ML21068A311
| ML21068A311 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/08/2021 |
| From: | Michael Lee Council on Intelligent Energy & Conservation Policy (CIECP) |
| To: | |
| SECY/RAS | |
| References | |
| 86FR8225, NRC-2021-0036 | |
| Download: ML21068A311 (10) | |
Text
From:
Michel Lee Council To:
Docket, Hearing
Subject:
[External_Sender] NRC Doc ID NRC-2021-0036 CIECP and LEAF of Hudson Valley Comments re Transfer Palisades Power Plant and Big Rock Point to Holtec Date:
Monday, March 08, 2021 11:58:42 PM Attachments:
Docket ID NRC-2021-0036 CIECP and LEAF Comments re Palisades and Big Rock Point Transfer to Holtec.pdf Submission of the attached.
Michel Lee, Esq.
Chairman Council on Intelligent Energy & Conservation Policy (CIECP)
1 Docket ID NRC-2021-0036 CIECP and LEAF of Hudson Valley Comments to NRC re Transfer of Palisades Power Plant and Big Rock Point to Holtec (March 8, 2021)
Via email to: Hearing.Docket@nrc.gov.
Dear U.S. Nuclear Regulatory Commission Commissioners and Staff,
Council on Intelligent Energy & Conservation Policy (CIECP) and LEAF (Legal Environmental Action Fund) of Hudson Valley oppose transfer of the Palisades Power Plant (Palisades) and Big Rock Point (Big Rock Point) nuclear power sites and Independent Spent Fuel Storage Installations (ISFSIs) from Entergy to Holtec.
(For ease of reference, these Comments will generally refer to Entergy Corporation and its various subsidiaries as Entergy and Holtec International and its various subsidiaries and controlled affiliated entities as Holtec.)
Introduction Palisades and Big Rock Point are located in Covert Township, Van Buren County, Michigan on the shore of Lake Michigan.
Entergy Corporation is a Fortune 500 integrated energy company which currently indicates it has annual revenues of $10 billion. Its primary business segments include utility operations (primarily fossil fuel and nuclear) and a wholesale commodities business. Entergys nuclear operations, as of March 8, 2021, include 8 nuclear reactor units: Arkansas Nuclear One Units 1 and 2; Cooper; Grand Gulf Nuclear Station; Indian Point Energy Center Unit 3; Palisades; River Bend Station; and Waterford 3. Entergy also operates and maintains two petroleum coke-fired units at the Nelson Industrial Steam Company in Louisiana. Entergy Wholesale Commodities business include 2 operating nuclear units (at 2 sites), one managed nuclear plant, a gas facility and 2 coal facilities. (See, e.g., Entergy: About US, accessed Mar 8, 2021.
https://www.entergy.com/about_entergy/.)
In 2018 and 2019, Entergy announced its plan to transfer its entire remaining merchant nuclear fleet - after their shutdowns and reactor defuelings - to Holtec International for decommissioning, site restoration, and maintenance of all nuclear waste. The Energy merchant fleet includes Palisades; Indian Point Units 1, 2, and 3 (in Buchanan, New York); Pilgrim Nuclear Power Station (Plymouth, Massachusetts). In 2019, Holtec International also took over the Oyster Creek Generating Station (Forked River, New Jersey) from Exelon for decommissioning.
Holtec International is a privately held company which does not disclose its financials. Its company structure is highly opaque and its business operations appear in constant flux, with precious little transparency vis--vis how different entities interrelate, the particulars of agreements, or the delegations of responsibilities among them.
2 Holtecs company structure has been described as a multitude of shell companies. A kaleidoscope full of tiny flimsy shells may be a more fitting analogy.
Holtec Internationals web pages - which are the sources most members of the public would be reasonably expected to access when seeking information - are exceptionally arduous to navigate and reveal little besides PR boasts. Given the harsh spotlight which has been shown upon the company since it embarked upon its acquisition of closing nuclear sites, its planned construction of a massive nuclear waste site in New Mexico, and its new small modular reactor enterprise, this glaring lack of transparency is actually quite revealing.
Holtecs self-description is pure marketing gobbledygook that - at best - describes an assemblage of entities which self-deal with one another without scrutiny. (See Appendix A to Comments - Notes on Holtec Structure)
What seems clear, is that the sundry subsidiaries, limited liability companies, and joint ventures can be cut off and left to dry sans any assets for states left to attach in the event of a serious problem. There are no safeguards to ensure that Holtec will do more than the bare minimum a superficial job of decommissioning, deplete Palisades' decommissioning trust fund as rapidly as possible, and walk away with the money but no liability. This would leave Michigan and the Great Lakes to shoulder the burden and costs of radiological contamination. As with Indian Point, site, groundwater, and source water contamination are matters of demonstrated concern.
(Gunter, Paul, Leak First, Fix Later: Uncontrolled and Unmonitored Radioactive Releases from Nuclear Power Plants, Beyond Nuclear report, Mar 2015. Mar17_LeakFirst_FinalDraft (sqspcdn.com))
Meanwhile, the parent company Holtec International has the ability to consume the only known assets of value involved here: the Decommissioning Trust Funds. This basic point has been repeatedly made in filings with the NRC by municipalities, hundreds of individuals, scores of public interest groups, and - most significantly - by the Attorneys General of the states of Massachusetts, New York, and, most recently, Michigan.
So as not to impose upon the current limited time resources of NRC staff, we will here not focus here on the many well articulated facts stated and concerns raised in such filings.
Rather, in these Comments, we seek to prevail upon the NRC to seriously take account of the real world conditions prevalent in our nation: real world extreme weather and natural disaster events - and the real world failures of adequate response thereto; real world deteriorated conditions of our national infrastructure; real world economics (of not just companies which seek profit, but of extremely strained government budgets); the demonstrable failures of adequate response to the real world injustices visited upon low-income Americans, persons of color and marginalized populations and the undeniable disparities of essentially all risk impacts upon such persons; and the real world security threats we face. (See Appendix B to Comments -
Examples of Real World Conditions)
Such real world conditions independently and in concert represent risk multipliers.
3 We also ask the NRC to analyze the license transfer of Palisades and Big Rock Point within the context of the entire Holtec business scheme, which is the only way these license, Decommissioning Trust Fund and liability transfers may be properly considered. In the real world, the Holtec scheme is integrally interconnected.
Conclusion We submit that the many recent and ongoing crises faced by the nation illustrate why low-probability, high consequence events such as multiple widespread and near-coincident extreme weather events, natural disasters, infrastructure failures, pandemics/epidemics, cyberattacks, civil unrest, and terrorism must be taken into consideration in cost and technical capability calculations, especially where the high consequence may be truly catastrophic.
APPENDIX A TO COMMENTS - NOTES ON HOLTEC STRUCTURE Entergy Nuclear Operations, Inc.s December 23, 2020 cover letter to its Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments for Palisades Nuclear Plant and Big rock Point, states: Approval of these transfers is sought to effectuate a transaction under which indirect control of Palisades and Big Rock Point will be transferred to Holtec pursuant to the terms of a Membership Interest Purchase and Sale Agreement (MIPA). Pursuant to the terms of the MIPA, the transaction would occur only after the permanent removal of fuel from the Palisades reactor. Just prior to the proposed transaction, Entergy will transfer all of the assets and liabilities of ENP to a new entity that ultimately will become Holtec Palisades, LLC (Holtec Palisades). Nuclear Asset Management Company, LLC (NAMCo), a wholly-owned subsidiary of Holtec, will then acquire the equity interests in either the new Holtec Palisades entity or the parent company owner of this entity; either way, NAMCo will emerge as the direct parent company of Holtec Palisades. Following the license transfers, Holtec Palisades will be the licensed owner of Palisades and Big Rock Point. In addition, HDI, an indirect wholly owned subsidiary of Holtec, will assume licensed responsibility for Palisades and Big Rock Point through transfers of ENOIs responsibility for licensed activities at Palisades and Big Rock Point to HDI. HDI is a special purpose entity formed by Holtec to be the licensed operator to decommission nuclear power plants including Palisades and Big Rock Point. HDI is the licensed decommissioning operator for Oyster Creek and Pilgrim decommissioning facilities.
Holtec Palisades will enter into a Decommissioning Operator Services Agreement with HDI, which will provide for HDI to act as its agent and for Holtec Palisades to pay HDIs costs of post-shutdown operations, including decommissioning and spent fuel management. (Entergy Nuclear Operations, Inc. cover letter to NRC re Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments for Palisades Nuclear Plant and Big rock Point, at pp 2 & 2. Microsoft Word - PNP 2020-042 Palisades and BRP License Transfer Application 12-21-20 (nrc.gov)
As of March 8, 2021, Holtec Internationals web page identifies the following entities under the heading Divisions & Affiliates: Holtec Power Division De Mexico; HoltecAsia; and Holtec
4 Decommissioning International (HDI); Holtec Site Services; Ukrainian Module Consortium; Orrvilion; Holtec Security International; Nuclear Consultants International (NCI); Oak Ridge Technologies (A Gilmartin Engineering Works and Holtec International SBA Approved JV Company); Holtec Brasil; HI-POWER (A Holtec and Eos JV Company); Holtec Manufacturing; Holtec Britain; Holtec Nuclear Power Division; Holtec Asia Precision Fabrication Systems; SMR; Holtec Government Services; Holtec Canada; Holtec Heat Transfer Division; Comprehensive Decommissioning International (CDI) (A Holtec and SNC-Lavalin Company).
From this potpourri, let us focus on a few already existing key Holtec International subsidiary/affiliate entities: Comprehensive Decommissioning International (CDI), Holtec Decommissioning International (HDI), and Nuclear Consultants International (NCI).
Holtecs own website jargon speaks for itself - it defies satirization:
Comprehensive Decommissioning International (CDI) is described, inter alia, as follows:
Comprehensive Decommissioning International, LLC (CDI) is a joint venture of Holtec International and SNC-Lavalin (TSX: SNC). The organization serves as the decommissioning general contractor for Holtecs fleet of shutdown nuclear plants. CDI (cdi-decom.com)
Holtec Decommissioning International (HDI) is described, inter alia, as follows: A wholly-owned subsidiary of Holtec International, HDI is the licensed operator for Holtec-owned nuclear power plants and provides the licensee oversight of the decommissioning work that is performed by Comprehensive Decommissioning International (CDI), Holtec and SNC-Lavalins jointly owned decommissioning general contractor. In addition, HDI manages the decommissioning trust fund as well as other owner interests, such as licensing strategy, insurance, land and government interface. HDIs managerial oversight utilizies a fleet management approach for decommissioning multiple sites. This includes standardized processes and procedures leading to improved safety, increased productivity and the minimization of duplicative managerial costs.
https://holtecinternational.com/company/divisions/nuclear-consultants-international/.
Nuclear Consultants International (NCI) - a/k/a Nuclear Consultants International, LLC is described, inter alia, as follows: Nuclear Consultants International, LLC (NCI) is an autonomously constituted business unit of Holtec International. NCI is chartered to support nuclear utility and industrial companies with management and technology support services.
NCIs principal area of concentration is the oversight of decommissioning projects to ensure the utility/industrial companys regulatory and safety compliance with utmost consideration of ALARA. NCIs mission is to support our Nuclear partners in their effort to ensure that desired program and/or project expectations. NCI can:
- Act as an Owners Engineer.. NCI performs goal-focused reviews of others work product through the deployment of Seasoned nuclear Professionals as agents of the customer to inspect, measure, assess and respond to program and/or project performance.
- Be a Specialty Technology Provider. The nuclear plant owners can leverage NCIs stable of cutting-edge technologies to secure specialty engineering services to analyze and solve problems that produce minimum cost and maximum design margin.
https://holtecinternational.com/company/divisions/nuclear-consultants-international/.
5 APPENDIX B TO COMMENTS - EXAMPLES OF REAL WORLD CONDITIONS Over just the past one year, we have witnessed 22 separate billion-dollar weather and climate disasters across the United States. The nation, more generally, experienced a record-breaking 30 named tropical cyclones, of which a record 12 made landfall. Many central states were impacted by a historically powerful derecho in August 2020, which cut a path of 770 miles in just 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />, and caused impacts comparable to an inland hurricane. The past year also brought, to various areas; other severe storm events, floodings; drought; and a record-breaking wildfire season that scorched over 10.2 million acres.
(See, e.g., Smith, Adam B., 2020 U.S. billion-dollar weather and climate disasters in historical context, Jan 8, 2021. https://www.climate.gov/news-features/blogs/beyond-data/2020-us-billion-dollar-weather-and-climate-disasters-historical.)
As detailed in a vast quantity of published peer-reviewed literature, we can expect more frequent and intense extreme weather and climate-related events and continuing alteration of average climate conditions for the remainder of this century, even with sharp greenhouse gas emissions reductions. Already emitted CO2 concentrations creates risks and exacerbates existing vulnerabilities and is expected to continue to damage infrastructure, ecosystems and social systems.
(See, USGCRP: Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment, Volume II [Reidmiller DR, Avery CW, Easterling DR, Kunkel KE, Lewis KLM, Maycock TK, and Stewart BC (eds.)], U.S. Global Change Research Program, Washington, DC, USA, 2018. https://nca2018.globalchange.gov/downloads/NCA4_2018_FullReport.pdf.)
Michigan and the Great Lakes are subject to new and evolving climate vulnerabilities which the publicly available evidence indicates has been assessed by neither Holtec nor the NRC, despite highly concerning developments.
(See, CBS: Powerful Derecho Leaves Path Of Devastation From Iowa To Michigan, CBS Minnesota, Aug 11, 2020. https://minnesota.cbslocal.com/2020/08/11/powerful-derecho-leaves-path-of-devastation-from-iowa-to-michigan/. Corley, Cheryl, Wet, Wild And High: Lakes And Rivers Wreak Havoc Across Midwest, South, NPR (National Public Radio), Aug 14, 2019.
https://www.npr.org/2019/08/14/749062901/wet-wild-and-high-lakes-and-rivers-wreak-havoc-across-midwest-south. National Weather Service: Lake Michigan at Near-Record High Water Levels, Jan 25-25, 2021. Lake Michigan at Near-Record High Water Levels (weather.gov).
Samenow, Jason, Satellite imagery reveals massive scope of Midland, Mich., flood disaster, The Washington Post, May 22, 2020.
https://www.washingtonpost.com/weather/2020/05/22/michigan-dams-failure-before-after/.
Sills D and Ashton A, Examination of a Remarkable Greak Lake-Spawned Tornadic Supercell:
The 2011 Goderich Ontario F3 Tornado Event, paper 26th Conf. on Severe Local Storms, 2012.
http://www.yorku.ca/pat/research/dsills/papers/SLS26/SLS26_manuscript_GoderichF3_FINAL.p df. Wuebbles D, Cardinale B, Cherkauer K, Davidson-Arnott R, Hellmann J, Infante D, Johnson L, de Lo R, Lofgren B, Packman A, Seglenieks F, Sharma A, Sohngen B, Tiboris M, Vimont D,
6 Wilson R, Kunkel K, and Ballinger A, An Assessment of the Impacts of Climate Change on the Great Lakes, report commissioned by the Environmental Law & Policy Center and Chicago Council on Global Affairs, Mar 2019.
Likewise, every single one of the decommissioning sites which Holtec has or seeks to acquire are subject to new and forecast climate vulnerabilities whose complex interactions with decommissioning activities and waste management remain unanalyzed. These vulnerabilities extend beyond the direct potential of accident-inducing natural phenomena to the many indirect ways severe weather can obstruct mitigation of events and prevent adequate emergency response. The vulnerabilities also extend to the ways climate is likely to heighten the vulnerability of other hazardous, transportation, energy and water infrastructure in ways which may interact in a wide variety of concerning ways with sites.
(See Flavelle, Christopher, Brad Plumer and Hiroko Tabuchi, Texas Blackouts Point to Coast-to-Coast Crises Waiting to Happen, New York Times, Feb 20, 2021.
https://www.nytimes.com/2021/02/20/climate/united-states-infrastructure-storms.html. Flavelle, Christopher, Denise Lu, Veronica Penney, Nadja Popovich and John Schwartz, New Data Reveals Hidden Flood Risk Across America, New York Times, Jun 29, 2020.
https://www.nytimes.com/interactive/2020/06/29/climate/hidden-flood-risk-maps.html.
Freebairn, William, Dukes Brunswick nuclear plant in North Carolina restores personnel access as flooding eases, S&P Global / Platts, Sep 19, 2018.
https://www.spglobal.com/platts/en/market-insights/latest-news/electric-power/091918-dukes-brunswick-nuclear-plant-in-north-carolina-restores-personnel-access-as-flooding-eases. Keys R, Castellaw J, Parker R, Phillips AC, White J, Galloway G, and Messera H, U.S. Sea Level Rise and the U.S. Militarys Mission, Military Expert Panel Report, 2nd Ed, Feb 2018.
https://climateandsecurity.files.wordpress.com/2018/02/military-expert-panel-report_sea-level-rise-and-the-us-militarys-mission_2nd-edition_02_2018.pdf. Marfin, Catherine, Jesus Jimenez, Nataly Keomoungkhoun, Charles Scudder, and Tom Steele, At least 6 dead in 133-car pileup in Fort Worth after freezing rain coats roads, Dallas Morning News, Feb 11, 2021.
Americas crumbling and deteriorated infrastructure, communications failures and non-robust hazardous infrastructure sites proximate to nuclear sites and radioactive waste transport routes represent other large sets of risk multipliers that are well documented but have not been given consideration by Holtec or the NRC in existing assessments and risk evaluations.
(See, ASCE: 2021 Americas Infrastructure scores a C-, American Society of Civil Engineers, Mar 2021. https://infrastructurereportcard.org/. Carew, Sinead, Hurricane sandy disrupts Northeast U.S. telecom networks, Reuters, Oct 20, 2012. https://www.reuters.com/article/us-storm-sandy-telecommunications/hurricane-sandy-disrupts-northeast-u-s-telecom-networks-idUSBRE89T0YU20121030. Ganzer, Tony, Infrastructure Suffers In The Freeze And Thaw Cycle, WOSU, Jan 30, 2019. https://radio.wosu.org/post/infrastructure-suffers-freeze-and-thaw-cycle#stream/0. Nixon, Ron, Human Cost Rises as Old Bridges, Dams and Roads Go
7 Unrepaired, New York Times, Nov 6, 2015.
http://www.nytimes.com/2015/11/06/us/politics/human-cost-rises-as-old-bridges-dams-and-roads-go-unrepaired.html. U.S. CSB (DHS): West Fertilizer Company Fire and Explosion, U.S.
Chemical Safety and Hazard Investigation Board, Final Investigation Report, Report No. 2013-02-I-TX, Jan 2016. https://www.hsdl.org/?view&did=806474. United Westchester, Storm Response Report, Aug 2020. https://nyassembly.gov/mem/Amy-Paulin/story/94811.
Cyberattacks, sabotage, and terror attacks are also discounted by Holtec and the NRC, with the NRC, using the irreconcilable logic that attack risk cannot be quantified while waving away such risks by pronouncing them of very low likelihood. At this point, given the astonishing rise of cyberattacks upon critical infrastructure, corporations (including major cybersecurity, IT and telecommunications firms) and governmental offices, it is an absurdity to conclude that an attack that could consequentially impact nuclear facilities or radioactive waste (in transit or at any site) to be of low likelihood. Likewise, the rise of violent domestic unrest events and malevolent actors involving circumstances where law enforcement and mitigative response action has been demonstrably wanting renders any assertion that nuclear sites and material are somehow invulnerable myopic and reckless.
(See, Bertrand, Natasha and Eric Wolff, Politico, Nuclear weapons agency breached amid massive cyber onslaught, Dec 17, 2020. https://www.politico.com/news/2020/12/17/nuclear-agency-hacked-officials-inform-congress-447855. Cybersecurity Observatory: Rail and Metro Cybersecurity - where is the Industry Now?, Cybersecurity Observatory webpage, accessed Jun 16, 2020. https://cyberstartupobservatory.com/rail-cybersecurity-where-is-the-industry-now/.
Fernandez, Manny, David E Sanger and Marina Trahan Martinez, Hackers Cripple Dozens of Cities, Hunting Ransom, New York Times, Aug 23, 2019.
https://www.nytimes.com/2019/08/22/us/ransomware-attacks-hacking.html. Grady, John, Experts: Maritime Industry Remains Vulnerable to Cyber Attacks, USNI News, Sep 28, 2020.
https://news.usni.org/2020/09/28/experts-maritime-industry-remains-vulnerable-to-cyber-attacks. Hambling, David, Dozens More Mystery Drone Incursions Over U.S. Nuclear Power Plants Revealed, Forbes Contributor, Sep 7, 2020.
https://www.forbes.com/sites/davidhambling/2020/09/07/dozens-more-drone-incursions-over-us-nuclear-power-plants-revealed/?fbclid=IwAR2oqyRo1uKepwaxYfXJlN7V5oUGQY7PZ9E5ctcgkUPpDvDf-1vbZ63GQkc#d4b074e6296b. Harris, Shane, Nashville bombing is a potent reminder that communications systems remain at risk from attack, Washington Post, Dec 28, 2020.
https://www.washingtonpost.com/national-security/nashville-bombing-is-a-potent-reminder-that-communications-systems-remain-at-risk-from-attack/2020/12/28/d734b76c-4949-11eb-839a-cf4ba7b7c48c_story.html. Koutsoukos X, Neema H, Bhatia S, Sztipanovits J, Stouffer KA, and Tang C-Y, Performance Evaluation of Secure Industrial Control System Design: A Railway Control System Case Study, paper presented at the National Institute of Standards and Technology 11th Annual Cyber and Information Security Research (CISR) Conference, Oak Ridge, TN, April 6-7, 2016. paper.
https://tsapps.nist.gov/publication/get_pdf.cfm?pub_id=919753. Mandia, Kevin: FireEye:
Shares Details of Recent Cyber Attack, Actions to Protect Community, FireEye blog, Dec 8, 2020. https://www.fireeye.com/blog/products-and-services/2020/12/fireeye-shares-details-of-
8 recent-cyber-attack-actions-to-protect-community.html. Myers, Lt. Col Michael, Our critical infrastructure isnt ready for cyber warfare, The Hill Op-Ed Feb 14, 2018.
https://thehill.com/opinion/cybersecurity/373815-our-critical-infrastructure-isnt-ready-for-cyber-warfare. Parfomak PW, Pipeline Cybersecurity: Federal Policy, Congressional Research Service report, Aug 16, 2012. http://nsarchive.gwu.edu/NSAEBB/NSAEBB424/docs/Cyber-076.pdf. Perlroth, Nicole, Russians Are Believed to Have Used Microsoft Resellers in Cyberattacks, New York Times, Dec 24, 2020. https://www.nytimes.com/2020/12/24/us/russia-microsoft-resellers-cyberattacks.html. Sanger. David E, Nicole Perlroth and Eric Schmitt, Scope of Russian Hack Becomes Clear: Multiple U.S. Agencies Were Hit, New York Times, Dec 14, 2020. https://www.nytimes.com/2020/12/14/us/politics/russia-hack-nsa-homeland-security-pentagon.html. Snell, Rogert, Michigan militia members helped FBI crack alleged Whitmer kidnap plot, The Detroit News Jan 22, 2021.
https://www.detroitnews.com/story/news/local/michigan/2021/01/22/michigan-militia-members-helped-fbi-crack-alleged-whitmer-kidnap-plot/6673255002/. TEXAS: Information Concerning the August 2019 Texas Cyber Incident, Texas Department of Information Resources briefing notice, Aug 20, 2019. https://dir.texas.gov/View-About-DIR/Article-Detail.aspx?id=209. Trend Micro: What is the state of SCADA vulnerabilities? Trend Micro Zero Day Initiative, Dec 16, 2019. https://www.trendmicro.com/vinfo/us/security/news/vulnerabilities-and-exploits/one-flaw-too-many-vulnerabilities-in-scada-systems. Turton, William, Michael Riley and Jennifer Jacobs, Hackers Tied to Russia Hit Nuclear Agency; Microsoft Is Exposed, Bloomberg, Dec 17, 2020.
https://www.bloomberg.com/news/articles/2020-12-17/u-s-states-were-also-hacked-in-suspected-russian-attack. U.S.-CERT: Compromise of U.S. Water Treatment Facility, U.S.
Department of Homeland Security and Federal Bureau of Investigation U.S. Computer Emergency Readiness Team Alert (AA21-042A), Feb 11, 2021. https://us-cert.cisa.gov/ncas/alerts/aa21-042a. U.S.-CERT: Russian State-Sponsored Cyber Actors Targeting Network Infrastructure Devices, U.S. Department of Homeland Security and Federal Bureau of Investigation U.S. Computer Emergency Readiness Team Alert (TA18-106A), revis.
Apr 20, 2018. https://www.us-cert.gov/ncas/alerts/TA18-106A. U.S.-CERT: Russian Government Cyber Activity Targeting Energy and Other Critical Infrastructure Sectors, U.S. Department of Homeland Security and Federal Bureau of Investigation U.S. Computer Emergency Readiness Team Alert (TA18-074A), Mar 15, 2018. https://www.us-cert.gov/ncas/alerts/TA18-074A. U.S.-
CERT: Advanced Persistent Threat Activity Targeting Energy and Other Critical Infrastructure Sectors, U.S. Computer Emergency Readiness Team Alert (TA17-293A), Oct 20, 2017.
https://www.us-cert.gov/ncas/alerts/TA17-293A. U.S. CISA: Advanced Persistent Threat Compromise of Government Agencies, Critical Infrastructure, and Private Sector Organizations, Cybersecurity & Infrastructure Security Agency (CISA) Alert (AA20-352A), Dec 17, 2020.
https://us-cert.cisa.gov/ncas/alerts/aa20-352a. U.S. COAST GUARD: Cyberattack Impacts MTSA Facility Operations, U.S. Coast Guard, Marine Safety Information Bulletin, MSIB no. 10-19, Dec 16, 2019. U.S. COAST GUARD: Cyber Incident Exposes Potential Vulnerabilities Onboard Commercial Vessels, U.S. Coast Guard, Marine Safety Alert no. 06-19, Jul 8, 2019.
https://www.dco.uscg.mil/Portals/9/DCO%20Documents/5p/CG-5PC/INV/Alerts/0619.pdf.
U.S. GAO: Weapons Systems Cybersecurity: DOD Just Beginning to Grapple with Scale of Vulnerabilities, U.S. Government Accountability Office Report to the Committee on Armed Services, U.S. Senate, GAO-19-128, Oct 2018. Link at: https://www.gao.gov/products/GAO 128?utm. Veritas Group: U.S. Freight Rail & Transit Cyber Vulnerabilities, Veritas Group
9 report, Jul 16, 2019. https://railsecurity.org/wp-content/uploads/2019/08/US-Freight-Rail-and-Transit-Cyber-Vulnerabilities-Updated-July-16-2019.pdf.)
Moreover, the matter of events impacting operation and management of the site and decommissioning extends way beyond the potentially catastrophic to the mundane. Accidents, problems, delays due to vendors, etcetera, at any large complex site commonly occur, as even applicants acknowledge. Such events can only be reasonably anticipated to occur with some regularity under the schema and with the byzantine rather incomprehensible structure Holtec proposes in its fleet plan.
Holtec has never decommissioned a single nuclear power plant in the United States. It has, until very recently, focused on spent fuel canister and cask systems - and its activities in fuel transfer at San Onofre have been marred by delays, safety culture problems and confusion over what mandates NRC review. For example thin-walled canisters have been scratched and gouged when transferred from fuel pools to casks. In one case a canister got caught while being lowered into the storage cask and was dangerously suspended for hours. Holtec did not report this occurrence.
It became known only when a whistleblower discussed the incident at a public hearing.
Nevertheless, Holtec now embarks upon a vast expansion of its nuclear operations, seeking to decommission multiple sites at the same time. Even with every optimistic assumption proffered by Holtec regarding its own estimated spectacular planned performance, how is this not a glaring fantasy in a world that will remain struggling with Covid-19 and its cascading impacts upon supply networks, transportation, and human capitol for a long time.
Finally, Holtecs divination that the nuclear waste will begin to be removed in the current decade is nothing more than a guess which is very likely guided by its financial self-interest in opening a massive HI-STORE Consolidated Interim Storage Facility (CISF) in Southeastern New Mexico.
That enterprise is being bitterly fought and is hardly assured of being brought to fruition. In fact, even if it were built, in proceedings before the NRC Atomic Safety and Licensing Board (ASLB), Holtec representatives said that if a spent fuel canister being received at its proposed HI-STORE CISF were found to be defective or leaking upon receipt in New Mexico, Holtec would send it back to the nuclear power site from whence it came. (ASLB: Official Transcript of Proceedings, in the Matter of Holtec International (HI-STORE Consolidated Interim Storage Facility), U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board hearings, Albuquerque, New Mexico, Docket No. 72-1051-ISFSI, ASLBP No. 18-958-01-ISFSI-BD01, Jan 24, 2019, at p 282. http://wethefourth.org/files/pdf/ELEA-NRC-transcript-2019-01-24.pdf.)
This alone would likely crease considerable planning, coordination, legal and regulatory oversight challenges that impact any number of or even all of Holtecs planned decommissioned or decommissioning sites.