Secretary
U.S. Nuclear Regulatory Commission
Washington, DC
20555-0001
ATTN: Rulemaking and Adjudications Staff

D-NRC-2020-0021-0001

To whom it may concern,

My name is Henry Kelly. My wife Corinne and myself live at 6 Mancuso Drive, Ossining New York 10562-2527.
We moved to Ossining in August of 1986.
We live within the ten mile Indian Point Evacuation Zone. Especially since the 9/11 terrorist attack, when a hijacked aircraft flew by the Indian Point reactors on the way to the twin towers, we have been burdened by the constant concern for ourselves and our neighbors of a possible terrorist attack on the Indian Point site. We have also been worried about an accident at the plant leading to a radiological release. Years have passed and luckily, no attack or serious accident has occurred. The plant and the evacuation plan were, and are, part of our lives. Sadly and unfortunately, the evacuation plan is completely untenable, as anyone who lives near the plant knows. If anything happened to cause a radiological release at Indian Point, due to prevailing winds, we would find ourselves in a radioactive plume coming from the plant. When the emergency sirens finally began to work properly, each time they were tested our hearts skipped a beat. Three Mile Island, Chernobyl, and most recently Fukushima Daiichi clearly showed that design errors, human error, and natural disaster can produce deadly accidents. The yearly Westchester County Indian Point Emergency Guide and the siren tests are reminders that a serious disaster is a real, not imagined. possibility. Frankly, if one were to happen, we would consider ourselves trapped and probably helpless to avoid being irradiated. Our neighbors like us live with that background fear.
I commuted to New York City for many years. I often wondered what would happen to the economic and cultural capital of our country if an accident sent a large airborne radiological release down the Hudson River toward Manhattan. Where could people go and how to escape the consequences. What would the aftermath be like?
While there have been issues at Indian Point such as Tritium leaks, shutdowns, small fires, gas releases and equipment failures, thankfully, Entergy has prevented a catastrophe from occurring. Approximately 25 million men women and children inhabit the possible radiological impact areas of an accident. Cleanup would be a long term, painfully slow, and extremely expensive task. Exposure would create a medical nightmare that would go on for generations. Like the nuclear plant at Shoreham on Long Island that was closed, the Indian Point site was, and still is, a poor choice for a nuclear plant location. The population has increased year after year while road systems have remained inadequate to the growing population on a good day. Population immediately around the plant has increased. Each year the plant became more problematic and remained a real threat.
Finally after much public pressure and activism and education, the reactors at Indian Point are due to close. However, unfortunately, the feeling of relief instead has turned now to concern and, sadly, dread in the surrounding communities and throughout the region as Entergy is looking to offload the decommissioning of Indian Point to a limited liability corporation, Holtec Decommissioning International, LLC(HDI,LLC. Holtec is a new player in this growing lucrative nuclear decommissioning business..Alarmingly in their recent PSDAR document of December 19, 2019, attached, Holtec clearly displays that their focus is on cost issues with very little focus at all on risk, contingency and accident avoidance, or public safety. Needless to say if you read the 117 page document you come away very concerned. Any accident has the potential to damage communities from Buchanan to New York City, to New Jersey and Connecticut. Yet no mention is there of planning for avoidance or response to an accident. Glaringly absent is any statement of their concern for pubic safety and acceptance of their responsibility to plan and cost for it..
There are many documents, maps, and reports circulating about the risks of decommissioning a nuclear plant. The NRC itself in its GEIS
Section 4.3.9.2 of NUREG-586 (Supplement 1) clearly states that “decommissioning increases the risk of accidents since activity is increased, raising accident potential above normal plant operations.” When you add that to the history at the site where baffling decisions were made to allow pipelines to be laid to pump high pressure gas through and under and adjacent to the site raising danger of fire and explosion that could result in compromised nuclear waste storage, you realize that the proper focus is missing and that there is a real danger to the public.
How a limited liability corporation could even be considered to do this decommissioning work is stunning. To insure the work is done correctly you need a company that fully realizes, accepts and commits to the financial, safety, and ethical responsibility to fully protect the public during their stewardship. Responsibility for avoiding accidents and the possible financial impacts and the human costs should be the top priority for the company doing the work to help them plan and train to avoid the problem…They need to cost and plan that into their work. They should be bound to that in any contract.
Holtec in its current PSDAR cost plan has made a disturbing assumption on Page 64 in a footnote and in the text, that DOE is expected to accept nuclear material in 2030… Their costing is based on that assumption which is totally unrealistic. There is now no place for the waste to go. New Mexico does not want it..The Yucca Mountain repository project has been shut down and defunded. Any decommissioning company tasked with the Indian Point work should factor the reality of long term in situ waste storage into their cost plan. The U.S.House of Representatives has a bill, the Stranded Act of 2020 H.R.5608 which needs to be passed for communities to deal with the long term burden that stranded nuclear material will face them with. Holtec in their proposal also ignores the fact that the Indian Point site is contaminated by radiological leakages ongoing over many years. There is no mention by Entergy, Holtec,or even the NRC of any clean up of this contamination as part of decommissioning. New York State has a petition for leave to intervene that includes documents showing Tritium and Strontium 90 plumes underground. Holtec only mentions soil down to three feet around the structures at the site in its decommissioning statements.
There are also now concerns about nuclear waste storage. Cask types and their ability to safely store waste over longer periods of time and even susceptibility to issues with eventual movement are coming up…The feeling is growing that Entergy and perhaps the NRC itself are in too much of a hurry to unload this “hot potato” to whoever will do the work with not enough questions asked…There are many companies that could do the work.
Citizen and community groups and local governments across the country are dealing with issues and after effects of plant decommissioning. The San Onofre plant decommissioning being done in part by Holtec and its subsidiaries is having issues. It appears that communities are left holding the bag on stranded nuclear waste, crippling tax shortfalls, decommissioning cost overruns, and security issues. Hoped for repurposing of sites is stalled..60 years after the first nuclear plants came online there is still no place to put the wastes..Nuclear waste seems to be stuck “in situ” for decades to come.

Given all the above issues there is a real need to halt and review in depth any transfer by Entergy to any LLC, including Holtec.
Full financial responsibility should be required of any decommissioning company. Decommissioning plans must include costs for long term robust secure storage. Sufficient infrastructure as well as associated support, monitoring, security, and accident avoidance and response costs must be identified and included.
Waste will be stuck at Indian Point for decades not years. That has to be realistically faced, planned for, and costed.
Pre decommissioning radiological contamination must be cleaned up.
Risks due to pipelines, fuel storage, power outages, possible terrorist attack must be identified and planned for.
Security and response plans are needed, based on thorough risk analysis and contingency planning for all possible scenarios.
Accident avoidance, response and training should be costed.

If decommissioning is not done correctly and an accident or accidents happen, the lives and futures of millions of men ,women and children will be compromised. The center of our country’s cultural and economic life could be crippled for decades.Videos showing the Chinese city of Wuhan turned into a ghost town by a virus are a chilling reminder of what can happen. They are a reminder that avoidance of a potential radiological disaster is crucial to the decommissioning. Monetary costs are but a fraction of the whole picture. Public safety is paramount.
Assumptions and scenarios of possible problems need to be created, planned for, and mitigation/contingency plans developed and costed and trained for.
Given human fallibility is a fact, it is hard to expect an error-free decommissioning. To avoid a tragedy, whoever gets the work should be fully aware and committed to their responsibility for public safety and held fully accountable legally and financially for the decommsioning of Indian.
Point.
Entergy alone should not have the final say in such a serious and important undertaking. New York State and the communities should also have a deciding say in the selection and approval process.

Sincerely,
Henry S. Kelly.