ML16043A032

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Comment (3) of Michael Shank Opposing Entergy Nuclear Operations Inc., Indian Point Nuclear Generating Unit Nos. 2 and 3; Draft Supplemental Environmental Impact Statement; Request for Comment
ML16043A032
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 02/03/2016
From: Shank M
- No Known Affiliation
To:
Rules, Announcements, and Directives Branch
References
80FR81377 00003, NRC-2008-0672
Download: ML16043A032 (3)


Text

Page 1 of 1 As of: 2/5/16 1:28 PM Received:

February 03, 2016 PUBLIC SUBMISSION taus: tenflng~4 ost Comments Due: March 04, 2(Submission Type: Web Docket: NRC-2008-0672 Environmental Impact Statement; Availability, etc.: Indian Point Nuclear Generating Unit Nos. 2 and 3, Buchanan, NY; License Renewal and Public Meeting Comment On: NRC-2008-0672-0029 Entergy Nuclear Operations, Inc.; Indian Point Nuclear Generating Unit Nos. 2 and 3; Draft Supplemental Environmental Impact Statement; Request for Comment Document:

NRC-2008-0672-DRAFT-0023 Comment on FR Doc # 2015-32777 016-'72 Submitter Information-..'" Name: Michael Shank General Comment"" N), See attached file(s)Attachments The NYC Security Risk That Candidates Are Not Discussing SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= A.J C. (2.)j- U.https://www, fdms.gov/fdms/getcontent?obj ectld=090000648 1 e4b6a3 &format=xml&showorig~false 0/521 02/05/2016 HUFFPOST[

NEW YOR K The NYC Security Risk That Candidates Aren't Discussing By Michael Shank. Ph.D.Americans are slowly, but surely, becoming more familiar with, and fearful of, acts of terror. "Terrorism" dominates the presidential campaign debates with few other policy topics getting such prominence.

Yet with all of the front runners' hometown familiarity with one of America's most frequent terror targets (i.e. New York City) -from Donald Trump to Hillary Clinton to Bernie Sanders -it's surprising that they don't do more, rhetorically at least, to protect the city's safety. To be fair, however, if you'd ask New Yorkers about potential threats to Manhattan, they too may not know the security risk that looms several miles up the Hudson River.It's an aging nuclear power plant called Indian Point Energy Center, just 25 miles north of New York City, and while it's eluded presidential candidates, it has moved quickly to the front of New York State's political burner lately as the company's operating licenses, which expired a while ago, are getting a strong rebuke from New York State Governor Andrew Cuomo. He doesn't want a Fukushima-style nuclear disaster happening to New Yorkers.Cuomo, to his credit, seems serious about safety, ordering a probe last month into the recent, multiple, unexpected and forced shutdowns at the plant. And while the governor is not keen to close all of New York's nuclear power plants, as he transitions the state off carbon-emitting fossil fuels, he has made it clear that he wants this particular nuclear plant shut down due to security concerns.New Yorkers, especially those in Manhattan, should take note. Tens of millions of Americans are within the reach and wake of an Indian Point nuclear disaster, which is why New York City councilmembers have come out against Indian Point and are attempting to close it. Evacuation strategies are pointless and impossible, as the roads can't handle the escaping throngs. Emergency responses (e.g. local residents are encouraged to take iodine tablets) are futile. And with the Nuclear Threat Initiative saying this month that we're only making slow progress on preventing nuclear terrorism, with cyber attacks increasing, we must take these warnings seriously, especially in our backyard.Add to the precariousness of the security situation a new Spectra gas pipeline, approved by the Federal Energy Regulatory Commission, which will cross Entergy property in proximity to the plant (which is currently storing 1500 tons of radioactive waste) -a move Members of Congress are calling into question given recent successful cyber attacks on local New York infrastructure.

And yet, despite all of that, Indian Point Energy Center continues to operate beyond its license date. The operating permits for the two plants were set to expire in 2013 and 2015 but have been extended until the Nuclear Regulatory Commission decides whether or not to renew them. If the licenses are not renewed, the plants will be shut down. Meanwhile, the Nuclear Regulatory Commission, known for its close ties to the nuclear power industry, seems to accept Entergy's word that certain safety and environmental mitigation measures aren't necessary, while withholding the data on which they base their assertions.

Unsurprisingly, local organizations like Hudson Riverkeeper couldn't disagree more with Entergy on this.This could all be easily avoided. We could keep debating the serious security concerns, as they will continue to compromise the safety of millions of Americans in the NYC area even if the licenses are renewed. Or we could nip this in the bud now, once and for all, and transition the region to something more sustainable and safe. It's totally doable.Based on a recent Synapse Energy Economics we know that the New York electric power system can be "operated reliably even in the absence of both of the Indian Point Energy Center units as of 2016 as long as 1 ) a number of anticipated electric system infrastructure improvements are completed across different parts of the New York electric power system," and as "2) anticipated generation supply increases from either new merchant plants or existing resources (currently mothballed or requiring repair)come online".So let's do this. We've got sufficient capacity to support a reliable electric system without IPEC, and the cost of replacing IPEC -a mere 1-3 percent increase in electricity costs -with new, less dangerous and more renewable energy sources will be outweighed by the health and safety benefits.

Besides, if Governor Cuomo is going to reach his 50 percent renewable energy goal0 by 2030, this is a great place to start.By exploiting large amounts of untapped energy efficiencies, maximizing surpluses and reserves, expanding renew ables and improving generation and transmission, we know we can retire the nuclear plant hovering above Manhattan on the Hudson River (something every New Yorker should be telling NRC to do before the public comment period closes). And we should do everything in our power to transition the bright minds at IPEC into the clean renewable energy sector in New York, which is growing daily. Let's keep them employed -and then some. But most importantly, let's keep this country safe. Every candidate, especially those from Westchester County, should be queuing to close IPEC before disaster strikes. The time is now. Our safety is at stake.Michael Shank, PhD, teaches sustainable development at NYU's Center for Global Affairs graduate prog~ramn.

This article was originally published on 1/29/1 6: http ://www.hu ffingtonpost.com/michael-shank/the-nyc-securitv-risk-tha b 91 15844 .html#comnments Page 1 of 1 As of: 2/5/16 1:28 PM Received:

February 03, 2016 PUBLIC SUBMISSION taus: tenflng~4 ost Comments Due: March 04, 2(Submission Type: Web Docket: NRC-2008-0672 Environmental Impact Statement; Availability, etc.: Indian Point Nuclear Generating Unit Nos. 2 and 3, Buchanan, NY; License Renewal and Public Meeting Comment On: NRC-2008-0672-0029 Entergy Nuclear Operations, Inc.; Indian Point Nuclear Generating Unit Nos. 2 and 3; Draft Supplemental Environmental Impact Statement; Request for Comment Document:

NRC-2008-0672-DRAFT-0023 Comment on FR Doc # 2015-32777 016-'72 Submitter Information-..'" Name: Michael Shank General Comment"" N), See attached file(s)Attachments The NYC Security Risk That Candidates Are Not Discussing SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= A.J C. (2.)j- U.https://www, fdms.gov/fdms/getcontent?obj ectld=090000648 1 e4b6a3 &format=xml&showorig~false 0/521 02/05/2016 HUFFPOST[

NEW YOR K The NYC Security Risk That Candidates Aren't Discussing By Michael Shank. Ph.D.Americans are slowly, but surely, becoming more familiar with, and fearful of, acts of terror. "Terrorism" dominates the presidential campaign debates with few other policy topics getting such prominence.

Yet with all of the front runners' hometown familiarity with one of America's most frequent terror targets (i.e. New York City) -from Donald Trump to Hillary Clinton to Bernie Sanders -it's surprising that they don't do more, rhetorically at least, to protect the city's safety. To be fair, however, if you'd ask New Yorkers about potential threats to Manhattan, they too may not know the security risk that looms several miles up the Hudson River.It's an aging nuclear power plant called Indian Point Energy Center, just 25 miles north of New York City, and while it's eluded presidential candidates, it has moved quickly to the front of New York State's political burner lately as the company's operating licenses, which expired a while ago, are getting a strong rebuke from New York State Governor Andrew Cuomo. He doesn't want a Fukushima-style nuclear disaster happening to New Yorkers.Cuomo, to his credit, seems serious about safety, ordering a probe last month into the recent, multiple, unexpected and forced shutdowns at the plant. And while the governor is not keen to close all of New York's nuclear power plants, as he transitions the state off carbon-emitting fossil fuels, he has made it clear that he wants this particular nuclear plant shut down due to security concerns.New Yorkers, especially those in Manhattan, should take note. Tens of millions of Americans are within the reach and wake of an Indian Point nuclear disaster, which is why New York City councilmembers have come out against Indian Point and are attempting to close it. Evacuation strategies are pointless and impossible, as the roads can't handle the escaping throngs. Emergency responses (e.g. local residents are encouraged to take iodine tablets) are futile. And with the Nuclear Threat Initiative saying this month that we're only making slow progress on preventing nuclear terrorism, with cyber attacks increasing, we must take these warnings seriously, especially in our backyard.Add to the precariousness of the security situation a new Spectra gas pipeline, approved by the Federal Energy Regulatory Commission, which will cross Entergy property in proximity to the plant (which is currently storing 1500 tons of radioactive waste) -a move Members of Congress are calling into question given recent successful cyber attacks on local New York infrastructure.

And yet, despite all of that, Indian Point Energy Center continues to operate beyond its license date. The operating permits for the two plants were set to expire in 2013 and 2015 but have been extended until the Nuclear Regulatory Commission decides whether or not to renew them. If the licenses are not renewed, the plants will be shut down. Meanwhile, the Nuclear Regulatory Commission, known for its close ties to the nuclear power industry, seems to accept Entergy's word that certain safety and environmental mitigation measures aren't necessary, while withholding the data on which they base their assertions.

Unsurprisingly, local organizations like Hudson Riverkeeper couldn't disagree more with Entergy on this.This could all be easily avoided. We could keep debating the serious security concerns, as they will continue to compromise the safety of millions of Americans in the NYC area even if the licenses are renewed. Or we could nip this in the bud now, once and for all, and transition the region to something more sustainable and safe. It's totally doable.Based on a recent Synapse Energy Economics we know that the New York electric power system can be "operated reliably even in the absence of both of the Indian Point Energy Center units as of 2016 as long as 1 ) a number of anticipated electric system infrastructure improvements are completed across different parts of the New York electric power system," and as "2) anticipated generation supply increases from either new merchant plants or existing resources (currently mothballed or requiring repair)come online".So let's do this. We've got sufficient capacity to support a reliable electric system without IPEC, and the cost of replacing IPEC -a mere 1-3 percent increase in electricity costs -with new, less dangerous and more renewable energy sources will be outweighed by the health and safety benefits.

Besides, if Governor Cuomo is going to reach his 50 percent renewable energy goal0 by 2030, this is a great place to start.By exploiting large amounts of untapped energy efficiencies, maximizing surpluses and reserves, expanding renew ables and improving generation and transmission, we know we can retire the nuclear plant hovering above Manhattan on the Hudson River (something every New Yorker should be telling NRC to do before the public comment period closes). And we should do everything in our power to transition the bright minds at IPEC into the clean renewable energy sector in New York, which is growing daily. Let's keep them employed -and then some. But most importantly, let's keep this country safe. Every candidate, especially those from Westchester County, should be queuing to close IPEC before disaster strikes. The time is now. Our safety is at stake.Michael Shank, PhD, teaches sustainable development at NYU's Center for Global Affairs graduate prog~ramn.

This article was originally published on 1/29/1 6: http ://www.hu ffingtonpost.com/michael-shank/the-nyc-securitv-risk-tha b 91 15844 .html#comnments