ML24320A070
| ML24320A070 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/11/2024 |
| From: | Alsterda T Palisades Park Country Club |
| To: | NRC/SECY |
| References | |
| NRC-2024-0135, PRM-50-125, 89FR76750 00009 | |
| Download: ML24320A070 (1) | |
Text
PUBLIC SUBMISSION As of: 11/15/24, 10:41 AM Received: November 11, 2024 Status: Pending_Post Tracking No. m3d-r58k-3mvf Comments Due: December 03, 2024 Submission Type: Web Docket: NRC-2024-0135 Returning a Decommissioning Plant to Operating Status Comment On: NRC-2024-0135-0003 Returning a Decommissioning Plant to Operating Status Document: NRC-2024-0135-DRAFT-0011 Comment on FR Doc # 2024-20936 Submitter Information Email:terryalsterda@gmail.com Organization:Palisades Park Country Club General Comment Comment on Behalf of Palisades Park to NRC on Petition on Rulemaking re: Holtecs Request to Restart Palisades Nuclear Plant Docket ID NRC-2024-0135 November 11, 2024 This comment is submitted on behalf of Palisades Park, the residential community immediately south of the Palisades Nuclear Plant (PNP) and within the Palisades Emergency Planning Zone (10 miles). Palisades Park was founded in 1905 and currently has over 200 homes, the great majority of which existed at the time PNP began operations in 1971, providing our residents with a clear understanding of life next door to a nuclear power plant.
After operating for over 50 years, it has been reported the plant was in financial distress and critical maintenance was deferred. Following the plants shutdown by Entergy in May 2022, Holtec International, the new owner, now seeks to restart the unlicensed and inoperable plant with no prior experience in operating a functioning nuclear facility.
Holtec has submitted a formal request to the NRC to approve returning the PNP, which is currently decommissioned, to operational status. An NRC approval of Holtecs request would bind Michigan communities for up to twenty-five years, increasing the need for caution and care given the long term impact to the region.
Concerns for the safety of all stakeholders in the region led to this petition for rulemaking (Docket No. PRM 125), which was submitted by Alan Blind and Roger Rapoport with an additional 154 co-petitioner signatures, all of whom have residences in the Palisades Emergency Planning Zone. The petition requests the NRC to establish a specific Nuclear Regulatory Commission-approval process for reviewing and approving the return of a decommissioned plant to operational status. This requested rulemaking is critical and necessary as the PNP is the first plant in the U.S. to seek NRC approval to transition from decommissioned back to operational status. The requested rulemaking would set a standard for similar requests from decommissioned plants and should increase support and confidence in the success and sustainability of these revived, first generation nuclear facilities.
PNPs age and its history of deferred maintenance and exemptions from requirements to upgrade to the most current technology are concerning. Our understanding is that the PNP is one of six nuclear plants that were designed in the mid-1960s; (PNP began operations in December 1971). At that time, neither the concept of defense in depth nor the
NRCs General Design Criteria were fully developed. As such, the plant was built with a much thinner safety margin than what is considered standard for modern nuclear plants. All six plants are now closed.
Federal regulations prevented the NRC from requiring PNPs previous owners to retrofit the plant to meet updated safety standards. This situation held until Entergy formally closed the plant in May 2022. Now, with Holtec seeking to transition the PNP out of decommissioning, the NRC is no longer restricted from requiring updates to the obsolete designs created over 50 yrs ago. This unprecedented event provides the NRC with a critical opportunity to reevaluate PNP's safety margins and design basis, for the benefit of the community, the industry and future groups seeking to restart decommissioned plants. Without requiring a specific review and approval process, how will the unique and potential negative effects of an aged, dormant plant be identified. If not now, we question when would a 55 year-old nuclear plant ever be brought to current industry, technology and safety standards.
Recent activity at the plant has exposed a serious issue with the PNP and the potential health of the equipment. On October 1, 2024, the NRC reported the results of PNPs two steam generators tube inspections. The inspection revealed the number of steam generator tubes with stress corrosive cracking (SCC) indications far exceed prior estimates developed from the August 2020 PNP inspection. Holtecs inspection reported that 1,032 tubes showed 1,417 SCCs. Prior to its shutdown in May 2022, Entergy reported 1,159 tubes with SCCs over the prior twenty-four years.
With the continued growth in the publics need for clean energy, it is expected that additional requests to restart decommissioned nuclear plants will be made. With this first request, it is incumbent upon the NRC to ensure that it develops specific steps for review and approval that reflect the unique conditions of these decommissioned plants and assure the health and safety of the public.
Respectfully submitted, Palisades Park Board of Directors