Letter Sequence Request |
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Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, ... further results|Request]]
- Acceptance
- Supplement, Supplement
Results
Other: ML19112A318, ML20006E044, ML20024F053, ML20024F063, ML20026A002, ML20091J918, ML20091J919, ML20091L448, ML20092G718, ML20297A321, ML20297A325, ML20297A360, ML20309A853, ML20316A008, ML20318A379, ML21126A008, ML21126A013, ML21147A553
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MONTHYEARML18066A0442018-03-0202 March 2018
March 2, 2018 Vermont Yankee Settlement Agreement
Project stage: Request
ML18066A7352018-03-0202 March 2018
Settlement Agreement Between Entergy, Northstar, State of Vermont Agencies, and Others Related to the Proposed Purchase and Sale of the Vermont Yankee Nuclear Station (License DPR-28, Docket No. 50-271)
Project stage: Request
3F0618-02, Site Specific Decommissioning Cost Estimate2018-06-27027 June 2018
Site Specific Decommissioning Cost Estimate
Project stage: Request
ML18156A1792018-08-15015 August 2018
Issuance of Amendment to Change the Permanently Defueled
Project stage: Request
BVY 18-033, Registration of Spent Fuel Cask Use and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2018-08-16016 August 2018
Registration of Spent Fuel Cask Use and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool
Project stage: Request
ML18242A6392018-10-11011 October 2018
Safety Evaluation of License Transfer Request (License DPR-28, Docket Nos. 50-271 and 72-59
Project stage: Request
ML19077A2322019-03-18018 March 2019
Applicants Answer Opposing the Commonwealth of Massachusetts Petition for Leave to Intervene and Hearing Request
Project stage: Request
ML19091A1892019-04-0101 April 2019
Watch Reply to Applicants Answer Opposing Pilgrim Watch Petition for Leave to Intervene and Hearing Request
Project stage: Request
ML19116A1622019-04-26026 April 2019
Watch Motion to Supplement Its Motion to Intervene and Request for Hearing. New Information
Project stage: Request
ML19112A3182019-06-20020 June 2019
FRN - Exemption for HDI to Use Oyster Creek Nuclear Decommissioning Trust Fund Re Request for License Transfer from Exelon
Project stage: Other
ML19177A0802019-06-26026 June 2019
Nuclear Generating Plant (CR-3) - Notification of Revised Post-Shutdown Decommissioning Activities Report (Revised PSDAR)
Project stage: Request
ML19210E4702019-07-29029 July 2019
Transmittal of Response to NRC Request for Additional Information Regarding Request for Direct and Indirect License Transfers, RAI-PFPB-1 and - 2
Project stage: Response to RAI
ML19247B4312019-09-0303 September 2019
Application of the Commonwealth of Massachusetts for a Stay of the Effectiveness of the NRC Staff Actions Approving the License Transfer Application and Request for an Exemption to Use the Decommissioning Trust Fund for Non-Decommissioning
Project stage: Request
ML19329C9922019-11-21021 November 2019
LTR-19-0459 Senator Charles Schumer, Et Al., Letter to Holtec Regarding Oversight of the Decommissioning Process and the Potential Transfer of Indian Points Nuclear Regulatory Commission License from Entergy Corporation to Holtec Internatio
Project stage: Request
NL-19-084, Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments2019-11-21021 November 2019
Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments
Project stage: Request
ML19329B3242019-11-25025 November 2019
Watch Motion to Supplement Its February 20, 2019 Motion to Intervene and Request for Hearing, Its April 1, 2019 Reply to Petitioners, and Its May 3, 2019 Motion to Supplement
Project stage: Request
DCL-19-082, Site-Specific Decommissioning Cost Estimate2019-12-0404 December 2019
Site-Specific Decommissioning Cost Estimate
Project stage: Request
ML19343C6922019-12-0909 December 2019
Applicants Answer Opposing Pilgrim Watchs Third Motion to Supplement Its Motion to Intervene and Request for Hearing
Project stage: Request
ML19347D4152019-12-13013 December 2019
Motion of the Commonwealth of Massachusetts to Amend Its Petition with New Information
Project stage: Request
ML19354A6982019-12-19019 December 2019
Post Shutdown Decommissioning Activities Report Including Site-Specific Decommissioning Cost Estimate for Indian Point Nuclear Generating Units 1, 2, and 3
Project stage: Request
ML20003E1522020-01-0303 January 2020
Acceptance Review Determination (E-mail Dated 1/3/19) Entergy-Holtec License Transfer Application
Project stage: Acceptance Review
ML20007E9182020-01-0707 January 2020
Applicants Answer Opposing the Commonwealth of Massachusetts Second Motion to Supplement Its Petition with New Information
Project stage: Request
ML20006E0442020-01-14014 January 2020
Notice of Consideration of Approval of Transfers of Renewed Facility Operating Licenses and Conforming Amendments, and Opportunity for a Hearing
Project stage: Other
ML20006E1222020-01-15015 January 2020
Individual Federal Register Notice for Consideration of Approval of Transfer of Licenses and Conforming Amendments
Project stage: Request
ML20017A2902020-01-17017 January 2020
Supplement to Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments
Project stage: Supplement
ML20023B3292020-01-21021 January 2020
LTR-20-0019 Senator Charles Schumer, Et Al., Letter Request for NRC to Extend the Public Comment Period for the License Transfer for Indian Point
Project stage: Request
ML20043F2732020-02-0505 February 2020, 10 February 2020, 12 February 2020
New York State Petition for Leave to Intervene and for Hearing with Supporting Declarations
Project stage: Request
ML20043E1232020-02-0505 February 2020
Declaration of George W. Heitzman in Support of New York Petition
Project stage: Request
ML20026A0022020-02-10010 February 2020
Proposed Post-Shutdown Decommissioning Activities Report and Site-Specific Decommissioning Cost Estimate
Project stage: Other
ML20043E1252020-02-10010 February 2020
Declaration of Alyse L. Peterson in Support of New York Petition
Project stage: Request
ML20024F0632020-02-11011 February 2020
Extension of Comment Period for Notice of Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments and Opportunity for a Hearing
Project stage: Other
ML20026A0012020-02-11011 February 2020
Request for Withholding Information from Public Disclosure
Project stage: Withholding Request Acceptance
ML20043E1212020-02-12012 February 2020
Declaration of Warren K. Brewer in Support of New York Petition
Project stage: Request
ML20043E1222020-02-12012 February 2020
Declaration of Daniel J. Evans in Support of New York Petition
Project stage: Request
ML20043F5302020-02-12012 February 2020
Petition of Riverkeeper, Inc. to Intervene and for a Hearing
Project stage: Request
ML20043F0542020-02-12012 February 2020
Petition by the Town of Cortlandt, Village of Buchanan, and Hendrick Hudson School Districts for Leave to Intervene and Hearing Request
Project stage: Request
ML20043E1282020-02-12012 February 2020
Declaration of Chiara Trabucchi in Support of New York Petition
Project stage: Request
ML20043E1262020-02-12012 February 2020
Declaration of Timothy B. Rice in Support of New York Petition
Project stage: Request
ML20024F0532020-02-13013 February 2020
Extension of Comment Period Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments
Project stage: Other
ML20056F0952020-02-13013 February 2020
Concerns Pertaining to Gas Transmission Lines at the Indian Point Nuclear Power Plant
Project stage: Request
ML20055G1192020-02-23023 February 2020
Comment from Janelle Peotter on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
Project stage: Request
ML20055G1112020-02-23023 February 2020
Comment from Sarah Eggleston on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
Project stage: Request
ML20055G1172020-02-23023 February 2020
Comment from Daniel Lucas on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
Project stage: Request
ML20055G1182020-02-23023 February 2020
Comment from Dolores Jones on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
Project stage: Request
ML20066H3662020-02-23023 February 2020
Comment from Deborah Dougherty on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
Project stage: Request
ML20066H3762020-02-23023 February 2020
Comment from Mark Bierman on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
Project stage: Request
ML20066H3742020-02-23023 February 2020
Comment from Leigh Hill on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
Project stage: Request
ML20066H3702020-02-23023 February 2020
Comment from Jeanne Casatelli on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
Project stage: Request
ML20066H3672020-02-23023 February 2020
Comment from Dennis Phayre on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
Project stage: Request
ML20066H3562020-02-23023 February 2020
Comment from Vincent Ferri on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)
Project stage: Request
2019-06-20
[Table View] |
Text
From: MH Specter <mhspecter@verizon.net>
Sent: Thursday, October 29, 2020 10:27 AM To: Petition Resource <Petition.Resource@nrc.gov> Cc:
Sheehan, Neil <Neil.Sheehan@nrc.gov>
Subject:
[External_Sender] Submittal of a 2.206 Petition To: The Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 October 29, 2020
Dear Sir,
I am filing this petition under the NRC's 2.206 Petition Process.
The specific action that I request is that approval not be given by the NRC to any transfer of licenses from Entergy to Holtec Decommissioning International (HDI) for any of the three Indian Point nuclear facilities, IP1, IP2, and IP3, located in Buchanan, New York. I further request that no exemptions be granted to HDI for any decommissioning activity involving any of these three nuclear plants.
My concern is based on the belief that there are not sufficient funds in any of the three decommissioning trust funds (DTFs) for HDI to execute a comprehensive decommissioning process to bring the Indian Point site to a final "green field" status that satisfies all federal and NY State requirements. If adequate decommissioning can not be achieved at Indian Point because of insufficient funds and/or inadequate HDI experience, there is the possibility that the Indian Point site could become a long term radiological hazard with partially dismantled structures and components and with insufficient long term oversight and security.
The bases for my concerns are provided in the two attached documents, however, they can be summarized as follows:
GENERAL: The funding levels that HDI uses in its decommissioning cost estimates appear to be hundreds of millions of dollars more than the DTF levels reported by Entergy to the NRC. HDI's treatment of Contingency Allowances appear to be inconsistent with the guidance given in NUREG-1757, Vol.3, Rev.1, page 4-11. The volumes of low level wastes claimed by HDI are significantly smaller than volumes calculated for similar PWRs in their decommissioning cost estimates.
IP1: The amount of money that HDI claims is initially available to accomplish both radiological and non-radiological decommissioning of IP1 is larger than the DTF level Entergy reported to the NRC by about $121.6 million dollars. If HDI has overstated the amount of IP1 decommissioning money initially available to it, then all subsequent IP1 financial analyses are invalid. The amount of money that the NRC has estimated just to achieve radiological decommissioning for IP1, as listed in Table 2 of SECY-18-0078 and updated from 2016 dollars to 2019 dollars, is larger than HDI's initial funding level assumption, which itself is inconsistent with Entergy's reported DTF dollar level for IP1. There appears to be a total decommissioning shortfall of about $275 million dollars for IP1.
IP2 and IP3: HDI's PSDAR claims that it would take $301 million more dollars to decommission IP3 than it would take to decommission IP2, yet does not provide any justification for this large cost difference. IP2 and IP3 are sister plants on the same site, with nearly identical operating histories, that would be subjected to the same decommissioning processes within a short time period of each other. One expects that their decommissioning costs would be quite similar.
Multiple searches were made, as described in the IP2&IP3 attached document, to see if this large cost difference was justified. No pairs of sister PWRS on the same site in the NRC's Table1 of SECY-18-0078 exhibited such a large cost differential, nor did a similar search among Site Specific Cost Estimates. A highly detailed search of HDI's PSDAR did not provide any justification for HDI to charge the more highly funded IP3 DTF more accomplish the same task as it charged the IP2 DTF. More importantly, if the IP3 decommissioning cost estimate is more realistic, then there would be a large shortfall in the money available to decommission IP2. The lack of any comprehensive justification for the much higher decommissioning cost for IP3 relative to IP2 casts doubt on the whole HDI cost analysis.
Please contact me if there are any questions about this submittal and/or if there are other ways I can be of assistance to the Commission.
Sincerely, Herschel Specter, President Micro-Utilities, Inc.
mhspecter@verizon.net 1-914-761-3748
