ML22159A267
| ML22159A267 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/02/2022 |
| From: | Prema Chandrathil NRC/RGN-III |
| To: | |
| References | |
| Download: ML22159A267 (4) | |
Text
From: Chandrathil, Prema To:
Cc: Mitlyng, Viktoria
Subject:
Answers to your Questions on Palisades Date: Thursday, June 2, 2022 12:42:00 PM Hello ,
Hope you are doing well and enjoying these warm days. I worked with the technical staff and have the answers to your questions below.
As always Viktoria and I are around if you need anything. Take care.
All the best.
-Prema
- 1. As Palisades has operated for over 50 years, analysis of materials freed up during decommissioning can provide critical data to help improve nuclear safety at other plants around the world. Therefore, transfer and analysis of these materials during decommissioning is recommended. When and by what methods will Holtec provide the following and to whom will these materials be given?
A. The test coupons in the Palisades Pressure vessel B. The metal of the pressure vessel itself C. Other subsystems / materials (piping, electrical, etc.)
Answer 1 The NRC is reviewing the possibility of acquiring components from the plant for research. Another term for this is called harvesting. The NRC does look to identify and determine which materials are viable and can fulfill technical objectives for the NRCs mission. The agency has secured material from operating and other permanently shutdown plants for research purposes in the past. Performing research on acquired materials can provide insights for commercial nuclear power plants and allow for a greater understanding of material degradation.
The NRC, DOE and the nuclear industry are trying to secure materials from both domestic and international plants to learn more about a variety of aging issues. The NRC plans to hold a public meeting this summer to discuss the NRCs efforts in this particular area. When the details are finalized, a public meeting noticed will be posted on the NRCs public meeting webpage.
- 2. Related to the failure of ultrasonic inspection procedures to detect primary water stress corrosion cracking. https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML19003A239 At the NRC, what are the lessons learned and corrective actions that have been taken related to this disturbing failure to detect a developing issue over several inspection periods?
Answer 2 The NRC required Palisades to have an inspection program to monitor primary water stress corrosion cracking on CRDM nozzles so that any issues, such as those identified would be found and corrected. The required inspection program included two independent examination methods, ultrasonic examinations to find the
presence of small cracks and visual inspections to find evidence of leakage before it can become safety significant.
Upon a thorough review of the issue, NRC experts concluded that the Palisades CRDM inspection program was in accordance with the NRC requirements since it was able to detect degradation at an early stage and well before reaching conditions that could challenge nuclear safety.
However, the NRC had questions about the implementation and testing conducted by the licensee and the vendor, Framatome. The NRC conducted several inspections and determined the vendor mischaracterized the issue and identified one issue of very low safety significance. The details are documented in these reports.
NRC reports that may be helpful:
-NRCs integrated inspection report at Palisades ML19201D321
-NRCs vendor inspection report ML19261A188.
-NRCs follow up vendor inspection report ML20083H560.
NRC regulations are designed to be conservative and identify areas of concern before they become safety significant issues. The NRCs regulatory oversight process and inspection focus on CRDM monitoring at Palisades resulted in corrective actions to both the licensees and vendors quality assurance programs and inspection procedures, brought awareness to the issue and triggered the industry to take generic corrective actions in this area.
- 3. Related to license definitions. What is the difference between the license Entergy has and the license Holtec is proposed to have for Palisades? In particular, please verify that Holtecs license doesnt include the ability to operate Palisades for electricity production.
Answer 3 The Palisades license will no longer authorize operation of the reactor. 10 CFR 50.82(a)(2) prevents the licensee from placing fuel back into the reactor once the letter for permanent cessation of operations and the letter of permanent removal of fuel have been submitted. The Holtec license will be modified so that the technical specifications needed for operating the plant will be removed.
- 4. Given Holtecs short history of decommissioning Nuclear Power Plants, it is important that oversight is present to ensure Holtec is held accountable to complete the work described in the PSDAR safely, successfully and within budget. Who is providing this oversight? Will the public have a way to monitor this oversight? How and on what dates will the public have this opportunity for oversight?
Answer 4 Inspectors in NRC Region 3 will conduct inspections throughout the decommissioning process to ensure radiological decommissioning meets NRC requirements. NRC requires the licensee to submit annual decommissioning funding status reports, which are then independently reviewed by the agencys experts in the financial assessment branch. Should any potential shortfall be identified, the licensee must remedy the funds to ensure decommissioning activities can be completed.
While the NRC provides oversight over decommissioning funding to make sure it is
sufficient to complete the radiological decommissioning of the site, the agency does not provide oversight of daily decommissioning activities and business decisions, such as selection of contractors or the cost of individual projects.
Regarding your statement about the company, the NRC conducts an in-depth review of license transfer requests to ensure the applicant company is capable of meeting the NRCs technical and financial requirements. Here is a link to stringent regulations that govern the license transfer process: https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/fs-transfer.html. After reviewing Holtecs application, the NRC approved the license transfer in December of 2021. It is Holtecs responsibility to ensure they are meeting NRC requirements. If the NRC identifies violations of these requirements, they agency can take a variety of enforcement actions to make sure the company resolves the violations.
The public can remain involved by reviewing inspection reports, annual submittals made by the licensee and contacting the NRC with any questions.
There will be an upcoming informational webinar on general decommission topics at Palisades. The details will be posted on the NRCs public meeting schedule once finalized. Then the agency will have at least two more NRC public meetings scheduled in the future. The first will be held within 90 days of receipt of the Post Shutdown Decommissioning Analysis Report. The second will be help upon the NRCs receipt of a License Termination Plan which must be provided to the NRC no later than 2 years prior to the date the licensee intends to request license termination.
While the NRC has no requirements related to citizens advisory panels at decommissioning plants, the agency encourages them and participates in CAP meetings to provide updates on the NRCs decommissioning activities. CAP meetings can be a good source of information. For example, the NRC participated in the PCAP meeting in March of this year and answered many questions from the public.
- 5. During the decommissioning process, what real time air and ground monitoring will be done, who will be performing it, and how will this be made public in real time?
Answer 5 The NRC has always required plants to monitor releases to the environment, both while operating and while undergoing decommissioning. The specifics for how the licensee monitors for releases to the environment will be contained in the licensees Offsite Dose Calculation Manual (ODCM). As site conditions change through the decommissioning process, with clean-up and demolition work going on, the ODCM will detail the specifics on how the licensee will meet NRC requirements for air, liquid, and direct radiation monitoring.
As required, the plant must still track, record, and assess the releases to the environment. The amount released must still be below NRC limits. This information will still be required to be reported to the NRC via the Annual Radioactive Effluent Release Report and the Environmental Monitoring Report, which can be accessed by
the public in ADAMS.
Prema Chandrathil Public Affairs Officer U.S. NRC Region III 630-829-9663