PALISADES DECOMMISSIONING: Groups Meet Public Comment Deadline


The U.S. Nuclear Regulatory Commission (NRC) set a December 27, 2022 public comment deadline re: Holtec’s Post-Shutdown Decommissioning Activities Report (PSDAR) and Site-Specific Decommissioning Cost Estimate (DCE). Despite the holidays, and the fact that Holtec is scheming to restart the reactor (and/or build one or more Small Modular Reactors on the site), not decommission it, watchdogs met the deadline. Toledo, OH attorney Terry Lodge, longtime legal counsel for opponents to Palisades, submitted comments on behalf of Beyond Nuclear, Don’t Waste Michigan, Michigan Safe Energy Future, and Nuclear Energy Information Service of Chicago. Beyond Nuclear also submitted its own set of comments. A common theme is protest of NRC’s flippant approval for Holtec to loot the already inadequate Decommissioning Trust Fund for improper expenses.

See the various comments, posted below:

Comments submitted by Terry Lodge, attorney based in Toledo, Ohio, on behalf of Beyond Nuclear, Don’t Waste Michigan, Michigan Safe Energy Future, and Nuclear Energy Information Service of Chicago —

12 27 22 coalition Palisades PSDAR - PSDAR comment FINAL-1

Comments submitted by Kevin Kamps, radioactive waste specialist at Beyond Nuclear —

12 27 22 public comments on psdar and dce

And here are comments submitted by Kraig Schultz, a member of MSEF and resident of Grand Haven, MI, submitted in his capacity as an individual citizen:

Docket ID NRC-2022-0158 Pertaining to Post Shutdown Decommissioning Activities Report (PSDAR) for Palisades Nuclear Power Plant provided by Holtec Decommissioning International (HDI). By letter dated December 23, 2020, Holtec Decommissioning International (HDI) submitted the Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report (PSDAR) (accession number ML20358A232) in accordance with 10 CFR 50.82(a)(4)(i). 1. The PSDAR lacks sufficient oversight to provide accountability for use of funds in the Decommissioning Trust Fund. The Decommissioning Trust Funds should be held by an independent third party that can hold HDI accountable to performance and budget criteria defined in the PSDAR. The money should be released only as work is completed, not given up front in a lump sum. 2. The PSDAR lacks specific details regarding the retention and testing of radiological test pieces that are inside the Reactor Pressure Vessel (RPV). These samples are critical for evaluating the brittleness of this and other RPV’s. The samples must not be lost and must be tested to provide data to enhance our ability to accurately model the effects of radiation on safety critical equipment. 3. It should be noted in the PSDAR that the funds in the decommissioning trust fund are not adequate to decommission the plant without delays and that the shortfall in funds was allowed to happen due to NRC requirements being set too low. This notation may provide support to help the NRC take action to update trust fund requirements so that this short fall is not repeated at other facilities. Kraig Schultz, Resident of Grand Haven, Michigan Member of Michigan Safe Energy Future

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