ML25231A045
| ML25231A045 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/15/2025 |
| From: | Jennings J - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 90FR34019 00017, NRC-2025-0313 | |
| Download: ML25231A045 (1) | |
Text
PUBLIC SUBMISSION As of: 8/19/25, 7:09 AM Received: August 15, 2025 Status: Pending_Post Tracking No. med-6zha-wxu8 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-0017 Comment on FR Doc # 2025-13501 Submitter Information Name: James Scott Jennings Address:
Covert, MI, 45226 Email:ecruit@gmail.com Phone:5132956362 General Comment Docket ID NRC-2025-0313
Dear NRC Staff,
I was born in 1971 and have vacationed approximately a mile from Palisades Park Nuclear power plant ever since.
Please accept my comment to provide input on the NRC Staff'sproposed determination that Holtec's license amendment request involves "no significant hazards consideration" (NSHC).
I respectfully request that the NRC reject Holtecs assertion that the proposed change is administrative in nature, and that it withhold final action on the NSHC determination and license amendment until the Atomic Safety and Licensing Board has fully reviewed the related safety and legal issues that have been raised.Holtec asserts that the proposed change to defer S2-15 is administrative in nature. I respectfully submit that this assertion is not correct, and I urge the NRC to reject Holtecs conclusion.
As explained to me by former Palisades Engineering Director Alan Blind, Holtecs proposed change to its license conditions is not administrative for multiple 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.
8/19/25, 7:11 AM NRC-2025-0313-DRAFT-0017.html file:///C:/Users/BHB1/Downloads/NRC-2025-0313-DRAFT-0017.html 1/2 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Justin Poole, Susan Lent, Mary Neely Comment (17)
Publication Date:
7/18/2025 Citation: 90 FR 34019
-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.
-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 grateful for the opportunity to provide public comments on this important Southwest Michigan nuclear safety issue.
8/19/25, 7:11 AM NRC-2025-0313-DRAFT-0017.html file:///C:/Users/BHB1/Downloads/NRC-2025-0313-DRAFT-0017.html 2/2