Letter Sequence RAI |
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EPID:L-2022-LRO-0073, Post-Shutdown Decommissioning Activities Report Public Meeting Slides - September 22, 2022 (Open) |
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Category:Request for Additional Information (RAI)
MONTHYEARML23354A2602023-12-21021 December 2023 Reference Simulator Inspection Request for Information ML23055A1542023-02-24024 February 2023 Attachment: Request for Additional Information on the Palisades PSDAR ML22292A2582022-10-31031 October 2022 PDEP-EAL Amendment RAI ML22102A2482022-04-14014 April 2022 Request for Additional Information Regarding License Amendment Request for Permanently Defueled Technical Specifications ML21274A4172021-10-0505 October 2021 Request for Information for an NRC Triennial Heat Exchanger/Sink Performance Inspection and Request for Information Inspection Report 05000255/2021004 ML21028A4092021-01-27027 January 2021 NRR E-mail Capture - Palisades Nuclear Plant - Acceptance of Holtec Exemption Request from 10CFR50.82(a)(8)(i)(A) and 10CFR50.75(h)(1)(iv) ML21028A0552021-01-27027 January 2021 NRR E-mail Capture - Palisades Nuclear Plant - Acceptance of License Transfer Application ML20272A0112020-09-26026 September 2020 Request for Additional Information - Palisades Relief Request RR 5-8 (Proposed Alternative) for Reactor Pressure Vessel Head Penetration Repairs ML20133K0562020-05-14014 May 2020 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection ML19357A2752019-12-23023 December 2019 Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000255/2020011 ML19226A2932019-08-14014 August 2019 NRR E-mail Capture - Request for Additional Information Re License Amendment Request to Adopt TSTF-425, Revision 3 for the Palisades Nuclear Plant ML19226A2922019-08-0505 August 2019 NRR E-mail Capture - Draft Request for Additional Information for Palisades License Amendment Request to Adopt TSTF-425 ML19122A4852019-04-29029 April 2019 NRR E-mail Capture - Request for Additional Information for Palisades License Amendment Request to Revise License Conditions Related to NFPA 805 Modifications ML19009A5392019-01-0909 January 2019 NRR E-mail Capture - Request for Additional Information for Palisades License Amendment Request to Revise Emergency Diesel Generator Degraded Voltage Surveillance Requirement 3.3.5.2a ML19009A5382018-12-12012 December 2018 NRR E-mail Capture - Draft Request for Additional Information for Palisades License Amendment Request to Revise Emergency Diesel Generator Degraded Voltage Surveillance Requirement 3.3.5.2a ML18337A1382018-11-30030 November 2018 NRR E-mail Capture - Request for Additional Information Related to Palisades Relief Request Number RR 5-7 ML18337A1402018-11-29029 November 2018 NRR E-mail Capture - Draft Request for Additional Information Related to Palisades Relief Request 5-7 ML18309A1342018-11-0808 November 2018 Supplemental Information Needed for Acceptance or Requested Licensing Action Amendment Request to Revise Technical Specifications to Adopt TSTF-425, Revision 3 ML18094B0922018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to B. S. Ford RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for ISFSI Docket Nos.: 72-43, 72-51, 72-1044, 72-07, 72-12, and 72-59) ML18081A2962018-03-22022 March 2018 NRR E-mail Capture - Palisades Nuclear Plant - Request for Additional Information Regarding Proposed Changes to Site Emergency Plan for Permanently Defueled Condition (CAC MG0198: EPID L-2017-LLA-0305) ML18059A8202018-02-28028 February 2018 NRR E-mail Capture - Palisades Nuclear Plant - Request for Additional Information Regarding Proposed Alternative for Relevant Condition ML17335A1042017-11-30030 November 2017 NRR E-mail Capture - Palisades Nuclear Plant - RAI Regarding Proposed Changes to Administrative Controls Section of the Technical Specifications for Permanently Defueled Condition (CAC MG0021; EPID L-2017-LLA-0266) ML17118A3342017-04-18018 April 2017 E-Mailed Request for Information Dated 04/18/2017 for Palisades Nuclear Power Station, Unit 1, Inservice Inspection - Part B Items (Exf) ML17118A3312017-04-18018 April 2017 E-Mailed Request for Information Dated 04/18/17 for Palisades Nuclear Power Station, Unit 1, Inservice Inspection - Part a Items ML17072A2752017-03-10010 March 2017 NRR E-mail Capture - Palisades Nuclear Plant - Final Request for Additional Information Regarding Relief Request No. RR 4-25 ML16238A0302016-08-29029 August 2016 Supplemental Information Needed for Acceptance of Requested Licensing Action Control Rod Drive Exercise Surveillance ML16130A0762016-05-11011 May 2016 Request for Additional Information Regarding the License Amendment Request for Implementation of an Alternative Repair Criterion on the Steam Generator Tubes ML16013A0642016-01-13013 January 2016 NRR E-mail Capture - Request for Additional Information Entergy CNRO-2015-00023 - Revision to Entergy Quality Assurance Program Manual (Fleet Submittal CAC Nos. MF7086-MF7097) ML15341A1662015-12-0707 December 2015 NRR E-mail Capture - Entergy Fleet RR-EN-15-1, Request for Additional Information (CACs MF6341-MF6349) ML15258A2432015-09-0101 September 2015 NRC Supplement to NRC Letter - Notification of NRC Inspection and Request for Information Dated May 1, 2015 - Palisades Nuclear Plant ML15149A2462015-05-28028 May 2015 Information Request to Support NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection (Mxg) ML15072A2542015-03-19019 March 2015 Request for Additional Information Regarding the License Amendment Request to Implement 10 CFR 50.61a CNRO-2015-00008, Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company2015-02-18018 February 2015 Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company ML15022A1382015-01-22022 January 2015 E-Mail - Palisades Request for Information ML15016A1842015-01-20020 January 2015 Request for Additional Information Regarding the License Amendment Request to Implement 10 CFR 50.61a ML15012A3052015-01-15015 January 2015 Request for Additional Information Regarding the License Amendment Request for an Equivalent Margin Analysis Completed in Accordance with 10 CFR 50, Appendix G ML14318A4002014-12-17017 December 2014 Vermont Yankee Nuclear and Big Rock Point - Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company (Tac Nos. MF3218 - MF3221) ML14157A3642014-06-0505 June 2014 CDBI Request for Information ML13353A0422013-12-16016 December 2013 NRR E-mail Capture - Request for Additional Information - Palisades - Proposed Revision to Palisades Site Emergency Plan (SEP) Emergency Response Organization (ERO) MF2321 ML13312A4232013-11-26026 November 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation ML13179A4622013-07-0505 July 2013 Entergy Nuclear Operations, Inc., Decommissioning Funding Status Report Request for Additional Information Regarding the Decommissioning Funding Status Report ML13051A7772013-02-19019 February 2013 Request for Additional Information, 2012 SG Inspection Report ML12314A4222012-11-0808 November 2012 ME8074 - Request for Additional Information Regarding Replacement of Spent Fuel Pool Region I Storage Racks ML12278A3862012-10-0404 October 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2, and 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford, Request for Additional Information, Round 2, Amendment Request to Revise QA Program Manual and Staff Qualification TSs ML12206A4042012-07-24024 July 2012 Request for Additional Information (Revised) - Palisades - SFP Rerack LAR - ME8074 ML12206A3322012-07-19019 July 2012 E-mail Combined Request for Additional Information for Several Branches of NRR for the Submittal on Palisades re-sack LAR ML12121A7032012-04-27027 April 2012 Relief Request - Proposed Alternative - Use of Alternate ASME Code Case N-770-1 Baseline Examination - ME8492 ML1209604492012-04-0505 April 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Request for Additional Information, Revise Quality Assurance Program Manual and Staff Qualification Technical Specificat ML12068A3882012-04-0202 April 2012 Request for Additional Information Regarding License Renewal Commitment to Submit Alloy 600 Program ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic 2023-02-24
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REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT HOLTEC DECOMMISSIONING INTERNATIONAL, LLC PALISADES NUCLEAR PLANT DOCKET NO. 50-255 On December 23, 2020, Holtec Decommissioning International, LLC (HDI) submitted to the U.S. Nuclear Regulatory Commission (NRC) a letter enclosing the Post-Shutdown Decommissioning Activities Report (PSDAR) and the Site-Specific Decommissioning Cost Estimate (DCE) for the Palisades Nuclear Plant (Palisades), contingent upon the transfer of the Palisades operating licenses to HDI. The PSDAR and DCE have been made publicly available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20358A232. The Palisades license transfer transaction closed on June 28, 2022 (ML22179A075), allowing the NRC staff to begin the review of the HDI PSDAR for Palisades.
Paragraph 50.82(a)(4)(i) of title 10 of the Code of Federal Regulations (10 CFR) states that a PSDAR must contain a description of the planned decommissioning activities along with a schedule for their accomplishment, a discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements, and a site-specific DCE, including the projected cost of managing irradiated fuel. In addition, the regulation at 10 CFR 50.82(a)(6) states, in part, that [l]icensees shall not perform any decommissioning activities that [r]esult in significant environmental impacts not previously reviewed .
In NUREG-0586, Generic Environmental Impact Statement [GEIS] on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, the NRC evaluated the environmental impacts during the decommissioning of nuclear power reactors. The decommissioning GEIS concludes that:
For those issues that have been determined to be generic, licensees may proceed with the decommissioning activity without further analysis provided that the impacts resulting from those activities fall within the range of impacts as described in Chapter 4. However, if the impacts of an activity fall outside the range predicted in Chapter 4, or if the activity results in impacts to environmental issues not considered in this Supplement, or if the impact involves an environmental issue determined to be conditionally site-specific as defined above, then the activity cannot be performed until a further site-specific analysis is completed along with a license-amendment request and NRC has approved
the license amendment (the license amendment request will provide an opportunity for a public hearing).
The following is a request for additional information (RAI) to facilitate the ongoing review of the Palisades PSDAR being conducted by the NRC staff. A timely and accurate response to this RAI is requested in order to continue the staffs review of the Palisades PSDAR.
RAI 1
The decommissioning GEIS evaluates the environmental impacts from three decommissioning methods or a combination of these methods: DECON, SAFSTOR, and ENTOMB. The decommissioning GEIS states that the selection of a decommissioning method(s) is left entirely to the licensee and is communicated to the NRC and the public in the PSDAR.
However, the Palisades PSDAR does not explicitly identify the decommissioning method, or combination of methods, that will be used at the facility. Please identify the decommissioning method or a combination of methods that will be used for the decommissioning of Palisades.
RAI 2
Section 5.3 of the Palisades PSDAR states that for radiation dose, waste management, air quality, water quality, ecological resources, and socioeconomics, [t]he NRC staff did not identify any new and significant information during their independent review of the Palisades license renewal environmental report at that time, the site audit, or the scoping process for license renewalthe NRC concluded that there are no impacts related to these issues beyond those discussed in the SEIS ([PSDAR] Reference 9), or the GEIS ([PSDAR] Reference 2) for decommissioning. The NRC found no site-specific issues related to decommissioning and there are no decommissioning activities contemplated for Palisades that would alter that conclusion. Section 5.5 of the Palisades PSDAR further states that based on the discussions presented in the Palisades PSDAR, including Section 5.3, HDI concludes that the environmental impacts associated with planned Palisades site-specific decommissioning activities will be bounded by the appropriate, previously issued environmental impact statements.
However, NUREG-1437, Supplement 27, Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Palisades Nuclear Plant - Final Report, did not reach conclusions related to Category 1 decommissioning issues with respect to the 2002 decommissioning GEIS (NUREG-0586, Supplement 1), but rather with respect to the 1996 license renewal GEIS (see Section 7.1 of NUREG-1437, Supplement 27).
Given that NUREG-1437, Supplement 27 reached conclusions related to applicable Category 1 decommissioning issues for Palisades with respect to the 1996 license renewal GEIS (i.e., the impacts associated with decommissioning following the license renewal term), rather than the decommissioning GEIS, please provide a basis for concluding that the environmental impacts associated with site-specific decommissioning activities for Palisades will be bounded by appropriate previously issued environmental impact statements for radiation doses, waste management, air quality, water quality, ecological resources, and socioeconomic impacts.