ML25132A244
| ML25132A244 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/12/2025 |
| From: | NRC |
| To: | NRC/NMSS/DREFS |
| References | |
| Download: ML25132A244 (6) | |
Text
From:
Mary Richmond Sent:
Monday, May 12, 2025 2:04 PM To:
PalisadesRestart-EnvDocsPUBLICem Resource
Subject:
FW: Palisades 401 Certification Letter Attachments:
Palisades 401 Certification FINAL.pdf From: Allison, Joshua (EGLE) <AllisonJ6@michigan.gov>
Sent: Monday, May 5, 2025 10:23 AM To: j.britting@holtec.com Cc: Mary Richmond <Mary.Richmond@nrc.gov>; Alexander, Christine (EGLE)
<ALEXANDERC2@michigan.gov>; Klang, Jennifer (EGLE) <KlangJ@michigan.gov>; Buckmaster, Tarek (EGLE) <BUCKMASTERT@michigan.gov>; McKay, Betsy (EGLE) <McKayB@michigan.gov>
Subject:
[External_Sender] Palisades 401 Certification Letter Good morning, Please see the attached.
All the best, Joshua Allison Secretary Water Quality and Aquatic Nuisance Control Permits Unit Water Resources Division Department of Environment, Great Lakes, and Energy 517-243-7260 l AllisonJ6@Michigan.gov Water Resources Division l Aquatic Nuisance Control l NPDES Permitting
Hearing Identifier:
PalisadesRestart_EnvDocs_Public Email Number:
122 Mail Envelope Properties (SJ0PR09MB10696F2CE1E2CD680CF8F0110E497A)
Subject:
FW Palisades 401 Certification Letter Sent Date:
5/12/2025 2:03:31 PM Received Date:
5/12/2025 2:03:35 PM From:
Mary Richmond Created By:
Mary.Richmond@nrc.gov Recipients:
"PalisadesRestart-EnvDocsPUBLICem Resource"
<PalisadesRestart-EnvDocsPUBLICem.Resource@nrc.gov>
Tracking Status: None Post Office:
SJ0PR09MB10696.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1068 5/12/2025 2:03:35 PM Palisades 401 Certification FINAL.pdf 148392 Options Priority:
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STATE OF MICHIGAN DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY WATER RESOURCES DIVISION CONSTITUTION HALL
- 525 WEST ALLEGAN STREET
- P.O. BOX 30458
- 800-662-9278 GRETCHEN WHITMER GOVERNOR PHILLIP D. ROOS DIRECTOR May 05, 2025 VIA EMAIL Johann Britting Holtec Decommissioning International, LLC 27780 Blue Star Memorial Highway Covert, Michigan 49043
Dear Johann Britting:
Subject:
Clean Water Act (CWA) Section 401 Water Quality Certification with Condition: Palisades Nuclear Power Plants Renewed Facility Operating License No. DPR-20, Covert Township, Van Buren County, Michigan The Michigan Department of Environment, Great Lakes, and Energy (EGLE), Water Resources Division, has reviewed the request sent by Holtec Decommissioning International, LLC (Holtec) for a CWA Section 401 Water Quality Certification (Certification) for the resumption of power operations at Palisades Nuclear Power Plant (Plant). The Certification request was submitted on December 17, 2024, and additional information to complete the request was submitted on December 18, 2024. Pursuant to Section 401 (a)(1) of the CWA, public notice of the EGLEs Water Quality Certification review of the proposed project was published in MiEnviro Portal and in the EGLE Environmental Calendar from March 13, 2025, through April 14, 2025. No comments were received.
As described in the Water Quality Certification request and associated communications, Holtec is applying for an amendment to the Palisades Nuclear Power Plant Renewed Facility Operating License from the U.S. Nuclear Regulatory Commission (NRC) to authorize the resumption of power at Palisades Nuclear Power Plant. Holtec is also applying to the NRC for related licensing actions to support the authorization of the resumption of power operations at the Plant. The resumption of power operations at the Plant is projected for October 2025, pending NRC authorization.
The Plant is located at 27780 Blue Star Memorial Highway, Covert, Van Buren County, Michigan 49043, and the Plant discharges treated wastewater to Lake Michigan through Outfall 001 at Latitude 42.32337, Longitude -86.31557. This wastewater discharge is authorized under National Pollutant Discharge Elimination System (NPDES) permit number MI0001457, which is currently extended. Holtec provided maps of the site and discharge location to EGLE. While operating, the Plant discharges noncontact cooling water, cooling tower blowdown, stormwater, and miscellaneous treated low volume wastewater consisting of steam generator blowdown, demineralizer backwash and regeneration waste, reverse osmosis filter backwash, turbine sump drainage, floor drainage, laboratory waste, and radwaste wastewater. While the Plant is idled, the Plant continues to require the use of cooling water and continues to withdraw water
CWA Section 401 Water Quality Certification with Condition: Palisades Nuclear Power Plants Renewed Facility Operating License Page 2 May 05, 2025 from and discharge wastewater to Lake Michigan. Restarting power operations at the Plant would result in a return to pre-shutdown levels of withdrawal of water from and discharge of treated wastewater to Lake Michigan. The types of wastewater discharged during operations, while idled, and while decommissioning are the same, but less cooling water is required while the plant is idled. Approximately 8.64 million gallons per day (MGD) is currently discharged, and approximately 124 MGD is discharged during normal power generating operations. No changes to the quantity or quality of the discharge to Lake Michigan are expected with the resumption of power operations compared with when the Plant was operating pre-decommissioning.
Holtec provided descriptions and an aerial photograph of current site conditions. Changes including the addition and removal of certain buildings and structures within the existing developed area at the Plant have taken place since decommissioning began and are planned with the resumption of power operations. However, these changes are not expected to affect the quantity or quality of water discharged to Lake Michigan. Descriptions of groundwater conditions and use and surface water use were also provided. Holtec provided a list of federal, state, and local environmental permits and authorizations held by the Plant as well as additional approvals sought by the Plant related to the Plant restart. Holtec requested a pre-filing meeting with EGLE for this Section 401 Water Quality Certification, and the pre-filing meeting was held on November 26, 2024.
Provided all required EGLE permits are issued and complied with, no adverse impacts to receiving water quality are anticipated from the resumption of power operations at the Plant, as described in the Section 401 Water Quality Certification request submitted on December 17, 2024, and completed on December 18, 2024. Adherence to the extended NPDES permit and future NPDES permit will assure that the discharge from Palisades Nuclear Power Plant to Lake Michigan by Holtec will comply with Section 401 of the CWA and will assure Michigans Water Quality Standards are met, provided the following condition is met:
Condition 1: Any discharge of wastewater from Palisades Nuclear Power Plant to Lake Michigan, or any other navigable waters, shall be authorized under the Plants NPDES permit.
Explanation: The provisions of the Plants NPDES permit (MI0001457) assure that the discharge from the Plant to Lake Michigan will comply with the applicable provisions of sections 301, 302, 303, 306, and 307 of the CWA and Part 31, Water Resources Protection, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (NREPA). The NPDES permit accounts for the possibility of the Plant resuming power operations or continuing to decommission.
CWA Section 401 Water Quality Certification with Condition: Palisades Nuclear Power Plants Renewed Facility Operating License Page 3 May 05, 2025 This Certification is contingent on the facility operating in accordance with the Section 401 Water Quality Certification request submitted on December 17, 2024, and completed on December 18, 2024. If changes in operation that affect the discharge of wastewater to Lake Michigan, or any other waters of the state, are proposed, Holtec shall notify EGLE and the NRC. Such changes to the proposed operation may warrant a modification of certification pursuant to Title 40 of the Code of Federal Regulations, Part 121, State Certification of Activities Requiring a Federal License or Permit, Section 121.10 prior to implementing the changes.
The Certification is subject to the following:
- 1. It is the duty of Holtec to comply with the water quality conditions of the Certification. Noncompliance with any water quality condition may constitute a violation of the NREPA and/or the Federal Water Pollution Control Act and constitute grounds for enforcement action; Certification modification; or denial of a future application.
- 2. Nothing in the Certification shall be construed to relieve Holtec from civil or criminal penalties for noncompliance with applicable state or federal law, regardless of whether such noncompliance is due to factors beyond Holtecs control, such as accidents, equipment breakdowns, labor disputes, or contractor performance.
- 3. Nothing in the Certification shall be construed to preclude the institution of any legal action or relieve Holtec from any responsibilities, liabilities, or penalties to which Holtec may be subject under Section 311 of the Federal Water Pollution Control Act except as are exempted by federal regulations.
- 4. Nothing in the Certification shall be construed to preclude the institution of any legal action or relieve Holtec from any responsibilities, liabilities, or penalties established pursuant to any applicable state or federal law.
- 5. The State of Michigan reserves the right to seek civil and/or criminal penalties and liabilities under applicable law for natural resource damages that may occur.
- 6. Nothing in the Certification shall relieve Holtec from the requirement to obtain any other necessary state, federal, or local permits, including permits from EGLE, certifications, licenses, or approvals for project implementation.
- 7. The Certification does not convey property rights in either real estate or material, nor does it authorize any injury to private property or invasion of public or private rights.
CWA Section 401 Water Quality Certification with Condition: Palisades Nuclear Power Plants Renewed Facility Operating License Page 4 May 05, 2025 If you have questions regarding this letter, please contact Betsy McKay at 517-599-3118 or McKayB@Michigan.gov or you may contact me.
Sincerely, Christine Alexander, Manager Permits Section Water Resources Division cc:
Jen Klang, EGLE Tarek Buckmaster, EGLE Betsy McKay, EGLE Mary Richmond, NRC