IR 05000255/2024011

Nuclear Plant - Restart Inspection Report 05000255/2024011

ML24197A185
Person / Time
Site:	Palisades
Issue date:	07/15/2024
From:	April Nguyen NRC/RGN-III/DORS
To:	Mlynarek M Holtec Decommissioning International
References
IR 2024011
Download: ML24197A185 (1)

Text

SUBJECT:

PALISADES NUCLEAR PLANT - RESTART INSPECTION REPORT 05000255/2024011

Dear Mike Mlynarek:

On May 1, 2024, and May 10, 2024, respectively, the U.S. Nuclear Regulatory Commission (NRC) completed two inspections at the Palisades Nuclear Plant. The enclosed inspection report documents these inspection results, which the inspectors discussed on May 1, 2024, and May 10, 2024, with you and other members of your staff.

Based on the results of these inspections, no findings or violations were identified.

On June 13, 2022, Palisades ceased permanent power operations and subsequently removed all fuel from the reactor, as detailed in the letter from Entergy to the NRC, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, (ADAMS Accession No. ML22164A067). On September 28, 2023, Holtec Decommissioning International, LLC (Holtec) submitted a letter to the NRC requesting exemptions from certain portions of the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(2) to pursue the potential reauthorization of power operations at Palisades (ADAMS Accession No. ML23271A140). The NRCs initial acceptance to review Palisades request for exemptions was documented in ADAMS at Accession No. ML23291A440 on November 3, 2023.July 15, 2024 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, April M. Nguyen, Lead Palisades Restart Team Division of Operating Reactor Safety Docket No. 05000255 License No. DPR-20

Enclosure:

As stated

Inspection Report

Docket Number: 05000255

License Number: DPR-20

Report Number: 05000255/2024011

Licensee: Holtec Decommissioning International, LLC

Facility: Palisades Nuclear Plant

Location: Covert, MI

Inspection Dates: April 29 - May 10, 2024

Inspectors: B. Bergeon, Senior Operations Engineer J. Cassidy, Senior Health Physicist T. Henning, Senior Operations Engineer

Approved By: April M. Nguyen, Lead Palisades Restart Team Division of Operating Reactor Safety

Enclosure

SUMMARY

This report covers announced inspections completed by regional inspectors.

The U.S. Nuclear Regulatory Commission (NRC) performed inspections of the licensees activities to ensure the adequate protection of workers and the public under the radiation safety cornerstone and to assess requalification training and evaluation of previously licensed operators under the reactor safety cornerstones.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

The Palisades Nuclear Plant ceased permanent power operations and subsequently removed all fuel from the reactor, as certified in a letter to the NRC on June 13, 2022. On September 28, 2023, Holtec Decommissioning International, LLC (Holtec) submitted a letter to the NRC requesting exemptions from certain portions of the requirements of 10 CFR 50.82(a)(2)to pursue the potential reauthorization of power operations. The NRC is conducting inspections to evaluate and assess the licensees activities for potential restoration to an operational status.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the referenced inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

REACTOR SAFETY

CORNERSTONES

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

(1) Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification written examinations administered on April 26, May 3, and May 10, 2024.

Annual Requalification Operating Tests

The inspectors evaluated the adequacy of the facility licensees annual requalification operating tests administered during the weeks of April 22, April 29, and May 6, 2024.

Administration of an Annual Requalification Operating Test

The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security

The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations

The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions

The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator

The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46. Control room simulator fidelity was previously evaluated on March 13, 2024, and documented in Inspection Report 05000255/2024010 (ADAMS Accession No. ML24078A315).

RADIATION SAFETY

CORNERSTONE

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Radiological Hazards Control and Work Coverage (IP Section 03.04)

The inspectors evaluated the licensees control of radiological hazards for the following radiological work:

(1) Unit 1 lifting the reactor head from the reactor cavity to the reactor head stand

(2) Unit 1 removal and replacement of the reactor head O-ring

(3) Cleaning and decontamination of the Unit 1 reactor flange and O-ring groove

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) Unit 1 containment building

(2) Unit 1 reactor cavity

(3) Unit 1 head stand area when reactor head was on stand Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

INSPECTION RESULTS

No findings or violations were identified during these inspections.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On May 1, 2024, the inspectors presented the radiation protection inspection results to G. Wright, Radiation Protection Manager, and other members of the licensee staff.

• On May 10, 2024, the inspectors presented the licensed operator requalification program results to M. Mlynarek, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.11B Miscellaneous Simulator Scenario SES-245 2

Simulator Scenario SES-246 2

Simulator Scenario SES-249 2

Simulator Scenario SES-270 1

Simulator Scenario SES-277 1

Simulator Scenario SES-278 1

Simulator Scenario SES-300 0

Job Performance Measure PLJPM-LOR-RO Admin 17 1

Job Performance Measure PLJPM-LOR-SRO Admin 17 0

Job Performance Measure PLJPM-LOR-AFW-05 3

Job Performance Measure PLJPM-LOR-ELEC-01 2

Job Performance Measure PLJPM-LOR-EOP-28 3

Job Performance Measure PLJPM-LOR-EOP-55 1

Job Performance Measure PLJPM-LOR-RO Admin 8 1

Job Performance Measure PLJPM-LOR-SRO Admin 18 0

Job Performance Measure PLJPM-LOR-AFW-06 0

Job Performance Measure PLJPM-LOR-AOP-34 2

Job Performance Measure PLJPM-LOR CPS-01 1

Job Performance Measure PLJPM-LOR-AOP-41 1

Job Performance Measure PLJPM-LOR-RO Admin 9 1

Job Performance Measure PLJPM-LOR-SRO Admin 19 0

Job Performance Measure PLJPM-LOR-AOP-14A 4

Job Performance Measure PLJPM-LOR-EOP-13 3

Job Performance Measure PLJPM-LOR-PZR-04 5

Job Performance Measure PLJPM-LOR-CRD-01 1

24 LOR Biennial RO-SRO Exam 1 0

24 LOR Biennial RO-SRO Exam 2 0

24 LOR Biennial RO-SRO Exam 3 0

24R1/24R2/24R3/24R4 LOR Training Cycle Schedules

Shift 1 Crew Notebook

Shift 2 Crew Notebook

Inspection Type Designation Description or Title Revision or

Procedure Date

Shift 3 Crew Notebook

Shift 4 Crew Notebook

Shift 5 Crew Notebook

Procedures PAL-2176 Sentinel Login Issue Extremity Multi-packs 04/29/2024

PAL-02185 NRC Questioned Potential Inconsistencies 04/30/2024

PNT-114 Licensed Operator Requalification Training Program 1

Description

PNT-201 Systematic Approach to Training Process 0

PNT-210 Conduct of Simulator Training 0

PNT-217 Examination Security 1

PNT-218 Licensed Operator Requalification Annual and Biennial 2

Exam Development

PNT-201-TF-10 Remediation Form 0

PNT-024-TF-SBT Scenario Based Testing Scenario 249 LOR Exam Scenario 2

LOR 2024-2026 LOR Long Range Training Plan 0

71124.01 Miscellaneous Radiological Work Permit and Associated ALARA Plan, 00

240433, Disassembly of the Rx Head, Reset the Rx Head

in the Cavity, and Associated Work Activities (Supports

Re-Start/PCS Chem Decon)

Radiological Survey Sheet Number 2024-0201, 649' CTMT 04/30/2024

General Areas

Airborne Radioactivity Calculation Form, 2024-AS-0173, 04/26/2024

Vacuum Head

Airborne Radioactivity Calculation Form, 2024-AS-0170, 04/26/2024

FME Walkdown in Cavity

Airborne Radioactivity Calculation Form, 2024-AS-0171, 04/26/2024

FME Walkdown in Cavity

Lapel Air Sample Alpha Analysis, 2024-AS-0186, 04/30/2024

Head Stand/ Clean Under Head

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.05 Procedures EN-RP-131 Air Sampling

EN-RP-122 Alpha Monitoring

EN-RP-141 Job Coverage

EN-RP-503 Selection, Issue and Use of Respiratory Protection

Equipment

8