PNP 2025-019, 2024 Annual Non-Radiological Environmental Operating Report
| ML25090A236 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/31/2025 |
| From: | Noval W Holtec Palisades |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| PNP 2025-019 | |
| Download: ML25090A236 (1) | |
Text
27780 Blue Star Highway, Covert, MI 49043 1 Holtec Palisades, LLC (Holtec Palisades) is the licensed owner of PNP. Holtec Decommissioning International, LLC (HDI) is the licensed operator of PNP while the facility is in decommissioning.
Pursuant to the license transfer application submitted in connection with the PNP restart (Reference),
licensed authority will transfer from HDI to Palisades Energy, LLC (Palisades Energy) upon NRCs approval of the transition from decommissioning back to power operations. Holtec Palisades will remain the licensed owner of PNP.
PNP 2025-019 RFOL Appendix B 5.4.1 March 31, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Docket No. 50-255 Renewed Facility Operating License No. DPR-20
Reference:
Holtec Decommissioning International, LLC letter to U.S. Nuclear Regulatory Commission, Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments, dated December 6, 2023 (ADAMS Accession No. ML23340A161)
Subject:
2024 Annual Non-Radiological Environmental Operating Report In accordance with the requirements of Palisades Nuclear Plant (PNP) Renewed Facility Operating License (RFOL) Appendix B, Environmental Protection Plan (Non-Radiological),
section 5.4.1, Routine Reports, Holtec1 on behalf of Holtec Palisades, LLC (Holtec Palisades) is submitting the 2024 Annual Non-Radiological Environmental Operating Report for PNP. The enclosed report describes the implementation of the Environmental Protection Plan from January 1, 2024, through December 31, 2024.
This letter contains no new and no revised regulatory commitments.
Should you have any questions or require additional information, please contact Amy Filbrandt, Acting Regulatory Assurance Manager at (269) 764-2520.
Respectfully, William Noval Director Regulatory Affairs Holtec Decommissioning International, LLC Digitally signed by William Noval DN: cn=William Noval, o=HDI, ou=Regulatory Affairs, email=w.noval@holtec.com Date: 2025.03.31 13:51:01 -04'00' William Noval
PNP 2025-019 Page 2 of 2
Enclosure:
Palisades Nuclear Plant Annual Non-Radiological Environmental Operating Report
- Herbicide and Pesticide Treatments cc:
NRC Region Ill Regional Administrator NRC Decommissioning Inspector - Palisades Nuclear Plant NRC NMSS Project Manager - Palisades Nuclear Plant
Enclosure to PNP 2025-019 Palisades Nuclear Plant Annual Non-Radiological Environmental Operating Report
PNP 2025-019 Enclosure Page 1 of 3 2024 ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT
1.0 BACKGROUND
Appendix B of the Renewed Facility Operating License for the Palisades Nuclear Plant (PNP) requires the submittal of an annual environmental operating report to the Nuclear Regulatory Commission (NRC), describing the implementation of the Environmental Protection Plan (EPP) during the previous year. The reporting period is January 1, 2024, through December 31, 2024.
The PNP operated for 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> and produced a net total of 0 MWHe during 2024.
Palisades was removed from service on May 20, 2022 at 15:57.
2.0 ENVIRONMENTAL IMPACT EVALUATIONS During 2024, there were four projects that were reviewed in the Environmental Review process in accordance with DSP-EN-001. The Engineering Changes are as follows:
Engineering Change (EC), CCDECP-PAL-0015 review was performed to install a new power panel in the Northeast Yard Power Panel utilizing a combination of existing cable tray, existing spare conduits, new cable tray and new conduits. The cables were routed through an existing cable tray to a new vertical cable tray that connects to two existing 3 conduits. Which then connects to the load center 200 room in the service building to a manhole. The cable then exits the manhole below grade in 3 rigid Steel conduit through 2 new penetrations and then routed up to the surface where it is run along the surface.
All work was performed in previously disturbed and paved areas within the PA. No state or environmental permitting was required and there were no environmental impacts or concerns. The EC and panel modification were completed in 2024.
Driven by the State of Michigans commitment to expand in-state carbon-free generation, the site has started a program to build their first two SMR-300 reactor units at the Palisades site. A petition was started to allow Palisades to investigate the site for a suitable location. A Soil Erosion and Sedimentation Control Permit was obtained by the Van Buren County Drain Commissioner prior to the start of investigating the site for future development. As part of the investigation, the site cleared trees and conducted bore-hole drilling in an area less than three acres. This area was located within the Covert Township Environmentally sensitive area but not in a High-Risk Erosion Area or Environmental Area as defined by EGLE. The investigation phase requiring tree clearing and bore-hole drilling was completed in 2024.
Engineering Change (EC), 93328 was evaluated to install new electrical cables for the Cooling Towers. In support of the Palisades Nuclear Plant restart effort, new power cables are being routed from the 4160V F&G Switchgear Building to the A & B Cooling Towers, replacing existing cables that have physically degraded. The cables will be routed in Plastibeton trenches and buried conduits. Spare buried conduits will also be provided for future use. This proposed activity requires excavation in protected dunes requiring a critical dune permit with Michigan Department of Environment and Great Lakes and Energy (EGLE). The EC, and new electrical cables are scheduled to be completed in 2025.
PNP 2025-019 Enclosure Page 2 of 3 Engineering Change (EC), 93350 was performed to install a new building and foundation for Digital Controls Staging Area (DCSA) Building. This proposed activity involves construction, demolition or abandon in place of any site or non-generating facility buildings or structures. An alignment is in progress with Van Buren County regarding the need for a Soil and Erosion permit. The Spill Prevention Program does not require regulatory permitting. The EC, new building and foundation modification are scheduled to be completed in 2025.
There were no additional changes, tests, or experiments that involved un-reviewed environmental questions or EPP changes.
3.0 ADDITIONAL ACTIVITIES AUTHORIZED UNDER NPDES In accordance with the department of Environment, Great Lakes, and Energy (EGLE) requirements a National Pollutant Discharge Elimination System (NPDES) permit application renewal was applied for and verified as being received by the State of Michigan prior to required due dates. Palisades new NPDES permit has not been received from the State of Michigan at this time; however, by submitting by the required due date, in accordance with (IAW) the process Palisades is still covered under the old NPDES permit. No changes at this time are expected to the permit. No additional activities were authorized under the National Pollutant Discharge Elimination System (NPDES) permit. As of this report being written, EGLE, has contacted the site with a few questions, as they are in the process of submitting a draft of the new NPDES permit to the site for review as part of the renewal process. A new permit is expected to be implemented in 2025.
The Air Operating Permit renewal application package was submitted and received by the State prior to the required due date in accordance with Article II, Chapter 1, Part 55 (Air Pollution Control) of P.A.451 of 1994 and the federal Clean Air Act of 1990.
Palisades has received confirmation that the Air Operating Permit application is administratively complete, has been granted an application shield pursuant to Rule 217(1)(a) from EGLE, and therefore the existing permit will not expire until the renewal permit has been issued or denied.
4.0 UNUSUAL ENVIRONMENTAL EVENTS No unusual environmental events occurred during 2024.
5.0 ENVIRONMENTAL MONITORING The site Building and Grounds department treated areas of the property for vegetation control and security needs during early 2024. North Shore Pest Control, Inc. was employed in 2024 to treat areas of the property for ticks and rodents as well as vegetation control. Herbicides were not applied to the transmission line exit corridor in 2024. The application of herbicides and pesticides is documented in Attachment 1.
The site continues to purchase an over-the-counter solution of herbicide for weed control, that was approved by Chemistry/Environmental. The approval was given in accordance with site procedure Admin 4.22, Environmental Protection Plan (Non-
PNP 2025-019 Enclosure Page 3 of 3 Radiological). Only premixed ready-to-use products are purchased and applied. If the product being used is changed, approval prior to use is required by the Chemistry/Environmental department. Concentrated products were applied by a certified vendor IAW industrial site application requirements.
6.0 NON-ROUTINE REPORTS During 2024, no non-routine reports were generated.
PNP 2025-019 Enclosure Page 1 of 5 HERBICIDE and PESTICIDE TREATMENTS Company:
North Shore Pest Control Inc.
PO Box 268 South Haven, MI 49090 Date of Treatment:
January 10, 2024 (0.6 grams Active Ingredient)
(0.13 pounds total applied)
February 1, 2024 (0.01 oz Active Ingredient)
(0.3 pounds total applied)
February 8, 2024 (1.5 grams Active Ingredient)
(0.33 pounds total applied)
March 6, 2024 (1.5 grams Active Ingredient)
(0.33 pounds total applied)
April 10, 2024
(.51 oz Active Ingredient)
(0.48 pounds total applied)
April 17, 2024 (2.4 grams Active Ingredient)
(0.53 pounds total applied)
May 2, 2024 (92.16oz Active Ingredient)
(12 gallons total applied)
May 10,2024 (108oz Active Ingredient)
(14.2 gallons total applied)
May 15, 2024 (2.4 grams Active Ingredient)
(0.53 pounds total applied)
May 20, 2024 (42.82 oz Active Ingredient)
(8.29 gallons total applied)
May 23,2024 (134.44oz Active Ingredient)
(30.85 gallons total applied)
June 14, 2024 (53.76 oz Active Ingredient)
(10 gallons total applied)
June 19, 2024 (29.82 oz Active Ingredient)
(3.44 gallons total applied)
June 19, 2024 (3 grams Active ingredient)
(0.66 pounds total applied)
June 21, 2024 (92.16 oz Active Ingredient)
(12 gallons total applied)
June 25, 2024 (107.52 oz Active Ingredient)
(18 gallons total applied)
July 9, 2024 (44.16oz Active Ingredient)
(11.5 gallons total applied)
July 16, 2024 (6.64 oz. Active Ingredient)
(1.56 gallons total applied)
July 17, 2024 (2.4 grams Active Ingredient)
(0.53 grams total applied)
July 23, 2024 (0.01 oz. Active Ingredient)
(0.1 oz total applied)
July 25, 2024 (40.33 oz Active Ingredient)
PNP 2025-019 Enclosure Page 2 of 5 (7.5 gallons total applied)
July 26,2024 (26.88oz Active Ingredient)
(3.5 gallons total applied)
August 5, 2024 (1.64oz Active Ingredient)
(0.15 gallons total applied)
August 21, 2024 (2.4 grams Active Ingredient)
(0.53 grams total applied)
August 22, 2024 (145.92oz Active Ingredient)
(19 gallons total applied)
September 18, 2024 (0.004oz Active Ingredient)
(0.42 gallons total applied)
September 18, 2024 (3.6 grams Active Ingredient)
(0.79 grams total applied)
September 19, 2024 (0.05oz Active Ingredient)
(0.5 ounces total applied)
September 23, 2024 (99.84oz Active Ingredient)
(12 gallons total applied)
October 11, 2024 (7.69oz Active Ingredient)
(4 gallons total applied)
October 16, 2024 (3.6 grams Active Ingredient)
(0.79 pounds total applied)
November 25, 2024 (3.6 grams Active Ingredient)
(0.79 pounds total applied)
December 18, 2024 (0.6 grams Active Ingredient)
(0.13 pounds total applied)
December 18, 2024 (3.2 oz Active Ingredient)
(0.13 gallons total applied)
December 18, 2024 (4.2 grams Active Ingredient)
(0.93 pounds total applied)
Commercial Names of Products in Solution:
Talstar Pro, Fastrac all weather Blox, Demand CS Insecticide,Tempo 1% Dust insecticide ready to use, Alpine WSG, Advion ant Bait Arena, PT P.I., MaxForce Ant Disc, Chemical Names of Products:
Talstar Pro - Bifenthrin (2-methyl [1,1'-biphenyl]-3-yl)methyl 3-(2-chloro-3,3,3-trifluoro propenyl)-2,2-dimethylcyclopropanecarboxylate Fastrac All Weather Blox-Bromethalin [N-Methyl-2,4-dinitro-N-(2,4,6-tribromophenyl)
(trifluoromethyl)benzenamine]
DEMAND CS INSECTICIDE - lambda-cyhalothrin, Hydrocarbons, C9, Aromatics, propane-1,2-diol, orthophosphoric acid, dioxosilane, 1,2-benzisothiazol-3(2H)-one TEMPO 1% DUST INSECTICIDE READY TO USE - Cyfluthrin, Crystalline quartz (respirable)
Alpine WSG - Dinotefuran
PNP 2025-019 Enclosure Page 3 of 5 ADVION ANT BAIT Arena - indoxacarb PT P.I. - Pyrethrin MaxForce FC Ant Disc - Fipronil Concentration of Active Ingredient in Field Use Mix:
Diluting Substance:
No dilutions for dry applications Total Amount Used (active ingredient amounts):
33.09 Grams total volume used for dry treatment 8.1 Gallons total volume used for liquid treatment Method of Application:
Bait Station Installation for dry application Hand sprayer for liquids Frequency of Application:
Throughout the year as needed Location:
Along and near roadways, fence lines, walkways, and the protected area.
Purpose of Treatment:
Tick, Flying Insects, Mice and Roach control.
PNP 2025-019 Enclosure Page 4 of 5 Company:
Holtec Palisades, LLC Building and Grounds 27780 Blue Star Memorial Highway Covert, Michigan 49043 Date of Treatment: July 26, 2024 (1.33 gallons applied)
July 30, 2024 (3.5 gallons applied)
Commercial Names of Products in Solution:
Roundup Ready-To-Use Extended Control Weed & Grass Killer Plus Weed Preventer II Chemical Names of Products:
Roundup Ready-To-Use Extended Control Weed & Grass Killer Plus Weed Preventer II -
Nonanoic and related fatty acids; {Pelargonic and related fatty acids}
Isopropylamine salt of N-(phosphonomethyl)glycine; {Isopropylamine salt of glyphosate}
Ammonium salt of 2-[4,5-dihydro-4-methyl-4-(1-methyl)-5-oxo-1H-imidazol-2-yl]-5-methyl pyridinecarboxylic acid; {Ammonium salt of imazapic}
Concentration of Active Ingredient in Field Use Mix:
4.06 oz of active ingredient per 1 gallon (Roundup Ready-To-Use Extended Control Weed &
Grass Killer Plus Weed Preventer II) applied to 200 square feet.
Diluting Substance:
No dilution was performed for Roundup Ready-to-use Extended Control Weed & Grass Killer plus Weed Preventer II, Spectracide Weed and Grass, and Ortho Home Defense Insect Killer for Indoor and Perimeter2 as products are purchased in ready to use concentrations.
Rate of Application:
1 gallon per 200 square feet liquid application (Roundup Ready-To-Use Extended Control Weed &
Grass Killer Plus Weed Preventer II)
Total Amount Used:
4.66 gallons total volume used for liquid treatment of roundup ready-to-use extended control weed & Grass Killer Plus Weed Preventer II (19.61 oz. of active ingredient).
Method of Application:
Hand sprayer for liquids Frequency of Application:
Throughout the year spot treatments as needed
PNP 2025-019 Enclosure Page 5 of 5 Location:
Along and near roadways, fence lines, walkways, parking lots, containment areas, substations, cooling towers, protected area, and microwave zones.
Purpose of Treatment:
Fertilizer, control of weed species, crabgrass, nuisance vegetation, nuisance broadleaf vegetation