ML25224A084
| ML25224A084 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/10/2025 |
| From: | Blind A - No Known Affiliation |
| To: | Office of Nuclear Reactor Regulation |
| Dennis Galvin | |
| References | |
| OEDO-25-00290, EPID L-2025-CRS-0000 | |
| Download: ML25224A084 (0) | |
Text
August 10, 2025 Docket 05000255 of 1
10 10 CFR 2.206 Petition Request for Enforcement Action Against Palisades Nuclear Plant for Violation of NUREG-0737 Technical Specification Requirement for Reactor Coolant Vent Valves Submitted by:
Alan Blind 1000 West Shawnee Road Baroda, Michigan 49101 a.alan.blind@gmail.com Summary of 10 CFR 2.206 Petition Alleging Failure to Report a Condition Outside the Design Basis - Missing Technical Specification for Reactor Coolant Vent Valves This petition is submitted pursuant to 10 CFR 2.206 and alleges that Holtec Palisades, LLC, has violated 10 CFR 50.72(b)(3)(ii)(B) and 10 CFR 50.73(a)(2)(ii)(B) by failing to report a condition that represents a departure
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10 from the plants Current Licensing Basis (CLB) and constitutes a condition outside the design basis of the plant.
NUREG-0737, Clarification of TMI Action Plan Requirements, Enclosure I, Item II.B.1, required that reactor vessel head and pressurizer vent valves be governed by Technical Specifications (TS) as part of the NRC-mandated implementation of NUREG-0578 recommendations following the Three Mile Island Unit 2 accident. This requirement was incorporated into the Palisades design basis via license condition and carried forward into the Final Safety Analysis Report (FSAR).
However, a review of the current NRC approved Palisades Technical Specifications (ML25157A127) reveals no Limiting Condition for Operation (LCO), Surveillance Requirement (SR), or other TS provision explicitly governing the operability of the Primary Coolant Gas Vent System (PCGVS). If this TS requirement was removed without documented NRC approval under 10 CFR 50.90 or relocation to another enforceable CLB document, the plant is operating with a licensing basis compliance gap.
Under NRC regulations, the discovery of such a condition obligates the licensee to make an 8-hour report under 10 CFR 50.72(b)(3)(ii)(B) and a
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10 follow-up Licensee Event Report under 10 CFR 50.73(a)(2)(ii)(B). No such reports appear in the NRCs ADAMS record for Palisades.
Here is a screenshot of NUREG-0737, Enclosure 1, Item II.B.1.
I. Petitioners Allegation Holtec Palisades, LLC, as the current licensee, is not in compliance with the requirement established in NUREG-0737, Enclosure I, Item II.B.1, that reactor vessel head and pressurizer vent valves be governed by Technical Specifications. The requirement to maintain these valves under TS control has not been located in the current Palisades TS, and no docketed NRC approval for removal or relocation has been identified.
Because NUREG-0737 explicitly marked TS Required for this safety requirement, and because Revision 35 of the Palisades FSAR (ML21125A327) incorporates all NUREG-0737 requirements for the PCGVS into the licensing basis including continuous remote operability
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10 from the control room the absence of an enforceable TS provision represents an unresolved variance from the CLB. Here is a screenshot from FSAR revision 35:
II. Licensing Basis Background The NRC defines a plants Current Licensing Basis in 10 CFR 54.3(a) as the set of NRC requirements applicable to a specific plant and a licensees written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basis, including all modifications and additions to such commitments over the life of the license.
The CLB includes:
Applicable NRC regulations in 10 CFR Parts 20, 50, 51, 54, 73, etc.
License conditions and Technical Specifications (10 CFR 50.36).
Approved design basis information (10 CFR 50.2).
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10 Commitments in the FSAR/UFSAR (10 CFR 50.71(e)).
NRC orders, confirmatory actions, and enforcement actions.
Regulatory guidance, NUREGs, and industry standards explicitly committed to and approved by the NRC.
Commitments in docketed correspondence, submittals, and NRC safety evaluations.
Any change to the CLB must be evaluated under 10 CFR 50.59, and if necessary, submitted for NRC approval under 10 CFR 50.90 or 50.12.
III. NUREG-0578 and NUREG-0737 Requirements for Reactor Coolant Vents Following the TMI-2 accident, NUREG-0578 identified the need for high-point vents from the reactor vessel head and pressurizer to remove steam and non-condensable gases that could impede natural circulation cooling.
NUREG-0737 formalized this as a mandatory license condition for all PWRs, with Enclosure I, Item II.B.1 stating:
All PWR licensees and applicants shall provide a vent path from the reactor vessel head and from the pressurizer steam space to permit removal of non-condensable gases that may inhibit natural
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10 circulation. These paths shall have adequate flow capacity and be capable of being remotely operated from the control room.
In the NUREG-0737 Enclosure I table, the column Technical Specifications Required is checked for Item II.B.1, meaning the NRC intended for this safety enhancement to be governed by enforceable TS requirements.
IV. FSAR Implementation of NUREG-0737 for the PCGVS FSAR (ML21125A327 - Revision 35, Approved July 25, 2025)
Section 4.8, Primary Coolant Gas Vent System states:
The Primary Coolant Gas Vent System (PCGVS) is designed to vent steam or non-condensible gases from the reactor vessel head and pressurizer areas of the Primary Coolant System. This is done to assure core cooling during natural circulation is not inhibited. This system was installed pursuant to NUREG-0737, Topic II.B.1.
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10 The FSAR describes relief and safety valves configured to vent steam and non-condensable gases from both the reactor vessel head and the pressurizer under normal and accident conditions, consistent with NUREG-0737s requirements.
V. Significance of Missing TS Requirement Because NUREG-0737 explicitly called for TS coverage, its absence from the current Palisades TS without NRC-approved relocation or removal represents:
A variance from the licensing basis; A potential violation of 10 CFR 50.36 requirements; A condition outside the design basis under 10 CFR 50.72(b)(3)(ii)(B) and 10 CFR 50.73(a)(2)(ii)(B), requiring 8-hour notification and a 60-day LER; A gap in enforceable operability requirements for a system whose continuous availability is a post-TMI safety enhancement.
Procedural Defect in Holtecs June 24, 2025 LAR (ML25175A275)
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10 Holtecs June 24, 2025 License Amendment Request (LAR) seeks to revise the Palisades NFPA-805 license condition to extend completion of Table S-2, Item 15 the reactor vessel head and pressurizer vent valves. The LAR describes this change solely as a license condition amendment, with no associated Technical Specification (TS) markup or TS Bases changes.
However, NUREG-0737, Enclosure I, Item II.B.1 (Reactor-coolant-system vents) includes a marked requirement that Technical Specifications be established for these valves. If this TS requirement remains part of the Palisades Current Licensing Basis (CLB), as indicated by the NUREG-0737 checklist and the design basis description in FSAR Revision 35 (§4.8), then Holtecs submittal is procedurally defective under 10 CFR 50.90.
A change to a CLB element governed by Technical Specifications must be processed as a TS amendment under 10 CFR 50.36, which requires:
Inclusion of proposed TS markup and Bases changes Justification meeting 10 CFR 50.36(c) criteria for TS content Federal Register notice identifying it as a TS amendment Without resolving the status of the TS requirement for these valves, the NRC cannot lawfully approve Holtecs LAR in its current form. Doing so
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10 would risk removing or altering a TS-governed safety function without the required TS amendment process, and without the Commissions explicit finding that the change maintains adequate protection.
VI. Requested NRC Enforcement Actions In light of the above, I respectfully request that the NRC:
1.
Determine whether the NUREG-0737, Item II.B.1 Technical Specification requirement for reactor vessel head and pressurizer vent valves remains part of the Palisades CLB.
2.
If yes, require Holtec to supplement its June 24, 2025 LAR (ML25175A275) to:
Include the associated TS and Bases markup for Item II.B.1 vent valves, or
Provide evidence of prior NRC approval relocating the TS requirement to another enforceable licensing basis document.
3.
If no approved relocation exists, direct Holtec to:
File a proper TS amendment request under 10 CFR 50.36, or
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Restore the applicable TS requirement before NRC review of the Table S-2 Item 15 schedule extension proceeds.
4.
Require Holtec to comply with 10 CFR 50.72(b)(3)(ii)(B) and 50.73(a)
(2)(ii)(B) reporting for a condition outside the design basis if the TS requirement is confirmed to be missing from the CLB without prior NRC approval.
5.
Withhold final approval of the June 24, 2025 LAR until the TS compliance question is resolved and all required amendment processes are completed.