ML22119A011

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Comment (42) of Sierra Club, Lower Hudson Group on Holtec'S Decommissioning Plan for Indian Point
ML22119A011
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 12/31/2021
From:
Sierra Club, Lower Hudson Group
To:
Office of Administration
References
86FR37346 00042, NRC-2021 -0125
Download: ML22119A011 (2)


Text

SUNI Review Complete ADD: Richard Guzman, Mary Neely Publication Date: 7/15/2021 Template=ADM-013 Comment (42) Doc. 0002 Citation: 86 FR 37346 E-RIDS=ADM-03 lll

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_Jl_ l (lll" l l l l l IH'/2 SEPTEMBER- DECEMBER2021 PUBL ISHE D BY VOLU NTEE RS FROM THE LOWE R HUDS ON GROU P SIER RA CLUB TAK E AC TIO N!

TEL L THE NR C TH AT HO LTE C NEEDS RO BUS T OV ERS IGH T FOR IND IAN PO INT DE CO MM ISS ION ING Compiled by Gale Pisha & Marilyn Elie We gratefully acknowledge the historic and current energy, it can claim as profit. A quick and dirty decommissioning could contributions and activism of Manna Jo Greene, Environ mental endanger communities around the plant and along the shipping Director, Hudson River Sloop Clearwater, Inc.

route for the spent fuel.

On July 29, 2021 , the U.S Nuclear Regulatory Commission (NRC)

The Indian Point Safe Energy Coalition (IPSEC), including Sierra held an in-person and teleconference hearing in Tarrytown to Club, have been asking for the cleanest, safest decommissioning gather comme nts on Holtec's decommissioning plan for Indian of IP with particular attentio n to safe, just, responsible Point (IP). At the hearing, excellent comments were delivered by management of the radioactive nuclear waste, now and for about 50 participants.

generations to come. In additio n, the location of the AIM tracked gas pipeline so close to IP poses a grave commu nity danger Written comments from the public are due by Octobe r during this massive deconstruction process.

22. Please let the NRC know your concerns so that the Concerns to address in comments on Holtec's Post Shutdown decommissioning process will be safer for residents of the Decommissioning Activities Report (PSDAR)

Hudson Valley and for residents living near other aging nuclear plants which will be closed and decommissioned in the futur_e

. OUR CONCERNS IN A NUTSHELL: Holtec's Plan (PSDAR) gives Instructions on how to comme nt are at the end of this article and woefully inadeq uate or non-existent treatm ent to key safety on our website at SierralowerHudson.org. and financial issues affecting the New York Metrop olitan Area.

Background

Indian Point's owner, Entergy, sold the reactors to Holtec Cask and Canister Issues International in 2019. Holtec is a multi billion dollar international

  • 20-25 year warran ty on canisters & cask system is corpora tion that has recently entered into the decommissioning inadequate.

business. They are promising a rapid decommissioning which

  • Visual inspection of canisters is not adequate, Pressure includes sending high level radioactive waste to interim storage in monitors or relief valves are needed to prevent New Mexico. Holtec has experience with spent fuel but has never radioactive leaks and hydrogen gas explosion.

comple ted decommissioning a nuclear plant before. They have

  • Thin-walled steel canisters containing fuel rods are an unsavory business reputation. The fear is that the company inside thicker concrete casks. The casks are lined up will attemp t to do the Job quickly and cheaply, and leave more like bowling pins making them vulnerable to terrorism.

money in the taxpayer-funded decommissioning trust fund that 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

... continuedfrom front page TAKE ACT ION : IND IAN POI NT COM MIS SIO NIN G closing ctive than Autopsy IP to assess aging impacts that can inform High-Burnup Fuel is much hotter and more radioa should be allowe d to stay in the fuel decisions in other plants.

ordinary spent fuel and years or more before movin g to dry cask pool at least seven billion not three years or less that is curren tly being propo sed. Financial Risk to New Yorkers If the $2.3+

storage, up by Holtec , NY taxpay ers Decommissioning Trust Fund is used ning costs. Holtec has said they will may be left with any remai Radiation Monit oring business ion be responsible for any shortfall. Given their shady

  • There is no plan for accurate off-site radiat trusted ?

any way to detec t increa sing reputation, can they be monit oring, nor is there pressure, temperature or crack formation in the or NRC Oversight canisters. There is no way to remediate a leak on site supposed repair a dama ged cask. The NRC is an agency captured by the industry it is has histori cally been lax, often e to regulate. This explains why it

  • Perimeter monit oring of the site will not captur health and safety . NRC has already t worke rs at the expense of public problems onsite that can impac that could have severe conse quenc es y made allowance to Holtec
  • Offsite monit oring is needed, especially at the nearb Interim Storag e in New Mexic o. It is by appro ving Centra lized elementary schoo l. e could entirely possible that this so-called temporary storag repos itory be found, become permanent. Should a permanent Pipeline Risks twice, a terribl e idea. Carefu l it would mean movin g the waste
  • Holtec 's plan does not even menti on Algon quin's 42" solutio n we have at the curren t nt monit oring on site is the only high-pressure and other AIM gas pipelines adjace se the hazard of time.

to IP. Demo lition work will increa explosion risk with the spent fuel being in the blast radius under some scenarios.

These gas pipelines should be shut down during

  • The NRC needs to put people before industry profit and worst case scenarios.

plan for decommissioning.

How to comment r, given Earthquake Zones in the area should be studied furthe s:

was constr ucted. 1) Writte n comments can be sent in to NRC as follow the advances in this field since the plant ssion a) The NRC encourages electronic comment submi ued as Emergency Planning and Response needs to be contin throug h the Federal Ru lemak ing Webs ite: Federa l long as spent fuel is stored onsite . to https: //www .regul ations .gov Rulemaking Website: Go and search for Docket ID NRC-2021 -0125 .

Transportation of highly radioactive fuel rods .gov b) Address questions about Docket IDs in Regulations

  • The plan currently calls for barge transportation down to Stacy Schum ann: 301 -415-0 624, Stacy. Schum ann@ nrc.

the the Hudson River. This poses risk to river towns and gov.

Federal New York City metro polita n area. c) This docum ent is has been published in the will

  • Transportation across the count ry by road and rail Register and is available online at federa lregist er.

ods along route.

threaten safety of neigh borho Aging infrastructure along the proposed roads have not been assessed for capability to handle 120,00 0

j gov/ d/ 2021-15068 and on TWFN-7-A60 M, U.S.

govin Nuclea r fo.gov d) Mail Comments to Office of Administration, Mail Regul atory Comm Stop:

ission ,

metric tons of nuclear waste and emerg ency respon ses e-Washington , DC 20555-0001 , ATTN: Program Manag have not been planned. ment, Announcements and Editing Staff.

portio nate essional Environmental Justice Concerns about the dispro 2) Comments should also be sent to your Congr ning, transp ortatio n and storag e of spent to NYS and local elected impac t of decommissio representative as well as on comm unitie s of color and low incom e, especially nuclear fuel representatives .

consid ered.

indigenous and Latinx communities, have not been alread y suffer ed from Service Many of these same communities have 3) Comments can and should be posted on Public and could now be forced to Task Force and uranium minin g and processing, Commission docket for IP Closure t their will. The Gover nor of New to https: Udocu ments .

host storage facilities agains Decommissioning Oversight Board: Go d the NRC Mexico along with other elected officials has notifie dps.ny.gov/public/Common/ Advan ceSea rch .aspx and enter ctive waste being the case that they do not conse nt to high level radioa 21 -01188 in the case numb er field. Once you get on to their state. We need to stand in solida rity with them. Post Comm ent.

shipped page, click the tab for VITAL NUMBERS LOWER HUDSON GROUP SIERRA CLUB Local Sierra Club website: SierraLowerHudson.org Rockland Sierra Club website: RocklandSierraClub.org aLowerHudson.org and select About Us For contact info on our core activists, please visit Sierr TER RAF IRM A 2