To:  Members and Advisors to NYS Decommissioning Board

Thank you for serving on this groundbreaking oversight committee.  The eyes of the nation are watching your work as more than 90 reactors still face decommissioning across the country with four more in western NY.

Since 9-11, Hudson River Sloop Clearwater has been studying the decommissioning of nuclear power plants across the nation and around the world and has brought much fact-based information and experience to our regional elected officials, other decision-makers and community members and to our elected officials in Congress 

Four EESI Congressional briefings to educate members of Congress and their staffs, the staffs of relevant federal agencies, and the media on decommissioning issues:

Decommissioning Nuclear Power Plants: What Congress, Federal Agencies and Communities Need to Know (2018)
Decommissioning: A New Era in the U.S. Nuclear Power Industry; a Critical Need for Congressional Oversight (2019). 
What Congress Needs to Know About Pending Nuclear Waste Legislation (2020)

Toward an Evidence-Based Nuclear Energy Policy:  What Congress Needs to Know About Nuclear Decommissioning, Radioactive Waste, and Nuclear Energy as a Climate Strategy (2021)

These briefings initiated a dialog on how federal policy and regulation can reduce risks, protect the environment, and ensure public health and safety.  Working with a coalition of national, regional and local groups, we recruited nationally-known presenters, including former Nuclear Regulatory Commission (NRC) Chair Gregory Jaczko.  The briefings were attended by major media outlets.  They resulted in follow-up educational meetings with many Congressional offices, and an in-depth, five-part investigative reporting series on decommissioning, “The Nuclear Option,” by the USA Today Network; the 2019 briefing was broadcast on C-SPAN. 

Regional Forums:  Fall 2019 Regional Nuclear Decommissioning Forum (Oct. 10, 2019) featured independent scientists and advocates from five northeast reactor communities, speaking before an audience of state, county, and local elected officials, appointed task force members, and concerned citizens.

When Indian Point Closes:  A Regional Forum on Workforce Transition  (Dec., 2017)
When Indian Point Closes: A Regional Forum on Workforce Transition Part II  (Dec., 2017)

Here are Clearwater’s comments on the Licence Transfer Application including comments on Holtec’s PSDAR  

https://www.clearwater.org/wp-content/uploads/2021/03/Stanne.pdf

From the Entergy License Tranfster Docket 19-E-0730

CW Public Comment Letter re IP LTA.3.26.20..pdf
CW Background Info on Holtec LTA.3.25.20.pdf
CW comments on IP PSDAR.1.15.2020.pdf
Adm. Hering Transcript on Holtec.5.19.pdf
NRC Inspector General Report Findings.pdf

And on the Joint Proposal of 4/29/21 with two important Appendices: PROBLEMS WITH HOLTEC’S SPENT FUEL MANAGEMENT SYSTEMS AFFECTING INDIAN POINT and  PROBLEMS WITH HOLTEC’S PLANS FOR TRANSPORTING INDIAN POINT’S SPENT FUEL 

https://www.clearwater.org/wp-content/uploads/2021/04/CWR-final-JP-comments.pdf
CWR final JP comments.4.29.pdf
Comments Qyestions from Officials.pdf
210223Puglisi.transcript.pdf
210223Latimer comments from transcript.pdf
Harckham.comments.pdf
Galef comments.pdf
Cortlandt comments.pdf
Creighton comments.pdf
Town of CorlandtCreighton.pdf
PublicWatchdogs comments.pdf

We have tried to summarize many of the public comments that raise key issues,which we request the  DOB focus on, especially those relating to the Post-Shutdown Activities Report, which is Holtec’s actual plan for decommissioning Indian Point.  Attached please find the list of issues, questions, concerns, comments and suggestions that have been raised repeatedly, and which the DOB now has the responsibility to address.  In doing so, you will not only be helping to ensure the safest possible decommissioning for Indian Point, but if these questions are taken seriously and addressed thoroughly and constructively, will set a standard for others to follow.

In addition to financial concerns about Holtec’s fiscal ability, their credibility and experience, some of which is addressed in the Joint Proposal, these remain importantly unaddressed:

  • On-Site Storage, including the important question Canisters and Casks — what the waste will be stored in for dry cask storage, i.e. the use of 5/8″  thin vs. 12″ – 18′ thick-walled canisters in hardened buildings, which are employed widely in Europe and elsewhere, 
  • The value Hardened On-Site Storage (HOSS), and other nuclear waste storage issues.
  • Rushed Decommissioning:  How long should High Burnup Fuel stay if fuel pools before being moved to dry cask storage?
  • On and Offsite Monitoring to protect workers and community members
  • Emergency Response
  • Transportation issues
  • Workforce transition to ensure just transition
  • Environmental Justice issues here and at potential so called “interim” offsite storage sites
  • … and others.

We hope the DOB will use the best research available provided by highly qualified experts to answer the technical questions and will provide the transparency and opportunities for real-time public comment that have been promised.

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Many thanks,
Manna