ML25023A240
| ML25023A240 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/31/2024 |
| From: | NRC |
| To: | NRC/NMSS/DREFS |
| References | |
| Download: ML25023A240 (27) | |
Text
From:
Jennifer Davis Sent:
Thursday, October 31, 2024 3:37 PM To:
thpo@badriver-nsn.gov; Paulacarrick@baymills.org; jaylen.strong@boisforte-nsn.gov; rep32jwb@gmail.com; Justin Moschelle; Johnny Ocean; Tracy.wind@potawatomi.org; Evanschroeder@fdlrez.com; Luke.Heider@fcp-nsn.gov; olivianunway@fcp-nsn.gov; thpo@grandportage.com; jareds@grandportage.com; aaron.chivis@gtb-nsn.gov; Dustin Meshigaud; Brian.bisonette@lco-nsn.gov; Sarah.thompson@ldftribe.com; Alina.shively@lvd-nsn.gov; gina.lemon@llojibwe.net; jonniesam@lrboi-nsn.gov; Mwiatrolik@ltbbodawa-nsn.gov; Lakota Hobia; Kaila Akina; Dgrignon@mitw.org; THPO@MiamiNation.com; mike.wilson@millelacsband.com; Kelly.applegate@millelacsband.com; susan.klapel@millelacsband.com; Onyleen Zapata; Rhonda.oto@gmail.com; Matthew Bussler; Cecil Wilson; Raphaelwahwassuck@pbpnation.org; Noah.White@piic.org; historicpreservation@quechantribe.com; marvin.defoe@redcliff-nsn.gov; kade.ferris@redlakenation.org; Mlhadden@sagchip.org; wandam@stcroixojibwe-nsn.gov; edonmyer1@saulttribe.net; Larus Longie; Jaime.Arsenault@whiteearth-nsn.gov; Gary Lewis; Kenny Pheasant Cc:
Laura Willingham; Mary Richmond; Conrad, Cyler N; Williamson, Alicia; Gehan Flanders
Subject:
Status Update #2 - Palisades Request for Reauthorization of Power Operations Attachments:
Summary Palisades Nuclear Plant Tribal Site Visit 09-11-2024.pdf; Palisades Site Visit 9-11-24ppt.pdf; Attachment 3_ML24278A027.pdf; Attachment 4_ML24278A027.pdf; Attachment 5_ML24278A027.pdf; Attachment 6 MI SHPO Comments on Holtec Procedures.pdf Good afternoon, We are sending out this email to keep NHPA Section 106 consulting parties informed about the status of the U.S. Nuclear Regulatory Commissions (NRCs) environmental review of the potential reauthorization of power operations at the Palisades Nuclear Plant (Palisades). Palisades is located in Van Buren County, Michigan, along the shore of Lake Michigan, approximately 2.5 miles northwest of Covert Township. As discussed in previous correspondence, the NRC is conducting National Historic Preservation Act Section 106 consultation through the National Environmental Policy Act of 1969 (NEPA) process per 36 CFR 800.8(c).
As discussed in our October 2, 2024, status update, the NRC conducted a Tribal site visit and meetings with representatives from the Gun Lake Tribe (Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians) and the Pokagon Band of Potawatomi on September 11, 2024. The NRC has prepared a meeting summary (see Attachment 1) that provides an overview of topics discussed. Attachment 2 contains the presentation slides from the September 11th site visit.
As part of the NRCs environmental audit, the staff requested additional information from Holtec Decommissioning International, LLC (Holtec) to support the preparation of the draft environmental assessment and associated consultations. Holtec responded on October 4, 2024, and the submittal is located at the following link:
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML24278A027.
Attachments 3, 4, and 5 are maps that delineate areas of proposed restart activities and associated laydown areas and are located in Holtecs October submittal under the response labeled GEN-1.
The NRC received a request from a consulting Tribe to review a copy of Holtecs cultural resources management plan. NRC staff has relayed this request to Holtec. Since this is a power plant procedure, the management plan will be sent from Holtec to your email address.
Additionally, the MI SHPO also requested to review Holtecs procedures and their response dated October 23, 2024 is attached (See attachment 6).
Again, thank you for taking the time to consult with NRC. If you have any questions, please let me know.
Jennifer Jennifer A. Davis Senior Environmental Project Manager Environmental Technical Review Branch 1 Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission (301) 415-3835
Hearing Identifier:
PalisadesRestart_EnvDocs_Public Email Number:
42 Mail Envelope Properties (BLAPR09MB73451CF49557AEBF3F7E605385552)
Subject:
Status Update #2 - Palisades Request for Reauthorization of Power Operations Sent Date:
10/31/2024 3:36:59 PM Received Date:
10/31/2024 3:36:00 PM From:
Jennifer Davis Created By:
Jennifer.Davis@nrc.gov Recipients:
"Laura Willingham" <laura.willingham@nrc.gov>
Tracking Status: None "Mary Richmond" <Mary.Richmond@nrc.gov>
Tracking Status: None "Conrad, Cyler N" <cyler.n.conrad@pnnl.gov>
Tracking Status: None "Williamson, Alicia" <alicia.williamson@hq.doe.gov>
Tracking Status: None "Gehan Flanders" <Gehan.Flanders@nrc.gov>
Tracking Status: None "thpo@badriver-nsn.gov" <thpo@badriver-nsn.gov>
Tracking Status: None "Paulacarrick@baymills.org" <Paulacarrick@baymills.org>
Tracking Status: None "jaylen.strong@boisforte-nsn.gov" <jaylen.strong@boisforte-nsn.gov>
Tracking Status: None "rep32jwb@gmail.com" <rep32jwb@gmail.com>
Tracking Status: None "Justin Moschelle" <jmoschelle@yahoo.com>
Tracking Status: None "Johnny Ocean" <JohnnyoceanwindyboyJWB@gmail.com>
Tracking Status: None "Tracy.wind@potawatomi.org" <Tracy.wind@potawatomi.org>
Tracking Status: None "Evanschroeder@fdlrez.com" <Evanschroeder@fdlrez.com>
Tracking Status: None "Luke.Heider@fcp-nsn.gov" <Luke.Heider@fcp-nsn.gov>
Tracking Status: None "olivianunway@fcp-nsn.gov" <olivianunway@fcp-nsn.gov>
Tracking Status: None "thpo@grandportage.com" <thpo@grandportage.com>
Tracking Status: None "jareds@grandportage.com" <jareds@grandportage.com>
Tracking Status: None "aaron.chivis@gtb-nsn.gov" <aaron.chivis@gtb-nsn.gov>
Tracking Status: None "Dustin Meshigaud" <dustin.meshigaud@hannahville.org>
Tracking Status: None "Brian.bisonette@lco-nsn.gov" <Brian.bisonette@lco-nsn.gov>
Tracking Status: None "Sarah.thompson@ldftribe.com" <Sarah.thompson@ldftribe.com>
Tracking Status: None "Alina.shively@lvd-nsn.gov" <Alina.shively@lvd-nsn.gov>
Tracking Status: None "gina.lemon@llojibwe.net" <gina.lemon@llojibwe.net>
Tracking Status: None "jonniesam@lrboi-nsn.gov" <jonniesam@lrboi-nsn.gov>
Tracking Status: None "Mwiatrolik@ltbbodawa-nsn.gov" <Mwiatrolik@ltbbodawa-nsn.gov>
Tracking Status: None "Lakota Hobia" <Lakota.Hobia@glt-nsn.gov>
Tracking Status: None "Kaila Akina" <Kaila.Akina@glt-nsn.gov>
Tracking Status: None "Dgrignon@mitw.org" <Dgrignon@mitw.org>
Tracking Status: None "THPO@MiamiNation.com" <THPO@MiamiNation.com>
Tracking Status: None "mike.wilson@millelacsband.com" <mike.wilson@millelacsband.com>
Tracking Status: None "Kelly.applegate@millelacsband.com" <Kelly.applegate@millelacsband.com>
Tracking Status: None "susan.klapel@millelacsband.com" <susan.klapel@millelacsband.com>
Tracking Status: None "Onyleen Zapata" <Onyleen.Zapata@nhbp-nsn.gov>
Tracking Status: None "Rhonda.oto@gmail.com" <Rhonda.oto@gmail.com>
Tracking Status: None "Matthew Bussler" <Matthew.Bussler@pokagonband-nsn.gov>
Tracking Status: None "Cecil Wilson" <Cecil.Wilson@pokagonband-nsn.gov>
Tracking Status: None "Raphaelwahwassuck@pbpnation.org" <Raphaelwahwassuck@pbpnation.org>
Tracking Status: None "Noah.White@piic.org" <Noah.White@piic.org>
Tracking Status: None "historicpreservation@quechantribe.com" <historicpreservation@quechantribe.com>
Tracking Status: None "marvin.defoe@redcliff-nsn.gov" <marvin.defoe@redcliff-nsn.gov>
Tracking Status: None "kade.ferris@redlakenation.org" <kade.ferris@redlakenation.org>
Tracking Status: None "Mlhadden@sagchip.org" <Mlhadden@sagchip.org>
Tracking Status: None "wandam@stcroixojibwe-nsn.gov" <wandam@stcroixojibwe-nsn.gov>
Tracking Status: None "edonmyer1@saulttribe.net" <edonmyer1@saulttribe.net>
Tracking Status: None "Larus Longie" <larus.longie@tmbci.org>
Tracking Status: None "Jaime.Arsenault@whiteearth-nsn.gov" <Jaime.Arsenault@whiteearth-nsn.gov>
Tracking Status: None "Gary Lewis" <garylewis@lrboi-nsn.gov>
Tracking Status: None "Kenny Pheasant" <kennypheasant@lrboi-nsn.gov>
Tracking Status: None
Post Office:
BLAPR09MB7345.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 2497 10/31/2024 3:36:00 PM Summary Palisades Nuclear Plant Tribal Site Visit 09-11-2024.pdf 67845 Palisades Site Visit 9-11-24ppt.pdf 2656957 _ML24278A027.pdf 1170400 _ML24278A027.pdf 2168814 _ML24278A027.pdf 1281889 MI SHPO Comments on Holtec Procedures.pdf 148339 Options Priority:
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Palisades Tribal Site Visit Meeting Summary September 11, 2024 Location: Palisades Nuclear Plant, 27780 Blue Star Hwy, Covert, MI, 49043 Attendees: U.S. Nuclear Regulatory Commission, Pokagon Band of Potawatomi, the Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians (Gun Lake Tribe), and Holtec Decommissioning International, LLC On Wednesday, September 11, 2024, the U.S. Nuclear Regulatory Commission (NRC) facilitated and led an in-person and virtual meeting and tour for the Palisades Nuclear Plant Potential Reauthorization of Power Operations Project. The day-long meeting and tour occurred at Palisades Nuclear Plant (Palisades) and included virtual sessions for remote participation.
This was a non-public meeting. Staff from the NRC, the Pokagon Band of Potawatomi, the Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians (Gun Lake Tribe), and Holtec Decommissioning International, LLC (HDI) participated. NRC and HDI contractors from Pacific Northwest National Laboratory (NRC contractor), Enercon and SEARCH, LLC, (HDI contractors) also participated.
The meeting included a presentation outlining the proposed restart project, undertaking and Federal actions, Federal agencies involved, past land disturbance at Palisades, the anticipated Area of Potential Effect, the NRCs environmental review schedule (including for the National Environmental Policy Act and the National Historic Preservation Act), and potential future projects at the Palisades site (subsequent license renewal and small modular reactor project).
The potential future projects would be separate undertakings and current estimated submittal date for these projects is 2026. Additionally, the NRC staff noted that the scoping summary report will be shared with the consulting parties. The report is scheduled to be issued in the October/November 2024 timeframe.
The tour included visiting locations where ground disturbing activities may occur, this included along the perimeter access road, and in locations near the cooling towers. Tours of the interior facilities also occurred and involved stops in the turbine building, along the lakeshore waterfront, and at the independent spent fuel storage installation. A final driving tour occurred at the proposed location where small modular reactors may be designed and constructed in the future.
Primary talking points, questions and action items included: 1) understanding the depth of past disturbance at Palisades, particularly along sand dune locations near where proposed ground disturbing activities may occur to ensure that the potential for uncovering cultural resources during excavation is properly characterized and understood, 2) providing access to the HDI archaeological survey for consulting Indian Tribes for review and comment, and 3) requesting that the NRC continue consulting, engaging and communicating directly with Indian Tribes throughout this project and environmental review.
Potential Reauthorization of Power Operations Palisades Nuclear Plant U.S. Nuclear Regulatory Commission Tribal Site Visit John Moses, Deputy Division Director, NRC Jennifer Davis, Environmental Project Manager, NRC Laura Willingham, Environmental Project Manager, NRC Alicia Williamson, Environmental Protection Specialist, DOE September 11, 2024
Agenda 8:30am - 9:15am: Arrive / Get Settled / Coffee 9:15am - 10:15am: Introductions, Overview of Proposed Undertaking*
10:15am - 10:30am: Safety Briefing & Security Badging 10:30am - 12:30pm: Site Tour 12:30pm - 1:30pm: Lunch break 1:30pm - 3:00pm: Question & Answer Session, Information Sharing*
3:00pm - 3:15pm: Environmental Review Schedule & Next Steps*
3:15pm - 3:30pm: Action Items & Closing Remarks
- virtual component 2
Potential Reauthorization of Power Operations at Palisades Nuclear Plant - Background
- The Palisades Nuclear Plant is a single unit pressurized-water reactor on Lake Michigans eastern shore, in Covert Township.
- Palisades shut down on May 20, 2022, after more than 40 years of commercial operation.
- On June 13, 2022, Palisades certified the permanent end of power operations and removal of fuel from the reactor vessel.
- The current license holder, Holtec Decommissioning International (HDI), decided in 2023 to pursue returning Palisades to full power operations.
- Holtec has filed several regulatory requests that, if approved, would authorize operating Palisades through March 24, 2031 - the end of the reactors current renewed operating license term.
An exemption from the rule that prohibits reactor power operations and fuel loading after filing a certification to permanently shutting down and defueling a reactor.
A transfer of the Palisades renewed operating license from HDI to Palisades Energy, LLC.
Several license amendment requests that would restore technical specifications and other requirements for normal operation.
3
Lead and Cooperating Agencies The NRC leads the National Environmental Policy Act (NEPA) analysis and National Historic Preservation Act (NHPA)
Section 106 consultation for the proposed Palisades restart. If other Federal agencies are involved in the same or connected action, they will be cooperating agencies to increase the NEPA reviews efficiency.
In addition to the NRCs review of the proposed restart, Holtec applied for a DOE loan guarantee for the costs of restoring Palisades and resuming operations. Because the issuance of a federal loan is considered a major Federal action, DOE also has NEPA responsibilities and is a cooperating agency for the Palisades environmental review.
4
Pre-1965 - Undeveloped sand dune environment with quarry on portion of site 1965 - Site selection and land development 1966 - Construction permit and operating license applications submitted to the Atomic Energy Commission (AEC*), site clearing begins 1971 - Operation begins 2007 - Initial Renewed License Granted 2022 - Fuel Removed and Plant Approved for Decommissioning 2023 - 2024 Potential Restart Review
- Predecessor to the U.S. Nuclear Regulatory Commission and U.S. Department of Energy 5
Palisades Nuclear Plant Construction/Operation History
1966 and 1967 Photographs of Palisades Nuclear Plant During Site Preparation and Initial Construction 6
Prior Site Disturbance
1968 and 1969 Photographs of Palisades Nuclear Plant Construction 7
Prior Site Disturbance
1971 U.S. DOE Photographs of Palisades Nuclear Plant 8
Prior Site Disturbance
Palisades Nuclear Plant Today vs. Prior to Construction
Located on Covert, MI Total size 432 acres (not all affected)
Key Distances
~18 miles N of Benton Harbor
~8 miles S of South Haven
~40 miles W of Kalamazoo Draft Area of Potential Effect
11 Proposed Restart Activities and Disturbance Areas
12 Proposed Restart Activities Activity Land disturbance Approx.
disturbance Complete the security infrastructure changes including new barrier/wall, Yes 4 Acres Replace eighteen (18) power cables from F &G Bus 4160 VAC load centers to cooling tower Yes 3 Acres Purchase and install mobile personnel in-processing buildings No 2.5 Acre Expanded Access Road at south end of Protected Area Yes 2 Acres Routine herbicide application in cooling tower areas. There are no anticipated changes to pesticide/herbicide management practices, plans, and procedures for restart. Activity is reported to the NRC in Annual Non-Radiological Environmental Operating Reports.
No As needed, 2 Acre Design and construct a new south radioactive material storage building inside the security protected area boundary.
Yes 1 Acre Stormwater outfalls pipe replacement and riprap movement which could require staging of riprap and placing the same riprap back to the stormwater outfalls Yes 0.5 Acre Renovate the former Feedwater Purity Building No 0.5 Acre Inspections of underground commodities Yes 0.1 Acre Upgrade the Heating, Ventilation, and Cooling (HVAC) units for the Administrative Buildings No 0.1 Acre Activity Land disturbance Approx.
disturbance Complete facility roofing inspections and repair/replace roofs No 0.1 Acre Complete all Inservice Inspection, Flow Accelerated Corrosion Program, and Heat Exchanger Inspection Program scope identified in the Code/Plant Programs Scoping Yes 0.1 Acre Routine maintenance of the stormwater outfalls Yes 0.1 Acre Removal of sand from the cooling tower basins No 0.1 Acre Mixing basin sediment removal.
No 0.1 Acre Construction of Digital Staging Testing Building (associated with the Digital Electrohydraulic Control Software and computer hardware control system replacement). The building will be approximately 40 feet wide by 80 feet long and 20 feet tall Yes 0.1 Acre New Blast Resistant Enclosures (BREs) constructed within the Protected Area. Five outdoor BREs between 30 to 40 feet tall (above grade) will be erected. Shallow (3-6 inch) foundations.
Yes 0.1 Acre Circulating Water Cooling System Expansion Joint Replacement No 0.1 Acre Complete all Preventive and Corrective Valve Maintenance identified in the PM Database. The scope of outdoor work is to replace buried cooling tower bypass valves and actuators located in valve houses next to the cooling towers.
Yes 0.1 Acre List of Outdoor Activities. Indoor Activities (mostly inspections) have no expected land disturbances.
13 Potential Contested Hearing(s) and Commission Decision Submittal(s)
Govt to Govt Consultation
Discuss evaluation
Draft review and comment
Complete Section 106 review We Are Here Govt to Govt discussions
Initiate Section 106 consultation
Identify issues to be considered in review
Understand expertise and plan involvement
Establish communication protocol Govt to Govt Consultation Contribute to development Continue Section 106 review
- The NRC has initiated National Historic Preservation Act Section 106 consultation and will conduct compliance through the NEPA process (per 36 CFR 800.8(c))
NRCs Environmental Review Process and Tribal Involvement Pre-Submittal Activities Govt to Govt Consultation
Resolve comments
Discuss changes to final
Close Consultation
Environmental Review Schedule 14 Notice of Intent June 27, 2024 Published NRC's Notice of Intent to prepare an environmental assessment (EA).
Public Scoping Period concluded July 29, 2024 Public process to review and comment on the scope and issues to be considered for analysis in the EA.
Draft Environmental Assessment and FONSI The NRC will consider all relevant comments received during the scoping period and will issue a draft EA and (if justified)
Public Comment on Draft Environmental Assessment and FONSI The NRC will provide the opportunity for public comment on the draft EA.
Final Environmental Assessment and FONSI Approximately 12 months to Publication of Final EA The NRC considers all relevant comments received in the development of the final EA and (if justified) FONSI
- Scoping Comment Period ended on July 29, 2024
- Draft Environmental Assessment - expected issuance January 2025.
Public Comment Period A copy of the draft EA will be made available to Federally recognized Tribes for review and comment.
- Final Environmental Assessment - expected issuance July 2025.
A copy of the final EA will be made available to Federally recognized Tribes.
We are here
- Is there interest in sharing Tribal expertise and/or Tribal participation during the NEPA evaluations of impacts to resource areas?
- Are there specific issues of interest or concern to the Tribes that should be considered in the environmental review?
- What ways would the Tribes like to participate in the NEPA review process (draft review, comments, etc.)?
- What else do the Tribes think we need to know?
- What protocols, point(s) of contact, method for and frequency of communication are preferred (regular virtual meetings, in-person meetings, emails, project website)?
- Is there anyone that is not here today, that we should talk to?
15 How Can NRC and DOE Meaningfully Engage & Consult?
16 Potential Future Projects
- Potential Small Modular Reactors Proposed location of new reactor(s) (see figure blue boundary)
Expected application submittal date is 2026 NRC will conduct a NEPA review and initiate NHPA Section 106 consultation once an application is received Evaluates the proposed construction, operation, and decommissioning of new reactor(s) onsite
- Potential Subsequent License Renewal Expected application submittal date is 2026 NRC will conduct an NEPA review and initiate NHPA Section 106 consultation once an application is received Evaluates continuing operations for 20 additional years
- U.S. Nuclear Regulatory Commission Jennifer Davis, NHPA Section 106 Contact Jennifer.Davis@nrc.gov or 301-415-3835 Laura Willingham, Environmental Project Manager Laura.Willingham@nrc.gov or 301-415-0857 Mary Richmond, Environmental Project Manager Mary.Richmond@nrc.gov or 301-415-7218
- U.S. Department of Energy, Loan Programs Office Alicia Williamson, Environmental Protection Specialist Alicia.Williamson@hq.doe.gov or 202-586-7272 17 Environmental Review Points of Contact
, Attachment 1 HDI PNP 2024-037 Page 8 of 10
, Attachment 1 HDI PNP 2024-037 Page 9 of 10
, Attachment 1 HDI PNP 2024-037 Page 10 of 10
STATE OF MICHIGAN GRETCHEN WHITMER MICHIGAN STRATEGIC FUND QUENTIN L. MESSER, JR.
GOVERNOR STATE HISTORIC PRESERVATION OFFICE PRESIDENT 300 NORTH WASHINGTON SQUARE LANSING, MICHIGAN 48913 michigan.gov/shpo (517) 335-9840 October 23, 2024 JENNIFER DAVIS SENIOR ENVIRONMENTAL PROJECT MANAGER ENVIRONMENTAL TECHNICAL REVIEW BRANCH 1 U.S. NUCLEAR REGULATORY COMMISSION Re:
Holtec Environmental and Cultural Review Procedures
Dear Jennifer Davis:
SHPO received Holtec Decommissioning International, LLC environmental review and cultural resources procedures. After having reviewed the aforementioned policy SHPO staff would like to make recommendations for some revisions.
The procedures state that the cultural resources procedures will be enacted when/if an archaeological site is uncovered. It is important to note, that in Michigan, an archaeological site can be defined by a single find spot, i.e.
a projectile point. Therefore, SHPO recommends changing the language in the procedures so it is clear that a single archaeological artifact would put the cultural resources procedures into motion.
The geographic and geologic location of the Palisades Nuclear Plant should be taken into consideration in the cultural resources procedures. The landscape and formation processes of the dune environment leads to deeply buried archaeological sites. What is considered disturbed in many circumstances, is not necessarily the case for dune environments. SHPO recommends cultural resource procedures that account for the unique dune environment and considers the potential for deeply buried sites.
Finally, the procedures state that SHPO should be contacted if an archaeological site is uncovered. SHPO recommends that the series of contacts includes the Tribal Historic Preservation Officers (THPOs) of consulting Tribal Nations.
If you have any questions, please contact Kathryn Frederick, Archaeologist at 517-855-0082 or by email at frederickk1@michigan.gov. Thank you for this opportunity to review and comment.
Sincerely, Kathryn Frederick Staff Archaeologist Copy:
Nick Culp, Holtec International