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Category:Rulemaking-Comment
MONTHYEARML22215A2362022-07-28028 July 2022 Comment (037) from Peter Gebhardt on PR-20, 26, 50, 51, 52, 72, 73 and 140 - Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning ML22215A0672022-07-26026 July 2022 Comment (032) from Jean Rivlin on PR-20, 26, 50, 51, 52, 72, 73 and 140 - Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning ML22215A0652022-07-26026 July 2022 Comment (030) from Evie Horton on PR-20, 26, 50, 51, 52, 72, 73 and 140 - Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning ML22215A0632022-07-26026 July 2022 Comment (028) from Emilia Silva on PR-20, 26, 50, 51, 52, 72, 73 and 140 - Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning ML21076A5332021-03-16016 March 2021 4 Form Comments from Citizens Opposing the Indian Point License Transfer Application (NRC-2020-0021) - (Version 2) ML21076A5302021-02-25025 February 2021 1 Form Comment from Citizen Opposing the Indian Point License Transfer Application (NRC-2020-0021) ML21076A5322021-02-23023 February 2021 Comment from Sandy Lehrenbaum Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments on Indian Point ML21076A5312021-02-23023 February 2021 Comment from Barbara and Edward O'Brien Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML21076A5292021-01-29029 January 2021 4 Form Comments from Riverkeeper Constituents to Commissioner Hanson Regarding the Indian Point License Transfer Application (NRC-2020-0021)- Subject: Fully Adjudicate All Pending Petitions NRC-2011-0189, Comment (20) of Michel Lee on Behalf of the Indian Point Safe Energy Coalition on the Proposed Rule for 10 CFR Parts 50 and 52 - Mitigation of Beyond-Design-Basis Events2016-02-11011 February 2016 Comment (20) of Michel Lee on Behalf of the Indian Point Safe Energy Coalition on the Proposed Rule for 10 CFR Parts 50 and 52 - Mitigation of Beyond-Design-Basis Events ML14017A1212014-01-16016 January 2014 Comment (00924) of Riverside Church on Behalf of 132 Individuals on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14006A3862013-12-20020 December 2013 Comment (00838) of Sally Jane Gellert on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML14002A0132013-12-19019 December 2013 Comment (00809) of Pam Krimsky on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13351A0032013-12-0707 December 2013 Comment (00394) of Mrs. Mary Ellen Kerr on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13336B4632013-11-29029 November 2013 Comment (00302) of Dale Saltzman on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13336A7232013-11-21021 November 2013 Comment (00279) of Grant Collier on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13336A5722013-11-21021 November 2013 Comment (00277) of Emily O'Mahony on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13320A0092013-11-15015 November 2013 Comment (00184) of Robert Tompkins on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13350A6512013-11-0606 November 2013 Comment (00378) of Jocelyn Decrecsenzo on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML13308D0852013-11-0303 November 2013 Comment (00127) of Gary Shaw on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel NRC-2012-0246, Comment (00938) of the Raging Grannies on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel2013-10-30030 October 2013 Comment (00938) of the Raging Grannies on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel ML12300A4692012-10-0202 October 2012 Comment (290) of Barbara Lenniger, Et. Al. on Behalf of Women'S Committee of Blawelt and Sparhill Dominions on PRM-50-104, Emergency Planning Zone Re Indian Point ML12278A0542012-09-24024 September 2012 Comment (288) of Catherine Howard and Other Three Individuals on Petition for Rulemaking PRM-50-104 Regarding Emergency Planning Zone ML12283A2602012-09-24024 September 2012 Comment (289) of Diane Forrest, Cecelia Lavan Et. Al. of Blauvelt Dominican Social Justice Committee on PRM 50-104 Regarding Resolution for Public Health and Safety Regarding Indian Point Nuclear Plants on Emergency Planning Zone ML12256B0272012-08-23023 August 2012 Comment (287) of Marie Gertrude Haughney and Three Other Individuals on Petition for Rulemaking PRM-50-104 Emergency Planning Zone ML12200A2972012-07-16016 July 2012 Comment (206) of Linda Griggs on PRM-50-104 Regarding Emergency Planning Zone ML12145A7172012-05-16016 May 2012 Comment (32) of Robert Cerello on PRM-50-104 Regarding Emergency Planning Zone ML1125211062011-09-0909 September 2011 Commission Memorandum and Order (CLI-11-05) Regarding Pr 52 ESBWR Design Certification Amendment ML1125210392011-09-0909 September 2011 Commission Memorandum and Order (CLI-11-05) Regarding Pr 52 AP1000 Design Certification Amendment NRC-2010-0135, Commission Memorandum and Order (CLI-11-05) Regarding Pr 52 AP1000 Design Certification Amendment2011-09-0909 September 2011 Commission Memorandum and Order (CLI-11-05) Regarding Pr 52 AP1000 Design Certification Amendment ML11209C4892011-07-21021 July 2011 Comment (8) of Mark Leyse on Petition for Rulemaking PRM-50-95 Requesting the NRC to Order Vermont Yankee to Lower the Licensing Basis Peak Cladding Temperature in Order to Provide a Necessary Margin of Safety in the Event of LOCA ML11209C4902011-07-21021 July 2011 Comment (21) of Mark Leyse, on Petition for Rulemaking PRM-50-93, Regarding NRC Revise Its Regulations Based on Data from multi-rod (Assembly) Severe Fuel Damage Experiments ML11175A3542011-06-21021 June 2011 2011/06/21-Comment (32) of Edwin Bergmann in Support of Petition for Rulemaking PRM-50-96, Regarding NRC Amends Its Regulations Regarding the Domestic Licensing of Special Material ML0929309822009-10-19019 October 2009 2009/10/19-Comment (26) of Mary Lampert, Et. Al., on Behalf of Pilgrim Watch on Rules PR-50 and 50, Enhancements to Emergency Preparedness Regulations. ML0914806402009-05-28028 May 2009 Supplemental Comments of Janice A. Dean on Behalf of the Office of the Attorney General of the State of New York on Pr 20, 30, 40, 50, 70 and 72 Regarding Decommissioning Planning ML0904804002009-02-0202 February 2009 Comment (88) of Sally Shaw on Pr 51 Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation, and Pr 51 Waste Confidence Decision Update ML0731002932007-10-31031 October 2007 Comment (2) of John Sweeney on Pr 52 Regarding Consideration of Aircraft Impacts for New Nuclear Power Reactor Designs ML0705104132007-02-16016 February 2007 Letter from Riverkeeper, Inc., Lisa Rainwater, Et. Al. on Proposed Rule Pr 50, 72 and 73 Re Requesting an Additional 60 Day Extension of the Comment Period ML0601905822006-01-19019 January 2006 Comment (27) Submitted by Jeff Wanshel on Proposed Rule PR-73 Regarding Design Basis Threat ML0524205852005-08-29029 August 2005 Comment (10) Submitted by Entergy Nuclear Operations, Inc., Travis C. Mccullough Opposing Andrew Spano'S Petition for Rulemaking PRM-54-02, Amendment to 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants ML0525602672005-08-23023 August 2005 Comment (21) Submitted by Jeffrey Wanshel Supporting Andy Spano'S Petition for Rulemaking PRM 54-02, Amendment to 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants ML0525604292005-08-22022 August 2005 Comment (20) Submitted by Gary Shaw Supporting Andy Spano'S Petition for Rulemaking PRM-54-02, Amendment to 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants ML0503102412005-01-24024 January 2005 Comment (200) Submitted by Felix Aguilar, Robert Gould and Jonathan Parfrey, on Behalf of the California Chapters of Physicians for Social Responsibility, Supporting Petition for Rulemaking PRM-73-12, Upgrade the Design Basis Threat Regulat ML0503102292005-01-24024 January 2005 Comment (199) Submitted by Robert K. Musil, on Behalf of the Physicians for Social Responsibility, on Petition for Rulemaking PRM-73-12, Upgrade the Design Basis Threat Regulations ML0504004342005-01-21021 January 2005 Comment (249) Submitted by Michael and Judy Hardy Supporting Petition for Rulemaking PRM-73-12, Upgrade the Design Basis Threat Regulations ML0504003832005-01-20020 January 2005 Comment (240) Submitted by Cindy L. Nance Supporting Petition for Rulemaking PRM-73-12, Upgrade the Design Basis Threat Regulations ML0502501652005-01-19019 January 2005 Comment (68) Submitted by Sallie and Otto Hunt Supporting Petition for Rulemaking PRM 73-12, Upgrade the Design Basis Threat Regulations ML0502501672005-01-19019 January 2005 Comment (69) Submitted by Allan Gill on Petition for Rulemaking PRM 73-12, Upgrade the Design Basis Threat Regulations ML0502503062005-01-19019 January 2005 Comment (86) Submitted by Dot Sulock on Petition for Rulemaking PRM 73-12, Upgrade the Design Basis Threat Regulations ML0327514662003-09-22022 September 2003 Comment (3) of Michael J. Colomb Re Proposed Generic Communication; Method for Estimating Effective Dose Equivalent from External Radiation Sources Using Two Dosimeters 2022-07-28
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From: Sarah Vogwill To: Docket, Hearing
Subject:
[External_Sender] Docket ID NRC-2020-0021 - opposing Indian Point license transfer to Holtec Date: Thursday, February 25, 2021 10:27:14 AM To the U.S. Nuclear Regulatory Commission, Rulemakings and Adjudications Staff:
Holtec and its subsidiaries are not qualified to hold the licenses of the Indian Point Energy Center. Given its record, area residents have no confidence in Holtec and do not accept it as the licensee. The Commission must not approve the license transfer, for the same reasons. Holtec has multiple problems, any one of which ought to disqualify it from decommissioning Indian Point. Taken together, they add up to a clear imperative to reject Holtec as the licensee.
Holtec lacks the experience needed to decommission Indian Point safely. Its entire nuclear fleet was acquired less than a year ago. It has never decommissioned a nuclear plant before; its first decommissioning job is Oyster Creek, which it acquired in July 2019. It is in effect learning on the job. The bulk of its experience is in spent fuel handling, where its performance has been poor.
Holtec and its subsidiaries are privately held and their finances are opaque. Their business model is based on maximally leveraging the decommissioning trust fund and taxpayer moneys for their profit. But they havent demonstrated sufficient capitalization to complete decommissioning, especially if decommissioning costs exceed their unreliably low estimates.
As New York Attorney General Letitia James said when she filed a petition to challenge license transfer to Holtec, Putting the decommissioning of Indian Point in the hands of a company with no experience and uncertain financial resources is very risky. Many elected officials in New York support the AGs filing and share her objections to Holtec.
In its premature Post-Shutdown Activities Report (PSDAR), improperly filed with the NRC as if it were already the licensee, Holtec significantly underestimated the cost to decommission Indian Point. In fact, there is no site characterization assessing current conditions on which to base an estimate. The PSDAR ignored the Algonquin Pipeline passing near Indian Points critical components, even though its presence greatly complicates decommissioning and raises risks of ruptures and fires. Holtec acknowledged in the PSDAR that there was radioactive contamination of groundwater at the site, which is also leaking into the Hudson River. But it stated it planned to do nothing to remediate it, and will only monitor it. Nor does it plan to remediate contaminated soil any deeper than three feet. The PSDAR also stated Holtec is considering shipping large radioactive components by barge down the Hudson, which raises a host of additional unacceptable risks.
Holtecs complex subsidiary structure of separate, undercapitalized LLCs shields it from liability and accountability. At the same time, its side businesses, including building small modular reactors (SMRs) and a consolidated interim storage (CIS) site for nuclear waste in New Mexico, pose unacceptable conflicts of interest which its compartmentalized subsidiary structure does not remedy. These side businesses create perverse incentives for Holtec for example to ship radioactive waste from Indian Point to its own CIS facilities, or eventually to use Indian Points waste or even its site to benefit Holtecs SMR business even if such choices run counter to the public interest and public safety.
Holtec and SNC-Lavalin, the two companies behind the proposed Indian Point decommissioning contractors, are embroiled in numerous scandals and controversies that tell against their claims of high standards in ethics, compliance, financially sustainable business practices and trusted stewardship of nuclear materials. Their actual record is full of corruption, bribery, fraud, pleading guilty to and paying fines for malfeasance, getting barred from doing business with the TVA and the World Bank, and misleading and
lying to officials and the public.
Holtec has demonstrated dangerous incompetence in its spent fuel handling at San Onofre Nuclear Generating Station. It put costs ahead of safety when it hired unqualified, low-skilled workers at Oyster Creek and has repeatedly exhibited a pattern of disregard for public concern or input.
Holtec is neither an honest broker nor a trustworthy partner in securing the safety and future of the region around Indian Point. 20 million people live and work within a 50-mile radius of the plant.
Decommissioning it is a complex undertaking and an awesome responsibility on which the safety and future viability of our region depends. Those of us who live and work here will not passively accept an unqualified, unscrupulous company such as Holtec being put in charge of Indian Point.
Its vital that Indian Points licensee be competent and trustworthy, free of the kind of serial malfeasance Holtec has committed, with a solid track record demonstrating it is well equipped to decommission Indian Point safely and responsibly. The Commission therefore has an obligation, statutory and otherwise, to clear the way for such a qualified candidate and reject Holtec as the licensee entrusted to decommission Indian Point.
Sincerely, Sarah Vogwill Saugerties, NY 12477