ML25217A037
| ML25217A037 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/04/2025 |
| From: | Stephens M - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2025-0313, 90FR34019 00006 | |
| Download: ML25217A037 (1) | |
Text
PUBLIC SUBMISSION As of: 8/5/25, 6:53 AM Received: August 04, 2025 Status: Pending_Post Tracking No. mdx-8rwo-buzm Comments Due: August 18, 2025 Submission Type: Web Docket: NRC-2025-0313 Holtec Decommissioning International, LLC, on behalf of Holtec Palisades, LLC; Palisades Nuclear Plant; License Amendment Request Comment On: NRC-2025-0313-0001 Holtec Palisades, LLC; Palisades Nuclear Plant; License Amendment Application Document: NRC-2025-0313-DRAFT-0006 Comment on FR Doc # 2025-13501 Submitter Information Name: Mary Lee Stephens Address:
Covert, MI, 49043 Email:stephensmarylee@gmail.com General Comment
Dear NRC Staff,
This comment is submitted to challenge the NRCs preliminary finding of No Significant Hazards Consideration (NSHC) for Holtecs June 24, 2025 License Amendment Request (LAR), docketed under ADAMS Accession No. ML25175A275.
This submission applies to the two license condition change proposed by Holtecspecifically, Table S2-15 concerning the Reactor/Pressurizer Head Vent Valve Modification.
Holtec asserts that the proposed change to defer S2-15 is administrative in nature. This assertion is not correct, and I urge the NRC to reject Holtecs conclusion. Holtecs proposed change to its license conditions is not administrative for three distinct and well-documented reasons:
It seeks to alter an enforceable license conditionrequiring a license amendmentnot a discretionary programmatic element.
It impacts a dual-basis, dual-method evaluation safety system, with deterministic method post-accident cooling requirements that cannot be substituted by fire protection program flexibility and use of PRA method alone.
It extends a long history of NRC deferred enforcement for Palisades fire protection violationswhere the NRC has already emphasized, starting in 2006, that further delay, and conditioned for the deferred enforcement, is only permissible when substantial progress has been demonstrated.
8/5/25, 7:59 AM NRC-2025-0313-DRAFT-0006.html file:///C:/Users/BHB1/Downloads/NRC-2025-0313-DRAFT-0006.html 1/2 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Justin Poole, Susan Lent, Mary Neely Comment (6)
Publication Date:
7/18/2025 Citation: 90 FR 34019
It involves corrective actions for Palisades the NRC previously found to be delayed beyond a time frame consistent with their safety significancea finding made in the NRCs 1996 civil penalty letter, which stated that the licensees corrective actions were not implemented within a time frame consistent with the potential safety significance of the deficiencies.
Each of these points is independently sufficient to refute Holtecs claim that the change is administrative.
Taken together, they underscore why Holtecs LAR submission must be treated as a substantive request subject to rigorous NRC review.
I am writing on behalf of myself and my community who live next to the plant. We are not against nuclear power. We simply strongly feel if this plant is to reopen, and set a precedent for other decommissioned plants across the country to reopen, our safety must be guaranteed.
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