Entergy is asking the Public Service Commission to approve the transfer of Indian Point nuclear power plant and the associated $2 billion decommissioning trust fund to Holtec. As described in our previous comments to the Nuclear Regulatory Commission, Riverkeeper believes that Holtec is unfit to manage Indian Point and the trust funds because Holtec has no experience decommissioning nuclear power plants and is likely to cut corners to maximize its profits as shown by its long history of lies, bribes, and risk-taking. If the trust fund is inadequate, Holtec’s corporate structure makes it nearly impossible for the public to force Holtec to cover the difference, so shortfalls will likely fall on the public. This is exacerbated by Holtec’s status as a private corporation, which creates significant hurdles for the public to monitor Holtec’s finances to prevent such shortfalls.
Holtec’s plan for decommissioning shifts all the financial risk to the public, and allows it to make a significant profit regardless of whether Holtec completes the job, as detailed in its Post Shutdown Decommissioning Activities Report. Holtec brings no money to the table, and is relying solely on the decommissioning trust fund to cover all expenses — a risky proposition as shown by the recent economic uncertainty created by COVID-19. Because of its limited experience and the vagueness of its plan, the reliability of the cost-estimate is questionable. Holtec is contracting with its own subsidiaries, so nearly all spending will contribute to Holtec’s bottom line. Additionally, Holtec is asking for exemptions to use the trust funds for non-decommissioning purposes such as spent fuel management, while it plans on pocketing all Dept. of Energy reimbursements for those same activities.
Holtec has everything to gain and nothing to lose, by shifting all financial risk onto the public.
Don’t let this become reality, write to the Commission and ask them to reject the transfer to Holtec; or at the very least, secure strong financial assurances from Holtec and continue monitoring the decommissioning process to protect the public from the financial risks.
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Dear: [Decision Maker],
Sincerely,[Your Name] [Your Address] [City, State ZIP]