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Petition to Intervene and Request for Adjudicatory Hearing by Beyond Nuclear, Dont Waste Michigan, and Michigan Safe Energy Future - Petitioners Declarations 1-9
	ML23339A194
Person / Time
Site:	Palisades
Issue date:	12/05/2023
From:	Ferry C, Hirt A, Kamps K, Keegan M, Kirk J, Pierman B, Wendy Reed, Scott A, Jeffrey Scott; - No Known Affiliation, Beyond Nuclear, Don't Waste Michigan, Michigan Safe Energy Future
To:	; NRC/OCM
	SECY RAS
References
	RAS 56863, 50-255-ER
	Download: ML23339A194 (0)
	v • d • e

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of

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Docket No. 50-255 Holtec Palisades LLC and Holtec

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Decommissioning International

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(Palisades Nuclear Plant December 5, 2023 Request for Exemption)

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PETITION TO INTERVENE AND REQUEST FOR ADJUDICATORY HEARING BY BEYOND NUCLEAR, DONT WASTE MICHIGAN, AND MICHIGAN SAFE ENERGY FUTURE PETITIONERS DECLARATIONS 1-9 Declaration of Beyond Nuclear Appendix 1 Declaration of W. Dillon Reed Appendix 2 Declaration of Carolyn Ferry Appendix 3 Declaration of Michigan Safe Energy Future Appendix 4 Declaration of James Scott Appendix 5 Declaration of Ann Scott Appendix 6 Declaration of Dont Waste Michigan Appendix 7 Declaration of Alice Hirt Appendix 8 Declaration of Joe Kirk Appendix 9 1

Appendix 1

Appendix 2

Appendix 3

Appendix 4

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of Holtec Decommissioning International LLC and Holtec Palisades LLC (Palisades Nuclear Plant)

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Docket No. 50-255

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December 1, 2023

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DECLARATION OF JAMES SCOTT IN SUPPORT OF PETITION FOR LEAVE TO INTERVENE IN PALISADES NUCLEAR PLANT EXEMPTION PROCEEDING Now comes James Scott and makes the following statements under penalty of perjury:

1) My name is James Scott. I am an adult citizen of the State of Michigan. I also am a member of Michigan Safe Energy Future, hereafter referred to as "Petitioner."

2) My residence is located at 80014 Ramblewood Hill, Covert, MI 49043, which is located 1.2 straight-line miles from the Palisades Nuclear Plant (Palisades). My home is near Lake Michigan and in the warm season I walk on the beach and wade in the Lake within a few hundred yards of Palisades Nuclear Plant (PNP), and I go boating with friends or relatives.

3) I understand that Holtec Decommissioning International LLC (HDI) and Holtec Palisades (HP) LLC have requested exemption from portions of Nuclear Regulatory Commission regulations at 10 CFR § 50.82, Termination of license, ¶ (a), subparagraph (2), 10 CFR § 50.82(a)(2) for the Palisades Nuclear Plant (PNP). HDI and HP seek the exemption in order to resume power generation operations at PNP.

4) I have read many documents, consulted experts and have carefully formulated my opinions about the restoration of power generation at Palisades. I oppose the granting of the exemption by the NRC because of concerns over safety, the potential for significant damage to public health and the environment, the lack of nuclear power generation experience and controversial historical performance of the parent company, Holtec International (Holtec), as a corporation.

5) Before Palisades could be restored to operate, for example, there would have to be resolution of its half-century-long plague of control rod drive mechanism (CRDM) seal leakage problems. The root cause(s) of the problem have never been established. CRDM seals are a key safety feature to protect the radioactive fuel core from damage. Palisades was permanently closed Appendix 5

on May 20, 2022 - 11 days early - because of the latest control rod drive mechanism seal failure.

6) The Palisades reactor vessel is severely embrittled. Palisades has perennially been ranked by the NRC as having one of the most embrittled reactor vessels in the industry, one which could critically fail in the event of too-rapid heating or cooling. There has been no meaningful physical scientific assessment of the Palisades reactor vessel for more than 20 years.

7) Restoration of Palisades to operation would also require replacement of the reactor pressure vessel head and replacement of the steam generators for the second time in Palisades history..

8) In 1994, an NRC safety inspector, Dr. Ross Landsman, identified violations of the reactors Safe Shutdown Earthquake Evaluation in the form of subsurface stability beneath the concrete pads for the loaded nuclear waste casks that are perched on the Lake Michigan shoreline. Both cask pads at Palisades violate NRC earthquake safety regulations.

9) Cask No. 4, the fourth dry storage cask (DSC) to be loaded with spent nuclear fuel at Palisades, has weld defects. Engineers for former plant owner Consumers Energy predicted that placing the thermally hot inner canister which contains the thermally hot SNF into the 100 degree F. indoor storage pool water while the SNF was at 400 degrees C. (750 degrees F.) could cause a steam flash and thermal shock to container and fuel. The steam flash could expose workers to radiation doses, while the thermal shock could degrade the canister and fuel, making physical conditions even worse than they already are. The spent nuclear fuel cannot be adequately cooled during the short window of time to cut into the storage cask and move it into a transfer cask.

Cask No. 4 has not been opened and remediated or replace and has been left on the storage pad at Palisades in defective condition for nearly 30 years.

10) No U.S. commercial nuclear power plant has ever been restored to operations after being permanently shut down. I am not confident that necessary quality assurance record keeping nor ongoing maintenance has been performed of key systems and components since power operations were permanently ended in May 2022.

11) I am afraid that if Palisades is restored to operability there could be one or more operations incidents or accidents that will result in radiation release and that my family and I might suffer irreparable damage to our health as well as to real and personal property located at my residence.

12) I request leave to intervene in this license transfer and/or amendment proceeding and to have my interests advanced and represented by Michigan Safe Energy Future (MSEF), a grassroots association of people in western and southwestern Michigan which since 2013 has advocated for the permanent shutdown of Palisades Nuclear Plant and replacement of nuclear and natural gas power generation with safe and renewable nonnuclear energy technologies. My interests will not be adequately represented absent my legal intervention and without the opportunity of MSEF to participate as a full party in this exemption proceeding on my behalf.

13) Further the Declarant saith naught.

Date James Scott 11/26/2023

Appendix 6

Appendix 7

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of Holtec Decommissioning International LLC and Holtec Palisades LLC (Palisades Nuclear Plant)

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Docket No. 50-255

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December 1, 2023

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DECLARATION OF ALICE HIRT IN SUPPORT OF PETITION FOR LEAVE TO INTERVENE IN PALISADES NUCLEAR POWER PLANT EXEMPTION PROCEEDING Now comes Alice Hirt and makes the following statements under penalty of perjury:

1) My name is Alice Hirt. I am an adult citizen of the State of Michigan. I also am a member of Dont Waste Michigan, hereafter referred to as "Petitioner."

2) My residence is located at 6677 Summit View, Holland, MI 49024, which is located 37 straight-line miles from the Palisades Nuclear Plant (Palisades). My home overlooks Lake Michigan and in the warm season I frequently walk on the beach and wade in the Lake with my dog, and often go boating with friends or relatives.

3) I understand that Holtec Decommissioning International LLC (HDI) and Holtec Palisades (HP) LLC have requested exemption from portions of Nuclear Regulatory Commission regulations at 10 CFR § 50.82, Termination of license, ¶ (a), subparagraph (2), 10 CFR § 50.82(a)(2) for the Palisades Nuclear Plant (PNP). HDI and HP seek the exemption in order to resume power generation operations at PNP.

4) I have read many documents, consulted experts and have carefully formulated my opinions about the restoration of power generation at Palisades. I oppose the granting of the exemption by the NRC because of concerns over safety, the potential for significant damage to public health and the environment, the lack of nuclear power generation experience and controversial historical performance of the parent company, Holtec International (Holtec), as a corporation.

5) Before Palisades could be restored to operate, for example, there would have to be resolution of its half-century-long plague of control rod drive mechanism (CRDM) seal leakage problems. The root cause(s) of the problem have never been established. CRDM seals are a key safety feature to protect the radioactive fuel core from damage. Palisades was permanently closed Appendix 8