished andthe taxpayers of New York will be forced to pay for the balance.
Thus, if NRC doesapprove the transfer of Indian Point to Holtec, the parent company should not beabsolvedoffinancial responsibility andHoltec should be compelledto provideany additional moniesbeyond those in the decommissioning fundneededto complete the work,independentof the status of CDI.
Theintendedfinancial arrangements also offerpreciselythe wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff,and rush through various phases of the work in order to complete it before the decommissioning fundis completelydepleted.
Holtechas requested permission to use decommissioning fundsfor spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRCmust take seriouslyitsobligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that youdenyHoltecsapplication for the transferand to hold a public hearing onnext steps forIndian Pointdecommissioning.
Sincerely, Thomas & Beatrix Comiskey 323 Kemeys Cove Scarborough NY 10510 Sent from my iPhone
From:
Carol Banker To:
Docket, Hearing
Subject:
[External_Sender] Indian Point Date:
Wednesday, February 12, 2020 2:32:42 PM Carol Sternau 45 Bank Street Cold Spring, NY 10516 February 12, 2020 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rule-makings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Respectfully, Carol Sternau
From:
donald kimmel To:
Docket, Hearing
Subject:
[External_Sender] Indian Point Date:
Wednesday, February 12, 2020 1:52:34 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But
there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Sincerely, Donald Kimmel 914-589-3929 dksecretgardener@gmail.com
From:
Annika Many To:
Docket, Hearing
Subject:
[External_Sender] Indian Point Nuclear Generating Unit Nos. 1, 2, and 3; Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments Date:
Wednesday, February 12, 2020 1:01:27 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
To Whom it May Concern,
As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, I am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise
such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project.
Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for
Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Sincerely, Annika Many 1015 McKinley Street, Peekskill, NY 10566
From:
Bryan Hickey To:
Docket, Hearing
Subject:
[External_Sender] Docket ID NRC-2020-0021 : Indian Point Decommissioning Date:
Wednesday, February 12, 2020 12:42:28 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
Dear Regulatory Commission,
As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
I am also requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
Holtec has never decommissioned a large nuclear power plant, however, it now proposes to perform several such decommissioning operations simultaneously; at Indian Point, Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on utterly untested performance.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. In fact, upon investigation you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Thank you for your consideration, Brian Hickey
From:
Sherman Alpert To:
Docket, Hearing
Subject:
[External_Sender] Holtecs decommissioning plan Date:
Wednesday, February 12, 2020 12:41:54 PM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff To Whom it May Concern, As a resident who lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, and request that you deny their application for the transfer of ownership of Indian Point Energy Center.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled with spent assemblies. The contractor also alleged the site was understaffed and its supervisors often replaced with less experienced managers. This does not generate confidence that Holtec is capable of safely executing major decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other than successful performance in an initial project before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be performed by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questions regarding Holtecs business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at
$2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate. We therefore cannot accurately know what the ultimate cost of this project will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make up the difference. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning
International (CDI), a joint venture with SNC-Lavalin. Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved of financial responsibility and Holtec should be compelled to provide any additional monies beyond those in the decommissioning fund needed to complete the work, independent of the status of CDI.
The intended financial arrangements also offer precisely the wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtec has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other rulings are made by NRC.
The NRC must take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that you deny Holtecs application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Sincerely, Sherman Alpert Briarcliff Manor, NY
From:
Stacey Gibson To:
Docket, Hearing
Subject:
[External_Sender] Holtec Date:
Wednesday, February 12, 2020 12:32:47 PM
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
To Whom it May Concern,
As a resident that lives in close proximity to Indian Point, I am asking that the NRCtake seriouslythe myriadconcernsabout Holtecs decommissioning plan that have been presented by professionals in the field, the media, and community members, andrequestthat you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly,I am requestingthatthe NRChold a public meeting to answersome of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning andHoltec.
At San Onofre in California,where Holtec has beenretainedto managespent fuel,a contractor reported an apparent near accident involving a dry cask filled withspentassemblies. Thecontractoralso alleged the site was understaffed and its supervisors often replaced with less experienced managers.This does not generate confidence that Holtec is capable ofsafely executingmajor decommissioning work.
Despite the fact that Holtec has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, butalsoPilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommissioning are too great to rely on other thansuccessfulperformance in an initialproject before authorizing additional endeavors.
It is far from clear that Holtec employs sufficient qualified senior staff to supervisesuchsimultaneousefforts, much less the large number of specially trained technical workers whose services will berequired. The nature of the work is such that it can only safely be performed by such skilled and experiencedspecialists.And the work will be more complicatedthan that at other reactors because of the absence of a rail spur at Indian Point.
There arealsoserious questions regarding Holtecs business ethics. When looking
into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate.Wethereforecannot accuratelyknow what the ultimate cost of thisproject will be.
The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnings achieved through investing the fund will make upthedifference.But there is no guarantee that such earningswill be adequate to complete the operation.
To perform the decommissioning, Holtec has formed Comprehensive Decommissioning International(CDI),a jointventure with SNC-Lavalin.Through the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankruptcy, the decommissioning will lie unfinished andthe taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of Indian Point to Holtec, the parent company should not be absolved offinancial responsibility and Holtec should be compelledto provideany additional moniesbeyond those in the decommissioning fundneededto complete the work,independentof the status of CDI.
Theintendedfinancial arrangements also offerpreciselythe wrong incentives. As proposed, Holtecs profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtec to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completelydepleted.
Holtec has requested permission to use decommissioning funds for spent fuel management. This should be denied regardless of what other rulings are made by NRC.
The NRCmust take seriouslyitsobligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York metropolitan area. For these reasons I ask that
youdenyHoltecsapplication for the transferand to hold a public hearing onnext steps forIndian Pointdecommissioning.
Yours truly, Stacey Gibson 70 Snake Hill Road Garrison, New York 10524 845-424-8318 (home) 914-419-0181 (cell)
Everyone you meet is fighting a battle you know nothing about. Be kind. Always.
Feb. 15. 2020 8: 14AM U.S. Nuclear Regulatory Commission -BY FAX: 301-415-1101 Washington, DC 20555-0001 ATTN: Rulemak.ings and Adjudications Staff RE: fNDIAN POJNT To Whom it May Concern, No. 1273 P. 1 As a resident that lives in close proximity to Indian Point, I am asking that the NRC take seriously the myriad concerns about Holtec's decommissioning plan that have been presented by pro [essionals in the field, the media, and community members, and requ.est that you deny their application for the transfer of ownership of Indian Point Energy Center.
Secondly, l am requesting that the NRC hold a public meeting to answer some of the lingering technical, fiscal, and ethical concerns surrounding Indian Point decommissioning and Holtec.
At San Onofre in California, where Holtec has been retained to manage spent fuel, a contractor reported an apparent near accident involving a dry cask filled 'With spent assemblies. The contractor also aJleged the site was understaffed and its supervisors often replaced with less experienced managers. This docs not generate confidence that Holtec is capable of safely executing 1najor decommissioning work.
Despite the fact that Holtcc has never decommissioned a large nuclear power plant, it now proposes to perform several such decommissioning operations simultaneously, including, not only Indian Point, but also Pilgrim in Massachusetts, Oyster Creek in New Jersey, and Palisades in Michigan. The potential risks in decommfasioning are too great to rely on other than successful perfonnance in an initial project before authorizing additional endeavors.
It is far lhn:n clear that Holtec employs sufficient qualified senior staff to supervise such simultaneous efforts, much less the large number of specially trained technical workers whose services will be required. The nature of the work is such that it can only safely be perfonned by such skilled and experienced specialists. And the work will be more complicated than that at other reactors because of the absence of a rail spur at Indian Point.
There are also serious questlons regarding Iloltec's business ethics. When looking into their history you will find a proven track record of dishonesty and corruption, whether it be bribery at the Tennessee Valley Authority, failed promises at its Orrville facility in Ohio, or misrepresentations in its application for tax benefits in New Jersey.
I also have grave financial concerns. Holtec has estimated the total cost of decommissioning at $2.3 billion. However, in essentially every nuclear plant decommissioning, unanticipated circumstances increase the cost above the initial estimate.
We therefore cannot accurately know what the ultimate cost of this pr.oject 'Will be.
Feb. 15. 2020 8:15AM No. 1273 P. 2 The fund established for decommissioning Indian Point contains about $2.1 billion and Holtec claims that earnmgs achieved through investing the fund will make up the dilTerencc. But there is no guarantee that such earnings will be adequate to complete the operation.
To perform the decommissioning, Holtec has for.med Comprehensive Decommissioning International (CDI), a joint venture with SNC~Lavalin. l11rough the CDI, the parent companies are insulated from financial responsibility for the project. Thus, should funds prove inadequate and CDI file for bankmptcy, the decommissioning will lie unfinished and the taxpayers of New York will be forced to pay for the balance.
Thus, if NRC does approve the transfer of lndian Pl)int to Iloltcc, the pa.rent company should not be absolved of financial responsibility and Iloltec should be compelled to provide any additional monies beyond those in the decommissioning fl.u::i.d needed to complete the work, independent of the status of CDI.
The intended financial auangements also offer precisely the WTOng incentives. As proposed, Holtec's profits will be enhanced by any money remaining in the decommissioning fund when the work is completed. Thus, there is every incentive for Holtcc to cut corners, employ less-qualified staff, and rush through various phases of the work in order to complete it before the decommissioning fund is completely depleted.
Holtcc has requested permission to use decommissioning funds for spent fuel management.
This should be denied regardless of what other mlings are made by NRC.
The NRC mnst take seriously its obligation to keep our community safe through the decommissioning process. If the NRC grants this license transfer to Holtec I fear there will be grave consequences for residents living along the lower Hudson Valley, and the greater New York n1etropolitan area. For these reasons I ask that you deny Holtec's application for the transfer and to hold a public hearing on next steps for Indian Point decommissioning.
Thank you for your time and consideration.
Lori Miranda - resident of Cortlandt Manor, NY