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| | issue date = 11/18/2013 | | | issue date = 11/18/2013 |
| | title = LTR-13-0897 - Robert Rio, Esq., Associated Industries of Massachusetts Ltr. Support for Pilgrim Nuclear Power Station | | | title = LTR-13-0897 - Robert Rio, Esq., Associated Industries of Massachusetts Ltr. Support for Pilgrim Nuclear Power Station |
| | author name = Rio R A | | | author name = Rio R |
| | author affiliation = Associated Industries of Massachusetts | | | author affiliation = Associated Industries of Massachusetts |
| | addressee name = Macfarlane A M | | | addressee name = Macfarlane A |
| | addressee affiliation = NRC/Chairman | | | addressee affiliation = NRC/Chairman |
| | docket = 05000293 | | | docket = 05000293 |
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Category:Letter
MONTHYEARML24240A1692024-09-18018 September 2024 Cy 2023 Summary of Decommissioning Trust Fund Status IR 05000293/20240022024-08-21021 August 2024 NRC Inspection Report No. 05000293/2024002 PNP 2024-030, Update Report for Holtec Decommissioning International Fleet Decommissioning Quality Assurance Program Rev. 3 and Palisades Transitioning Quality Assurance Plan, Rev 02024-08-0202 August 2024 Update Report for Holtec Decommissioning International Fleet Decommissioning Quality Assurance Program Rev. 3 and Palisades Transitioning Quality Assurance Plan, Rev 0 ML24151A6482024-06-0303 June 2024 Changes in Reactor Decommissioning Branch Project Management Assignments for Some Decommissioning Facilities ML24129A1042024-05-26026 May 2024 Preapplication Readiness Assessment Plan for the Holtec Decommissioning International License Termination Plan ML24136A2382024-05-14014 May 2024 Annual Radiological Environmental Operating Report for 2023 ML24135A3212024-05-14014 May 2024 Annual Radioactive Effluent Release Report, January 1 Through December 31, 2023 IR 05000293/20240012024-05-0707 May 2024 NRC Inspection Report No. 05000293/2024001 L-24-009, HDI Annual Occupational Radiation Exposure Data Reports - 20232024-04-29029 April 2024 HDI Annual Occupational Radiation Exposure Data Reports - 2023 L-24-010, Request for Preapplication Readiness Assessment of the Draft License Termination Plan2024-04-22022 April 2024 Request for Preapplication Readiness Assessment of the Draft License Termination Plan L-24-007, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations – Holtec Decommissioning International, LLC (HDI)2024-03-29029 March 2024 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations – Holtec Decommissioning International, LLC (HDI) IR 05000293/20230032024-02-29029 February 2024 NRC Inspection Report Nos. 05000293/2023003 and 05000293/2023004 L-24-002, Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G2024-02-0202 February 2024 Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G ML23342A1182024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 ML23334A1822023-11-30030 November 2023 Biennial Report for the Defueled Safety Analysis Report Update, Technical Specification Bases Changes, 10 CFR 50.59 Evaluation Summary, and Regulatory Commitment Change Summary – November 2021 Through October 2023 L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23306A0992023-11-0202 November 2023 and Indian Point Energy Center, Notification of Changes in Schedule in Accordance with 10 CFR 50.82(a)(7) IR 05000293/20234012023-08-31031 August 2023 NRC Inspection Report No. 05000293/2023401 & 2023001 (Cover Letter Only) IR 05000293/20230022023-08-0404 August 2023 NRC Inspection Report No. 05000293/2023002 L-23-008, Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI)2023-05-23023 May 2023 Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI) ML23135A2152023-05-15015 May 2023 Annual Radioactive Effluent Release Report, January 1 Through December 31, 2022 ML23136A7792023-05-15015 May 2023 Annual Radiological Environmental Operating Report, January 1 Through December 31, 2022 L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023 HDI Annual Occupational Radiation Exposure Data Reports - 2022 L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-31031 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations ML23088A0382023-03-29029 March 2023 Stations 1, 2, & 3, Palisades Nuclear Plant, and Big Rock Point - Nuclear Onsite Property Damage Insurance ML23069A2782023-03-13013 March 2023 Request for Scoping Comments Concerning the Environmental Review of Monticello Nuclear Generating Plant, Unit 1 Subsequent License Renewal Application ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities IR 05000293/20220042023-02-15015 February 2023 NRC Inspection Report No. 05000293/2022004 ML22356A0712023-01-31031 January 2023 Issuance of Exemption for Pilgrim Nuclear Power Station ISFSI Regarding Annual Radioactive Effluent Release Report - Cover Letter ML22347A2782022-12-21021 December 2022 Independent Spent Fuel Storage Installation Security Inspection Plan Dated December 21, 2022 L-22-042, Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.152022-12-14014 December 2022 Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.15 L-22-041, Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension2022-12-0909 December 2022 Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension IR 05000293/20220032022-11-18018 November 2022 NRC Inspection Report No. 05000293/2022003 L-22-036, Decommissioning Trust Fund Agreement2022-11-0808 November 2022 Decommissioning Trust Fund Agreement ML22276A1762022-10-24024 October 2022 Decommissioning International Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22266A1922022-09-23023 September 2022 and Pilgrim Nuclear Power Station - Request to Withdraw Prior Submissions from NRC Consideration ML22272A0352022-09-22022 September 2022 S. Lynch-Benttinen Letter Regarding U.S. Citizen Intent to Sue U.S. Fish and Wildlife and NOAA Fisheries Representing the Endangered Species (Na Right Whale) Which Will Be Adversely Affected by Holtec International Potential Actions ML22269A4202022-09-22022 September 2022 Citizen Lawsuit ML22241A1122022-08-29029 August 2022 Request for Exemption from 10 CFR 72.212(a)(2), (b)(2), (b)(3), (b)(4), (B)(5)(i), (b)(11), and 72.214 for Pilgrim ISFSI Annual Radioactive Effluent Release Report IR 05000293/20220022022-08-12012 August 2022 NRC Inspection Report No. 05000293/2022002 ML22215A1772022-08-0303 August 2022 Decommissioning International (HDI) Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22221A2592022-08-0101 August 2022 LTR-22-0217-1-NMSS - Town of Duxbury Letter Opposing the Irradiated Water Release from Pilgrim (Docket No. 05000293) ML22206A1512022-08-0101 August 2022 NRC Office of Investigations Case Nos. 1-2022-002 & 1-2022-006 ML22175A1732022-07-28028 July 2022 LTR-22-0153-1 - Response Letter to D. Turco, Cape Downwinders, from A. Roberts, NRC, Regarding Holtec-Pilgrim Plans to Dump One Million Gallons of Radioactive Waste Into Cape Cod Bay ML22193A1662022-07-28028 July 2022 LTR-22-0154-1 - Heather Govern, VP, Clean Air and Water Program, Et Al., Letter Regarding Radioactive Wastewater Disposal from the Pilgrim Nuclear Power Station (Docket No. 05000293) ML22154A4882022-06-0101 June 2022 Letter from Conservation Law Foundation Regarding Irradiated Water Release from Pilgrim ML22154A1622022-05-26026 May 2022 Letter and Email from Save Our Bay/Diane Turco Regarding Irradiated Water Release from Pilgrim ML22136A2602022-05-16016 May 2022 Submittal of Annual Radiological Environmental Operating Report for January 1 Through December 31, 2021 ML22136A2572022-05-16016 May 2022 Submittal of Annual Radioactive Effluent Release Report for January 1 Through December 31, 2021 2024-09-18
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- Assoc!ared Industries ol Massachusetts B*?.>.on 11'> Floo1 Bo;,lon * .'.\A 02108 November 18,2013 Original by Email chairmanra:nrc.gov Allison M. Mcfarlane, Chairman US Nuclear Regulatory Commission Mail Stop 1604 Washington DC 205'55-0001
Dear Ms. Mcfarlane:
Unfortunately, I was not able to attend the recent briefing you had in Plymouth, Massachusetts concerning the Plymouth Nuclear Power Station. However, Associated Industries of Massachusetts (AIM) believes it is important for you to understand the importance of this station to Massachusetts.
AIM is the largest nonprofit, nonpartisan association of Massachusetts' employers.
AIM's mission is to promote the well-being of its thousands of members and their employees and the prosperity ofthe Commonwealth of Massachusetts by improving the economic climate, proactively advocating fair and equitable public policy, and providing relevant, reliable information and excellent services.
The continued operation of Pilgrim Station is vital to the Massachusetts economy for four major reasons: its positive impact on electricity prices, its importance to the diversity of our power generation fleet, its contribution to reducing total greenhouse gas emission impacts from our power plants, and its financial impact in the local economy. ELECTRICIY PRICES: According to the Federal Department of Energy Energy Information Administration (EIA) the Commonwealth currently has the highest or near the highest electricity rates in the continental United States, significantly higher than the national average and significantly higher than our competitor states-Arizona, North Carolina, etc.1 AIM members continually mention electricity and energy costs as issues they consider when expanding or locating here. Our electric rates have continued tor se even though natural gas prices have dropped considerably.
This is not good for Massachusetts.
If industrial and commercial businesses are not expanding or are leaving Massachusetts due to high costs, the impact on jobs and tax revenues will be felt in 1 See http://www eia.gov/electricity/monthly/epm_table_grapher.cfm?t=epmt_S
_ 6 _a all corners. It is not just manufacturers who are impacted -biotech and others are also impacted.
Even non-profit institutions such as hospitals and universities and even municipalities are all struggling under high electricity and energy costs. Because Plymouth Station provides reliable base load capacity, if Plymouth Station were to close the power would have to be replaced at the highest rates further causing energy costs to increase.
DIVERSITY OF OUR POWER FLEET: Currently, Massachusetts is almost 50% dependent on natural gas for our power, with some days near 60% "--a dangerously high level of dependence that has significant ramifications regarding price and supply. Despite warnings, we expect this trend to continue as greenhouse gas regulations become even more pronounced.
In fact, during a few days in January and February of last year, Massachusetts experienced huge price spikes in the cost of natural gas and electricity due to congestion on the natural gas lines. This year, electricity and gas prices during those months are expected to be significantly higher, representing the risk premium that suppliers build into their prices. Therefore, it is important that Plymouth Station, as the only nuclear power plant in Massachusetts, remain operating as it serves as an important hedge for power supplies.
GREENHOUSE GAS CONCERNS:
As you may know, Massachusetts is a signatory to the Regional Greenhouse Gas Initiative, which reduces greenhouse gases over time through an auction process. Since nuclear power produces no greenhouse gas emissions, if Plymouth Station were not operating plants which would fill the void would be required to purchase greenhouse gas allowances, further increasing the cost of these allowances to every other generator.
Therefore, the costs of meeting the Regional Greenhouse Gas Initiative carbon reduction program would be another burden to Massachusetts' businesses.
LOCAL ECONOMIC IMPACTS: Finally, Plymouth Station provides over 650 good-paying jobs and it also conducts business with more than 75 Massachusetts-based companies with an economic output of over $145 million dollars. In sum, the Plymouth Nuclear Power Station produces clean, dependable, base load power that is crucial to Massachusetts' energy portfolio.
We support the Plymouth Nuclear Power Station because it will help Massachusetts sustain businesses, lower greenhouse gases, and help provide cost-effective electricity prices. Should you have any questions please do not hesitate to contact me. Sincerely, Robert A. Rio, Esq.
Senior Vice President and Counsel Joosten, Sandy From: Sent: To:
Subject:
Attachments:
Chairman Mcfarlane:
Bob Rio <rar@aimnet.org>
Monday, November 18, 2013 1:50 PM CHAIRMAN Resource AIM letter in support of Plymouth Nuclear Station Letter to NRC concerning Plymouth Nuclear Station.pdf Attached please find a letter in support of Plymouth Nuclear Power Station. A hard copy will be sent in the mail. Please do not hesitate to contact me if there are any questions.
Robert A. Rio, Esq. Senior Vice President and Counsel Associated Industries of Massachusetts, Inc. 617.488.83081 rrio@aimnet.orgl www.aimnet.org One Beacon Street, 16th Floor, Boston, MA 02108 1