ML23005A203
| ML23005A203 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/27/2022 |
| From: | Council on Intelligent Energy & Conservation Policy (CIECP) |
| To: | Office of Administration |
| References | |
| NRC-2022-0158, 87FR52598 00011 | |
| Download: ML23005A203 (1) | |
Text
1/4/23, 3:01 PM blob:https://www.fdms.gov/5ab2ecca-0fe4-4f1f-bfe5-4045293cb186 blob:https://www.fdms.gov/5ab2ecca-0fe4-4f1f-bfe5-4045293cb186 1/2 PUBLIC SUBMISSION As of: 1/4/23, 3:00 PM Received: December 27, 2022 Status: Pending_Post Tracking No. lc7-1pit-zv35 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-0011 Comment on FR Doc # 2022-18387 Submitter Information Email:Lee2CouncilEnergy@gmail.com Organization:Council on Intelligent Energy & Conservation Policy General Comment The full Comments of The Council on Intelligent Energy & Conservation Policy (CIECP) and Promoting Health and Sustainable Energy (PHASE) are attached.
Our preliminary statement notes:
The Council on Intelligent Energy & Conservation Policy (CIECP) and Promoting Health and Sustainable Energy (PHASE) aver that the Post-Shutdown Decommissioning Activities Report (PSDAR) including a Site-Specific Decommissioning Cost Estimate (DCE), submitted by Holtec Decommissioning International (Holtec or HDI) for the Palisades Nuclear Plant (Palisades) in December 2020 is superficial and deficient. We strongly urge the Nuclear Regulatory Commission (NRC) to:
(1) Maintain a resident inspector at Palisades throughout decommissioning and major site remediation operations. A resident inspector is imperative given (a) the vital need to ensure protection of Lake Michigan; (b) Holtecs track record and minimal experience in decommissioning a nuclear reactor site; and (c) Holtecs rapidly growing nuclear portfolio of activity expansion, including its fleet approach, in which the company seeks to rapidly decommission multiple reactor sites at or about the same time - a plan which virtually guarantees rushing and the cutting of corners.
(2) Provide detailed inspection reports which comprehensively identify challenges and problems which occur, even where regulatory violations are not found. These should be published at least quarterly and drafted in a manner which would reasonably be expected to be understood by laypersons. Such reporting is needed to comply with the NRCs recently enunciated objectives to improve transparency and more fully engage with public stakeholders. Such reporting is crucial given the need to inform decommissioning and site cleanup work at other nuclear reactor sites, including but not limited to those conducted by Holtec and its large complex of limited liability companies.
SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Marlayna Doell, Sarah Achten, Pam Buzdygon-Menefee, Mary Neely Comment (11)
Publication Date:
8/26/2022 Citation: 87 FR 52598
1/4/23, 3:01 PM blob:https://www.fdms.gov/5ab2ecca-0fe4-4f1f-bfe5-4045293cb186 blob:https://www.fdms.gov/5ab2ecca-0fe4-4f1f-bfe5-4045293cb186 2/2 (3) Require the licensee to apprise the public with reasonable advance notice of major planned activities at the site, particularly those which are reasonably likely to involve potential release of radioactivity or other contaminants. Such notice is particularly important for the protection of women, pregnant mothers, adolescents, children (especially girls), babies in utero, and other vulnerable individuals in the community for which current standards and the roentgen equivalent man (rem man) framework is grossly inadequate.
(4) Maintain and retain a detailed mapping of areas at the site where significant and/or greater amounts of radioactivity and/or hazardous chemicals are found, with - where possible - a cross-checking of those locations with legacy and/or recent activities at the facility. This is important to inform operations at other nuclear sites, both those which are still running and those which are being decommissioned.
(5) Hold a series of transcribed virtual public meetings - at least two a year - during the Palisades decommissioning process, and ensure such meetings enable public stakeholders to ask questions and get their questions answered, to the best of the NRCs ability, during such meetings. These meetings will facilitate the NRCs enunciated objective of transparency and better enable engagement with public stakeholders. Such meetings would also help inform stakeholders in the vicinity of other decommissioning nuclear sites.
(6) Require that Holtec preserve major safety-related structures, equipment and components of the site, so these may be available for harvesting and evaluation by the national laboratories, EPRI and other investigators to inform maintenance and oversight of old reactors applying for extreme license extensions.
Attachments Comments CIECP PHASE re PSDAR for Palisades Docket NRC 2022 0158
1 December 27, 2022 Re: Docket No. NRC-2022-0158 Holtec Decommissioning International, LLC December 2020 Post-Shutdown Decommissioning Activities Report (PSDAR) for the Palisades Nuclear Plant (Palisades PSDAR (nrc.gov))
Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff Via email to:
Hearingdocket@nrc.gov
Dear Nuclear Regulatory Commission:
The Council on Intelligent Energy & Conservation Policy (CIECP) and Promoting Health and Sustainable Energy (PHASE) aver that the Post-Shutdown Decommissioning Activities Report (PSDAR) including a Site-Specific Decommissioning Cost Estimate (DCE), submitted by Holtec Decommissioning International (Holtec or HDI) for the Palisades Nuclear Plant (Palisades) in December 2020 is superficial and deficient. We strongly urge the Nuclear Regulatory Commission (NRC) to:
(1) Maintain a resident inspector at Palisades throughout decommissioning and major site remediation operations. A resident inspector is imperative given (a) the vital need to ensure protection of Lake Michigan; (b) Holtecs track record and minimal experience in decommissioning a nuclear reactor site; and (c) Holtecs rapidly growing nuclear portfolio of activity expansion, including its fleet approach, in which the company seeks to rapidly decommission multiple reactor sites at or about the same time - a plan which virtually guarantees rushing and the cutting of corners.
(2) Provide detailed inspection reports which comprehensively identify challenges and problems which occur, even where regulatory violations are not found. These should be published at least quarterly and drafted in a manner which would reasonably be expected to be understood by laypersons. Such reporting is needed to comply with the NRCs recently enunciated objectives to improve transparency and more fully engage with public stakeholders. Such reporting is crucial given the need to inform decommissioning and site cleanup work at other nuclear reactor sites, including but not limited to those conducted by Holtec and its large complex of limited liability companies.
(3) Require the licensee to apprise the public with reasonable advance notice of major planned activities at the site, particularly those which are reasonably likely to involve potential release of radioactivity or other contaminants. Such notice is particularly important for the protection of women, pregnant mothers, adolescents, children (especially girls), babies in utero, and other vulnerable individuals in the community for which current standards and the roentgen equivalent man (rem man) framework is grossly inadequate.
2 (4) Maintain and retain a detailed mapping of areas at the site where significant and/or greater amounts of radioactivity and/or hazardous chemicals are found, with - where possible - a cross-checking of those locations with legacy and/or recent activities at the facility. This is important to inform operations at other nuclear sites, both those which are still running and those which are being decommissioned.
(5) Hold a series of transcribed virtual public meetings - at least two a year - during the Palisades decommissioning process, and ensure such meetings enable public stakeholders to ask questions and get their questions answered, to the best of the NRCs ability, during such meetings. These meetings will facilitate the NRCs enunciated objective of transparency and better enable engagement with public stakeholders. Such meetings would also help inform stakeholders in the vicinity of other decommissioning nuclear sites.
(6) Require that Holtec preserve major safety-related structures, equipment and components of the site, so these may be available for harvesting and evaluation by the national laboratories, EPRI and other investigators to inform maintenance and oversight of old reactors applying for extreme license extensions.
=
Background===
The Palisades Nuclear Plant (Palisades), a single unit pressurized water reactor (PWR) in Covert, Township, Michigan, began operation in 1971 and shut down on May 20, 2022, which was 11 days earlier than its then licensee, Entergy, had planned due to the failure of a reactor control rod drive seal.
Along with the shut nuclear reactor, the site hosts an Independent Spent Fuel Storage Installation (ISFSI), along the eastern shore of Lake Michigan, a little over 4 miles south of South Haven, Michigan.
On December 23, 2020, Entergy on behalf of itself and Holtec submitted a License Transfer Application (LTA) to the NRC requesting approval for the transfer of the license for Palisades and its ISFSI, as well as the Big Rock Point ISFSI to Holtec. The PSDAR describes the decommissioning plan to be implemented following NRC approval of the requested license transfers and the sale from Entergy to Holtec. Upon NRC approval of the requested license transfers and transaction closing, Holtec plans to rename Entergy Nuclear Palisades Holtec Palisades, LLC.
The schedule plan postulated by Holtec assumes that spent fuel and Greater Than Class C (GTCC) waste are removed from the site by 2040 and NRC license termination occurs in 2041.
(PSDAR, p 3)
COMMENTS POINT 1: The Unique Operational History of Palisades Needs Better Consideration Reactors have unique operational histories and the NRC has documented over the years how incidents which have occurred at reactor sites, many in the early decades of operation, have gone unreported. The NRC has also acknowledged that it does not require post-shutdown retention of much documentation regarding operational history (incidents, events, spills, etc) or
3 the specifics of all components, equipment and systems of reactor sites (including those that are buried) over the decades. Thus it is speculation on the part of Holtec to assume the condition of the site. It is further reasonable to anticipate unpleasant surprises based on Palisades troubled recorded history, which has involved failures and problems related to control rod drive mechanism seals, leakages, reactor pressure vessel embrittlement, electrical system breaker faults, and reactor cooling system malfunctions. A report published by the Union of Concerned Scientists in 2013, found that Palisades had 3 near-misses over the 3-year period covered by the report. (Lochbaum, 2013)
Holtec has made public statements - including at a December 19, 2022 public meeting in Michigan - attesting that it has already commenced decommissioning work, but the specifics of what has been done to date have not been communicated to the public.
Astonishingly, in its PSDAR, Holtec fails to evaluate the conditions and infrastructure highly specific to the Palisades site.
COMMENTS POINT 2: The Cost Estimate is Reverse Engineered and the PSDAR Fails to Account for Specific Issues and Situations Pertinent to Palisades, the State of Michigan, and the Region The PSDAR nakedly appears to be a generic document created by Holtec with the overall cost estimate reverse engineered to fit the sum which is hoped to be available in the decommissioning fund with investment growth.
Holtecs flippant approach is also evident in its failure to analyze environmental impacts based on its summarily stated, not explicated conclusion that environmental impacts associated with decommissioning activities are less than and bounded by previously issued environmental impact statements.
The PSDAR is particularly deficient in its failure to consider low-probability, high consequence events such as extreme weather, natural disasters, and malicious attack or sabotage. Such events are essential to take into consideration in cost and technical capability calculations, especially where the high consequence may be truly catastrophic.
Not unique to the site, but nevertheless quite relevant to its decommissioning, cleanup and potential hazard risks, are the increasingly frequent and severe extreme weather events wrought by climate change. Derechos and tornados, for instance, have hit Michigan and the wider region in which Palisades sits in recent years. (See, e.g., CBS, 2020; Hendson, 2020; NASA, 2022; Samenow, 2021) Past records can no longer be relied upon to predict the course, duration, or severity of major weather events.
Changing climate conditions have also demonstrated that the geographic region is quite susceptible to major flooding, widespread prolonged power outages, and a wide array of severe weather-caused transportation and other infrastructure problems. To assume decommissioning and cleanup work, much less any nuclear waste transport regime, will not be impacted by the conditions of climate change is not reasonable. While the PSDAR acknowledges that problems may arise and there may be unanticipated events, it does not engage in any analysis whatsoever of how or the degree to which even quite probable such events may impact proposed work or the estimated costs thereof.
4 It should also be noted that severe natural events affecting another part of the state can be opportunistically exploited by malevolent actors seeking to inflict damage upon Palisades or create civic unrest. Michigan, unfortunately, has demonstrated that domestic terrorist plots which may have been deemed not credible in previous decades, must now be considered plausible in the current and future decades. (See, e.g., Smith, 2022; Flesher, 2022; Nessel, 2021)
The many events which have unfolded in the early decades of our current century illustrate the need to incorporate significant levels of uncertainty and unpredictability into calculations. The cascading impacts of the pandemic and Russias war on Ukraine, especially significant supply chain issues, further illustrate the point.
Holtecs cost estimates are based on outdated assumptions and give no serious consideration to the possibility of a major accident. The potential for an accident (radiological or other) during decommissioning is not inconsequential due to extensive activity that does not occur during normal operation of the active plant.
COMMENTS POINT 3: Assumptions Relating to Rapid Decommissioning and Site Restoration Removal are Unfounded Holtecs schedule assumes that all of its decommissioning and site restoration activities, as well as all of the spent fuel and Greater Than Class C (GTCC) radioactive waste will be removed from the site by 2040 and that the company will be relieved from the obligations under its NRC license by 2041. There is no reasonable basis for such assumptions.
To begin with, the large national project of the decommissioning of its aging first generation nuclear power plants is in its early phase. Few sites have been fully decommissioned and released for unrestricted use. Holtecs plan for site restoration anticipates demolition with above-ground structures removed to a nominal depth of three (3) feet below the surrounding grade level and anticipates the volume of 1.13 million cubic feet of low-level radioactive waste (Class A, B, and C LLRW) will be removed. (PSDAR, p 12 & 33) This is not site restoration. At best, it can be characterized as the relocation of contaminants most readily removed (e.g., down a yard) which will invariably leave highly hazardous material situated at a greater depth. A site left in such condition may be compliant with NRC regulations, but it in no way accurately supports a claim that the site will be left clean or safe for unrestricted use.
Decommissioning can take decades and findings of unexpected contamination have challenged sites. For example, the facility license for Zion, which was permanently shut down in early 1998, was transferred from Exelon to ZionSolutions for the express purpose of expediting the decommissioning of the site in 2010. However, radiological status surveys and sampling turned up unexpected findings of hot particles, now being referred to by the NRC as discrete radioactive particles (DPRs). Based on their radionuclide profiles, ZionSolutions expressed the opinion that most of the DPRs found in the site soil were from reactor vessel internals segmentation, with additional particles originating from fuel fragments, internal containment concrete, or welding rod residue. For 8 sample particles, ZionSolutions listed the postulated origin and hypothetical radionuclide mix as: barium (Ba-133), cobalt (Co-60), europium (Eu-152
& Eu-154), and plutionium (Pu-238 & Pu-239/240) from internal containment concrete; americium (Am-241), cesium (Cs-137), cobalt (Co-60), curium (Cm-244), europium (Eu-154 &
Eu-155), and plutonium (Pu-238 & Pu-239/240) from fuel fragments; and radium (Ra-228),
thorium (Th-228, Th-230 & Th-232), and uranium (U-234 & U-238) from welding rod residue.
5 (ZionSolutions, 2022, at p 4) ZionSolutions postulated that potential radionuclide releases from decommissioning activity would have occurred from 2012 through 2017 and in winter-spring 2018. ZionSolutions also offered the observation that the size of some particles (e.g., from activated concrete) could change due to weathering and other environmental influences, thereby affecting the potential dose to a future site occupant. The most likely reason for why DPRs or other materials had not been identified during licensee surveys, ZionSolutions explained, was that surveys were not designed to detect such particles. However during active decommissioning, 255 particles were identified and remediated and another 25 particles were identified and remediated during FSS {final status Survey} or RAs, for a total of 280 particles discovered by ZionSolutions using the standard instrumentation and survey methodologies in use at the time. (ZionSolutions, 2022 at p 10)
Problems have also arisen at sites where Holtec is involved.
On August 3, 2018, a near-miss event occurred while Holtec was downloading a loaded spent fuel storage canister into the storage vault at the San Onofre Nuclear Generating Station (SONGS). A NRC Special Inspection involved interviews of employees of Holtec subcontractors Williams Industrial Services Group and Sonic Systems. The Special Inspection team found out that, from January 30 to August 3, 2018, during canister downloading, contact between the spent fuel canister and the vault components frequently occurred but the licensee Southern California Edisons (SCE) and its contractor Holtec failed to enter these incidents into the sites corrective action program, failed to develop procedures to prevent reoccurrence, and failed to assess the exterior conditions of the downloaded canisters and vault components. (US NRC Special Inspection Report SONGS, 2018 at p 8) On August 2, 2018, these problems led to the inadvertent disabling of important to safety downloading slings while a canister full of spent fuel was being loaded into the ISFSI storage vault. For some 45 minutes, the canister rested on a shield ring unsupported by the redundant downloading slings at approximately 17-18 feet above the fully seated position. Holtecs own causal evaluation report on the incident, as reported in the NRC Special Inspection report, found that Holtecs Management failed to implement appropriate program improvements or the necessary level of oversight commensurate with the complexity and risks associated with downloading operations. Management failed to establish licensee and contractor training to support procedure implementation. Management failed to sufficiently detail contractor Oversight Specialist guidance. ISFSI project management was not routinely observing dry cask storage operations.. ISFIS project management was not consistently initiating condition reports for dry cask storage operations that deviated from normal. (US NRC Special Inspection Report SONGS, 2018, at p 18) The SONGS incident led to a significant delay in spent fuel canister loading activities.
More recently, Holtec has been cited with violations related to its decommissioning activities at Oyster Creek and Indian Point. (U.S. NRC Inspection Report Oyster Creek, 2021; U.S. NRC Inspection Report Indian Point, 2022)
Other types of problems can emerge during decommissioning from labor strife and disputes or partings-of-the-ways between Holtec and its partners and subcontractors. For example the PSDAR advertises the support (presumed at the time of its submission) that would be provided by SNC-Lavalin in areas such as legal, financial reporting systems, information technology, procurement, and human resources. (PSDAR, p 13) However the arrangement with SNC-Lavalin ended by January 2022 (Holtec Notice to NRC, 2022) and soon thereafter labor issues emerged at the Pilgrim site. (Legere, 2022)
6 Fierce opposition has also emerged to plans proposed by Holtec to release wastewater contaminated with radionuclides and other toxicants into source water bodies. (See, e.g.,
Barnes; 2022; Cronin, 2022; Damiano, 2022; Govern, 2022; U.S. EPA, 2022)
In sum, Holtecs vision of a cake walk with decommissioning and site remediation activities lacks foresight and insight regarding the challenges ahead.
COMMENTS POINT 4: The Assumption Relating to Nuclear Waste Removal is Idle and Discredited by the Historic Record As the NRC is well aware, the United States has accumulated one of the largest inventories of spent fuel in the world and - despite decades of effort and untold billions of public expenditure -
finding a solution has proven elusive. Disposing of such waste will involve numerous daunting challenges.
Putting aside all other issues and defects, the PSDAR is fatally flawed because its conclusions regarding risk, public health and environmental impact, and cost all rest on the unfounded assumption that all of the nuclear waste will be removed from the site, with spent fuel transferred to Holtecs as yet unlicensed and not built HI-STORE consolidated interim storage facility (CISF) in Lea County, New Mexico.
That site, dangerously in the heart of the Permian Basin, is vigorously opposed by the state of New Mexico, Native American groups, and many organizations and individuals. (All Pueblo Council; 2019; Chamberlain, 2019; Lujan, 2020; Resnikoff, 2020) Its creation would be an environmental justice atrocity. The majority Hispanic communities in Lea County, and large Hispanic communities in adjacent counties, as well as Native American and other people of color and low-income communities nearby, already suffer the heath impacts from intensive, heavily polluting fossil fuel industries, heavy mining activities, and the existing complex of nuclear facilities. Adding more radioactivity to the area already burdened by radioactivity and hazardous chemicals would effectively transform the region into a toxic sacrifice zone.
In any event, Holtecs divination that the waste will be removed by 2040 is nothing more than a guess which is very likely guided by its financial self-interest in opening the CISF. As the history of other sites shows, even if licensed, the CISF enterprise is hardly assured of being brought to fruition. (Beyond Nuclear, 2012)
Moreover, in proceedings before the NRC Atomic Safety and Licensing Board (ASLB), Holtec representatives said that if a spent fuel canister being received at its proposed HI-STORE CISF were found to be defective or leaking upon receipt in New Mexico, Holtec would send it back to the nuclear power site from whence it came. (ASLB, 2019)
In this regard it must also be emphasized that numerous issues relating to management of the spent fuel, especially the high burnup fuel which is much more hot and radioactive than traditional lower burnup fuel, remain unresolved. A September 2019 report to Congress by the U.S. Nuclear Waste Technical Review Board (NWTRB), an independent federal agency established by the 1987 Nuclear Waste Policy Amendments Act, points to the fact that, while periodic small-scale shipments of spent fuel have occurred for decades, most have involved transport of naval spent fuel conducted by the U.S. Navy. In contrast, transportation of large quantities of spent nuclear fuel (or SNF) and high level waste (HLW) has not been done in this country and will require significant planning and coordination by the Department of Energy
7 (DOE). The NWTRB observes that unresolved technical issues could significantly delay or impede the implementation of a national transportation program for radioactive waste: The large size, broad scope, and geographic distribution of the U.S. SNF and HLW program make resolving the technical and integration issues associated with a nationwide transportation effort a significant challenge. SNF and HLW inventories in the U.S. include a diverse collection of waste forms, waste storage containers, storage conditions, storage locations, waste transportation containers, and licensing requirements. Current waste storage sites also include several unique challenges, such as varying degrees of accessibility for large transport vehicles or railcars. Addressing the unresolved technical and integration issues associated with these program elements prior to initiating transportation will require a well-planned and well-integrated effort. (Bahr, 2019)
Robert Alvarez, a senior scholar at the Institute for Policy Studies who previously served as a DOE Secretary Senior Policy Adviser, warns that high burnup fuel poses inadequately studied challenges to even temporary spent fuel storage plans. (Alvarez, 2018. See also Billone, 2014)
Moreover, issues relating to the thin-wall canisters used and proposed by Holtec for additional use at Palisades keep emerging. Of concern is a report where scientists at Sandia National Lab and Pacific Northwest National Lab changed the priority of stress corrosion cracking risks of thin-wall canisters to a high priority no 1 for research and identified a technology gap relating to assessment of impact of through-wall canister cracks. (Teague, 2019)
In sum, the merits of the contention that decommissioning would flow smoothly and all the nuclear waste would be removed from Palisades at the time Holtec envisions with nary a hitch are fanciful.
Conclusion For all the reasons stated herein, CIECP and PHASE aver that the PSDAR is flawed and urge heightened NRC oversight of the Palisades site throughout decommissioning and cleanup.
CIECP and PHASE also urge the NRC to refrain from being complicit in perpetuating misleading claims about how quickly spent fuel will be removed from shut reactor sites and how quickly these sites will be able to be safely released for unrestricted use.
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Decommissioning Nuclear Power Plants: What Congress, Federal Agencies and Communities Need to Know, Environmental and Energy Study Institute Decommissioning forum briefing, Jul 16, 2018. Link at: www.eesi.org/071618nuclear.
8 ASLB: Official Transcript of Proceedings, in the Matter of Holtec International (HI-STORE Consolidated Interim Storage Facility), U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board hearings, Albuquerque, New Mexico, Docket No. 72-1051-ISFSI, ASLBP No.
18-958-01-ISFSI-BD01, Jan 24, 2019, at p 282. http://wethefourth.org/files/pdf/ELEA-NRC-transcript-2019-01-24.pdf.
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https://www.washingtonpost.com/weather/2021/12/15/wind-storm-tornado-minnesota-iowa/.
Smith, Mitch, Man Sentenced to 16 Years in Prison for Plotting to Kidnap Michigans Governor, New York Times, Dec 27, 2022. https://www.nytimes.com/2022/12/27/us/michigan-whtimer-governor-kidnapping-sentencing.html. (This is kind of a canary in a coal mine, the federal
10 prosecutor Nils Kessler said in court on December 27, 2022, the day of the sentencing of a member in the plot to abduct Michigans governor.)
Stockman C and Kalinina E, Cooling Times for Storage and Transportation of Spent Nuclear Fuel, Sandia National Laboratories brief presentation for U.S. Department of Energy, SAND2013-1698C, Feb 25, 2013, at pp 2 & 4. https://www.osti.gov/servlets/purl/1145261.
Teague MC, Saltzstein SJ, Hanson B, Sorenson KB, and Freeze GA, Gap Analysis to Guide DOE R&D in Supporting Extended Storage and Transportation of Spent Nuclear Fuel: An FY2019 Assessment, Sandia National Laboratories and Pacific Northwest National Laboratories report to U.S. Department of Energy Office of Nuclear Energy, SANDA-2019-15479R; 681990, Dec 23, 2019. https://www.osti.gov/servlets/purl/1592862 Link at:
https://www.osti.gov/biblio/1592862.
U.S. EPA: Chow, James, Deputy Director, Enforcement and Compliance Assurance Division, Region I, U.S. Environmental Protection Agency letter to Kelly Thrice, President, Holtec Decommissioning International, Dec 5, 2022. https://media.wbur.org/wp/2022/12/Holtec_CWA-Info.Request.pdf.
U.S. NRC Inspection Report Indian Point: Holtec Decommissioning International, LLC, Indian Point Energy Center Units 1, 2 and 3 - NRC Inspection Report Nos. 05000003/2022002, 05000003/2022003, 05000247/2022002, 05000247/2022003, 05000286/2022002, 05000286/2022003, and 07200051/2022001, U.S. Nuclear Regulatory Commission (ML22306A065), Nov 17, 2022.
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22306A065.
U.S. NRC Inspection Report Oyster Creek, 2021: NRC Inspection Report No.
05000219/2021001 and Independent Spent Fuel Storage Installation Report 07200015/2021001, Holtec Decommissioning International, LLC, Oyster Creek Nuclear Generating Station, U.S. Nuclear Regulatory Commission, May 18, 2021.
https://www.nrc.gov/docs/ML2113/ML21132A064.pdf.
U.S. NRC Special Inspection Report SONGS, 2018: NRC Special Inspection Report re Southern California Edison Company Spent Fuel Storage San Onofre Nuclear Generating Station (SONGS), report nos. 050-00206/2018-005, 050-00361/2018-005, 050-00362/2018-005, 072-00041/2018-001 and Notice of Violation, Nov 28, 2018. ML18332A357(1).
https://www.nrc.gov/docs/ML1833/ML18332A357.pdf. (Attached to this report is a NRC internal memorandum explaining that the special inspection was chartered to review the near-miss drop event involving a loaded spent fuel storage canister at the San Onofre Nuclear Generating Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI) on August 3, 2018.
NRCs Region IV became aware of the SONGS near-miss incident on Monday, August 6, 2018, when the licensee provided a courtesy notification and described it as a near-miss or near-hit event. (Pruett, Troy W, Division of Nuclear Materials safety to Eric J. Simpson, Health Physicist, Fuel Cycle and Decommissioning Branch Division of Nuclear Materials safety, W.
Chris Smith, Reactor Inspector, Engineering Branch 1, Division of Reactor safety and Marlone X. Davis, Transportation & Storage Safety Inspector, Inspections & Operations Branch, Division of Spent Fuel Management, U.S. Nuclear Regulatory Commission, (ML18229A203), Aug 17, 2018))
ZionSolutions: Revised Response to Request for Additional Information Related to Partial Site Release and Recent Survey Activities - Zion Nuclear Power Station, Units 1 and 2,
11 ZionSolutions, LLC submission to U.S. Nuclear Regulatory Commission (ZS-2022-010, Mar 28, 2022. https://www.nrc.gov/docs/ML2208/ML22089A098.pdf.