Reject Holtec’s unacceptable Indian Point decommissioning plan
On December 20, 2019, Holtec improperly submitted a Post-Shutdown Decommissioning Activities Report for Indian Point. This PSDAR is insufficient in all aspects, including at its very inception as it was submitted by Holtec instead of the Licensee, Entergy. As such, the NRC has made the PSDAR a supplement of the License Transfer Application, which has the silver lining of providing the public the opportunity to comment on the report as part of the license transfer process.
As we detailed in our request for a hearing, Holtec has repeatedly lied and misled government officials and in one instance has even bribed a nuclear power plant operator to get business. Holtec’s partner SNC-Lavalin has an even worse record and has recently pled guilty to fraud and been fined $280M.
The rest of Holtec’s decommissioning plan only follows its lackluster start, and only goes to illustrate Holtec’s sole goal — to maximize its own profits. PSDARs serve as the roadmap for the decommissioning process and provide both an analysis of potential environmental impacts and a cost-estimate of all activities to ensure funding is available to finish the job. The NRC should reject this barebones PSDAR for Indian Point since its cursory overview fails to fulfill its basic objectives. A few of its main flaws are:
- 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.
- 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.
- 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.
- 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.
- 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.
