We have until March 25, 2020 to stop one of the greatest threats our region has ever faced: the pending sale of the Indian Point nuclear plant to an unqualified, untrustworthy company called Holtec. Here’s how — and why – you need to weigh in:
In 2020 and 2021, after more than 40 years of operation, Indian Point’s nuclear reactors will shut down and enter the decommissioning phase, where they will be taken apart, and their waste is supposed to be secured. The operating license, held by Indian Point’s current owner, Entergy, is required to manage a ratepayer financed decommissioning trust fund that will pay for this decommissioning. That’s the good news, since Indian Point has built up some of the highest concentrations of radioactivity on the planet, which is also leaking into the groundwater and the Hudson River.
But there is bad news as well: Entergy has applied to the Nuclear Regulatory Commission for approval to sell the plant and transfer its licenses to an incompetent, untrustworthy company called Holtec. Not only does this risk further and worse contamination of the land and water around Indian Point, it means that if decommissioning costs more than expected, Holtec can simply declare bankruptcy, and Entergy will have no further responsibility.
You can encourage the Nuclear Regulatory Commission to deny permission for Entergy to transfer the license to Holtec via the public comment process. Public comment on the license transfer process is open for one more month, until March 25th. Information on how to comment is posted at regulations.gov.
Submitting a comment is easy and will just take a few minutes. But if the sale of Indian Point to Holtec goes through, our region will be stuck with the consequences of whatever Holtec does, or fails to do, for decades, perhaps even centuries, to come. Comment now via the Web!
Holtec is a poor choice for dismantling and remediating Indian Point and safeguarding its radioactive waste, and it’s already telegraphing it will do a bad job. Among Holtec’s many disqualifying problems:
- Holtec lacks experience in nuclear plant decommissioning.
- Holtec’s record is full of malfeasance — bribery, fraud, getting barred from doing business with entities like the TVA and the World Bank, lying to public officials, risk-taking, dangerous incompetence and contempt for public concern or input.
- Holtec’s complex subsidiary structure of siloed, undercapitalized LLCs shields it from liability and accountability. Its side businesses pose serious conflicts of interest.
- Holtec is privately held and secretive about its finances. It hasn’t demonstrated the capitalization required to complete the estimated $1.3 billion decommissioning, as opposed to walking away and sticking taxpayers with the consequences and costs. Its business model is about using the ratepayer financed decommissioning trust fund and taxpayer money to maximize its profits.
- In a premature and improper report filed with the NRC about its plans, Holtec lowballed its decommissioning cost estimate, even though there isn’t even an assessment of site conditions to base an estimate on. The company ignored the Algonquin gas pipeline passing near Indian Point’s critical components, even though that complicates decommissioning and raises risks of rupture and fire. It plans to do nothing about radioactive contamination of groundwater. It won’t remediate contaminated soil at the site any deeper than 3 feet. It stated it is considering shipping radioactive wastes by barge down the Hudson, raising a host of unacceptable risks.
Concerned? You’re not alone. Holtec has attracted opposition from public officials in New York State and across the country including New York Attorney General Letitia James, who intervened legally to challenge Indian Point license transfer to Holtec. “Putting the decommissioning of Indian Point in the hands of a company with no experience and uncertain financial resources is very risky,” she said. Elected officials who support the AG’s effort and have echoed her concerns about Holtec include U.S. Representatives Eliot Engel and Sean Patrick Maloney; State Senators David Carlucci, Peter Harckham, Shelley B. Mayer and Jen Metzger, and State Assembly Members David Buchwald and Ellen Jaffee, among others.
In addition, nine Rockland County Legislators, including Legislative Chairman Alden Wolfe, Vice Chair Aney Paul, Majority Leader Jay Hood, Deputy Majority Leader Phil Soskin and Legislators Michael Grant, Itamar Yeger, Toney Earl, Harriet Cornell, and Aron Wieder, have urged the NRC to reject the sale of the plant to Holtec and to ensure proper decommissioning and site restoration.
It’s not too late to make your own voice heard as well, and it’s vital that you do. Approval of license transfer to Holtec is still pending, and the window for the public to comment on it is open until March 25th. Sample comments and links that will help you file them with a couple of clicks are posted here[hyperlink].
This is a chance to tell the NRC loudly and clearly that we won’t accept an incompetent, unscrupulous company taking over Indian Point. The safe decommissioning of the Indian Point facility is an awesome responsibility that requires a competent, trustworthy company.
How to Submit Your Comments to the NRC
Here are ways to send your comments to the Nuclear Regulatory Commission on whether it should approve transfer of Indian Point’s licenses to Holtec. Comments are due by March 25th, 2020.
1. Automatically via eMail:
Simply click here, insert your full name and address, modify the message (optional) and press “send”.
2. Via the Federal Rulemaking Web Site:
Go to https://www.regulations.gov/comment?D=NRC-2020-0021-0002 and fill out the comment form. A sample comment is shown below. Please read the sample comment below and change or add to it as you see fit. Personalized comments have more impact, but it’s also okay to submit the sample comment as is, provided you agree with it and don’t choose to edit it further.
Address questions about using Regulations.gov to Jennifer Borges; telephone: 301-287-9127; email: Jennifer.Borges@nrc.gov.
SAMPLE COMMENT
Holtec and its subsidiaries are not qualified to hold the licenses of the Indian Point Energy Center. Given its record, area residents have no confidence in Holtec and do not accept it as the licensee. The Commission must not approve the license transfer, for the same reasons. Holtec has multiple problems, any one of which ought to disqualify it from decommissioning Indian Point. Taken together, they add up to a clear imperative to reject Holtec as the licensee.
Holtec lacks the experience needed to decommission Indian Point safely. Its entire nuclear “fleet” was acquired less than a year ago. It has never decommissioned a nuclear plant before; its first decommissioning job is Oyster Creek, which it acquired in July 2019. It is in effect learning on the job. The bulk of its experience is in spent fuel handling, where its performance has been poor.
Holtec and its subsidiaries are privately held and their finances are opaque. Their business model is based on maximally leveraging the decommissioning trust fund and taxpayer moneys for their profit. But they haven’t demonstrated sufficient capitalization to complete decommissioning, especially if decommissioning costs exceed their unreliably low estimates.
As New York Attorney General Letitia James said when she filed a petition to challenge license transfer to Holtec, “Putting the decommissioning of Indian Point in the hands of a company with no experience and uncertain financial resources is very risky.” Many elected officials in New York support the AG’s filing and share her objections to Holtec.
In its premature Post-Shutdown Activities Report (PSDAR), improperly filed with the NRC as if it were already the licensee, Holtec significantly underestimated the cost to decommission Indian Point. In fact, there is no site characterization assessing current conditions on which to base an estimate. The PSDAR ignored the Algonquin Pipeline passing near Indian Point’s critical components, even though its presence greatly complicates decommissioning and raises risks of ruptures and fires. Holtec acknowledged in the PSDAR that there was radioactive contamination of groundwater at the site, which is also leaking into the Hudson River. But it stated it planned to do nothing to remediate it, and will only monitor it. Nor does it plan to remediate contaminated soil any deeper than three feet. The PSDAR also stated Holtec is considering shipping large radioactive components by barge down the Hudson, which raises a host of additional unacceptable risks.
Holtec’s complex subsidiary structure of separate, undercapitalized LLCs shields it from liability and accountability. At the same time, its side businesses, including building small modular reactors (SMRs) and a “consolidated interim storage” (CIS) site for nuclear waste in New Mexico, pose unacceptable conflicts of interest which its compartmentalized subsidiary structure does not remedy. These side businesses create perverse incentives for Holtec — for example to ship radioactive waste from Indian Point to its own CIS facilities, or eventually to use Indian Point’s waste or even its site to benefit Holtec’s SMR business — even if such choices run counter to the public interest and public safety.
Holtec and SNC-Lavalin, the two companies behind the proposed Indian Point decommissioning contractors, are embroiled in numerous scandals and controversies that tell against their claims of high standards in ethics, compliance, financially sustainable business practices and trusted stewardship of nuclear materials. Their actual record is full of corruption, bribery, fraud, pleading guilty to and paying fines for malfeasance, getting barred from doing business with the TVA and the World Bank, and misleading and lying to officials and the public.
Holtec has demonstrated dangerous incompetence in its spent fuel handling at San Onofre Nuclear Generating Station. It put costs ahead of safety when it hired unqualified, low-skilled workers at Oyster Creek and has repeatedly exhibited a pattern of disregard for public concern or input.
Holtec is neither an honest broker nor a trustworthy partner in securing the safety and future of the region around Indian Point. 20 million people live and work within a 50-mile radius of the plant. Decommissioning it is a complex undertaking and an awesome responsibility on which the safety and future viability of our region depends. Those of us who live and work here will not passively accept an unqualified, unscrupulous company such as Holtec being put in charge of Indian Point.
It’s vital that Indian Point’s licensee be competent and trustworthy, free of the kind of serial malfeasance Holtec has committed, with a solid track record demonstrating it is well equipped to decommission Indian Point safely and responsibly. The Commission therefore has an obligation, statutory and otherwise, to clear the way for such a qualified candidate and reject Holtec as the licensee entrusted to decommission Indian Point.
3. Submitting Comments via Email Manually:
Please read the sample comment email below and change or add to it as you see fit. Personalized comments have more impact, but it’s also okay to send the sample email as is and just add your name and contact information, provided you agree with it and don’t choose to edit it further.
When the comment letter is the way you want it, you can to email it to Hearing.Docket@nrc.gov. Just complete the required fields below and send your email. Make sure to include “Docket ID NRC-2020-0021” in the subject line. You should receive an automatic email reply confirming receipt. If you don’t, contact the NRC at 301-415-1677.
Contact Information
Be sure to include the following information in your email:
- *First Name:
- *Last Name:
- *ZIP Code
Without this information, the NRC may ignore your comment. Be sure to include it in your email, as shown in the sample below.
SAMPLE COMMENT EMAIL
[To:] Hearing.Docket@nrc.gov
[Subject: ] Docket ID NRC-2020-0021 – opposing Indian Point license transfer to Holtec
[Body] To the U.S. Nuclear Regulatory Commission, Rulemakings and Adjudications Staff:
Holtec and its subsidiaries are not qualified to hold the licenses of the Indian Point Energy Center. Given its record, area residents have no confidence in Holtec and do not accept it as the licensee. The Commission must not approve the license transfer, for the same reasons. Holtec has multiple problems, any one of which ought to disqualify it from decommissioning Indian Point. Taken together, they add up to a clear imperative to reject Holtec as the licensee.
Holtec lacks the experience needed to decommission Indian Point safely. Its entire nuclear “fleet” was acquired less than a year ago. It has never decommissioned a nuclear plant before; its first decommissioning job is Oyster Creek, which it acquired in July 2019. It is in effect learning on the job. The bulk of its experience is in spent fuel handling, where its performance has been poor.
Holtec and its subsidiaries are privately held and their finances are opaque. Their business model is based on maximally leveraging the decommissioning trust fund and taxpayer moneys for their profit. But they haven’t demonstrated sufficient capitalization to complete decommissioning, especially if decommissioning costs exceed their unreliably low estimates.
As New York Attorney General Letitia James said when she filed a petition to challenge license transfer to Holtec, “Putting the decommissioning of Indian Point in the hands of a company with no experience and uncertain financial resources is very risky.” Many elected officials in New York support the AG’s filing and share her objections to Holtec.
In its premature Post-Shutdown Activities Report (PSDAR), improperly filed with the NRC as if it were already the licensee, Holtec significantly underestimated the cost to decommission Indian Point. In fact, there is no site characterization assessing current conditions on which to base an estimate. The PSDAR ignored the Algonquin Pipeline passing near Indian Point’s critical components, even though its presence greatly complicates decommissioning and raises risks of ruptures and fires. Holtec acknowledged in the PSDAR that there was radioactive contamination of groundwater at the site, which is also leaking into the Hudson River. But it stated it planned to do nothing to remediate it, and will only monitor it. Nor does it plan to remediate contaminated soil any deeper than three feet. The PSDAR also stated Holtec is considering shipping large radioactive components by barge down the Hudson, which raises a host of additional unacceptable risks.
Holtec’s complex subsidiary structure of separate, undercapitalized LLCs shields it from liability and accountability. At the same time, its side businesses, including building small modular reactors (SMRs) and a “consolidated interim storage” (CIS) site for nuclear waste in New Mexico, pose unacceptable conflicts of interest which its compartmentalized subsidiary structure does not remedy. These side businesses create perverse incentives for Holtec — for example to ship radioactive waste from Indian Point to its own CIS facilities, or eventually to use Indian Point’s waste or even its site to benefit Holtec’s SMR business — even if such choices run counter to the public interest and public safety.
Holtec and SNC-Lavalin, the two companies behind the proposed Indian Point decommissioning contractors, are embroiled in numerous scandals and controversies that tell against their claims of high standards in ethics, compliance, financially sustainable business practices and trusted stewardship of nuclear materials. Their actual record is full of corruption, bribery, fraud, pleading guilty to and paying fines for malfeasance, getting barred from doing business with the TVA and the World Bank, and misleading and lying to officials and the public.
Holtec has demonstrated dangerous incompetence in its spent fuel handling at San Onofre Nuclear Generating Station. It put costs ahead of safety when it hired unqualified, low-skilled workers at Oyster Creek and has repeatedly exhibited a pattern of disregard for public concern or input.
Holtec is neither an honest broker nor a trustworthy partner in securing the safety and future of the region around Indian Point. 20 million people live and work within a 50-mile radius of the plant. Decommissioning it is a complex undertaking and an awesome responsibility on which the safety and future viability of our region depends. Those of us who live and work here will not passively accept an unqualified, unscrupulous company such as Holtec being put in charge of Indian Point.
It’s vital that Indian Point’s licensee be competent and trustworthy, free of the kind of serial malfeasance Holtec has committed, with a solid track record demonstrating it is well equipped to decommission Indian Point safely and responsibly. The Commission therefore has an obligation, statutory and otherwise, to clear the way for such a qualified candidate and reject Holtec as the licensee entrusted to decommission Indian Point.
Sincerely,
FIRST AND LAST NAME
TOWN, STATE, ZIP CODE
3. By U.S. Mail:
Mail comments to: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Rulemakings and Adjudications Staff. Be sure to include the Docket ID NRC-2020-0021, as well as the same contact information as required for email:
- *First Name:
- *Last Name:
- *ZIP Code
