NRC-2018-0237, Comment from Paul Dressler of the Concerned Citizens for Lacey Coalition, Regarding the Oyster Creek Nuclear Plant License Transfer Application
| ML19161A084 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/07/2019 |
| From: | Dressler P, Martyn R Concerned Citizens of Lacey Coalition (CCLC) |
| To: | NRC/SECY |
| SECY/RAS | |
| References | |
| NRC-2018-0237 | |
| Download: ML19161A084 (4) | |
Text
From: dressler_p@verizon.net To: Docket, Hearing; Sheehan, Neil Cc: ronmartyn41@gmail.com; cbmartyn@gmail.com; matthew.golembeski@gmail.com; onwisconsin71@gmail.com; mgalbavy1@comcast.net; senconnors@njleg.org; Ben.Giovine@mail.house.gov; dressler_p@verizon.net; jbrancifortesr@gmail.com
Subject:
[External_Sender] Re: (Docket ID NRC-2018-0237) Request on Oyster Creek Nuclear Plant License Transfer by Concerned Citizens for Lacey Coalition-----request that the NRC hold the license transfer decision in abeyance until all matters are resolved.
Date: Friday, June 07, 2019 10:47:28 PM It is our understanding the ESI must be completed before the LTA can be completed between Exelon and Holtec Intl.
Paul Dressler Concerned Citizens for Lacey Coalition Member Ron Martyn Concerned Citizens for Lacey Coalition Chairman CC: Senator Chris Connors (NJ)
Congressman Andy Kim (NJ)
Original Message-----
From: dressler_p <dressler_p@verizon.net>
To: Hearing.Docket <Hearing.Docket@nrc.gov>; neil.sheehan <neil.sheehan@nrc.gov>
Cc: ronmartyn41 <ronmartyn41@gmail.com>; cbmartyn <cbmartyn@gmail.com>; matthew.golembeski
<matthew.golembeski@gmail.com>; onwisconsin71 <onwisconsin71@gmail.com>; mgalbavy1 <mgalbavy1@comcast.net>;
senconnors <senconnors@njleg.org>; Ben.Giovine <Ben.Giovine@mail.house.gov>
Sent: Fri, Jun 7, 2019 1:53 pm
Subject:
Re: (Docket ID NRC-2018-0237) Request on Oyster Creek Nuclear Plant License Transfer by Concerned Citizens for Lacey Coalition-----request that the NRC hold the license transfer decision in abeyance until all matters are resolved.
To: NRC The investigation by a New Jersey special task force into Economic Development Grants awarded to Holtec International constitutes new information and an area of concern that should be completely resolved before the NRC makes a decision on the Oyster Creek sale and license transfer from Exelon Corp. to Holtec International. We request that the NRC hold the license transfer decision in abeyance until all matters are resolved.
Paul Dressler Concerned Citizens for Lacey Coalition Member Ron Martyn Concerned Citizens for Lacey Coalition Chairman CC: Senator Chris Connors (NJ)
Congressman Andy Kim (NJ)
Original Message-----
From: dressler_p <dressler_p@verizon.net>
To: Hearing.Docket <Hearing.Docket@nrc.gov>
Cc: dressler_p <dressler_p@verizon.net>; ronmartyn41 <ronmartyn41@gmail.com>; cbmartyn <cbmartyn@gmail.com>;
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<matthew.golembeski@gmail.com>; onwisconsin71 <onwisconsin71@gmail.com>; greg.adams32 <greg.adams32@gmail.com>
Sent: Fri, Nov 16, 2018 12:42 pm
Subject:
(Docket ID NRC-2018-0237) Comments on Oyster Creek Nuclear Plant License Transfer by Nov 19, 2018 by Concermed Citizens for Lacey Coalition Date: Nov 16, 2018 To: NRC Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Rulemakings and Adjudications Staff.
Subject:
- (Docket ID NRC-2018-0237) Comments on Oyster Creek Nuclear Plant License Transfer by Nov 19, 2018 From: The Concerned Citizens for Lacey Coalition submission of comments to the NRC regarding Request for Public Hearing on Oyster Creek Nuclear Plant License Transfer by November 19, 2018 include: Financial, Safety, Technical, Security, and Environmental Concerns.
Financial NRC officials have placed the projected cost of decommissioning Oyster Creek at around $1.4 billion. At the PSDAR meeting the end of July 2018, the decommissioning trust fund for Oyster Creek was approximately $945 million. We are seeking a full, transparent and detailed accounting audit as we surmise Holtec International does not have enough money to complete the
decommissioning. How will Holtec International spend the money and what will their plan and schedule for decommissioning be?
The Producer Price Index for final demand rose 0.6 percent in October, seasonally adjusted, the U.S. Bureau of Labor Statistics reported in October 2018. In October, the Consumer Price Index for All Urban Consumers increased 0.3 percent seasonally adjusted; rising 2.5 percent over the last 12 months, not seasonally adjusted. Has Holtec International accounted for these increases which will affect their purchasing materials, goods and services?
We are concerned about SNC-Lavalin, a Montreal, Canada based company which is expected to play a key role in the decommissioning of Oyster Creek as is Comprehensive Decommissioning International, LLC, a joint venture between HDI and SNC. In Canada, SNC has been charged with corruption, fraud and bribery relating to business dealings in Libya committed over a period of 10 years. Isnt Libya on the U.S. Terrorist List of not doing business with? Will the NRC please have a complete investigation done Looking at SNC-Lavalins management and legal issues?
The present owner, Exelon Corp has a $420 million insurance policy with an additional $400 Million available from a pool of any insurance issues with the Oyster creek Nuclear Plant. We are requesting what insurance policy coverage will Holtec International carry once the licensing is transferred to them?
We need to know more about Holtec International and why they believe they are qualified to do the work. Holtec has indicated Comprehensive Decommissioning International, LLC (CDI), formed January 2018, Camden, New Jersey and SNC-Lavalin (TSX: SNC), Montreal Canada will be doing the Decommissioning. CDI being a relatively new company would raise a lot of questions including the concerns Holtec International has about its CDI employees which was voiced by Holtec International's owner, Mr. Singh in September 2018 (see attached article link https://whyy.org/segments/protesters-call-holtec-ceos-comments-on-camden-workers-racist/ ). Mr. Singh's comments on the hired workforce has causes a multitude of Issue with the Mayor of Camden asking for apologies, etc. The above could affect their decommissioning schedules, etc. and have a financial impact on Holtec international. What are Holtec Internationals plans to rectify this?
Holtec international has put together a complex corporate structure of limited liability on the Oyster Creek deal and partnered with a Canadian firm, SNC Lavalin, which is facing corruption charges in that country. Additionally, numerous reports and articles have been published about Holtec International's track record in other global projects, as well as articles concerning standards of decommissioning components, plant management issues, etc. Should there a significant shortfall in Holtecs International decommissioning, what is their overall liability. What happens if Holtec International cannot complete the decommissioning?
In addition to the Oyster Creek sales agreement, Holtec International has signed 2 other sales agreements with US utility Entergy and they have agreed to sell the Pilgrim and Palisades nuclear power plants to Holtec International after their closures in 2019 and 2022. The three nuclear plants will be decommissioned during the same time-frame. Will Holtec have enough financials to properly fund the decommissioning of the 3 nuclear plants? Will Holtec the necessary personnel (employees) to complete these decommissions safely, properly and on schedule?
The NRC Pre-Submittal Meeting for License Transfer Application of August 15, 2018 shows the following:
Holtec International has a large and diversified customer base in the U.S. and 16 foreign countries and has no Look term debt noted in the presentation. How is this possible? We would request a complete and transparent audit of Holtec International financials as well as their as all their business partners who will be involved in this decommissioning?
Holtec is creating a wholly owned subsidiary, called Oyster Creek Environmental Protection LLC, to own the property and control the trust fund. Another wholly owned subsidiary, Holtec Decommissioning International, would hold the operating license to run the decommissioning, according to an outline Holtec presented at a meeting. Comprehensive Decommissioning International (LLC) is a limited liability company.
We as citizens in standing express concern about the complexity of the companies involved, and who ultimately would be responsible should an accident occur or the money run out before the job is done. Will you investigate and determine which company will be responsible for any and all liabilities?
Technical Holtec proposes to use its proposed new dry cask storage design in order to complete the transfer of the spent fuel within 2.5 years in comparison to the current industry standard schedule of 5 years. Has the NRC completed its review and due diligence in regard to the safety and technical performance of the new design? How can the NRC ensure the community that the process will be safe?
In regard to use of Holtecs new dry cask storage design and accelerated plans for decommissioning Oyster Creek. Holtecs timeline calls for the fuel transfer process to begin sometime next year with a 2021 completion date, and fuel removal from the site by 2034 and full license termination by 2035. What is Holtecs plan, schedule, and cost projection if the new design is not approved by the NRC? How will it ensure safety and financial impacts are not passed on to ratepayers?
Holtec has an application before the NRC for an interim spent nuclear fuel repository to which it will transfer the spent fuel casks from Oyster Creek. It has stated that its Oyster Creek decommissioning plan and schedule are based on use of that repository.
What is Holtecs plan in the case that the interim repository is not approved? What is the cost and schedule impact to Oyster Creek decommissioning and how will the ratepayers be protected from these risks.
High burnup fuel was typically sold to nuclear operators in the late 1990s and early 2000s. It is twice as irradiated and takes up to 20 years to cool before moving out of wet storage. Holtec plans indicate emptying the spent fuel pool in 2 1/2 years. Were the high burnup fuel rods used at Oyster Creek and stored in the spent fuel pool? If so, is sufficient time scheduled for cooling and transferring to dry cask storage?
Nuclear decommissioning requires high level technical expertise, culture of compliance, highest ethical and safety behaviors.
Holtecs core business is engineering and manufacturing so that nuclear decommissioning is a new line of business and a very significant responsibility. Holtec will be challenged by undertaking three major decommissioning, i.e., Oyster Creek, Palisades, Pilgrim, without a learning curve or demonstrating its capability on a single project. Furthermore, its intended partner, SNC-Lavalin, has been charged with corruption, fraud and bribery. How can Holtec ensure that it can successfully meet the technical and safety challenges ahead?
Environmental The closing of the Oyster Creek nuclear plant raises several concerns to our community not the least of which is the potential environmental impact on the residents and business community. Specifically, the Concerned Citizens for Lacey Coalition has the following concerns and comments.
Given the proposed sale to Holtec by Exelon the decommissioning of the plant is to be expedited and begin next year with a 2021 completion date, fuel removal from the site by 2034 and full license termination by 2035. While the initial timeframe allowed for the plant to lay dormant for a longer period allowing the radiation to decay to safer levels the new proposal will result in the wait time being cut in half. This raises concerns about the safety of transporting the fuel rods and increased environmental exposure to the community and state as this higher level of radioactive material is transported.
Holtec has proposed using a new dry cask storage design. However, it is our understanding, this design has not been formally approved by the NRC. Besides Holtecs assurances the NRC must complete a thorough review of their design and certified it is appropriate and, at least as environmentally safe, as prior cask storage.
Given our community location and the multitude of waterways near the plant, especially Barnegat Bay and Oyster Creek our concerns go beyond the concerns of a typical nuclear power plant. One of our communitys strongest assets, both from a residential and commercial perspective, is the use of these waterways for commercial and recreational purposes. Should the bay, creek, or other waterways be affected by the storage or transportation of the radioactive waste in would have a disastrous impact on our environment and economy.
Safety Does Holtec and its subsidiaries/subcontractors have all the required and necessary safety capabilities to perform the decommissioning and dismantling process (i.e., equipment, sub-contractor labor certifications, previous experience, standards equal to European standards, etc.)?
How will Holtec transport the nuclear waste? Will there be local infrastructure issues and maintenance costs? Permits for transport on local, county and state roads? Local and state police transfer escorts? Compensation for same and other?
Various reports mention that Holtec has extensive experience in nuclear clean-up. What detailed information can they provide to document this as to types, sites, successes and failures, and unique problems related to specific types of nuclear clean-up?
Are these canisters at the Oyster Creek plant an equivalent weight to other canisters (up to 104,000 pounds at another decommissioned site)? If so, refer to question #2. Also, if any of these canisters were to fall from a 25 above ground storage site during the transfer process, what is the likelihood of a catastrophic event? Impact on plant and citizen safety? Time for clean-up and resultant damage?
Citizens and government regulatory agencies need information on Holtecs new, dry cask proprietary design (per previous Sierra Club inquiry), and also Holtecs confirmation on the safety of taking just 2.5 years to transfer the spent fuel.
Per the Lacey Township request for a public hearinghave you responded to their concerns that as the geographical host for this decommissioning process, they are keenly interested in the specifics of the decommissioning process as it relates to health, safety, environmental and economic reasons?
Security Exelon, has stored spent rods on site since its inception. Under the new agreement between Exelon and Holtec, Holtec through its LLC, have committed to certain performance metrics. In todays global political environment where the creativity and innovation of terrorists has exceeded the average law abiding persons imagination let alone prevention techniques. Our concern is Holtec has introduced a new and innovative storage container, one made of aluminum. Our concern is what approval process did Holtec have to undergo. What were the testing metrics. What tests were performed, for how long, and under what conditions was this new product tested, where are the test results? Holtec proposes to store spent rods in a salt mine. Salt is a corrosive! Salt destroys cement and metal. The test results should show over what period of time does corrosion begin and how rapid is it. Further the spent rods being stored today are of a more powerful rod that existed several years ago.
We can appreciate the business opportunity for storing spent rods, (Holtec), stands to generate approximately
$15Billion dollars for storage fees), a significant business opportunity. Lacey has been storing spent rods for over 40 years. without receiving its due remuneration. Since Yucca is non-operational, why shouldnt Lacey benefit from
on site storage. Lacey has been doing this for over 40 years. Now is the time for Lacey to receive its fair compensation for storing spent rods over that period of time. We are concerned about out tourism industry, fishing, and quality of life. In our opinion, none of these issues have been a part of the plant decommissioning process.
Holtec is striving to have an accelerated decommissioning, we ask why? Well, the answer is obvious; Holtec wants to benefit from storing ALL spent rods. After all, $15 Billion a year is a lot of money. Acknowledging, the business of the Holtec owner, Mr. Singh, stands to make a very large profit. One only has to look at whom he has signed on as executives of the LLC. Meanwhile, Lacey Citizens are left out of the fair remuneration due them.
Exelon will have at least 20 nuclear plants, which will undergo decommissioning. We ask what are the security protocols should a terrorist attack occur. How is Homeland Security involved in plant security? What would be the role of NJ Sate Police, Ocean County Sheriff, and Lacey PD? What drills, frequency of drills and live training exercises among all agencies take place? What NRC inspections take place, their frequency, their interaction with Homeland Security, New Jersey, and Lacey agencies to insure roles and responsibilities are clearly understood.
We as concerned citizens are asking for answers. The NRC has a very important responsibility to act fairly. Our Lacey citizens are due more considerations for what it already has experienced. Holtec, as a business, is interested in making money. We dont object to that, however, we want fair consideration to be given to us, for our support of Exelon. and its Oyster Creek Plant.
Reference The formal notice is available at https://www.regulations.gov/document?D=NRC-2018-0237-0001 The NRC published a notice in the Federal Register on Friday (Oct. 19) regarding our review of the license transfer application for the Oyster Creek nuclear power plant. The notice advises the public that the window to request a hearing on the application has opened and requests will be accepted for 20 days, or until Nov. 8. It also notes the public comments on the application can be submitted for up to 30 days, or until Nov. 19.
To NRC:(Docket ID NRC-2018-0237) Comments on Oyster Creek Nuclear Plant License Transfer by Nov 19, 2018 Email comments to: Hearing.Docket@nrc.gov. If you do not receive an automatic email reply confirming receipt, then contact us at 301-415-1677.
Mail comments to: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Rulemakings and Adjudications Staff.
Repectfully, Chairman Concerned Citizens of Lacey Coalition (CCLC): Ron Martyn Executive Board Concerned Citizens of Lacey Coalition (CCLC): Matt Golembeski, Paul Dressler, Charlotte Martyn, Mike Galbavy, Russ Arlotta, Nick Spaltro, Carsten Bischoff, Stu Feldman, Greg Adams