The Hazardous Path to Recommision Nuclear at Palisades, MI
The Nuclear Regulatory Commission faces impossible hurdles to bring Holtec’s vision online.
by Alan Blind
“Holtec is no longer shielded by a decommissioning status that kept its restart plans in a regulatory gray zone. From here on out, its compliance will be measured against the full, enforceable standards of an NRC operating license. That changes everything.”
Alan Blind, retired nuclear executive, former Emergency Plan Director at Palisades and Indian Point, and a lead petitioner in the Palisades restart proceeding, reports on the NRC’s approval of operations at Palisades, and where it goes from here.
In a decision long expected by some and long contested by others, the U.S. Nuclear Regulatory Commission (NRC) is poised* to reauthorize full operating status for the Palisades Nuclear Plant in Covert, Michigan. On or about July 24, 2025, the NRC will approve a sweeping package of licensing actions, including the withdrawal of Palisades’ decommissioning certifications, amendments to the technical specifications, and approval of an operating license transfer to a new Holtec subsidiary. The agency will also issue a “no significant hazards” finding, clearing the path for Palisades to legally load fuel and begin power operations for the first time since May 2022.
[* as of July 24th, @ 2pm CST, the NRC has reauthorized full operating status for the plant]
To Holtec International, which acquired the site from Entergy in June 2022, this will likely be marketed as a triumphant milestone: a federal green light for reactor startup, with regulatory obstacles behind and a power-generating future ahead. One can already imagine the press releases and political photo ops.
But the truth is more complicated—and the next chapter may prove more difficult than the one Holtec just finished.
A Loophole Closed
When my fellow petitioners and I filed for a public hearing last fall, we didn’t argue over whether Holtec had filed the right paperwork. We argued that they were using the wrong playbook.
Palisades was shut down and defueled. By regulation—specifically 10 CFR 50.82(a)(2)—that means it no longer held an operating license in the practical sense. Holtec’s plan to return the plant to service leaned on a controversial interpretation of NRC policy: namely, that plants like Palisades can use the “existing regulatory framework” for restart, even though that framework was never written with restarts in mind.
We argued that Holtec’s reliance on 1969-era design bases, its selective use of regulations like 10 CFR 50.59, and its attempt to update safety documents and quality assurance programs without prior NRC approval created unacceptable risks. We asked that the NRC General Counsel formally review and approve Holtec’s proposed regulatory pathway, as required under 10 CFR 50.3. Without this check, we contended, Holtec was essentially self-certifying its own safety roadmap.
The Atomic Safety and Licensing Board (ASLB) dismissed our petition in March 2025—but not because we were wrong. Instead, it ruled that we hadn’t identified a current violation, since Holtec was still operating under a decommissioning license at the time. In other words, our petition was too early. We were caught in a procedural catch-22: the license didn’t exist yet, so Holtec couldn’t be found in violation of it.
Now that the NRC is issuing the operating license, that loophole closes. Holtec is no longer shielded by a decommissioning status that kept its restart plans in a regulatory gray zone. From here on out, its compliance will be measured against the full, enforceable standards of an NRC operating license. That changes everything.
The Steam Generator Question
Nowhere is this shift more evident than in the issue of steam generator tube integrity—a technical concern with high safety stakes.
During 2024 inspections, Holtec identified a large number of degraded steam generator tubes. The company blamed improper lay-up procedures by the previous owner. Whatever the cause, the result was clear: the plant's steam generators—already more than 30 years old and built with obsolete Alloy 600 materials—raised serious questions about their operability.
The NRC has been asking hard questions. In its Requests for Additional Information (RAIs), the agency demanded detailed data on tube plugging, inspection intervals, and long-term integrity. Under a decommissioning license, Holtec could sidestep these questions. Under an operating license, it cannot.
The term “operable” in NRC regulation doesn’t just mean “working today.” It means that the component will meet its intended safety function through the end of the approved inspection interval. That interval must be defensible—and if the NRC determines the steam generators can't meet that standard, Holtec may be forced to replace them altogether. That is not a fast or cheap proposition.
Put simply: NRC license approval doesn’t make the steam generator issue go away. It puts it under a brighter spotlight.
A New Petition Is Coming
That’s why I’ve already begun preparing a new petition for public hearing. This time, we won’t be challenging interpretations or future plans. We’ll be evaluating compliance against the actual, enforceable requirements of the operating license Holtec now holds.
And this time, Holtec won’t be able to argue that no violation exists. There will be a license to violate.
Our new petition will address not only the steam generator issue, but also deficiencies in quality assurance, fire protection upgrades, reactor vessel head venting, and other deterministic safety requirements that must be in place before full operations. Under NRC regulations, many of these requirements cannot be deferred or justified solely using probabilistic risk assessment (PRA) techniques—a strategy Holtec has previously attempted.
In other words, approval of the license is not the end of oversight. It’s the start of real accountability.
The Public Shouldn’t Be Misled
Holtec and its backers in Congress and the Department of Energy will no doubt herald this licensing decision as a historic win. And in some ways, it is: this marks the first time the NRC has reversed a decommissioning license, and it’s a major procedural breakthrough.
But the public must understand that the road to safe power operations at Palisades is just beginning. Holtec still must:
Demonstrate steam generator tube integrity across the entire NRC-approved inspection cycle
Show that its Quality Assurance Program Description (QAPD) meets the standards of Appendix B to 10 CFR 50
Resolve outstanding NRC questions on fire protection compliance and design basis documentation
Complete physical modifications to meet the deterministic safety criteria outlined in NUREG-0737 and NFPA-805
Undergo NRC inspection and testing sufficient to support fuel loading and criticality
Every one of these steps has the potential to delay restart or require further regulatory action.
So while Holtec may claim that a restart is imminent, that optimism is premature. They have a license—but not yet a running plant.
Final Word
When Palisades shut down in 2022, it was considered uneconomical to operate. Holtec’s gamble to reverse that decision has won political support, but its technical case is still under review.
As residents, engineers, and petitioners, we are not opposed to nuclear energy done right. We are opposed to nuclear shortcuts. The NRC’s decision this month may conclude one chapter, but the story of Palisades—and its safety—has just begun. /off
Alan Blind is a retired nuclear executive, former Emergency Plan Director at Palisades and Indian Point, and a lead petitioner in the Palisades restart proceeding.
In Context
Alan Blind provides answers to topics covered in this story
Michigan Governor Gretchen Whitmer and former Governor Jennifer Granholm who served as Energy Secretary in the Biden Administration launched the plan to restart Palisades. Why didn’t they pick a company with long experience in building and operating nuclear power plants to restart Palisades.
We cannot know exactly why. But we do know that based on media reports that Entergy, who was operating Palisades at the time, declined the Governor's offer of financial assistance.
If Holtec attempted to build a new nuclear plant equivalent to Palisades today would they be able to get a license?
No. The design of Palisades does not meet current Nuclear Regulatory Commission design standards. The most important example is how the plant is able to respond to a critical steam generator tube rupture. Palisades does not currently have the ability to contain radioactive steam from such a rupture. Current design requirements do.
How does Holtec propose to get around this requirement that applies to all currently operating nuclear power plants in the United States?
The NRC has announced it will allow Holtec use of the 1969 design which is no longer applicable to any other nuclear power plant in America. That was all made possible by Holtec’s proposed use of a loophole in the NRC regulations allowing any plant in decommissioning status to do so. This is unprecedented and is equivalent to taking a house scheduled for demolition and allowing it to be rebuilt without meeting building code safety requirements for sewer, gas and electric power.
Holtec is doing something that has never been done before in American nuclear power plant history?
Correct.
Is there a risk here?
The risk is that the public won’t have the benefit of all of the new safety features that were applied to modern plants based on 50 years of operating experience. That means if there were to be a natural disaster or operator mistake, there would be far less safety margin to protect the public from harm. A bit like rolling back seat belt and infant car seat requirements in a vehicle.
What do you think the Nuclear Regulatory Commission should do now?
Given that they are going to approve the license they need to complete an in depth review that Palisades meets all of those licensing requirements, for example the steam generatoers. The new license they are receiving now stipulates that they must meet the original steam generator requirements. They have been skirting the requirements for steam generator operation because decommissioning doesn’t require steam generators. The NRC can now hold Holtec’s feet to the fire on the steam generators because now they are required to meet operating plant requirements. The one thing we know for sure is that Holtec has not submitted the required reports to the NRC to demonstrate that they can meet requirements that were central to the original operating license.
The largest nuclear fleet operator in the world, Constellation Energy, is restarting the Three Mile Island 1 reactor with a three year lead time. How can Holtec, a company that has never operated a reactor, restart Palisades in just one month?
That is indeed the paradox that no one at the Nuclear Regulatory Commission has been able to explain. The rush job is an attempt to bypass the licensing requirements central to nuclear power plant safety. Adding to the paradox is that Constellation is currently far ahead of Holtec in showing its Steam Generators meet all current licensing requirements.
