ML25112A343
| ML25112A343 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/15/2025 |
| From: | Lodge T, Taylor W Wallace L. Taylor, Attorney at Law |
| To: | Carrie Safford NRC/SECY |
| References | |
| Download: ML25112A343 (1) | |
Text
April 15, 2025 Office of the Secretary Nuclear Regulatory Commission VIA EMAIL Washington, D.C. 20555-0001 Attention: Rulemakings and Adjudication Staff Re: Palisades Request to to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving; ADAMS Accession No. ML25043A348 SUNSI request Greetings:
This letter is to request access to Sensitive Unclassified Non-Safeguards Information (SUNSI) in the above docket, in which Holtec International requests a license amendment to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving. This license amendment request appears in ADAMS as Accession No. ML25043A348. It was placed into ADAMS on February 21, 2025, and has been noticed in the Federal Register on April 15, 2025, at 90 Federal Register 15722.
This license amendment, if granted, would be one aspect of a multi-faceted plan to return the Palisades Nuclear Plant to power operation status from its current decommissioning status.
The steam generators at Palisades are severely compromised and instead of replacing them Holtec proposes to simply put sleeves on the generator tubes.
The potential parties who expect to intervene in the above docket to challenge the license amendment request described above and their interests that could be harmed by the license amendment request are described as follows:
Beyond Nuclear Beyond Nuclear is a not-for-profit public policy, research, education organization based in Takoma Park, Maryland that advocates the immediate expansion of renewable energy sources to replace commercial nuclear power generation. Beyond Nuclear has over 12,000 members of whom a number reside, work and recreate near the Palisades Nuclear Plant, and who would intervene to protect their interests in physical health and safety, the health and safety of their family members, their real property, and the health and stability of the physical environment proximate to Palisades. Beyond Nuclears address is 7304 Carroll Ave., #182, Takoma Park, MD 20912, phone (301) 270-2209, www.beyondnuclear.org.
Michigan Safe Energy Future Michigan Safe Energy Future (MSEF) is 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. MSEF has a dozen members and does not have a fixed office address. At least two of its members live within 1.5 miles of the Palisades plant. They would intervene to protect their interests in physical health and safety, the health and safety of their family members, their real property, and the health and stability of the physical environment proximate to Palisades.
Dont Waste Michigan Dont Waste Michigan (DWM) is a 40-year-old grassroots association with over 50 members in southern, western and central Michigan. DWM is located at 811 Harrison St.,
Monroe, MI 48161. DWM works to shut down aging, dangerous nuclear power plants in the Great Lakes Basin; to halt or block the construction of new nuclear power plants; to educate the public about the dangers of nuclear power and nuclear waste, its deadly by-product; and to block the practice of landfilling nuclear waste. DWM has members who live near the Palisades plant. They would intervene to protect their interests in physical health and safety, the health and safety of their family members, their real property, and the health and stability of the physical environment proximate to Palisades.
Three Mile Island Alert Three Mile Island Alert (TMIA) is a nonprofit grassroots organization with approximately 500 members and supporters. TMIA was founded in central Pennsylvania in 1977 as a grassroots advocacy organization opposed to commercial nuclear power for safety and economic reasons, two years before the accident at Three Mile Island, Unit 2. Three Mile Island, Unit 1, which is presently closed and undergoing decommissioning, is more recently being considered for reopening and restoration of power operations, similarly to Palisades.
TMIA opposes a restart for multiple reasons, many relating to the expectations of safe operation of a reactor with some 45 years of operations. TMIA opposes as a matter of policy the proposed restart of Palisades Nuclear Plant. TMIA opposes the grant of the proposed exemption and four operating license amendments for Palisades. TMIA also recognizes that the decisions the Commission makes regarding Palisades will be a precedent for any decisions regarding the attempted restart at Three Mile Island. TMIA has one member who lives near the Palisades plant and would intervene to protect their interests in physical health and safety, the health and safety of their family members, their real property, and the health and stability of the physical environment proximate to Palisades.
Nuclear Energy Information Service Nuclear Energy Information Service (NEIS) is located at 3411 W Diversey Avenue,
- 13, Chicago, IL 60647. NEIS opposes the grant of the proposed exemption and four amendments to Renewed Facility Operating License (RFOL) No. DPR-20 for the Palisades Nuclear Plant (PNP) sought by Holtec Decommissioning International LLC (HDI) Holtec Palisades, LLC, and Palisades Energy, LLC to cause the potential reauthorization of power
operations at Palisades. NEIS is a nonprofit organization committed to ending nuclear power and advocating for sustainable ecologically sound and socially just energy solutions. NEIS educates, activates and organizes the public on energy issues, builds and mobilizes grass roots power and nonviolent opposition to nuclear power, as it advocates for sustainable and ecologically sound energy alternatives. NEIS has over 200 members, one or more of whom lives within 50 miles of Palisades Nuclear Plant. NEIS is concerned that if the NRC authorizes the proposed exemption from NRC regulations, the reopening and restart of Palisades could adversely affect the public health and safety of its members and the integrity of the physical environment in which its members live.
An Atomic Safety and Licensing Board, in a companion docket regarding Palisades, 50-255-LA-3, determined that all of the potential parties have standing to challenge the proposed restart of Palisades. The ASLB decision is found in ADAMS at ML25090A164.
The license amendment request proposing to address the deficient condition of the Palisades steam generators is allegedly supported by an analysis and report from Framatome, Inc., a nuclear energy consulting company. The Framatome report is an attachment to the license amendment request, but the public version of the report has many portions that have been redacted. Although it is difficult, and in some instances impossible, to know the nature of the redacted information, it appears to be technical information claiming to justify the proposed sleeves on the steam generators will be adequate to allow Palisades to safely return to power operation status. It appears to include the results of calculations and other technical specifications that were important to the conclusions in the report that installing sleeves on the steam generators would be the preferred option.
The requesters have retained the expert evaluation of Arnold Gundersen, an experienced nuclear engineer, to evaluate the issues inherent in trying to return Palisades to operational status. Mr. Gundersen has expressed the opinion that the steam generators cannot be repaired, with sleeves or otherwise, and must be replaced. He will be asked to evaluate the Framatome report to assess its analysis and conclusions. Without having access to the technical information redacted from the Framatome report, Mr. Gundersen will not be able to properly evaluate the report and its conclusions and render an expert opinion in support of a contention challenging the license amendment.
In addition, the requesters attorneys, Wallace Taylor and Terry Lodge, have many years of experience in litigating issues regarding nuclear power and nuclear waste, before the NRC and in the courts. They will be able to know how to properly use the information, with Mr.
Gundersens, expert input, to craft contentions to support a petition to intervene in the licensing proceeding.
Based on the foregoing, the Petitioners request that they be provided with an unredacted version of the Framatome report.
/ s/ Terry J. Lodge
/ s/ Wallace L. Taylor Terry J. Lodge Wallace L. Taylor 316 N. Michigan St, Suite 520 4403 1st Ave. N.E., Suite 402 Toledo, Ohio 43604 Cedar Rapids, Iowa 52402 419-205-7084 319-366-2428 (Fax) 419-932-6625 (Fax) 319-366-3886 e-mail: tjlodge50@yahoo.com e-mail: wtaylorlaw@aol.com CO-COUNSEL FOR PETITIONING ORGANIZATIONS