(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
|
---|
Category:Legal-Public Comment
MONTHYEARNRC-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-202021-07-31031 July 2021 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 ML21181A3312021-06-18018 June 2021 Form Comment from Citizen Opposing the Indian Point License Transfer Application (NRC-2020-0021) - (Version 2) ML21109A3092021-04-0909 April 2021 Comment from Herschel Specter, Micro-Utilities, Inc., on the Indian Point Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) ML21075A0302021-03-0606 March 2021 Comment from Herschel Specter, Micro-Utilities, Inc., on the Indian Point Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) ML20364A0342020-12-25025 December 2020 5 Form Comments from Riverkeeper Constituents to Commissioner Hanson Regarding the Indian Point License Transfer Application (NRC-2020-0021)- Subject: Fully Adjudicate All Pending Petitions ML20338A3902020-12-0303 December 2020 Comment from Deborah Gordon-Brown Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20338A3892020-12-0303 December 2020 2 Form Comments from Riverkeeper Constituents to Commissioner Hanson Regarding the Indian Point License Transfer Application (NRC-2020-0021)- Subject: Fully Adjudicate All Pending Petitions NRC-2012-0021, 3 Form Comments from Riverkeeper Constituents to Commissioner Hanson Regarding the Indian Point License Transfer Application (NRC-2020-0021)- Subject: Fully Adjudicate All Pending Petitions2020-11-16016 November 2020 3 Form Comments from Riverkeeper Constituents to Commissioner Hanson Regarding the Indian Point License Transfer Application (NRC-2020-0021)- Subject: Fully Adjudicate All Pending Petitions ML20322A1452020-11-0505 November 2020 Comment from Eileen Bartley Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments.Pdf ML20322A1442020-11-0505 November 2020 Comment from Freya Goldstein Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments.Pdf ML20304A0912020-10-28028 October 2020 Comment from Beverly Harris Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0692020-10-26026 October 2020 Comment from Margaret Sikora Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1002020-10-25025 October 2020 Comment from Eileen Leonard Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0672020-10-23023 October 2020 Comment from Linda Brunner Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1132020-10-23023 October 2020 Comment from Jude Jussim Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1122020-10-23023 October 2020 Comment from John Sullivan Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1102020-10-23023 October 2020 Comment from Jeff Wanshel Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0972020-10-23023 October 2020 Comment from Deborah Brown Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0682020-10-22022 October 2020 Comment from Louise Golub Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0702020-10-22022 October 2020 Comment from Marie Inserra Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0712020-10-21021 October 2020 Comment from Mary Mallonee Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0802020-10-20020 October 2020 Comment from Susan Schwarz Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1152020-10-20020 October 2020 Comment from Kate D Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1112020-10-20020 October 2020 Comment from Joan Schildwachter Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0732020-10-20020 October 2020 Comment from Nancy Houghton Brown Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1162020-10-20020 October 2020 Comment from Kevin Cawley Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1052020-10-20020 October 2020 Comment from Gale Pisha Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0992020-10-20020 October 2020 Comment from M. Doretta Cornell Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0942020-10-20020 October 2020 Comment from Carol Milano Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0822020-10-20020 October 2020 Comment from Wendy Alberg Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0812020-10-20020 October 2020 Comment from Terry Meyers Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1142020-10-20020 October 2020 Comment from K. Muller Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0782020-10-20020 October 2020 Comment from Stephen Mantor Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1042020-10-20020 October 2020 Comment from Francis Breen Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0962020-10-20020 October 2020 Comment from Courtney Nandagiri Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0902020-10-20020 October 2020 Comment from Barbara Warren Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20309A8532020-10-19019 October 2020 329 Form Comments from Riverkeeper Constituents to Commissioner Hanson Regarding the Indian Point License Transfer Application (NRC-2020-0021)- Subject: Fully Adjudicate All Pending Petitions ML20304A0872020-10-19019 October 2020 Comment from Andrew Stein Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20308A7662020-10-19019 October 2020 Comment from Margaret Teahan Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments.Pdf ML20304A1032020-10-19019 October 2020 Comment from Frances Jacobson Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0892020-10-19019 October 2020 Comment from Barbara Lalicki Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0852020-10-19019 October 2020 Comment from Allan Goldhammer Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0982020-10-19019 October 2020 Comment from Deidre Moderacki Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1022020-10-19019 October 2020 Comment from Elsa Leviseur Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20308A7672020-10-19019 October 2020 Comment from Beverly Simone Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments.Pdf ML20304A0932020-10-19019 October 2020 Comment from Carol Greenstreet Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A0882020-10-19019 October 2020 Comment from Andy Lukas Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1012020-10-19019 October 2020 Comment from Elizabeth Lynch Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20304A1082020-10-19019 October 2020 Comment from Jean Mcavoy Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments ML20308A7652020-10-19019 October 2020 Comment from Briana Rose Re Indian Point Consideration of Approval of Transfer of Licenses & Conforming Amendments.Pdf 2021-07-31
[Table view] |
Text
From: Riverkeeper on behalf of Charles Zekus To: Docket, Hearing
Subject:
[External_Sender] Docket ID NRC-2020-0021 - Reject Holtec"s PSDAR Date: Friday, February 14, 2020 7:05:00 AM Feb 14, 2020 U.S. Nuclear Regulatory Commission, Rulemakings and Adjudications Staff
Dear:
Rulemakings and Adjudications Staff, I believe corners will be cut in order to save money thus making safety an afterthought. The NRC should reject Holtec's PSDAR for Indian Point since a cursory overview shows that the Report fails to fulfill its basic objectives. A few of its main flaws are:
- 1. A full site characterization has not been completed, which immediately casts a doubt on the entire report. The site characterization provides the foundational information about the site's current situation, including the extent of any contamination, needed to determine what needs to be done to decommission the site. It is highly doubtful that Holtec can accurately gauge the cost of its activities when it does not know what needs to be done.
- 2. The PSDAR does not even mention the Algonquin Pipeline, a giant high-pressured gas pipeline only 105 feet from critical safety infrastructure at the Indian Point nuclear plant and next to two major earthquake fault lines. Without properly considering the pipeline, Holtec cannot begin to take the necessary precautions to minimize the risk of potential pipeline explosions during the decommissioning process.
- 3. Similarly, the activities that are included within the PSDAR are vague to the point of meaninglessness. For example, the Report mentions the possibility that large components will be removed by barge and then loaded on rail. However, there is no discussion of possible routes, when barging would be needed, safety precautions to prevent the release of radioactive materials or accidents during the barging process, or the environmental impacts of barging. The lack of information makes it impossible to figure out what Holtec intends, and as such, it is unfathomable that accurate safety considerations and cost estimate was provided for this option.
- 4. Holtec's minimal effort is further highlighted by its method of choice to address the known radioactive groundwater contamination on-site, monitored natural attenuation -- essentially doing nothing.
Doing nothing about radioactive groundwater could lead to it flowing into the Hudson. To cut costs, Holtec also only proposes removing above ground structures to a depth of 3 feet and proposes abandoning the circulating water intake structures and discharge structure in place as one option. Simply leaving all the radioactive contamination and structures in place, Holtec is not proposing to fully restore the site for future uses.
- 5. Finally, the PSDAR cannot be clearer in showing Holtec's true intentions of draining the decommissioning trust fund. Though Indian Point Units 2 and 3 are functionally similar other than the size of their decommissioning fund, the PSDAR projects that decommissioning Unit 3 will cost almost $200 million more. The PSDAR also notes that Holtec anticipates that it will get exemptions to use the decommissioning fund for non-decommissioning purposes, such as spent fuel management and site restoration. This not only diverts funds away from its intended purpose, but also allows Holtec to pocket any reimbursement for spent fuel management it recovers later from the Department of Energy. In conjunction to draining the funds, Holtec limits its own risk if funding runs out through the use of limited liability subsidiaries with no assets, which would make it nearly impossible to collect shortfalls from Holtec.
Therefore, as outlined in the PSDAR, Holtec has everything to gain and nothing to lose, by shifting all risk onto the public.
Don't let this plan become reality. I urge you to reject this unacceptable PSDAR.
Sincerely, Charles Zekus 151 Depeyster St Sleepy Hollow, NY 10591-2442 zzzcz@aol.com