ML20303A335

OEDO-20-00434 - Herschel Specter, President, Micro-Utilities, Inc, Email the Transfer of Licenses from Entergy to Holtec Decommissioning International (HDI) for Any of the Three Indian Point Nuclear Facilities, IP1, IP2, and IP3

ML20303A335
Person / Time
Site:	Indian Point
Issue date:	10/29/2020
From:	Specter H Micro Utilities
To:	NRC/EDO, Office of Nuclear Reactor Regulation
Poole, Justin
Shared Package
ML20303A322	List: ML20303A335 ML20303A337 ML20303A338 ML20349A098
References
OEDO-20-00434
Download: ML20303A335 (3)

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