NRC-2020-0021, Comment from Kevin Cawley on Behalf of Deignan Earth and Spirit Institute and Thomas Berry Forum for Ecological Dialogue on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-20

Comment from Kevin Cawley on Behalf of Deignan Earth and Spirit Institute and Thomas Berry Forum for Ecological Dialogue on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-00

ML21215A090
Person / Time
Site:	Indian Point
Issue date:	07/31/2021
From:	Cawley K Deignan Earth and Spirit Institute, Thomas Berry Forum for Ecological Dialogue
To:	NRC/SECY
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML21215A090 (2)

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Question or Comment: DEIGNAN EARTH AND SPIRIT INSTITUTE AND THOMAS BERRY FORUM FOR ECOLOGICAL DIALOGUE AT IONA COLLEGE COMMENTS SUBMITTED JULY 30, 2021, TO THE US NUCLEAR REGULATORY COMMISSION ON HOLTECS PLANNED SHUT-DOWN ACTIVITIES REPORT (PSDAR) FOR INDIAN POINT REACTOR SITE , NY The Deignan Institute and the Berry Forum have concerns specifically with the eco-justice features of the proposal. The 2015 publication of Pope Francis concerning the care of Earth, Laudato si: On Care for Our Common Home, bring these ecojustice perspectives into sharper focus. We begin with a selection from Laudato si: It needs to be said that there is little in the way of clear awareness of problems which particularly affect the excludedIndeed, when all is said and done, they frequently remain at the bottom of the pile. This is due partly to the fact that many professionals, opinion makers, communications media and centres of power are far removed from the poor, located in affluent urban areas, with little direct contact with their problems. This lack of physical contact and encounter, encouraged at times by the disintegration of our cities, can lead to a numbing of conscience and to tendentious analyses which neglect parts of reality Today, however, we have to realize that a true ecological approach always becomes a social approach; it must integrate questions of justice in debates on the environment, so as to hear both the cry of the earth and the cry of the poor. (LS49) We believe that the operation and decommissioning of nuclear power plants, as well as transportation and storage of spent nuclear fuel disproportionately impacts poor communities - often situated in sacrifice zones for such plants and similar industries with toxic reputations. The transport routes and final destinations also tend to be clustered in or near marginalized communities. Examples are ready to hand, such as the Dine peoples near the Trinity Atomic Test Sites. We recall the language of free, prior and informed consent for those impacted. Free, Prior and Informed Consent (FPIC) is a specific right that pertains to indigenous peoples and is recognised in the United Nations Declaration on the Rights of Indigenous Peoples (2007). It allows them to give or withhold consent to a project that may affect them or their territories. These communities should not be forced to host spent fuel canisters from nearly 100 reactors across the United States. The reactors often benefit the most affluent among us. Why should the poor bear the burdens of such waste having had little benefit from their use and no voice in their final disposition? Specifically, we believe Holtecs plans for off-site transport of radioactive waste -

shipping Indian Points spent fuel to New Mexico to be stored at Holtecs interim storage facility - are unacceptably dangerous. They violate the principles of environmental justice and

they violate federal law, which prohibits interim storage before a permanent repository is sited. We ask that the NRC not permit Holtecs be the final word on how to proceed with this inherently perilous undertaking at Indian Point. This is a chance for the NRC to end its practice of routinely granting waivers and exemptions for the industry. They must finally put public health, public safety and environmental justice before industry profit.

Would you like to remain anonymous?: False Name: Kevin Cawley E-mail: kcawley1@mac.com Organization: Thomas Berry Forum for Ecological Dialogue at Iona College Address: 173 Stratton Road City: New Rochelle State: NY ZIP/Postal Code: 10804 Country: United States of America Phone: 9142604512 ContactUsCaptcha:

Form inserted: 8/1/2021 12:02:34 AM Form updated: 8/1/2021 12:02:34 AM