ML25231A051
| ML25231A051 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/18/2025 |
| From: | Stark W - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 90FR34019 00023, NRC-2025-0313 | |
| Download: ML25231A051 (1) | |
Text
PUBLIC SUBMISSION As of: 8/19/25, 8:35 AM Received: August 18, 2025 Status: Pending_Post Tracking No. meh-k2aa-eylh 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-0023 Comment on FR Doc # 2025-13501 Submitter Information Name: William Stark Address:
Covert, MI, 49043 Email:williamhstark0630@gmail.com Phone:847-637-7257 General Comment
Dear NRC Staff:
Holtec has requested a delay in completing a firesafety upgrade required under the Palisades Nuclear Plant operating license. Holtec would like to defer completion of these upgrades and claims thisrequestedchange is only "administrative." A proposeddetermination by the NRC Staff states that Holtec's amendment request involves "no significant hazard consideration." The purpose of this comment is to provide input on the NRC Staff'sproposed "no significant hazard" determination.
Holtec previously indicatedin August 2024 that all outstanding license condition fire protection modifications (over 20 items) would be completed before plant re-start. Critical system redundancy, fire protection, and fire suppression are absolutely essential to assuresafe plant operations and emergencyresponse.
However, one of these outstanding items, the S2-15 fire safety upgrade - related to reactor/pressurizer head vent valve modifications and developed as a license condition in 2006 after the Browns Ferry fire -
is a key safety requirement to help preserve "defense-in-depth" and assure critical venting systems and components areoperable in an emergency.
The NRC stated in 2006 that compliance with S2-15 is safety critical and it must be achieved before the startof Operating Cycle 28 (which has now arrived). Holtec, however, has unilaterally decided, despite a long historyof NRC efforts to enforce S2-15 and assure compliance by prior Palisades plantoperators, that these upgrades (which were once acknowledged and agreed to by Holtec in August 2024) are now only "administrative" in nature and, therefore, can be deferred. This is contrary to past rulings by the NRC that only allow an additional period of enforcement discretion: 1) by the agency; and 2) on a case-by-case basis, if the licensee has made substantial progress. Neither of these conditions have been met by Holtec.
Holtec's effort to nowre-frame this critical fire and operating safety requirement as anything less than 8/19/25, 8:36 AM NRC-2025-0313-DRAFT-0023 (1).html file:///C:/Users/BHB1/Downloads/NRC-2025-0313-DRAFT-0023 (1).html 1/2 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Justin Poole, Susan Lent, Mary Neely Comment (23)
Publication Date:
7/18/2025 Citation: 90 FR 34019
mandatory is a disservice to previous NRC enforcement efforts and a danger to the public. The public expects and demandsnothing less than safe plant operations and emergency response. Holtec should not be allowed to re-start the plant without all safety systemsin-place and fully protected. The plant must be able to meet its nuclear safety performance requirements - more specifically, the critical RCGVS valve circuits for the removal of noncondensablegases from the reactor vessel head and pressurizersteam space must be fully protected and safety maintained.
The NRC must not allow Holtec to by-pass a safety critical requirement by simply callingit "administrative." Mode 4 operations must not be allowed until all safety critical license requirements are met. Anything less would undermine public confidence and NRC oversight.
Please do not allow Holtec to defer compliance with safety critical elements.
Thank you -
William Stark 8/19/25, 8:36 AM NRC-2025-0313-DRAFT-0023 (1).html file:///C:/Users/BHB1/Downloads/NRC-2025-0313-DRAFT-0023 (1).html 2/2