[Federal Register Volume 90, Number 160 (Thursday, August 21, 2025)]
[Notices]
[Pages 40864-40868]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-16022]


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NUCLEAR REGULATORY COMMISSION

[Docket No. 50-255; NRC-2024-0123]


Holtec Palisades, LLC; Holtec Decommissioning International, LLC; 
Palisades Nuclear Plant; Petition

AGENCY: Nuclear Regulatory Commission.

ACTION: Director's decision under 10 CFR 2.206; issuance.

-----------------------------------------------------------------------

SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) has issued a 
director's decision with regard to a petition dated December 5, 2023, 
as supplemented by public meeting transcript dated April 10, 2024, 
filed by Beyond Nuclear, Michigan Safe Energy Future, and Don't Waste 
Michigan (the petitioner), requesting that the NRC take action with 
regard to Holtec Palisades, LLC and Holtec Decommissioning 
International, LLC (the licensee). The petitioner's requests and the 
director's decision are included in the SUPPLEMENTARY INFORMATION 
section of this document.

DATES: The director's decision was issued on August 14, 2025.

ADDRESSES: Please refer to Docket ID NRC-2024-0123 when contacting the 
NRC about the availability of information regarding this document. You 
may obtain publicly available information related to this document 
using any of the following methods:
     Federal Rulemaking Website: Go to https://www.regulations.gov and search for Docket ID NRC-2024-0123. Address 
questions about Docket IDs in Regulations.gov to Bridget Curran; 
telephone: 301-415-1003; email: [email protected]. For technical 
questions, contact the individual(s) listed in the FOR FURTHER 
INFORMATION CONTACT section of this document.
     NRC's Agencywide Documents Access and Management System 
(ADAMS): You may obtain publicly available documents online in the 
ADAMS Public Documents collection at https://www.nrc.gov/reading-rm/adams.html. To begin the search, select ``Begin ADAMS Public Search.'' 
For problems with ADAMS, please contact the NRC's Public Document Room 
(PDR) reference staff at 1-800-397-4209, at 301-415-4737, or by email 
to [email protected]. For the convenience of the reader, 
instructions about obtaining materials referenced in this document are 
provided in the ``Availability of Documents'' section.
     NRC's PDR: The PDR, where you may examine and order copies 
of publicly available documents, is open by appointment. To make an 
appointment to visit the PDR, please send an email to 
[email protected] or call 1-800-397-4209 or 301-415-4737, between 8 
a.m. and 4 p.m. eastern time (ET), Monday through Friday, except 
Federal holidays.

FOR FURTHER INFORMATION CONTACT: Zachary M. Turner, Office of Nuclear 
Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 
20555-0001; telephone: 301-415-2258; email: [email protected].

SUPPLEMENTARY INFORMATION: The text of the director's decision is 
attached.
    Availability of Documents: The documents identified in the 
following table are available to interested persons through ADAMS.

[[Page 40865]]



----------------------------------------------------------------------------------------------------------------
                    Document description                                     ADAMS accession No.
----------------------------------------------------------------------------------------------------------------
Palisades Exemption Request--Exemption from Certain          ML23271A140.
 Termination of License Requirements of 10 CFR 50.82, dated
 September 28, 2023.
Petition to Intervene and Request for Adjudicatory Hearing   ML23339A192.
 by Beyond Nuclear, Don't Waste Michigan, and Michigan Safe
 Energy Future, dated December 5, 2023.
Petitioners' Reply in Support of Petition for Leave to       ML23352A215.
 Intervene Against Palisades Exemption, dated December 18,
 2023.
NRC SECY Order referring the petition to the 10 CFR 2.206    ML23352A325.
 process, dated December 18, 2023.
NRC Management Directive 8.11, ``Review Process for 10 CFR   ML18296A043.
 2.206 Petitions,'' dated March 1, 2019.
Email from the NRC to the Petitioners regarding Palisades    ML24032A244.
 Misuse of Decommissioning Trust Fund 2.206 Petition--
 Initial Screening Notification, dated February 1, 2024.
Email from the NRC to the Petitioners regarding Palisades    ML24061A014.
 Misuse of Decommissioning Trust Fund 2.206 Petition--
 Initial Assessment Notification, dated February 29, 2024.
Public Meeting Official Transcript of Proceedings, dated     ML24114A016.
 April 10, 2024.
Email from the NRC to the Petitioners regarding Palisades    ML24170A881.
 Misuse of Decommissioning Trust Fund 2.206 Petition--
 Abeyance Notification, dated May 15, 2024.
NRC Acknowledgement Letter, dated July 2, 2024.............  ML24137A014.
Proposed Director's Decision, dated June 18, 2025..........  ML25097A165 (package).
Proposed Director's Decision, dated June 18, 2025..........  ML25097A167.
NRC Letter--Proposed Director's Decision, dated June 18,     ML25097A168.
 2025.
NRC Letter--Proposed Director's Decision, dated June 18,     ML25097A169.
 2025.
Comments on Proposed Director's Decision, dated July 2,      ML25183A399.
 2025.
Director's Decision--DD-25-02, dated August 14, 2025.......  ML25199A053 (package).
Director's Decision--DD-25-02, dated August 14, 2025.......  ML25199A096.
Director's Decision--Letter to Petitioners, dated August     ML25199A095.
 14, 2025.
Regulatory Guide 1.184, Revision 1, ``Decommissioning of     ML13144A840.
 Nuclear Power Reactors,'' published October 2013.
Palisades Nuclear Plant, Post Shutdown Decommissioning       ML20358A232.
 Activities Report (PDSAR) Including Site-Specific
 Decommissioning Cost Estimate for Palisades Nuclear Plant,
 dated December 23, 2020.
NRC Approval of Palisades Exemption--Exemption from 10 CFR   ML21286A294 and ML21286A506.
 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for Holtec
 Decommissioning International, LLC, dated December 13,
 2021.
Response to Palisades Nuclear Plant--Request for Additional  ML23060A039.
 Information Related to the Post-Shutdown Decommissioning
 Activities Report, dated March 1, 2023.
NRC Letter--Palisades Nuclear Plant--Review of the Post-     ML23087A036.
 Shutdown Decommissioning Activities Report, dated May 2,
 2023.
NRC Inspection Procedure 71801, ``Decommissioning            ML20240A293.
 Performance and Status Reviews at Permanently Shutdown
 Reactors,'' dated January 1, 2021.
NRC Inspection Report No. 05000255/2023002, dated July 19,   ML23200A142.
 2023.
NRC Inspection Report No. 05000255/2023003, dated October    ML23276B452.
 4, 2023.
NRC Inspection Report No. 05000255/2023004, dated February   ML24045A147.
 20, 2024.
NRC Inspection Report No. 05000255/2024004, dated February   ML25041A225.
 14, 2025.
Calendar Year 2023--Report on Status of Decommissioning      ML24089A117.
 Funding for Reactors and Independent Spent Fuel Storage
 Installations--Holtec Decommissioning International, LLC,
 dated March 29, 2024.
Calendar Year 2023--Results of the NRC Analysis of the       ML24240A169.
 Decommissioning Funding Status Reports for Various
 Decommissioning Reactors, dated September 18, 2024.
----------------------------------------------------------------------------------------------------------------


    Dated: August 19, 2025.

    For the Nuclear Regulatory Commission.
Zachary Turner,
Project Manager, Plant Licensing Branch II-1, Division of Operating 
Reactor Licensing, Office of Nuclear Reactor Regulation.

United States of America

Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Jeremy Groom, Acting Deputy Director
In the Matter of: Holtec Palisades, LLC, and Holtec Decommissioning 
International, LLC, Palisades Nuclear Plant, Docket No. 50-255, License 
No. DPR-20

Director's Decision Under 10 CFR 2.206

I. Introduction

    On September 28, 2023, Holtec Decommissioning International, LLC 
(Holtec), on behalf of Holtec Palisades, LLC, submitted a request to 
exempt the Palisades Nuclear Plant (Palisades) from certain 
requirements in Title 10 of the Code of Federal Regulations (10 CFR) 
50.82, ``Termination of license'' (Agencywide Documents Access and 
Management System (ADAMS) Accession No. ML23271A140). By letter dated 
December 5, 2023, and in response to Holtec's exemption request, Beyond 
Nuclear, Michigan Safe Energy Future, and Don't Waste Michigan (the 
petitioner) filed a petition to intervene and a request for hearing on 
that exemption request (ML23339A192). On December 18, 2023, the 
Commission denied the request for hearing and referred Contention 2 of 
the petition, which asserted Holtec's misuse of decommissioning funds, 
to the enforcement process under 10 CFR 2.206, ``Requests for action 
under this subpart'' (ML23352A325).
    The underlying concern in Contention 2 of the December 5, 2023, 
request is that Holtec has misused the decommissioning trust fund (DTF) 
to keep Palisades in a status to restart the reactor, rather than to 
decommission the plant. The petitioner cited 10 CFR 50.82(a)(8) 
regarding appropriate uses of the DTF. Specifically, the petitioner 
asserted the following:
    1. Holtec expended $44 million from the Palisades DTF from June 28 
to December 31, 2022.
    2. Holtec continued improper utilization of the Palisades DTF from 
December 31, 2022, to the present.
    The staff of the U.S. Nuclear Regulatory Commission (NRC) assembled 
a Petition Review Board (PRB) in accordance with Management Directive 
(MD) 8.11, ``Review Process for 10 CFR 2.206 Petitions,'' dated March 
1, 2019, and its associated Directive Handbook 8.11, section III, dated 
March 1, 2019 (ML18296A043). On February 29, 2024 (ML24061A014), the 
petition manager informed the petitioner that the PRB's initial 
assessment was to not accept the petition for review. The PRB's 
position was that the petition did not meet the MD 8.11 criteria for 
acceptance under 10 CFR 2.206 because the issues raised regarding 
Holtec's use of the Palisades DTF in 2022 had already been addressed 
through the NRC's inspection and enforcement process.
    In August and November 2023 (ML23276B452 and ML24045A147, 
respectively), the NRC completed inspections that addressed, in part, 
the use of the Palisades DTF. As a result of these inspections, the NRC 
identified several instances, totaling just over $57,000, of the 
licensee using the Palisades DTF to pay for activities not considered 
legitimate decommissioning

[[Page 40866]]

expenses under the definition in 10 CFR 50.2, ``Definitions.''
    The NRC confirmed that the unauthorized reimbursements from the 
Palisades DTF resulted from inadvertent oversights or inattention to 
detail, or both, in the coding associated with the billing for various 
projects and community donations. The licensee has implemented several 
process revisions to address order coding modification issues and 
errors, as well as training to eliminate these issues from future DTF 
expenditures. The licensee also reimbursed the unauthorized expenses to 
the Palisades DTF. On February 20, 2024 (ML24045A147), the NRC issued 
Holtec a Severity Level IV noncited violation to address the 
illegitimate use of decommissioning funds at Palisades stemming from 
the staff's findings during the November 2023 inspection.
    On February 29, 2024, the petition manager offered the petitioner 
an opportunity to address the PRB in a public meeting (ML24061A014), 
which subsequently took place on April 10, 2024. The transcript of that 
meeting (ML24114A016) is publicly available in ADAMS and is considered 
a supplement to the petition.
    During the April 10, 2024, public meeting, the petitioner discussed 
DTF expenditures of $120 million noted in the 2023 Decommissioning 
Funding Status Report for Palisades, which was submitted to the NRC on 
March 29, 2024 (ML24089A117). The petitioner also raised concerns about 
whether the $120 million was properly used for decommissioning 
expenditures in accordance with NRC requirements and guidance.
    Following the April 10, 2024, public meeting, the PRB met to 
consider what had been presented during the session. The PRB found that 
the issues regarding use of the Palisades DTF in 2022 have been 
thoroughly addressed through the NRC's inspection and enforcement 
process, as noted above. Therefore, the PRB did not accept those issues 
into the 10 CFR 2.206 process. The concerns the petitioner raised at 
the public meeting regarding the recently submitted 2023 expenditure 
report for Palisades involved new information that the NRC had not yet 
fully considered. Therefore, in accordance with MD 8.11, section III.C, 
the PRB accepted that portion of the petitioner's concern into the 10 
CFR 2.206 process for further review.
    On July 2, 2024, the NRC issued an acknowledgement letter 
(ML24137A014) informing the petitioner that the concerns raised in the 
petition, as supplemented, now meet the MD 8.11 criteria for 
acceptance.
    Publicly available documents created or received at the NRC are 
accessible electronically through ADAMS in the NRC's library at http://www.nrc.gov/reading-rm/adams.html. Persons who do not have access to 
ADAMS, who encounter problems in accessing the documents located in 
ADAMS, or who want to inspect publicly available documents at the NRC's 
Public Document Room at 11555 Rockville Pike, Rockville, Maryland 
20852, should contact the NRC's Public Document Room reference staff by 
telephone at 1-800-397-4209 or 301-415-4737, or by email at 
[email protected].

Petitioner's Concern

    The petitioner asserts that Holtec misused the DTF to keep 
Palisades in a status to restart the reactor as opposed to 
decommissioning the plant. Specifically, as described in the April 10, 
2024, public meeting transcript, the petitioner alleged that Holtec 
withdrew $120 million from the Palisades DTF, as noted in Holtec's 2023 
Decommissioning Funding Status Report, and raised concerns about 
whether the $120 million was properly used for decommissioning 
expenditures in accordance with the current NRC requirements and 
guidance.

II. Discussion

Regulatory Requirements

    The NRC has a comprehensive, regulation-based framework that 
provides oversight of licensee DTFs. The regulation at 10 CFR 
50.82(a)(8)(i) specifies that licensees may use DTFs if the following 
three criteria are met:
    (A) The withdrawals are for expenses for legitimate decommissioning 
activities consistent with the definition of decommissioning in Sec.  
50.2;
    (B) The expenditure would not reduce the value of the 
decommissioning trust below an amount necessary to place and maintain 
the reactor in a safe storage condition if unforeseen conditions or 
expenses arise; and
    (C) The withdrawals would not inhibit the ability of the licensee 
to complete funding of any shortfalls in the decommissioning trust 
needed to ensure the availability of funds to ultimately release the 
site and terminate the license.
    ``Decommission'' is defined in 10 CFR 50.2 as--
    . . . to remove a facility or site safely from service and reduce 
residual radioactivity to a level that permits--
    (1) Release of the property for the unrestricted use and 
termination of the license; or
    (2) Release of the property under restricted conditions and 
termination of the license.
    Furthermore, as outlined in Regulatory Guide 1.184, Revision 1, 
``Decommissioning of Nuclear Power Reactors,'' issued October 2013 
(ML13144A840), which licensees may follow as a method of compliance 
with decommissioning requirements, the licensee's ability to use the 
trust funds set aside for decommissioning depends on reaching certain 
milestones in the decommissioning process. The limitation on the 
accessibility of the decommissioning funds is designed to ensure that 
sufficient trust funds are always available to place the facility in a 
safe, stable condition that ultimately leads to decommissioning and 
license termination. Further information regarding the Palisades' 
specific decommissioning plans and cost estimates can be found in the 
``Post Shutdown Decommissioning Activities Report [PSDAR] including 
Site-Specific Decommissioning Cost Estimate [DCE] for Palisades Nuclear 
Plant,'' dated December 23, 2020 (ML20358A232), as supplemented by 
letter dated March 1, 2023 (ML23060A039), which the NRC reviewed and 
approved by letter dated May 2, 2023 (ML23087A036).
    On December 13, 2021, the NRC granted Holtec an exemption 
(ML21286A294 and ML21286A506) from the requirements of 10 CFR 
50.82(a)(8)(i)(A) to allow the use of a portion of the funds from the 
Palisades DTF for spent fuel management and site restoration activities 
at Palisades, in accordance with Holtec's PSDAR and DCE.

Reported Decommissioning Expenditures for Palisades

    As described in the NRC's letter to the petitioner dated July 2, 
2024, the agency limited the scope of the 10 CFR 2.206 petition to a 
review of the new information presented during the April 10, 2024, 
public meeting and the independent validation that the expenses claimed 
against the Palisades DTF, not previously reviewed by the NRC, were 
legitimate decommissioning expenses as opposed to expenses related to 
the Palisades restart initiative. During the April 10, 2024, public 
meeting, the petitioner referenced $120 million of decommissioning 
expenditures, which can be found in enclosure 4 to Holtec's 2023 
Decommissioning Funding Status Report. In table 1 of enclosure 4 of 
that report, Holtec characterized its Palisades decommissioning 
expenses for 2022 and 2023 as summarized in table 1.

[[Page 40867]]



            Table 1--Summary of Holtec's Decommissioning Expenses at Palisades Since License Transfer
----------------------------------------------------------------------------------------------------------------
                                                      License       Spent fuel         Site
                      Year                          termination     management      restoration      Total \1\
----------------------------------------------------------------------------------------------------------------
              Holtec Decommissioning Expenditures--10 CFR 50.82(a)(8)(v)(A) Since License Transfer
----------------------------------------------------------------------------------------------------------------
2022............................................            $38M             $6M             $0M            $44M
2023............................................             43M             56M              0M             99M
                                                 ---------------------------------------------------------------
    Total Spent to Date.........................             81M             62M              0M        \2\ 143M
----------------------------------------------------------------------------------------------------------------
\1\ Columns may not add up due to rounding.
\2\ $120M of incurred costs have not been reimbursed as of December 31, 2023.
Note: M = million.

    Holtec's report shows that a total of $143 million of Palisades' 
decommissioning-related expenses were accounted for, with $44 million 
in expenses for 2022 and an additional $99 million in expenses for 
2023. Notably, footnote 2 to table 1 clarifies that Holtec has only 
withdrawn $23 million of the $143 million of expenses from the 
Palisades DTF, and the $120 million of expenses had not been reimbursed 
as of December 31, 2023. Table 2 of enclosure 4 explains that Holtec 
intends to withdraw the $120 million of reimbursable funds from the DTF 
during the years 2040 and 2041 ($60 million is expected to be withdrawn 
each of these years). This approach ensures that sufficient money 
remains in the DTF to complete decommissioning and is consistent with 
the regulations in 10 CFR 50.82 and guidance provided in Regulatory 
Guide 1.184.
    The NRC staff reviewed Holtec's decommissioning expenses during 
various routine inspections at Palisades and independently found that 
there have been several instances of misallocation of DTF funds, as 
described in the next section of this letter. The staff has taken 
appropriate action on these instances under its normal inspection and 
enforcement processes. However, as discussed below, the staff has 
determined that these misallocations are outside the scope of the 
petition because they were not related to Palisades' restart-specific 
initiatives.

NRC Inspection Activities

    The NRC staff performs routine inspections at Palisades, as 
required by the Decommissioning Power Reactor Inspection Program. 
Specifically, the NRC inspection activities at Palisades included 
review of Holtec's decommissioning expenditures, in accordance with NRC 
Inspection Procedure 71801, ``Decommissioning Performance and Status 
Reviews at Permanently Shutdown Reactors,'' dated January 1, 2021 
(ML20240A293). Table 2 lists the NRC staff's inspection activities, 
their respective inspection reports, and their associated findings. The 
timeframe of the selected inspection reports below covers inspections 
for which the NRC staff reviewed Palisades' 2023 DTF expenses and 
withdrawals.

             Table 2--List of NRC Staff Inspection Reports for Palisades Covering Calendar Year 2023
----------------------------------------------------------------------------------------------------------------
                                                                      Document ADAMS
         Inspection report No.                  Document date         accession No.     Findings related to DTF
----------------------------------------------------------------------------------------------------------------
05000255/2023002.......................  July 19, 2023.............      ML23200A142  None.
05000255/2023003.......................  October 4, 2023...........      ML23276B452  Unresolved Item (URI)
                                                                                       05000255/2023003[dash]01.
05000255/2023004.......................  February 20, 2024.........      ML24045A147  Severity Level IV noncited
                                                                                       violation.
05000255/2024004.......................  February 14, 2025.........      ML25041A225  Severity Level IV noncited
                                                                                       violation URI 05000255/
                                                                                       2024004[dash]01.
----------------------------------------------------------------------------------------------------------------

    As previously described in the NRC's letter to the petitioner dated 
July 2, 2024, Holtec's use of the DTF up to October 2023 had already 
been reviewed by the NRC's routine inspection and enforcement 
processes, which independently identified several instances in which 
Holtec used the Palisades DTF for nondecommissioning activities, 
totaling just over $57,000. The staff described these issues in detail 
in Inspection Report Nos. 05000255/2023003, dated October 4, 2023 
(ML23276B452), and 05000255/2023004, dated February 20, 2024 
(ML24045A147), resulting in the NRC issuing a Severity Level IV 
noncited violation for Palisades.
    As of the April 10, 2024, public meeting, the NRC staff had not yet 
completed a review of Holtec's 2023 Decommissioning Funding Status 
Report and inspection of Palisades DTF use for October through December 
2023, and therefore the petition was held in abeyance until these 
processes could be completed. The NRC concluded its annual financial 
assurance report review for Holtec's 2023 Decommissioning Funding 
Status Report in a memorandum dated September 18, 2024 (ML24240A169). 
This review concluded that the licensee continued to satisfy the 
decommissioning funding assurance requirements of 10 CFR 50.82. In 
November 2024, the NRC conducted its routine DTF inspection at 
Palisades, which is documented in Inspection Report No. 05000255/
2024004, dated February 14, 2025 (ML25041A225). This inspection 
concluded that no withdrawals from the DTF were made from October 1 
through December 31, 2023, which is the timeframe encompassed by the 
petitioner's concern that had not already been reviewed when the staff 
accepted the petition. However, the inspection report does document 
several withdrawals made in 2024 that were not for legitimate 
decommissioning activities, which constituted a violation of NRC 
requirements. This review did not identify any withdrawals from the DTF 
for restart-specific activities; however,

[[Page 40868]]

the inspectors opened an unresolved item to address questions related 
to use of the DTF for routine site maintenance costs because the 
inspection identified that the licensee continued to use the DTF for 
these expenditures in 2024. The NRC will address these issues through 
its normal inspection and enforcement processes; because they do not 
concern withdrawals for restart-specific activities, they are beyond 
the scope of this 10 CFR 2.206 petition.

III. Conclusion

    In summary, the NRC has a comprehensive, regulation-based framework 
that provides for oversight of a licensee's use of the DTF. The NRC 
staff reviewed Holtec's 2023 Decommissioning Funding Status Report for 
Palisades, in addition to Holtec's 2023 decommissioning expenditures, 
and found that the NRC's inspection and enforcement process 
independently identified instances of DTF misuse for which the agency 
issued applicable violations as required by regulations. The sole 
unresolved item from the staff's inspections related to misuse of the 
DTF during the relevant timeframe does not relate to restart-specific 
activities. Therefore, based on the NRC's continuous oversight of 
Holtec's use of the Palisades DTF, no further action is necessary at 
this time to address the petitioner's concern.
    As a result of the NRC staff's evaluation of the petitioner's 
concerns, the Office of Nuclear Reactor Regulation has denied the 
petitioners' request to take enforcement action concerning Holtec's use 
of the Palisades DTF. The PRB concludes that the issues raised 
regarding Holtec's use of the Palisades DTF in 2023 have already been 
addressed through the NRC's inspection and enforcement process, that 
violations related to these inspection findings have already been 
cited, and that there is no indication that withdrawals from the DTF 
were for restart-specific activities. Therefore, there is insufficient 
basis on which to take further enforcement-related action against 
Holtec, and the petitioner's request is denied.
    In accordance with 10 CFR 2.206(c), a copy of this director's 
decision will be filed with the Secretary of the Commission for 
Commission review. As provided for by this regulation, the decision 
will constitute the final action of the Commission 25 days after the 
date of the decision unless the Commission, on its own motion, 
institutes a review of the decision within that time.

    Dated at Rockville, Maryland, this 14th day of August 2025.

    For the Nuclear Regulatory Commission.

/RA/

Jeremy Groom,
Acting Deputy Director, Reactor Safety Programs and Corporate 
Support Office of Nuclear Reactor Regulation.

Attachment

Petitioner's Comments on Proposed Director's Decision and Nuclear 
Regulatory Commission Response

    By letter dated July 2, 2025 (Agencywide Documents Access and 
Management System Accession No. ML25183A399), the petitioner 
provided comments (ML25097A165) to the U.S. Nuclear Regulatory 
Commission (NRC) on the proposed director's decision regarding 
Holtec Decommissioning International, LLC's (Holtec's), misuse of 
decommissioning funds, to the enforcement process under Title 10 of 
the Code of Federal Regulations (10 CFR) 2.206, ``Requests for 
action under this subpart,'' regarding Palisades Nuclear Plant.
    The petitioner's comments do not alter the NRC staff's 
conclusions in the proposed director's decision and therefore do not 
require modification to the final director's decision. This 
attachment provides the petitioner's comments on the proposed 
director's decision and the NRC's responses to the comments.
    The petitioner's comments are summarized below.
    Comment 1: Notably, 18 CFR 35.32(a)(6) warrants that.
    (6) Absent the express authorization of the Commission, no part 
of the assets of the Fund may be used for, or diverted to, any 
purpose other than to fund the costs of decommissioning the nuclear 
power plant to which the Fund relates, and to pay administrative 
costs and other incidental expenses, including taxes, of the Fund.
    That is, decommissioning funds must be spent on decommissioning. 
The proposed decision provides no discussion of how it is that 
expenditures for spent fuel management, costs indisputably incurred 
during the period following June 2022 during which Holtec actively 
sought and obtained federal and state assistance commitments for the 
restart of Palisades, can be deemed ``costs of decommissioning.''
    NRC Response to Comment 1: The Code of Federal Regulations (CFR) 
is a codification of the general and permanent rules published in 
the Federal Register by the Executive departments and agencies of 
the Federal Government. The CFR is divided into 50 titles that 
represent broad areas subject to Federal regulation. Each title is 
divided into chapters, which usually bear the name of the issuing 
agency. Title 18, ``Conservation of Power and Water Resources,'' is 
composed of two volumes. The first volume, containing parts 1-399, 
of which you reference 18 CFR part 35, ``Filing of Rate Schedules 
and Tariffs,'' includes all current regulations codified under this 
title by the Federal Energy Regulatory Commission, U.S. Department 
of Energy.
    The regulation in 18 CFR 1.101, ``Definitions,'' defines 
``Commission'' as the Federal Energy Regulatory Commission, as 
referenced within 18 CFR. Therefore, the regulation that you cited 
(18 CFR 35.32(a)(6)) is outside the NRC's jurisdiction. However, the 
NRC has a similar regulation at 10 CFR 50.82(a)(8)(i)) which states, 
in part, the following:
    Decommissioning trust funds may be used by licensees if--
    (A) The withdrawals are for expenses for legitimate 
decommissioning activities consistent with the definition of 
decommissioning in [10 CFR] 50.2.
    The regulation in 10 CFR 50.2, ``Definitions,'' defines 
``Decommission'' as--. . . to remove a facility or site safely from 
service and reduce residual radioactivity to a level that permits--
    (1) Release of the property for unrestricted use and termination 
of the license; or
    (2) Release of the property under restricted conditions and 
termination of the license.
    Furthermore, on December 13, 2021, the NRC granted Holtec an 
exemption (ML21286A294, ML21286A506) from the requirements of 10 CFR 
50.82(a)(8)(i)(A) to allow the use of a portion of the funds from 
the Palisades Decommissioning Trust Fund (DTF) for spent fuel 
management and site restoration activities at Palisades.
    These points were previously detailed in the proposed director's 
decision section titled ``Regulatory Requirements.''
    Comment 2: The Petitioners' original question still remains 
unanswered: How could Holtec legitimately spend $143,000,000 from 
the decommissioning trust fund when Holtec admits that it has never 
engaged in any decommissioning activity?
    NRC Response to Comment 2: As described in the proposed 
director's decision section titled ``NRC Inspection Activities,'' 
the NRC staff reviewed Holtec's use of the DTF and verified the 
expenses incurred. The staff also independently identified several 
instances in which Holtec used the Palisades DTF for 
nondecommissioning activities and took appropriate enforcement 
action for these findings. Notably, in NRC Inspection Report No. 
05000255/2024004 (ML25041A225), the NRC staff issued Unresolved Item 
(URI) 05000255/2024004-01, which seeks to clarify at what point a 
decommissioning plant undergoing a restart initiative should 
transition away from using the DTF for otherwise legitimate 
expenditures. This URI is still under review and is being 
dispositioned through the NRC's inspection and enforcement process.
    In conclusion, the Petition Review Board has determined that the 
petitioner's comments did not provide any relevant additional 
information or support for the petition that was not previously 
considered. Thus, the comments did not change the conclusion of the 
proposed director's decision. The final director's decision denies 
the petitioner's request for enforcement action. The NRC appreciates 
the petitioner's comments and thanks the petitioner for raising 
concerns in the interest of protecting public health and safety.

[FR Doc. 2025-16022 Filed 8-20-25; 8:45 am]
BILLING CODE 7590-01-P