ML23005A197

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Comment (7) of Kraig Schultz on Behalf of Schultz Engineering on Holtec Decommissioning International, LLC, Palisades Nuclear Plant, Post-Shutdown Decommissioning Activities Report
ML23005A197
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/27/2022
From: Schultz K
Schultz Engineering
To:
Office of Administration
References
NRC-2022-0158, 87FR52598 00007
Download: ML23005A197 (1)


Text

1/4/23, 10:06 AM blob:https://www.fdms.gov/12c3ee89-545f-41bb-b50a-0b72da0e4772 SUNI Review Complete Template=ADM-013 As of: 1/4/23, 10:05 AM E-RIDS=ADM-03 Received: December 27, 2022 PUBLIC SUBMISSION ADD: Marlayna Doell, Status: Pending_Post Sarah Achten, Pam Tracking No. lc6-h7k1-ukuu Buzdygon-Menefee, Comments Due: December 27, 2022 Mary Neely Comment (7) Submission Type: API Publication Date:

8/26/2022 Docket: NRC-2022-0158 Citation: 87 FR 52598 Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report Comment On: NRC-2022-0158-0001 Holtec Decommissioning International, LLC, Palisades Nuclear Plant, Post- Shutdown Decommissioning Activities Report Document: NRC-2022-0158-DRAFT-0007 Comment on FR Doc # 2022-18387 Submitter Information Name: Kraig Schultz Address:

Grand Haven, MI, 49417 Email: kraig@schultzengineering.us Phone: 616-540-7027 General Comment Docket ID NRC-2022-0158 Pertaining to Post Shutdown Decommissioning Activities Report (PSDAR) for Palisades Nuclear Power Plant provided by Holtec Decommissioning International (HDI).

By letter dated December 23, 2020, Holtec Decommissioning International (HDI) submitted the Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report (PSDAR) (accession number ML20358A232) in accordance with 10 CFR 50.82(a)(4)(i).

1. The PSDAR lacks sufficient oversight to provide accountability for use of funds in the Decommissioning Trust Fund. The Decommissioning Trust Funds should be held by an independent third party that can hold HDI accountable to performance and budget criteria defined in the PSDAR. The money should be released only as work is completed, not given up front in a lump sum.
2. The PSDAR lacks specific details regarding the retention and testing of radiological test pieces that are inside the Reactor Pressure Vessel (RPV). These samples are critical for evaluating the brittleness of this and other RPVs. The samples must not be lost and must be tested to provide data to enhance our ability to accurately model the effects of radiation on safety critical equipment.
3. It should be noted in the PSDAR that the funds in the decommissioning trust fund are not adequate to blob:https://www.fdms.gov/12c3ee89-545f-41bb-b50a-0b72da0e4772 1/2

1/4/23, 10:06 AM blob:https://www.fdms.gov/12c3ee89-545f-41bb-b50a-0b72da0e4772 decommission the plant without delays and that the shortfall in funds was allowed to happen due to NRC requirements being set too low. This notation may provide support to help the NRC take action to update trust fund requirements so that this short fall is not repeated at other facilities.

Kraig Schultz, Resident of Grand Haven, Michigan Member of Michigan Safe Energy Future blob:https://www.fdms.gov/12c3ee89-545f-41bb-b50a-0b72da0e4772 2/2