ML25204A144
| ML25204A144 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/22/2025 |
| From: | Blind A - No Known Affiliation |
| To: | Office of Nuclear Reactor Regulation |
| Dennis Galvin | |
| Shared Package | |
| ML25157A008 | List: |
| References | |
| OEDO-25-00290, EPID L-2025-CRS-0000 | |
| Download: ML25204A144 (0) | |
Text
From:
Alan Blind To:
Petition Resource Cc:
PalisadesRestartProject
Subject:
[External_Sender] Supplemental Filing to May 2025 10 CFR 2.206 Petition - Omission of Tendon 388F from Required Containment Inspection Date:
Tuesday, July 22, 2025 10:57:29 AM
Subject:
Supplemental Filing to May 2025 10 CFR 2.206 Petition - Omission of Tendon 388F from Required Containment Inspection
Dear NRC Petition Review Board,
I respectfully request that the following supplemental information be added to the record of my May 2025 petition submitted pursuant to 10 CFR § 2.206, titledRequest for NRC Enforcement Action Regarding Omission of Tendon 388F from the 2025 Palisades Containment Tendon Surveillance Inspection.
In that petition, I presented evidence that Holtec Decommissioning International, LLC failed to include tendon 388F an NRC-flagged, non-homologous tendon uniquely replaced during the 1990-1991 Steam Generator Replacement Projectin its 2025 50-Year Containment Tendon Surveillance Inspection Summary Report (ML25062A010). The petition further demonstrated that Holtec submitted this report under the proposed Technical Specifications (TS 5.5.5 and 5.6.7), which govern containment structural integrity and associated surveillance documentation. I asked the NRC to require Holtec to inspect tendon 388F and incorporate it into the surveillance program prior to authorizing any return to operation.
I now submit this critical supplemental development:
A final no significant hazards consideration determination and license amendment approving changes to the operating license and technical specifications to support the reauthorization of power operations at Palisades Nuclear Plant (Palisades) will be issued on or about July 24, 2025.
NRC Notification of Significant Licensing Action, July 17, 2025 (ADAMS Accession No. ML25188A013)E250717t143054_Palisade This action confirms that Holtecs previously proposed Technical Specificationsincluding TS 5.5.5, TS 5.6.7, and SR 3.6.1.2are now formally approved and fully enforceable. Consequently, Holtec's tendon surveillance report, submitted on March 3, 2025, must now be evaluated forfull compliancewith these provisions as a condition of reactor containment operability and NRC authorization to re-enter Mode 4.
As documented in my petition:
Tendon 388F has a unique replacement historyacknowledged by the NRC, including a new tendon installed in 1991 with materials and stress history not shared by the rest of the population.
The tendon surveillance sampling methodology used by Holtecdid not include tendon 388F, nor did it disclose or justify this exclusion in the 2025 report.
Holtec explicitly stated in its submission (ML25062A010) that the report was filedin accordance with Technical Specification 5.6.7and was part of its regulatory compliance for return to service.
With the NRCs final approval of Holtecs TS and Operating License Amendment now in effect,the omission of tendon 388F from the surveillance report is no longer a hypothetical oversight under proposed requirements it is now a matter of enforceable regulatory noncompliance.
In summary, I respectfully request the Petition Review Board to:
- 1. Incorporate this new licensing development into the record of my 10 CFR § 2.206 petition;
- 2. Recognize that the omission of tendon 388F from Holtecs surveillance program now constitutes afailure to complywith approved Technical Specifications TS 5.5.5, TS 5.6.7, and SR 3.6.1.2;
- 3. Require Holtec to perform inspection and analysis of tendon 388F prior to NRC acceptance of the 2025 tendon surveillance report or authorization of Palisades entry into Mode 4.
Thank you for your attention to this serious structural integrity concern and the implications it holds for the safety basis of containment operability.
Sincerely, Alan Blind 1000 West Shawnee Road Baroda, Michigan 49101 a.alan.blind@gmail.com