ML25231A050
| ML25231A050 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/18/2025 |
| From: | - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2025-0313, 90FR34019 00022 | |
| Download: ML25231A050 (1) | |
Text
PUBLIC SUBMISSION As of: 8/19/25, 8:21 AM Received: August 18, 2025 Status: Pending_Post Tracking No. meh-e7tz-oqbu 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-0022 Comment on FR Doc # 2025-13501 Submitter Information Name: Anonymous Anonymous General Comment See attached file(s)
Attachments Public Comment to NRC 8/19/25, 8:22 AM NRC-2025-0313-DRAFT-0022.html file:///C:/Users/BHB1/Downloads/NRC-2025-0313-DRAFT-0022.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Justin Poole, Susan Lent, Mary Neely Comment (22)
Publication Date:
7/18/2025 Citation: 90 FR 34019
Dear NRC Staff,
I submit this comment 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 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.
I respectfully submit that this assertion is not correct, and I urge the NRC to reject Holtecs conclusion. I respectfully request that the NRC considers Holtecs LAR submission to be substantive in nature, and thus subject to rigorous NRC review.
I believe that Holtecs proposed change to its license conditions is not administrative, but is in fact substantive, for these distinct and well documented reasons:
- 1. This proposed change seeks to alter an enforceable license condition, one which requires a license amendment. This license condition is not discretionary, it is required for the license.
Regulatory Guide 1.174, Rev. 3: Once a license condition is imposed, it becomes part of the licensing basis and is legally binding on the licensee. Any modification, removal, or relaxation of the license condition requires prior NRC approval through a license amendment under 10 CFR 50.90 or an exemption under 10 CFR 50.12. RG 1.174, Rev.
3, § 2.2.1, ML19342C905
- 2. This proposed change impacts a dual-basis, dual-method evaluation safety system, with deterministic method postaccident cooling requirements that cannot be substituted by fire protection program flexibility and use of PRA method alone.
Appendix R (III.L.1) and NFPA-805 (Section 1.5.1) define safe shutdown to include a loss of offsite power (LOOP). In that scenario, safe cooldown relies on natural circulation. For natural circulation to function, the RCGVS (Reactor Coolant Gas Vent System) must remain operablefrom the control room-during any postulated fire. This requirement is not optional, substitutable, or flexible.
- 3. This proposed change extends a long history of NRC deferred enforcement for Palisades fire protection violations where 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, as determined by the NRC, not as determined by Holtec.
In the August 2024 NRC public meeting, Holtec explicitly stated that all 22 license condition fire protection modifications would be completed before restart. Nearly one
year later, Holtec now proposes to defer S2-15, signaling a significant reversal and undermining the basis for prior NRC planning and public communication. This shift, without a detailed progress assessment or technical justification, undercuts Holtecs credibility and amplifies the need for formal NRC evaluation before any further compliance delay is approved.
- 4. This proposed change 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.
Taken together, or standing independently, each of these reasons provides ample factual and historical evidence to challenge Holtecs assertion that the proposed change is merely administrative.
My family and I have vacationed every summer in Palisades Park for more than 50 years. We purchased property to build a cottage in 1968. I sincerely hope that you will act to protect the health and safety of citizens who work, live and vacation near the Palisades nuclear power plant. That is your mission. I support Alan Blinds position, and have referenced his thoughtful arguments throughout my letter.
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 raised in this comment Thank you for your time and attention to this critically important issue.