ML21293A200
| ML21293A200 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/15/2021 |
| From: | Boykin B, Shimsky M, Anthony Williams Westchester County, NY, Board of Legislators |
| To: | Office of Administration |
| References | |
| 86FR37346 00017, NRC-2021-0125 | |
| Download: ML21293A200 (4) | |
Text
10/20/21, 12:50 PM blob:https://www.fdms.gov/818e7adc-b5f9-40dc-8329-aed1239dd6a7 blob:https://www.fdms.gov/818e7adc-b5f9-40dc-8329-aed1239dd6a7 1/1 PUBLIC SUBMISSION As of: 10/20/21 12:50 PM Received: October 15, 2021 Status: Pending_Post Tracking No. kus-l604-816x Comments Due: October 22, 2021 Submission Type: Web Docket: NRC-2021-0125 Holtec Decommissioning International, LLC Indian Point Nuclear Generating, Unit Nos. 1, 2, and 3 Post-Shutdown Decommissioning Activities Report Comment On: NRC-2021-0125-0002 Holtec Decommissioning International, LLC; Indian Point Nuclear Generating, Unit Nos. 1, 2, and 3; Post-Shutdown Decommissioning Activities Report Document: NRC-2021-0125-DRAFT-0019 Comment on FR Doc # 2021-15068 Submitter Information Email:lahc@westchestergov.com
Government Agency Type:Local
Government Agency:Westchester County Board of Legislators General Comment See attached file(s) Please see attached letter submitted on behalf of the Westchester County Board of Legislators regarding the Indian Point PSDAR Docket ID NRC-2021-0125 Attachments NRC FINAL Comments on Indian Point PSDAR 101521 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Richard Guzman, Mary Neely Comment (17) Doc.
0002 Publication Date:
7/15/2021 Citation: 86 FR 37346
October 15, 2021 Submitted electronically via https://www.regulations.gov Docket ID NRC-2021-0125 Comments on the Indian Point Post Shutdown Decommissioning Activities Report (PSDAR)
We, the undersigned Westchester County Legislators, submit these comments on the Indian Point PSDAR to urge the NRC to be vigilant and proactive by taking and/or requiring necessary measures to safely decommission, remediate and restore the Indian Point site to productive use.
Potential risks and impacts identified below are exacerbated due to densely populated surroundings and close proximity to the Buchanan-Verplanck Elementary School and the City of Peekskill, which has been defined by New York State Department of Environmental Conservation as a Potential Environmental Justice Area.
Gas Pipelines. The presence of natural gas and high-pressure gas pipelines running adjacent to and beneath the site multiply and compound the potential hazards associated with decommissioning. We find it inexplicable and reckless that there was no safety evaluation done prior to installation of the AIM/Algonquin Pipeline Expansion.
Radioactive Leaks. The PSDAR fails to assess how excavation activity escalates the potential for radioactive leaks and/or rupture of the gas pipelines. Excavation will involve moving heavy machinery onto the site, disturbing soil conditions, and demolishing structures with a prior history of contamination. Certain activities will increase the likelihood of radioactive release, particularly if they coincide with extreme weather events, which are becoming more common.
We are particularly concerned about pre-existing leaks that are likely to release radioactivity when certain structures are dismantled.
Long-term Storage of Nuclear Waste. The PSDAR provides a decommissioning timeline based on certain stated assumptions. One assumption is that nuclear waste will be removed from Indian Point to an interim storage facility in southeast New Mexico. Such facility has not yet been built or licensed and it faces major opposition. Nearby Indigenous and Hispanic populations have already suffered disproportionately high adverse human health and environmental effects from nuclear energy and weapons programs of the United States, which is a grave environmental injustice. The New Mexico Attorney General has sued to block the facility, citing, among other objections, negative impacts to the states agricultural economy as well as the oil and gas industry. Transporting nuclear waste through densely populated areas, utilizing aging and vulnerable infrastructure gives rise to serious safety and security concerns.
Based on these potential impacts and hazards, it is reasonable to expect that spent fuel would remain where it is, at least until the federal government builds a permanent repository. Given the obstacles associated with establishing an interim storage site, there needs to be a contingency plan for storage of high-level nuclear waste at Indian Point.
Westchester County Board of Legislators Page 2 Mitigation. In addition to a contingency plan for onsite storage of nuclear waste, the following proactive measures are necessary to mitigate the catastrophic risks associated with demolition, excavation and other onsite decommissioning activities.
- Pipeline gas shut off during excavation work
- Detailed decommissioning timeline with sufficient description of planned activities, updated as necessary to reflect changes due to weather, supply problems, labor issues, etc.
- Public notice for high-risk excavation and demolition activities which would exacerbate risk of rupture or release, to allow risk assessment and, if advisable, extra precautions for those who are particularly vulnerable to radioactivity (e.g., children and pregnant women)
- Comprehensive baseline inventory of onsite contaminants
- Robust ongoing monitoring program using state-of-the-art technology and equipment
- Website to facilitate public access to updated decommissioning timeline and monitoring information
- Contingency plan for radioactive leak containment (e.g., shielded nuclear radiation containment chambers)
- Resident inspector to keep a close watch on site safety during excavation and demolition
- Oversight and investigation reports with detailed and specific findings Now, more than ever, the Nuclear Regulatory Commission must prioritize the health and safety of people over the interests of the nuclear industry.
Sincerely, Chairman Benjamin Boykin II Vice Chair Alfreda A. Williams Legislator, 5th District Legislator, 8th District Majority Leader MaryJane Shimsky Majority Whip Christopher A. Johnson Legislator, 12th District Legislator, 16th District Minority Leader Margaret A. Cunzio Colin D. Smith Legislator, 3rd District Legislator, 1st District
Westchester County Board of Legislators Page 3 Kitley S. Covill Vedat Gashi Legislator, 2nd District Legislator, 4th District Nancy E. Barr Catherine F. Parker Legislator, 6th District Legislator, 7th District Catherine Borgia Damon R. Maher Legislator, 9th District Legislator, 10th District Terry Clements Tyrae Woodson-Samuels Legislator, 11th District Legislator, 13th District David Tubiolo Ruth Walter Legislator, 14th District Legislator, 15th District Jose I. Alvarado Legislator, 17th District