ML21295A032
| ML21295A032 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/21/2021 |
| From: | Galef S State of NY, Assemblywoman |
| To: | Office of Administration |
| References | |
| 86FR37346 00026, NRC-2021-0125 | |
| Download: ML21295A032 (3) | |
Text
10/22/21, 7:07 AM blob:https://www.fdms.gov/d7bd4ea6-08aa-4156-8f02-3de9f4b36d5e SUNI Review Complete Template=ADM-013 As of: 10/22/21 7:05 AM E-RIDS=ADM-03 Received: October 21, 2021 PUBLIC SUBMISSION ADD: Richard Guzman, Mary Neely Status: Pending_Post Tracking No. kv1-dv8n-jjh5 Comment (26) Doc.
0002 Comments Due: October 22, 2021 Publication Date: Submission Type: API 7/15/2021 Citation: 86 FR 37346 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-2021-0125-0001 Holtec Decommissioning International, LLC; Indian Point Nuclear Generating, Unit Nos. 1, 2, and 3; Post-Shutdown Decommissioning Activities Report Document: NRC-2021-0125-DRAFT-0027 Comment on FR Doc # 2021-13474 Submitter Information Name: Sandy Galef Address:
Ossining, NY, 10562 Email: galefs@nyassembly.gov Phone: 914-941-1111 General Comment See attached file(s)
Attachments NRC IPEC PSDAR blob:https://www.fdms.gov/d7bd4ea6-08aa-4156-8f02-3de9f4b36d5e 1/1
THE ASSEMBLY CHAIR Real Property Taxation STATE OF NEW YORK COMMITTEES ALBANY Corporations, Authorities and Commissions Election Law Governmental Operations Health SANDRA R.GALEF Assemblywoman 95th District October 21, 2021 Submitted electronically via https://www.regulations.gov Docket ID NRC-2021-0125 Comments on the Indian Point Post Shutdown Decommissioning Activities Report (PSDAR)
The NRC must act to ensure the safe and timely decommissioning of Indian Point. The PSDAR, as written, has key deficiencies that raise concerns about Holtecs ability to perform decommissioning without significant guidance from the NRC. The central concern to be raised is the credibility of Holtec Inc. Their track record is littered with cut corners and poor decision making. All other concerns flow from a concern that Holtec is unwilling to perform a rigorous decommissioning at Indian Point.
The PSDAR does not mention the presence of natural gas and high-pressure gas pipelines that traverse Indian Point. The effect of decommissioning on the safety of the AIM/Algonquin Pipeline Expansion is unknown. The PSDAR does not grapple with the danger decommissioning poses to the pipelines. The pipelines must be shut down during all excavations in the vicinity of the pipelines and during the transportation of heavy machinery, waste, or any other activity that could endanger the structural integrity of the pipeline. A brazen and cavalier approach to pipeline safety would greatly endanger countless lives of nearby school children, residents, and Holtec employees working on site. Without mention of the pipeline in the PSDAR one is left to wonder if Holtec is prepared to execute their mission with competence.
Spent nuclear fuel storage and management is one of the most important aspects of decommissioning. The PSDAR insists that the spent nuclear fuel will be removed by the DOE beginning in 2030 and completed by 2061. There is no evidence that this timeline is reasonable.
There is no approved long-term storage location for the storage of this material. Holtec suggests use of an interim storage facility, but this will essentially foist spent nuclear fuel on a community that is opposed. This is inappropriate. There are also concerns that the infrastructure required to safely transport this waste from Indian Point to the proposed facility does not exist. Any means of transportation will entail spent nuclear fuel moving through very densely populated areas with few safeguards to prevent an adverse event. Holtec does not propose a possible alternative for the disposal of the spent nuclear fuel in either the medium or long term. This willful neglect will lead to shortsighted solutions that will endanger those who live near the plant. The practical reality is that the fuel will be housed at Indian Point until a long-term federal repository is constructed.
Holtec does not acknowledge this and is not prepared to meaningfully engage with this possibility.
ALBANY OFFICE: Room 641, Legislative Office Building, Albany, New York 12248, (518) 455-5348, FAX (518) 455-5728 DISTRICT OFFICE: 2 Church Street, Ossining, New York 10562, (914) 941-1111, FAX (914) 941-9132 E-MAIL: galefs@assembly.state.ny.us WEBSITE: www.assembly.state.ny.us
THE ASSEMBLY CHAIR Real Property Taxation STATE OF NEW YORK COMMITTEES ALBANY Corporations, Authorities and Commissions Election Law Governmental Operations Health SANDRA R.GALEF Assemblywoman 95th District Lastly, the PSDAR does not contemplate the full extent of remediation that the site requires. At present there are known leaks of radioactive material into the soil at Indian Point. If Holtec is not careful, the decommissioning of the plant risks exacerbating this environmental hazard. The excavation and use of heavy machinery at Indian Point could disturb the soil and expose workers and residents alike to radioactive material. True diligence is needed to ensure that remediation is done concurrently and in concert with decommissioning so that there are no unforeseen risks. By compartmentalizing decommissioning and remediation Holtec has created a convenient timeline but has not engaged with site-specific hazards that must be addressed.
The best way to ensure the safety of all involved is to have rigorous oversight performed by the NRC. A full-time resident inspector will help to ensure that the NRC is able to perform this oversight, but the inspector can monitor the safety of excavation work that endangers the pipelines and remediation of any leaks to ensure worker safety. The NRC must be the eyes and ears keeping watch, keeping the public aware of high-risk activities. Indian Point is a unique plant with a unique set of circumstances. Holtecs cookie cutter approach to decommissioning must not be allowed to put the public at risk.
The NRC must be the bulwark to ensure a safe decommissioning of Indian Point.
Sincerely, Sandy Galef ALBANY OFFICE: Room 641, Legislative Office Building, Albany, New York 12248, (518) 455-5348, FAX (518) 455-5728 DISTRICT OFFICE: 2 Church Street, Ossining, New York 10562, (914) 941-1111, FAX (914) 941-9132 E-MAIL: galefs@assembly.state.ny.us WEBSITE: www.assembly.state.ny.us