ML25225A169
| ML25225A169 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/10/2025 |
| From: | Blind A - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2025-0313, 90FR34019 00013 | |
| Download: ML25225A169 (1) | |
Text
PUBLIC SUBMISSION As of: 8/13/25, 12:51 PM Received: August 10, 2025 Status: Pending_Post Tracking No. me5-sg2z-imxy 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-0013 Comment on FR Doc # 2025-13501 Submitter Information Name: Alan Blind Address:
Baroa, MI, 49101 Email:a.alan.blind@gmail.com Phone:269-303-6396 General Comment This comment challenges the NRCs preliminary no significant hazards determination for Holtecs June 24, 2025 License Amendment Request to defer completion of reactor vessel head and pressurizer vent valve modifications. These valves were originally required by NUREG-0737 Item II.B.1 to be governed by Technical Specifications, meaning the proposed deferral affects a credited TS function and must be evaluated under the three criteria in 10 CFR 50.92(c). Holtecs NSHC analysis omits this TS-specific evaluation, failing to address the potential for increased accident consequences, the creation of new accident scenarios, and the reduction of established safety margins. Without such an analysis, the preliminary NSHC finding is procedurally and substantively invalid.
The full coment is attached.
Attachments Comment CLB 8/13/25, 12:57 PM NRC-2025-0313-DRAFT-0013.html file:///C:/Users/BHB1/Downloads/NRC-2025-0313-DRAFT-0013.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Justin Poole, Susan Lent, Mary Neely Comment (13)
Publication Date:
7/18/2025 Citation: 90 FR 34019
Docket ID NRC-2025-0313 Comments on Proposed No Significant Hazards Consideration Determination Holtec Palisades, LLC - Palisades Nuclear Plant
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 S2-15 involves no significant hazards consideration (NSHC). I strongly disagree with this conclusion.
I have no comments on Table S2-13.
The NRCs finding of no significant hazards is procedurally and technically flawed because it fails to account forand evaluate as part of its NSHCthe potential that the reactor vessel head and pressurizer vent valves in Table S2-15 are Technical Specification (TS)-controlled equipment under the Palisades Current Licensing Basis (CLB).
NUREG-0737, Enclosure I, Item II.B.1 contains an explicit check mark in the Technical Specifications Required column for these vent valves. If
the TS requirement remains in the CLB, any change to the operability, configuration, or implementation date of this function is a TS amendment, not merely an administrative NFPA-805 schedule change.
Background:
TS Requirements for Reactor Coolant Vent Valves NUREG-0737, Clarification of TMI Action Plan Requirements, Enclosure I, Item II.B.1 (Reactor-coolant-system vents) was incorporated into the Palisades CLB through FSAR Section 4.8, Primary Coolant Gas Vent System (ML21125A327, Rev. 35), which 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 system was installed pursuant to NUREG-0737, Topic II.B.1.
Item II.B.1 of NUREG-0737 further specifies that these valves shall have adequate flow capacity and be capable of being remotely operated from the control room, and that TS are required for their operability. This establishes them as a credited design-basis function with enforceable operability requirements.
FSAR Revision 35 further establishes that the Primary Coolant Gas Vent System (PCGVS) must meet the requirements of NUREG-0737, Item II.B.2, Vents from High Points in the Reactor Coolant System.
Item II.B.2 specifies that the vent paths shall have adequate flow capacity and be capable of being remotely operated from the control room, and that they must be operable under accident conditions to remove steam and non-condensible gases which could impede natural circulation cooling. By explicitly stating in FSAR Section 4.8 that the PCGVS was installed pursuant to NUREG-0737, Topic II.B.1 and is designed to satisfy these functional and operational requirements, the CLB unambiguously
links the Palisades vent valve design, operability, and testing obligations to the full NUREG-0737 Item II.B.2 criteria.
If these valves were relocated from TS to another CLB document (e.g.,
FSAR) under a TS improvement program, there must be a documented, NRC-approved change in the docketed record. I could not find such a document in ADAMS. Absent such approval, their omission from the current Palisades TS represents a potential condition outside the design basis, reportable under 10 CFR 50.72(b)(3)(ii)(B) and 10 CFR 50.73(a)(2)(ii)(B).
Omission from Holtecs NSHC Analysis Holtecs NSHC justification in the June 24, 2025 LAR does not address the Technical Specification (TS) applicability of the reactor vessel head and pressurizer vent valves, nor does it evaluate the change under the three explicit criteria in 10 CFR 50.92(c) that must be applied when a TS function is affected. If, as established in NUREG-0737 Item II.B.1, these vent valves were originally required to be governed by TS, then deferring their operability date is not merely an administrative extension of a license condition it is effectively a TS amendment, which requires a different and more rigorous NSHC analysis.
Under 10 CFR 50.92(c), a valid NSHC analysis for a TS amendment must explicitly evaluate:
1.
Significant increase in the probability or consequences of an accident previously evaluated
- The FSAR (Rev. 35, § 4.8) confirms the vent valves are credited to meet NUREG-0737 Item II.B.1 requirements to maintain natural circulation cooling during loss-of-forced-flow events. Deferring completion of required modifications could impair this capability during design-basis events, directly affecting core cooling and accident mitigation functions.
2.
Creation of the possibility of a new or different kind of accident from any previously evaluated
- Deferring operability of a credited design-basis function alters the plants accident response capability and could create new failure modes or operational vulnerabilities if alternative venting is used in place of the qualified, remotely operable valves required by NUREG-0737.
3.
Significant reduction in a margin of safety
- TS operability requirements for these valves exist to preserve
safety margins for natural circulation and core heat removal. Post-TMI lessons learned established that immediate remote operability from the control room was essential to ensure this margin; deferring that capability without TS-level justification erodes the safety margin built into the plants licensing basis.
Holtecs June 24, 2025 NSHC evaluation does not explicitly address these TS-specific criteria for the vent valves. Instead, the LAR treats the change as an administrative extension of a license condition deadline, omitting the TS functional analysis required if the valves remain part of the Palisades Current Licensing Basis as a TS-governed function. This omission undermines the procedural validity of the NRCs preliminary no significant hazards finding, as the evaluation required by 10 CFR 50.92(c) for the specific TS function was never performed.
Conclusion and Request Contrary to Holtecs assertion that the deferral of Table S2-15 is administrative in nature, the vent valve function has a documented licensing basis link to Technical Specifications. If so, deferring its required modifications without a TS amendment process and function-specific NSHC analysis is procedurally deficient.
I respectfully request that the NRC:
1.
Reject the preliminary finding of no significant hazards consideration for this LAR.
2.
Require Holtec to confirm the TS status of the reactor vessel head and pressurizer vent valves, and if confirmed, submit a revised NSHC analysis addressing each 10 CFR 50.92(c) criterion for the TS function.
3.
Ensure that any final NSHC determination fully considers the safety significance and licensing basis role of these valves, as established by NUREG-0737 and the Palisades FSAR.
4.
Provide the public an opportunity to comment on any revised NSHC analysis before issuing a final determination.
This public comment supplements my prior filings and should be considered in the record of this proceeding.
Sincerely, Alan Blind 1000 West Shawnee Road
Baroda, MI 49101 a.alan.blind@gmail.com