ML20304A109

Comment from Jean Naples Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments

ML20304A109
Person / Time
Site:	Indian Point
Issue date:	10/19/2020
From:	- No Known Affiliation
To:
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML20304A109 (2)

Text

Docket, Hearing From: Riverkeeper <info@Riverkeeper.org> on behalf of Jean Naples <info@Riverkeeper.org>

Sent: Monday, October 19, 2020 11:03 PM To: CMRHanson Resource

Subject:

[External_Sender] Fully adjudicate all pending petitions on Docket Nos. 50-3, 50-247 and 50-286 Oct 19, 2020 Christopher Hanson, NRC Commissioner

Dear:

Hanson, NRC Commissioner, I am writing as a physician and public health advocate, who lives along the banks of the Hudson River in Suffern, NY, in regard to the proposed transfer of Indian Point's licenses to Holtec. At this time, I am very concerned by the fact that its past actions show a complete lack of character, competence, and integrity, as well as the necessary candor, truthfulness and willingness to abide by Nuclear Regulatory Commission regulatory requirements.

The Nuclear Regulatory Commission (the "Commission") must fully adjudicate all pending petitions regarding the proposed transfer of Indian Point Energy Center ("IPEC") prior to making a determination on the license transfer application and related exemption requests, Docket Nos. 50-3, 50-247 and 50-286.

As also discussed in the State of New York's Supplemental Comments (Accession No: ML022811A635),

approval of the proposed transfer prior to the Commission's ruling on the pending petitions to intervene--

submitted by the State, Riverkeeper, and others--would place the public at risk. It is essential that the concerns raised about Holtec's financial qualifications and character be properly assessed and mitigated if necessary.

At this time, I am writing to make the NRC aware that Holtec has continued to break the law in New Jersey by moving forward with construction without local permits. In addition, Holtec is under criminal investigation in New Jersey and responded by bring suit for damages due to the suspension of its tax breaks in relation to the criminal investigation in New Jersey, which is evidence that Holtec is financially unsound. It is very important to be aware that Holtec has deliberately violated local laws during the decommissioning of Oyster Creek.

Upon information and belief, the current criminal investigation into Holtec is for committing perjury or lying on a form to obtain tax credits from New Jersey, and fraud. Riverkeeper has also learned that Holtec is unable to pay back some of its debts. In addition, a lawsuit filed by Lacey Township makes it plain that Holtec willfully violated local laws and did not stop certain work at Oyster Creek until the municipality obtained an injunction from a court.

Due to documentation of Holtec frequent and lawless law breaking, I am significantly concerned about the potential risks to ensure full protection of our public health and our environment that are posed by the potential decision by the NRC to entrust Holtec with the closure of Indian Point Nuclear Power Plant.

Please be aware that this decision poses significant safety risks to the local communities due to Holtec's corner-cutting measures. Due to the fact that the costly process of decommissioning of nuclear power plants can last decades and involve the complex removal and disposal of radioactive materials, this process presents a significant risk to the community if not properly executed. It is also very important to realize that the action of incomplete decommissioning will leave local communities with financial and public health safety concerns.

The law provides for a number of safeguards to ensure that decommissioning is safely and completely executed including funding from decommissioning trust funds made up in part of rate payer contributions, 1

which totals over $2 billion for the three Indian Point reactors. Failure to comply with these laws may lead to significant safety and financial ramifications on the public. Further, corner cutting may impact both the safety and job security of the many IPEC employees both current and future. Giving this huge responsibility to an untrustworthy company would only put the local communities, IPEC employees, and New York State taxpayers at risk, especially in light of Holtec's proven record of cutting corners to maximize its own profits.

Therefore, the Commission must fully adjudicate all pending petitions on Docket Nos. 50-3, 50-247 and 50-286 before issuing a determination on the Indian Point license transfer application. As part of this process, I strongly urge the Commission to please examine the proposed license transfers and exception requests, giving heightened scrutiny to financial and character qualifications of Holtec, and requiring financial assurances as needed to protect the public.

Please remember that this potential decision by the NRC will reward a trust fund of monies into the Holtec corporation, but unfortunately, will leave the taxpayers with the remaining bill. This decision also poses a threat to the safety and job security of IP workers due to cost-cutting measures, At this time, I thank you for your consideration of my letter. Please know that I strongly urge the state of New York to please not allow the NRC to issue a determination on the license transfer without addressing all the potential public health and environmental problems that are posed by these critical issues. As a New York physician and public health advocate, I strongly demand that all pending petitions on this matter are fully addressed before the NRC definitely rules on any license transfer.

Sincerely, Jean Marie Naples, MD-Ph.D.

Sincerely, Jean Naples 26 Montebello Commons Dr Suffern, NY 10901-4250 jeannaples7@gmail.com 2