ML25219A059
| ML25219A059 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/06/2025 |
| From: | Blind A - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2025-0313, 90FR34019 00007 | |
| Download: ML25219A059 (1) | |
Text
PUBLIC SUBMISSION As of: 8/7/25, 7:12 AM Received: August 06, 2025 Status: Pending_Post Tracking No. mdz-tlip-u4o4 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-0007 Comment on FR Doc # 2025-13501 Submitter Information Name: Alan Blind Address:
Baroda, MI, 49101 Email:a.alan.blind@gmail.com Phone:269-303-6396 General Comment This public comment opposes the NRCs preliminary finding of no significant hazards consideration (NSHC) regarding Holtecs proposed deferral of NFPA-805 fire protection modifications at the Palisades Nuclear Plant. It highlights Holtecs failure to evaluate the continued reliance on compensatory fire watchesparticularly the inappropriate assignment of these duties to security officers. This longstanding practice has drawn prior NRC enforcement attention and raises unresolved safety and security concerns.
Contrary to Holtecs claim that the deferral is merely administrative, the burden on security staff is a material factor that must be evaluated in the NSHC analysis. More details are provided in the included PDF file.a Attachments Comment 3 8/7/25, 7:13 AM NRC-2025-0313-DRAFT-0007.html file:///C:/Users/BHB1/Downloads/NRC-2025-0313-DRAFT-0007.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Justin Poole, Susan Lent, Mary Neely Comment (7)
Publication Date:
7/18/2025 Citation: 90 FR 34019
Dear NRC Staff,
This comment is submitted in response to the U.S. Nuclear Regulatory Commissions (NRCs) preliminary determination that Holtecs June 24, 2025 License Amendment Request (LAR) to defer License Condition NFPA-805 Table S2 involves no significant hazards consideration (NSHC). I strongly disagree with this conclusion.
The NRCs finding of no significant hazards is procedurally and technically flawed because it fails to account forand evaluate as part of its No Significant Hazards Consideration (NSHC)the extended reliance on compensatory fire watches, a temporary fire protection measure originally permitted under deferred enforcement conditions. More specifically, the NRCs evaluation omits consideration of the impact of assigning these duties to security officers, whose primary role is to implement the NRC-approved Security Plan. This omission further undermines Holtecs assertion that the proposed change to extend the full transition to NFPA-805 is merely administrative.
Background:
Regulatory Requirements for Evaluating Compensatory Measures, Security Department Fire Watches
In its December 9, 2008 enforcement discretion letter to Palisades (ML083260577), the NRC agreed to extend the period of enforcement discretion for the licensees failure to complete the fire protection upgrades required under 10 CFR 50, Appendix Rcontingent upon full transition to NFPA-805. In doing so, the NRC made clear that any future request to extend the implementation schedule under this deferred enforcement policy must include, at a minimum, the following element:
A list of known fire protection non-compliances and the associated compensatory measures.
This requirement has remained in effect is part of the current Palisades Licensing Basis, and continues to apply to requests like Holtecs today, which seek to defer fire protection modifications originally mandated under License Condition Amendment 254, Table S2.
Yet Holtecs NSHC evaluation fails to include any assessment of the ongoing compensatory measures associated with the License Condition Table S2 fire protection deficiencyspecifically the continued reliance on hourly fire tours by
security personnel in lieu of fully qualified fire detection and suppression infrastructure.
Security Officers as Fire Watch Personnel: A Known Safety and Security Concern The decision to assign compensatory fire watch duties to security officers is not merely administrative as Holtec claims in its LARit has been the subject of serious scrutiny by the NRC and the security officers themselves. This practice places undue strain on limited security resources, undermines the implementation of the NRC-approved Security Plan, and imposes dual-role responsibilities that have historically proven unsustainable.
While NRC Security Inspection Reports details are not typically made public, making it difficult to cite specific findings, I am confident that NRC reviewers of this LAR in consultation with NRC Security Inspectors would confirm the concerns raised here. Nevertheless, the following publicly available accounts clearly illustrate the seriousness of the issue:
In 2016, Entergy placed 22 security officers at Palisades on paid leave after inconsistencies were discovered in fire watch documentation. As reported by the Associated Press, Entergy acknowledged that security personnel had been assigned fire patrol dutiesan inappropriate role for Security Officers.
The NRC subsequently issued Inspection Report 05000255/2018416 and Investigation Report 3-2016-010 (ML19074A313), which documented both a Severity Level IV violation and a "Green" finding of security significance.
The NRC cited programmatic failures in training, supervision, and oversight, stating that deviations from standards and expectations were not corrected promptly and that leaders failed to ensure adequate oversight of both employees and contractors assigned fire watch responsibilitiesFire Tours.
Despite these findings, Holtecs current June 2025 LAR contains no reference to these previous security-related findings, nor any evaluation of the risks associated with continuing this compensatory practice.
Omission from Holtecs NSHC Analysis
Holtecs NSHC justification does not evaluate the impact of extending compensatory fire watches, as required by NRC for extending the period of deferred enforcementnor does it disclose or assess the use of security officers for this task. By omitting this critical information, Holtec has failed to meet the threshold for a valid NSHC evaluation under 10 CFR § 50.92.
The continued use of security staff for fire watch duties constitutes an operational burden with implications for both safety and physical security. It should have triggered a more robust assessment under Holtecs §50.92 evaluation and NRCs review, particularly considering the documented regulatory history and enforcement actions related to this issue.
Conclusion and Request Contrary to Holtecs assertion that the License Condition Table S-2 deferral is administrative in nature, the associated compensatory measuresespecially the use of dual-role security/firewatch personnelare not administrative. They have real-world safety, compliance, and human performance consequences that have previously resulted in NRC violations and must be evaluated in any determination of hazard significance.
I respectfully request that the NRC:
1.
Reject the preliminary finding of no significant hazards consideration as it applies to Holtecs proposed deferral of License Condition Table S-2.
2.
Require Holtec to submit a full disclosure and impact evaluation of all compensatory measures associated with the deferred fire protection modifications.
3.
Evaluate the operational and safety implications of continued reliance on security officers for fire patrols as part of any final NSHC determination.
This public comment is submitted as a supplement to prior comments submitted on July 23, 2025 (ML25204A056) and July 31, 2025, and should be considered jointly in the record of this proceeding.
Sincerely, Alan Blind 1000 West Shawnee Road Baroda, MI 49101 a.alan.blind@gmail.com