ML24264A004
| ML24264A004 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/20/2024 |
| From: | Blind A - No Known Affiliation |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 57109, 50-255-LA-3, ASLBP 24-986-01-LA-BD01 | |
| Download: ML24264A004 (0) | |
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September 19, 2024 Docket No. 50-255-LA-3 of 1
6 Supplemental Submission to the Petition Regarding the Safety Impact of Steam Generator Tube Plugging at Palisades Nuclear Plant
Subject:
Supplemental Filing to Support Contention Two and Strengthen the Argument for NRC Review of the FSAR Docket No.: 50-255 Date: September 19, 2024 To the NRC Licensing Board, This supplemental submission builds upon the petition filed on September 9, 2024, to provide further arguments regarding Contention Two, addressing Holtecs flawed reliance on the Defueled Safety Analysis Report (DSAR) instead of submitting a fully updated Final Safety Analysis Report (FSAR). Recent developments, particularly the ongoing steam generator tube failures, further emphasize the urgency of resolving this contention before any assessment of the Palisades Nuclear Plant restart can take place.
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- 1. Introduction Holtec Internationals efforts to restart the Palisades Nuclear Plant have exposed new concerns about the plants operational integrity, particularly the condition of its steam generator (SG) tubes.
As per a recent notice to the public by NRC staff, a large number of tubes have exhibited signs of failure, requiring further analysis and potential plugging.
Without an NRC-approved FSAR, it is impossible for either the NRC or Holtec to accurately assess the safety risks associated with these failures. This supplemental submission aims to support Contention Two by demonstrating the infeasibility of evaluating these failures without a NRC approved, FSAR.
- 2. Steam Generator Tube Plugging and Safety Implications As indicated in the recent report, filed after the last refueling outage, ML21084A077, on the Palisades plants SG tube testing, 1,159 out of 16,438 tubes have already been plugged, representing 7.1% of the total. The NRC staff has recently reported that a significant number of additional tubes are showing indications of failure, perhaps necessitating further plugging. Under Contention
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6 Two, neither Holtec nor the NRC has an approved analysis to evaluate whether the tube plugging will remain within the safety limits established in the FSAR.
Without an NRC-approved FSAR, it is impossible to determine the maximum allowable percentage of plugged tubes. The FSAR serves as the foundational document for such safety evaluations, and its absence leaves both the NRC and Holtec operating in a regulatory and safety vacuum.
- 3. FSAR Issues and Contention Two Holtecs reliance on the DSAR instead of submitting an updated FSAR is deeply flawed. The FSAR is the only NRC-approved document that can confirm whether the plugging limits are being respected. Without an approved FSAR, the NRC cannot conduct a thorough review of the steam generator issues, and Holtec cannot justify acceptability of the current Steam Generators.
Holtecs proposal to update the FSAR through the 10 CFR 50.59 leads to this situation. The 50.59 process governs changes, tests, and experiments without prior NRC approval. However, without a valid FSAR to evaluate as argued in Contention Two, the use of the 50.59 process is inappropriate for assessing such a
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6 critical safety component as the steam generators. This procedural oversight must be addressed before any meaningful safety assessments can take place.
- 4. NRCs Role in Ensuring Regulatory Compliance The NRC is tasked with ensuring that nuclear plants operate within a robust, transparent, and approved safety framework. By allowing Holtec to proceed without submitting a PSAR, and the NRC approval of the FSAR, the NRC is failing to meet its regulatory responsibilities. The unresolved issues surrounding the SG tubes, and the possibility that the plugging limits have been exceeded, pose safety risks. The absence of an NRC approved FSAR further exacerbates these risks, as it prevents a full safety evaluation of the plant's current condition.
The NRC must resolve Contention Two and demand that Holtec submit an PSAR for NRC approval, before continuing with the evaluation of the SG tube failures and restart plans. Doing so will ensure that the necessary safety margins are preserved and that the Palisades plant operates in compliance with NRC standards.
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- 5. Conclusion Without the resolution of Contention Two and the approval of the FSAR, neither the NRC staff nor Holtec can adequately evaluate the safety impact of the SG tube failures at the Palisades Nuclear Plant. The ongoing concerns related to the SG tubes, combined with the lack of a valid FSAR, create significant safety and regulatory challenges. Moving forward with the plants restart without addressing these concerns would compromise public health and safety. Therefore, it is imperative that the NRC prioritize resolving these issues before considering any further steps in the plants restart process.
Sincerely, Alan Blind Representative for the Joint Petitioners Date: September 19, 2024
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6 Declaration of Alan Blind in Support of Supplemental Submission to Petition for Hearing - Docket No. 50-255