ML23005A197
| ML23005A197 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| 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 blob:https://www.fdms.gov/12c3ee89-545f-41bb-b50a-0b72da0e4772 1/2 PUBLIC SUBMISSION As of: 1/4/23, 10:05 AM Received: December 27, 2022 Status: Pending_Post Tracking No. lc6-h7k1-ukuu Comments Due: December 27, 2022 Submission Type: API Docket: NRC-2022-0158 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 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Marlayna Doell, Sarah Achten, Pam Buzdygon-Menefee, Mary Neely Comment (7)
Publication Date:
8/26/2022 Citation: 87 FR 52598
1/4/23, 10:06 AM blob:https://www.fdms.gov/12c3ee89-545f-41bb-b50a-0b72da0e4772 blob:https://www.fdms.gov/12c3ee89-545f-41bb-b50a-0b72da0e4772 2/2 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