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Indian Point Safe Energy Coalition (IPSEC) Statement 

Supporting the Closure of Indian Point

IPSEC is a non-partisan coalition comprised of public interest, environmental and civic groups.  (While IPSEC works closely with elected officials - at the local, state, and federal level - elected officials are not part of the IPSEC coalition.)

1) IPSEC calls for the immediate closure and the safe and orderly decommissioning of the Indian Point nuclear power facility.

2) IPSEC calls for the immediate and permanent upgrade of security measures at the Indian Point plant. IPSEC recognizes Indian Point is vulnerable to terrorist attack, particularly the irradiated (“spent” or “used”) fuel storage buildings which house the majority of the site’s high level radioactive waste.

3) IPSEC recognizes the vulnerability of Indian Point’s current method of storing irradiated (“spent” or “used”) fuel[1] to terrorist attack. Therefore, IPSEC calls for the “hardening” of the wet and dry storage for all of Indian Point’s irradiated fuel and other radioactive waste at Indian Point to the maximum extent possible. 

BACKGROUND: Spent fuel storage facilities and casks must immediately be hardened to repel entry or penetration into building via air or ground attack. All irradiated fuel older than five years must be moved out of the wet storage (e.g. cooling pools) and into hardened dry cask storage. Stored in hardened on-site storage, the irradiated spent fuel is less vulnerable to a spent fuel fire triggered by accident, sabotage or terrorist attack. As recommended by industry experts, the remaining spent fuel assemblies in the pool must be reconfigured so that there is more space in between each assembly.  The current spacing between fuel assemblies is dangerously close which increases the likelihood of a spent fuel pool fire consuming more fuel and releasing greater amounts of radioactivity.  The dry cask storage system must involve the spacing of casks at an adequate distance from one another and the concealing of these casks through the use of berms and other protective measures.

4) IPSEC recognizes that the radiological emergency preparedness plan covering the ten-mile emergency planning zone (EPZ) around Indian Point could never be made to work. IPSEC believes current federal regulations for emergency planning are inadequate to protect the health and safety of those living and working near the Indian Point nuclear power plant in the event of a radioactive release from the plant.

BACKGROUND: The emergency plan is essentially unfixable in light of glaring flaws and obstacles including: (a) the region’s high population density; (b) the nature of the road infrastructure; (c) problems caused by spontaneous evacuation within the 10-mile EPZ; (d) shadow evacuation beyond the 10-mile EPZ; (e) parental behavior that would compromise school evacuation; (f) inability to protect the public in the event of a fast-breaking scenario; (g) outdated vulnerability assessment; (h) use of outdated technologies; (i) lack of first responder confidence in the plan; (j) difficulties in communications; and (k) the lack of recovery measures, especially for reservoir contamination. IPSEC recognizes there to be a clear distinction between an accident-triggered and terrorist triggered radiological emergency at Indian Point.

5) IPSEC recognizes the current emergency plan does not take into consideration a fast breaking scenario triggered by a terrorist attack on the Indian Point plant, in particular an attack on the irradiated (“spent”) fuel storage buildings which house the majority of the sites high level radioactive waste.

6) IPSEC believes that any radiological emergency plan to protect the public must cover a 50-mile radius, the population of which is approximately 20 million people including residents of NYC.  Government research clearly conveys that a radioactive release from Indian Point can impact the public well beyond the 10-mile emergency planning zone.

7) IPSEC recognizes the public is at risk from an accident at Indian Point triggered by mechanical failure involving age-related degradation.

8) IPSEC calls for comprehensive independent review of the safety of plant operation, consistency with plant design, feasibility of evacuation and adequacy of plant security.

9) IPSEC calls on Entergy to be held fully responsible in the event of an accident or terrorist triggered radioactive release.  Currently, Entergy’s liability is limited by the Price-Anderson Act. In addition, all homeowner insurance policies exclude nuclear accidents from coverage, leaving homeowners to bear the risk of Indian Point's operations.

BACKGROUND: Under the Price-Anderson Act, commercial nuclear operators are required to carry only $200 million in primary insurance. A second level of retrospective premiums in the event of an accident is capped at approximately $88 million per reactor, for an industry-wide total of approximately $9.4 billion.  The sizable discrepancy between the coverage available under Price-Anderson and the calculated consequences of severe nuclear incidents leaves the public unprotected and the industry unaccountable in the event of a serious accident. Furthermore, by artificially limiting the liability of nuclear operators, the Price-Anderson Act serves as a subsidy to the nuclear industry in terms of foregone insurance premiums. 

10) IPSEC calls on the NRC to reopen public access to all non-security related and non-proprietary documents including emergency plans and Updated Final Safety Analysis Reports.

11) If Indian Point is shut down tomorrow there will be adequate electricity generation and transmission capacity to power New York City, Westchester County, and New York State as a whole.

 BACKGROUND:

• Numerous programs and options already in place, as well as other programs and options that can be implemented in the short-term and long-term, will enable New York to meet the New York Independent System Operator's 18% statewide reserve margin requirements thereby ensuring adequate reliability with Indian Point permanently offline.
• In addition to the 18% requirement, the NYISO also requires that generating capacity equal to 80% of New York City’s projected peak demand be installed within the city limits (5 boroughs).  The projected peak demand for is 11,238 MW for 2004 and 11,434 MW for 2005.  Available in-city generation is 8,740 MW for 2004 and 9,690 MW for 2005.  In addition, New York City has an import capability of 5,120 MW.
• Because Indian Point is not located within NYC, its retirement would not reduce the amount of in-city generating capacity that would be available to meet this requirement.  
• With Indian Point permanently offline, NYC has access to over 13,860 MW for 2004 and 14,810 MW for 2005 of electric generating and transmission import capacity available to meet projected demands.
• This reserve margin is sufficient to meet projected demands while providing adequate system reserves to meet unexpected plant outages or higher than normal summer temperatures.  And there are a number of options for enhancing this reserve margin.
• Westchester County – which has a projected peak demand of 1700 MW for next summer – has access to about 5600 MW of power that can be imported from upstate New York through existing transmission lines.
• In the short-term, the NYISO’s 80%-of-peak-demand requirement plus the ability to import power from neighboring grids, distributed generation, existing demand response programs and new projects under construction and about to go online provides an adequate supply and reserve margin.  Also, in the short-term, the NYC metropolitan area and the state would benefit greatly from increased investments in energy efficiency and conservation programs, including a public education campaign promoting common-sense energy efficiency and conservation measures. 
• Long term options, which can help meet projected peak demands in the future, include: further implementation of energy efficiency/conservation programs and renewable power sources in the New York metropolitan area and statewide; a mid-sized natural gas-fired combined-cycle power plant at the Indian Point site; the potential for 2000 megawatts of additional clean, onsite distributed generation which will reduce the strain on the grid and displace the need for 2 large-sized power plants; and proposed transmission lines between New Jersey and upstate New York to New York City.

12) IPSEC seeks an assessment of the feasibility of replacing Indian Point’s nuclear facility with an on-site non-nuclear alternative source of power.

13) IPSEC, in advocating for Indian Point’s closure, does not in any way promote new electric generating facilities that will impose an unjust or inequitable distribution of environmental, economic, or health burdens.  IPSEC supports the principle of environmental justice and is in solidarity with other communities’ quest for environmental justice. 

BACKGROUND: Entergy is deliberately exploiting and manipulating the principles of environmental and economic justice, along with issuing misinformation regarding energy supply, in a failed attempt to create division among environmental and social justice groups and citizens in the region. CURE (Communities United for Responsible Energy) joined IPSEC due to IPSEC’s support for the prohibition of siting new power plants in already environmentally over-burdened neighborhoods and IPSEC’s support for promoting cleaner energy alternatives to Indian Point. (CURE is NYC’s only citywide coalition of community based groups fighting against the disproportionate siting of polluting power plants in low income communities and communities of color). IPSEC also supports the prohibition of large scale hydropower projects in indigenous territories.  IPSEC urges state officials to enact a power-plant siting process that prohibits the siting of new power plants in already environmentally over-burdened neighborhoods.

14) IPSEC promotes, in general, greater implementation of energy efficiency programs and renewable power sources in the New York metropolitan area and statewide.

15) IPSEC, in advocating for Indian Point’s closure, promotes a worker re-training and transition plan to mitigate impacts on Indian Point’s labor force.  Entergy Nuclear is disingenuously claiming that if Indian Point were to close, the very next day, their 1500 employees would be out of work.

BACKGROUND: IPSEC finds Entergy’s claim to be misleading for the following reasons: (1) Entergy, itself, is planning to reduce the size of the Indian Point workforce by more than 20 percent in the very near future partly through the merging of the workforces at Indian Point 2 and 3; (2) The task of decommissioning Indian Point will take from 5 to 10 years.  Decommissioning is a labor intensive endeavor that will employ hundreds of workers, and IPSEC advocates training current workers for this job; and (3) Representatives from Local 1-2, UWUA, which represents 700 workers at Indian Point, have stated publicly that they can, and are obligated to find new jobs in the region for all of their workers.

16) IPSEC recognizes that more research is needed into the correlations between routine radioactive emissions from the Indian Point nuclear power plant and the cancer rates of residents living around the plant.

BACKGROUND: IPSEC recognizes that the rates of cancers most commonly linked to radiation are significantly higher in Westchester and Rockland County than in the U.S. as a whole, according to the National Center for Health Statistics.  Therefore, IPSEC calls for independent studies to assess the health risks of the regular and routine radioactive emissions from Indian Point.

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