ML25324A400
| ML25324A400 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/20/2025 |
| From: | Blind A - No Known Affiliation |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 57540, 50-255-LA-5, ASLBP 25-990-02-LA-BD01 | |
| Download: ML25324A400 (0) | |
Text
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7 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Jeremy A. Mercer, Chair Dr. Gary S. Arnold Dr. Arielle J. Miller Docket No. 50-255-LA-5 License No. DPR-20 JOINT PETITIONERS MOTION TO WITHDRAW ALL PETITIONS Joint Petitioners respectfully move to withdraw all petitions, supplemental petitions, motions, and contentions previously filed in this proceeding.
On November 20, 2025, the NRC Staff issued its approval of Holtec Palisades, LLCs License Amendment Request and published the associated Safety Evaluation Report and license amendment (ADAMS Accession No. ML25288A099). Because the Staff has approved the amendment, there is no longer any licensing action before this Board to adjudicate.
Any further pursuit of Joint Petitioners filings would be outside the authority of the Atomic Safety and Licensing Board, which does not have jurisdiction to
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7 review, modify, or overturn the Staffs Safety Evaluation or the issued license amendment.
Joint Petitioners therefore withdraw all filings, including:
- The original Petition to Intervene,
- The Supplemental Petition,
- All motions for leave, and
- All contentions and attachments.
This withdrawal is voluntary and made in good faith.
Joint Petitioners reserve all rights available under Commission regulations, including the right to seek Commission review under 10 C.F.R. § 2.341 or to pursue future petitions under 10 C.F.R. §§ 2.206 or 2.802.
CONSULTATION UNDER 10 C.F.R. § 2.323(b)
Holtec Holtec does not object to the withdrawal of Joint Petitioners petitions/contentions.
NRC The NRC Staff does not oppose your motion to withdraw, but we disagree that Because the Staff has approved the amendment, there is no longer any licensing action before this Board to adjudicate. and that any further filings would be outside the authority of the Atomic Safety and Licensing Board, which does not have jurisdiction to review, modify, or overturn the Staffs Safety Evaluation or the
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7 issued license amendment. Pursuant to 10 CFR 50.91(a)(4), as the NRC Staff made a final no significant hazards consideration determination, the amendment is effective on issuance even though adverse public comments have been received and even though a request for a hearing has been filed. Additionally, because the Staff made a final no significant hazards consideration determination the Commission need hold the required hearing only after the amendment is issued.
REQUESTED RELIEF Joint Petitioners respectfully request that the Board:
1.
Grant this Motion to Withdraw, and 2.
Terminate this proceeding and close the docket.
3.
Share my Appeal for Reason Why This Matters After 50 Years with NRC Staff CERTIFICATION UNDER 10 C.F.R. § 2.304(d)
I certify under penalty of perjury that the statements in this filing are true and correct to the best of my knowledge and belief.
Executed this 20 day of November, 2025.
/s/ Alan Blind Alan Blind Pro Se Representative for Joint Petitioners 1000 West Shawnee Road
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7 Baroda, MI 49101 269-303-6306 Appeal for Reason Why This Matters After 50 Years Yes, Holtec and the NRC Staff have now secured approval for one more extension of the fire-protection modifications. But the crucial point the one that should give everyone pause is that this is not the first extension. It is simply the latest in a long line dating back nearly half a century to the 1975 Fire at Browns Ferry Plant.
The NRCs own words about the Browns Ferry fire have guided the industry for 50 years:
The Browns Ferry fire was one of the most significant events in the history of commercial nuclear power.
The fire demonstrated that a single fire can disable redundant safety systems, compromise shutdown capability, and threaten public health and safety.
Appendix R exists because Browns Ferry showed that unprotected circuits can fail simultaneously, defeating defense-in-depth.
These statements are not academic, and they are not simply phrases exchanged in petitions, answers, and repliesthey describe real, persistent vulnerabilities. They are the foundation for every fire-protection requirement that followed Appendix
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7 R, NFPA-805, operator-action feasibility, cable protection, remote shutdown, and safe-shutdown ventilation.
And yet, after decades, the same vulnerabilities identified in the 1980s and placed into the same license condition, still remain uncorrected at Palisades.
Every time the required modifications come due, Palisades asks for one more period of time The NRC calls these schedule changes administrative.
But the underlying vulnerabilities do not change.
And after 50 years of delay, it is reasonable to ask:
What is to prevent Holtec from asking again for another two years and then another, and another? When does this end?
Oh, right: they are only administrative requests.
This is not an argument against nuclear power.
This is not an argument against Palisades.
It is an argument for basic regulatory closure the idea that after half a century, safety requirements adopted in response to the most significant fire in nuclear history should eventually be implemented.
A Documented 50-Year Pattern
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7 This concern is not hypothetical. The record shows a long history of unfinished obligations at Palisades:
1978 Civil Penalty:
The licensee has failed to complete modifications required to assure safe shutdown in the event of a fire.
1990s-2000s: Recurrent hot-short and spurious-operation vulnerabilities across multiple systems.
2008 NRC Enforcement Discretion:
Operator Manual Actions must be shown feasible and reliable.
The NRC will determine whether substantial progress has been demonstrated.
2015, 2018, 2019: NFPA-805 transitions with multiple unfinished items carried forward.
2024-2025: Five additional NFPA-805 modifications now deferred again.
Each extension was justified as temporary. Trust us this time, we will finish the modifications.
But the pattern has repeated for five decades.
The Real Question A Reasonable One
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7 Does calling a schedule change administrative make the underlying safety vulnerability any less real? Unfortunately, its impossible to make an admissible contention on that question but the question itself remains real. Someone needs to care. Who, if not the NRC, the ASLB, the ACRS, or Holtec?
If Palisades has been unable to complete these modifications in 50 years across four owners, multiple regulatory frameworks, repeated enforcement actions, and decades of NRC warnings then what gives confidence that this extension will be the last?
This is not a political question, These are not legal questions, It is not an ideological question, It is a question of reason, experience, and ethics.
When the same safety corrections are deferred for 50 years, at what point does the promise of just two more years lose credibility?
The public deserves a clear, honest answer.