ML22119A011
| ML22119A011 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/31/2021 |
| From: | Sierra Club, Lower Hudson Group |
| To: | Office of Administration |
| References | |
| 86FR37346 00042, NRC-2021 -0125 | |
| Download: ML22119A011 (2) | |
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l (lll" l l l l l IH'/2 SEPTEMBER-DECEMBER2021 PUBLISHED BY VOLUNTEERS FROM THE LOWER HUDSON GROUP SIERRA CLUB TAKE ACTION!
TELL THE NRC THAT HOLTEC NEEDS ROBUST OVERSIGHT FOR INDIAN POINT DECOMMISSIONING Compiled by Gale Pisha & Marilyn Elie We gratefully acknowledge the historic and current energy, contributions and activism of Manna Jo Greene, Environmental Director, Hudson River Sloop Clearwater, Inc.
On July 29, 2021, the U.S Nuclear Regulatory Commission (NRC) held an in-person and teleconference hearing in Tarrytown to gather comments on Holtec's decommissioning plan for Indian Point (IP). At the hearing, excellent comments were delivered by about 50 participants.
Written comments from the public are due by October
- 22. Please let the NRC know your concerns so that the decommissioning process will be safer for residents of the Hudson Valley and for residents living near other aging nuclear plants which will be closed and decommissioned in the futur_e.
Instructions on how to comment are at the end of this article and on our website at SierralowerHudson.org.
Background
Indian Point's owner, Entergy, sold the reactors to Holtec International in 2019. Holtec is a multi billion dollar international corporation that has recently entered into the decommissioning business. They are promising a rapid decommissioning which includes sending high level radioactive waste to interim storage in New Mexico. Holtec has experience with spent fuel but has never completed decommissioning a nuclear plant before. They have an unsavory business reputation. The fear is that the company will attempt to do the Job quickly and cheaply, and leave more money in the taxpayer-funded decommissioning trust fund that it can claim as profit. A quick and dirty decommissioning could endanger communities around the plant and along the shipping route for the spent fuel.
The Indian Point Safe Energy Coalition (IPSEC), including Sierra Club, have been asking for the cleanest, safest decommissioning of IP with particular attention to safe, just, responsible management of the radioactive nuclear waste, now and for generations to come. In addition, the location of the AIM tracked gas pipeline so close to IP poses a grave community danger during this massive deconstruction process.
Concerns to address in comments on Holtec's Post Shutdown Decommissioning Activities Report (PSDAR)
OUR CONCERNS IN A NUTSHELL: Holtec's Plan (PSDAR) gives woefully inadequate or non-existent treatment to key safety and financial issues affecting the New York Metropolitan Area.
Cask and Canister Issues 20-25 year warranty on canisters & cask system is inadequate.
Visual inspection of canisters is not adequate, Pressure monitors or relief valves are needed to prevent radioactive leaks and hydrogen gas explosion.
Thin-walled steel canisters containing fuel rods are inside thicker concrete casks. The casks are lined up like bowling pins making them vulnerable to terrorism.
Hardened Onsite Storage should be considered.
continued on next page Membership Meeting Schedule Visit SierralowerHudson.org and select Events Visit RocklandSierraClub.org All meetings via Zoom, link on websites SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Richard Guzman, Mary Neely Comment (42) Doc. 0002 Publication Date: 7/15/2021 Citation: 86 FR 37346
TAKE ACTION: INDIAN POINT COMMISSIONING... continuedfrom front page High-Burnup Fuel is much hotter and more radioactive than ordinary spent fuel and should be allowed to stay in the fuel pool at least seven years or more before moving to dry cask storage, not three years or less that is currently being proposed.
Radiation Monitoring There is no plan for accurate off-site radiation monitoring, nor is there any way to detect increasing pressure, temperature or crack formation in the canisters. There is no way to remediate a leak on site or repair a damaged cask.
Perimeter monitoring of the site will not capture problems onsite that can impact workers Offsite monitoring is needed, especially at the nearby elementary school.
Pipeline Risks Holtec's plan does not even mention Algonquin's 42" high-pressure and other AIM gas pipelines adjacent to IP. Demolition work will increase the hazard of explosion risk with the spent fuel being in the blast Autopsy IP to assess aging impacts that can inform closing decisions in other plants.
Financial Risk to New Yorkers If the $2.3+
billion Decommissioning Trust Fund is used up by Holtec, NY taxpayers may be left with any remaining costs. Holtec has said they will be responsible for any shortfall. Given their shady business reputation, can they be trusted?
NRC Oversight The NRC is an agency captured by the industry it is supposed to regulate. This explains why it has historically been lax, often at the expense of public health and safety. NRC has already made allowance to Holtec that could have severe consequences by approving Centralized Interim Storage in New Mexico. It is entirely possible that this so-called temporary storage could become permanent. Should a permanent repository be found, it would mean moving the waste twice, a terrible idea. Careful monitoring on site is the only solution we have at the current time.
radius under some scenarios.
The NRC needs to put people before industry profit and plan for These gas pipelines should be shut down during worst case scenarios.
decommissioning.
Earthquake Zones in the area should be studied further, given the advances in this field since the plant was constructed.
Emergency Planning and Response needs to be continued as long as spent fuel is stored onsite.
Transportation of highly radioactive fuel rods The plan currently calls for barge transportation down the Hudson River. This poses risk to river towns and the New York City metropolitan area.
Transportation across the country by road and rail will threaten safety of neighborhoods along route.
Aging infrastructure along the proposed roads have not been assessed for capability to handle 120,000 metric tons of nuclear waste and emergency responses have not been planned.
Environmental Justice Concerns about the disproportionate impact of decommissioning, transportation and storage of spent nuclear fuel on communities of color and low income, especially indigenous and Latinx communities, have not been considered.
Many of these same communities have already suffered from uranium mining and processing, and could now be forced to host storage facilities against their will. The Governor of New Mexico along with other elected officials has notified the NRC that they do not consent to high level radioactive waste being shipped to their state. We need to stand in solidarity with them.
How to comment
- 1) Written comments can be sent in to NRC as follows:
a) The NRC encourages electronic comment submission through the Federal Rulemaking Website: Federal Rulemaking Website: Go to https://www.regulations.gov and search for Docket ID NRC-2021 -0125.
b) Address questions about Docket IDs in Regulations.gov to Stacy Schumann: 301 -415-0624, Stacy.Schumann@nrc.
gov.
c) This document is has been published in the Federal Register and is available online at federalregister.
j gov/d/2021-15068 and on govinfo.gov.
d) Mail Comments to Office of Administration, Mail Stop:
TWFN-7-A60M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Program Manage-ment, Announcements and Editing Staff.
- 2) Comments should also be sent to your Congressional representative as well as to NYS and local elected representatives.
- 3) Comments can and should be posted on Public Service Commission docket for IP Closure Task Force and Decommissioning Oversight Board: Go to https:Udocuments.
dps.ny.gov/public/Common/AdvanceSearch.aspx and enter 21 -01188 in the case number field. Once you get on the case page, click the tab for Post Comment.
VITAL NUMBERS LOWER HUDSON GROUP SIERRA CLUB Local Sierra Club website: SierraLowerHudson.org Rockland Sierra Club website: RocklandSierraClub.org For contact info on our core activists, please visit SierraLowerHudson.org and select About Us 2
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