PNP 2023-005, Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report

Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report

ML23060A039
Person / Time
Site:	Palisades
Issue date:	03/01/2023
From:	Fleming J Holtec Decommissioning International
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
EPID L-2022-LRO-0073, HDI PNP 2023-005
Download: ML23060A039 (1)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 HOLTEC Telephone (856) 797-0900 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL HDI PNP 2023-005 10 CFR 50.82(a)(4) 0DUFK, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Docket No. 50-255 and 72-007 Renewed Facility Operating License No. DPR-20

Subject:

Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report (EPID No.

L-2022-LRO-0073)

References:

1) Holtec Decommissioning International LLC, to U.S. Nuclear Regulatory Commission, Post Shutdown Decommissioning Activities Report including Site-Specific Decommissioning Cost Estimate for Palisades Nuclear Plant, (NRC ADAMS Accession Number ML20358A232), dated December 23, 2020

2) U.S. Nuclear Regulatory Commission, Letter to Holtec International, LLC, Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report (EPID No.

L-2022-LRO-0073), (NRC ADAMS Accession Package Number ML23055A152), dated February 14, 2023 In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 50, Section 82, Termination of License, paragraph (a)(4), 10 CFR 50.82(a)(4), Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Palisades, LLC (Holtec Palisades), submitted a Post-Shutdown Decommissioning Activities Report (PSDAR), including the Site-Specific Decommissioning Cost Estimate (DCE) to the U.S. Nuclear Regulatory Commission (NRC)

(Reference 1).

In Reference 2, HDI received a request for additional information (RAI) from the NRC on the subject PSDAR (Reference 2). The HDI response to the RAI is provided in the enclosure to this letter.

This letter contains no new commitments and no revised regulatory commitments.

Should you have any questions or require additional information, please contact Jim Miksa, Regulatory Assurance Engineer at (269) 764-2945.

HDI PNP 2023-005 Page 2 of 2 Respectfully, Jean A. Fleming Digitally y

signed by Jean A. Fleming Date: 2023.03.01 08:06:26 -05'00' Jean A. Fleming Vice President, of Licensing, Regulatory Affairs & PSA Holtec International

Enclosure:

Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report cc: NRC Region Ill Regional Administrator NRC Decommissioning Inspector - Palisades Nuclear Plant NRC NMSS Project Manager - Palisades Nuclear Plant Designated Michigan State Official American Nuclear Insurers - Principal Account Engineer

HDI PNP 2023-005 Enclosure Page 1 of 4 Enclosure to HDI PNP 2023-005 Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report

HDI PNP 2023-005 Enclosure Page 2 of 4 Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report NRC RAI 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 NRC staff. A timely and accurate response to this RAI is requested in order to continue the staffs review of the Palisades PSDAR.

HDI PNP 2023-005 Enclosure Page 3 of 4

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.

HDI Response to RAI 1 The NUREG-0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1 method of decommissioning for Palisades is incremental DECON.

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

HDI PNP 2023-005 Enclosure Page 4 of 4 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.

HDI Response to RAI 2 Per NUREG-0856, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, (Decommissioning GEIS) Supplement 1 (Reference 1), the environmental impacts of radiation dose, waste management, air quality, water quality and socioeconomic impacts have been determined to be VPDOO. Holtec Decommissioning International (HDI) has not identified any planned decommissioning activities for Palisades that are outside those considered in the Decommissioning GEIS. Therefore, HDI concludes that the impacts for the issues of radiation doses, waste management, air quality, water quality, ecological resources, and socioeconomic associated with decommissioning of Palisades are bounded by the Decommissioning GEIS impacts. This conclusion is further supported by the site-specific analyses of the impacts for these issues documented in NUREG 1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 27, Regarding Palisades Nuclear Plant, (SEIS)

(Reference 2). If site-specific activities were to be performed that are not within the bounds covered by the Decommissioning GEIS, a site- specific analysis of the activities would be conducted prior to these activities being performed.

References

1. NUREG-0856, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, ADAMS Accession No. ML023470304, dated November 2002.

2. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 27, Regarding Palisades Nuclear Plant, ADAMS Accession No. ML062710300, dated October 2006