ML20304A090

Comment from Barbara Warren Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments

ML20304A090
Person / Time
Site:	Indian Point
Issue date:	10/20/2020
From:	- No Known Affiliation
To:
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML20304A090 (2)

Text

Docket, Hearing From: Riverkeeper <info@Riverkeeper.org> on behalf of Barbara Warren, RN, MS <info@Riverkeeper.org>

Sent: Tuesday, October 20, 2020 10:34 AM To: CMRHanson Resource

Subject:

[External_Sender] Fully adjudicate all pending petitions on Docket Nos. 50-3, 50-247 and 50-286 Oct 20, 2020 Christopher Hanson, NRC Commissioner

Dear:

Hanson, NRC Commissioner, The Nuclear Regulatory Commission (the "Commission") must fully adjudicate all pending petitions regarding the proposed transfer of Indian Point Energy Center ("IPEC") prior to making a determination on the license transfer application and related exemption requests, Docket Nos. 50-3, 50-247 and 50-286.

As also discussed in the State of New York's Supplemental Comments (Accession No: ML022811A635),

approval of the proposed transfer prior to the Commission's ruling on the pending petitions to intervene--

submitted by the State, Riverkeeper, and others--would place the public at risk. It is essential that the concerns raised about Holtec's financial qualifications and character be properly assessed and mitigated if necessary.

Specifically, Riverkeeper had challenged the proposed transfer of Indian Point's licenses to Holtec on the grounds that its past actions show a lack of character, competence, and integrity, as well as the necessary candor, truthfulness and willingness to abide by NRC regulatory requirements. Since then, as detailed in supplemental filings, Riverkeeper has learned that Holtec is currently under criminal investigation in New Jersey, is financially unsound, and has deliberately violated local laws during the decommissioning of Oyster Creek.

Upon information and belief, the current criminal investigation into Holtec is for perjury, i.e. lying on a form to obtain tax credits from New Jersey, and fraud. Riverkeeper has also learned that Holtec is unable to pay back some of its debts due to cancellation of the tax credit due to the fraud as shown in Holtec's brazen suit for damages due to the cancellation of its tax breaks. In addition, a lawsuit filed by Lacey Township makes it plain that Holtec willfully violated local laws and did not stop certain work at Oyster Creek until the municipality obtained an injunction from a court.

The costly process of decommissioning of nuclear power plants can last decades and involve the complex removal and disposal of radioactive materials, presenting a significant risk to the community if not properly executed. The law provides for a number of safeguards to ensure that decommissioning is safely and completely executed including funding from decommissioning trust funds made up in part of rate payer contributions-- which totals over $2 billion for the three Indian Point reactors. Failure to comply with these laws may lead to significant safety and financial ramifications on the public. Further, corner cutting may impact both the safety and job security of the many IPEC employees both current and future. Giving this huge responsibility to an untrustworthy company would only put the local communities, IPEC employees, and New York State taxpayers at risk, especially in light of Holtec's proven record of cutting corners to maximize its own profits.

Therefore, the Commission must fully adjudicate all pending petitions on Docket Nos. 50-3, 50-247 and 50-286 before issuing a determination on the Indian Point license transfer application. As part of this process, I urge the Commission to examine the proposed license transfers and exception requests, giving heightened scrutiny to financial and character qualifications of Holtec, and requiring financial assurances as needed to protect the public.

1

In relation to the San Onofre nuclear power plant, Holtec delivered newly manufactured casks that it failed to inspect. Spent nuclear fuel was then loaded, despite loose parts being present in the casks. This could cause damage during transportation. Holtec was supposed to train its employees for loading canisters into its UMAX system but trained them on the wrong equipment resulting in a condition that was never supposed to happen--

a potential load drop incident. Workers were exposed to excess radiation. The loading procedure damaged stainless steel canisters, affecting their future longevity in dry storage. NRC knew that this same system is proposed to be used for CIS in New Mexico, but NRC failed to require Holtec to correct their failures.

Holtec needs to be held to higher standards at Indian Point.

Sincerely, Barbara Warren, RN, MS Executive Director Citizens' Environmental Coalition 422 Oakland Valley Rd.

Cuddebackville, NY 12729 Sincerely, Barbara Warren, RN, MS 422 Oakland Valley Rd Cuddebackville, NY 12729-5131 warrenba@msn.com 2