ML24036A108
| ML24036A108 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/06/2024 |
| From: | Holtec |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML24036A108 (29) | |
Text
www.holtec.com Pre-Submittal Meeting Palisades Nuclear Plant License Amendment Request to Support Resumption of Power Operations - Technical Specification Administrative Controls February 6, 2024
www.holtec.com l Page 2 Meeting Agenda
Introductions
Purpose & Outcome
Background
License Amendment Request (LAR) Content Reason for Proposed Changes Technical Specifications Administrative Controls (TS Admin) Section Reinstatement Regulatory Basis Environmental Assessment Licensee Actions to Support Reinstating Power Operations Licensing Basis (POLB)
Schedule Questions
www.holtec.com l Page 3
Introductions
U.S Nuclear Regulatory Committee (NRC) Staff Holtec Decommissioning International, LLC (HDI)
Jean Fleming - Holtec International, Vice President of Licensing, Regulatory Affairs & PSA Michael Schultheis - HDI, Manager of Regulatory Assurance for Palisades Jim Miksa - HDI, Regulatory Assurance Engineer for Palisades
www.holtec.com l Page 4 Purpose & Outcome
Purpose:
Present proposed changes to the Palisades Nuclear Plant (PNP)
Technical Specifications (TS):
Section 1.1, Definitions
Section 5.0, Administrative Controls 5.1 Responsibility 5.2 Organization 5.3 Plant Staff Qualifications 5.4 Procedures Outcome:
Solicit NRC Staff questions and comments ahead of submittal
Provide information to support NRC resource allocation
www.holtec.com l Page 5
Background
The Governor of the State of Michigan voices support for power operations at Palisades Nuclear Plant (PNP) (April 20, 2022, and September 9, 2022)
PNP Docketed 10 CFR 50.82(a)(1) Certifications, Permanent Cessation Power Operations, Permanent Removal of Fuel from Reactor Vessel (June 13, 2022)
Permanently Defueled Technical Specifications implemented at PNP (June 15, 2022)
PNP ownership and license transferred from Entergy to Holtec (June 28, 2022)
Holtec attends public meeting to present a proposed regulatory path for return of PNP to power operations (March 20, 2023)
www.holtec.com l Page 6
Background
Holtec attends public meeting to present a proposed regulatory framework for return of PNP to power operations with emphasis on exemption request to 10 CFR 50.82(a)(2) (May 24, 2023)
The State of Michigan legislature expressed their support for the restart of PNP by approving a 2024 budget that includes 150 million dollars for the return of PNP to power operations (June 28, 2023)
Holtec announces long-term power purchase agreement (PPA) with two PPA off-takers (September 12, 2023)
HDI submitted Exemption to 10 CFR 50.82(a)(2) on September 28, 2023 (ADAMS Accession Number ML23271A140)
www.holtec.com l Page 7
Background
HDI submitted License Transfer Application for PNP Operational Authority on December 6, 2023 (ADAMS Accession Number ML23340A161)
HDI submitted License Amendment Request Power Operations Technical Specifications on December 14, 2023 (ADAMS Accession Number ML23348A148)
PNP Renewed Facility Operating License (RFOL) remains active (i.e., it has not been terminated)
The PNP License Renewal 20-year term ends on March 24, 2031 (i.e., PNP return to power operations is currently within the License Renewal term)
HDI Commences project to pursue subsequent license renewal for PNP to 2051 (October 2023)
www.holtec.com l Page 8 LAR Content Reason for Proposed Change Description of Each Change with Basis Applicable Regulatory Requirements Precedent No Significant Hazards Consideration Environmental Evaluation Mark-ups and Clean TS Pages
www.holtec.com l Page 9 Reason for Proposed Change Supports State of Michigan clean energy initiative
Governor of the State of Michigan Letters to US Secretary of Energy
Legislature State of Michigan 2024 Budget Approval 150 Million dollars for return of Palisades Nuclear Plant (PNP) to power operations Supports reinstatement of PNP POLB One of five key licensing actions
10 CFR 50.82(a)(2) exemption to remove operational restrictions
License transfer application for operational authority
License amendment to restore Power Operations Technical Specifications
License amendment for Technical Specifications administrative changes (This proposed change)
License amendment to restore a power operations emergency plan
www.holtec.com l Page 10 Reason for Proposed Changes TS Section 1.0, Use and Application:
TS 1.1 Definitions
Delete CERTIFIED FUEL HANDLER and NON-CERTIFIED OPERATOR TS Section 5.0, Administrative Controls Sections are reinstated (Added or Deleted Text) to match Amendment 271 Permanently Defueled Technical Specification (PDTS)
Amendment 272 Retained Changes:
Previous title changes (ex. plant superintendent to plant manager)
www.holtec.com l Page 11 TS Admin Section Reinstatement TS Section 5.0, Administrative Controls TS 5.1, Responsibility - Reinstates
Control room command function TS 5.2, Organization - Reinstates
Organizational authority and independence for safe plant operation
Operating crew composition and minimum staffing TS 5.3, Plant Staff Qualification - Reinstates
The operating staff qualification requirements TS 5.4, Procedures - Reinstates
The full scope of RG 1.33, Quality Assurance Program Requirements operating procedures
Emergency operating procedures for an operating plant
www.holtec.com l Page 12 Regulatory Basis 10CFR 50.36, Technical specifications 10CFR 50.54, Conditions of licenses
www.holtec.com l Page 13 Environmental Assessment
10 CFR 51.22(c)(9) Categorical Exclusion
No Significant Hazards Consideration
No changes proposed to the power operations design basis configuration or operation of the plant as originally designed / constructed / operated
No relaxations in criteria used to establish safety limits or safety system settings or TS Limiting Conditions of Operation (LCOs) that were in effect during power operations prior to the decommissioning certifications
No significant change in the types or significant increase in the amounts of any effluents that may be released offsite
No physical plant changes
Restoration of Systems, Structures and Components (SSCs) to monitor and limit the amounts of effluents released ensures the 1972 FES-OL, the 1978 final addendum, and the 2006 license renewal Supplemental Environmental Impact Statement (SEIS) environmental impacts are not significantly changed
Resumed power operations conducted under existing environmental permits
www.holtec.com l Page 14 Environmental Assessment
10CFR51.22(c)(9) Categorical Exclusion (cont.)
No significant increase in individual or cumulative public or occupational dose
Plant programs and processes to support an operating plant will be restored to ensure 10 CFR 20 limits are not exceeded. The previous radiological impacts to the public, as evaluated in the Final Environmental Statement (FES) and 1978 Addendum for the original 40 years and the SEIS for the additional 20 years is still bounding.
www.holtec.com l Page 15 Licensee Actions to Support Reinstating POLB
- Restore commitments closed based on decommissioning certification
- Restore Updated Final Safety Analysis Report (UFSAR) to reflect power operations plant
- Restore compliance to NRC Orders and industry initiatives
- Develop Return to Service Plans for Safety Related and Important to Safety SSCs
- Restore Regulatory Programs and Operating Procedures (e.g.)
- Quality Assurance Program
- Inservice Inspection Program
- Emergency Operating Procedures
www.holtec.com l Page 16 Schedule Effective Request Approval Submit Title Aug 2025 Dec 31, 2024 Sept 28, 2023 Exemption Aug 2025 Dec 31, 2024 Dec 6, 2023 License Transfer Aug 2025 Jan 31, 2025 Dec 14, 2023 Power Ops Tech Specs Aug 2025 Mar 2025 Feb 2024 Power Ops Admin Tech Specs Aug 2025 Apr 2025 Mar 2024 Emergency Plan - Power Ops NA NA Mar 2024 10 CFR 50.82(a)(7) - PSDAR NA NA Aug 2025 Notice of Transition - POLB Effective Date -
Transition Date, Palisades Transitions from Facility in Decommissioning to Power Operations Plant
www.holtec.com l Page 17 Questions / Comments NRC Staff Questions or Comments?
www.holtec.com Quality Assurance Program Reinstatement Plan Palisades Nuclear Plant To Support Resumption of Power Operations February 6, 2024
www.holtec.com l Page 2 Discussion Topics Purpose & Outcome
Background
Quality Assurance Program Manual (QAPM) Revision History Decommissioning Quality Assurance Program (DQAP)
Power Operations QAPM Regulatory Basis Submittal Schedule Questions / Comments
www.holtec.com l Page 3 Purpose & Outcome
Purpose:
Present plan to reinstate the Palisades Nuclear Plant (PNP)
Quality Assurance Program Manual (QAPM)
Pre-Shutdown Entergy QAPM
HDI Decommissioning Quality Assurance Plan (DQAP)
Palisades Power Operations QAPM Outcome:
Solicit NRC Staff questions and comments on QAPM reinstatement plan
www.holtec.com l Page 4
Background
PNP Docketed 10 CFR 50.82(a)(1) Certifications, Permanent Cessation Power Operations, Permanent Removal of Fuel from Reactor Vessel (June 13, 2022)
Permanently Defueled Technical Specifications (PDTS) implemented at PNP coincident with Site Specific QAPM.
Site specific QAPM revised to reflect Certified Fuel Handlers (CFH)
(June 15, 2022)
PNP ownership and license transferred from Entergy to Holtec Decommissioning International, LLC (HDI) (June 28, 2022).
Palisades and Big Rock Point (BRP) added to HDI DQAP.
www.holtec.com l Page 5 QAPM Revision History Entergy Fleet QAPM R42 effective at PNP prior to June 15, 2022 PNP Site Specific QAPM R0 implemented on June 15, 2022
Removed Entergy Sites from QAPM except for PNP and BRP PNP Site Specific QAPM R1 implemented on June 15, 2022, until June 28, 2022.
Revised site specific QAPM to include Certified Fuel Handlers and removed licensed operators.
Holtec Decommissioning International, LLC (HDI) DQAP R2 adopted at PNP on June 28, 2022.
Reduced commitments to reflect a facility in decommissioning.
www.holtec.com l Page 6 DQAP Effective at PNP and BRP until the transition date (Q3 2025).
Transition date - the date PNP transitions from a facility in decommissioning to a power operations plant Supports the current decommissioning licensing basis. Maintains alignment and prevents conflicts between current licensing basis documents.
DQAP remains effective for BRP
www.holtec.com l Page 7 Power Operations QAPM 2Q 2024 target submittal of PNP Power Ops QAPM for NRC staff review Power Ops QAPM followed during Palisades restart activities prior to Effective Date PNP Project Execution Plan (PEP) provides details for QAPM prior to Effective Date Effective and implemented at PNP on the Q3 2025 transition date to Power Operations QAPM enables verification of design classification, testing, and maintenance in preparation for reinstating SSC functionality / operability Supports Return to Service Plans
QAPM Aligns with previous power operations site implementing procedures
www.holtec.com l Page 8 Power Operations QAPM Based on Entergy Fleet QAPM R42 (ML22104A078) - Effective at PNP prior to shutdown Removes other Entergy Sites and Entergy Site Specific Information Removes Big Rock Point Changes Owner Description Changes Organizational Titles Updated Staff Position Responsibilities to Match Revised Power Operations Organization Change name of off-site safety review committee to Nuclear Safety Review Board (NSRB)
www.holtec.com l Page 9 Regulatory Basis
10 CFR 50.54(a), Conditions of licenses PDTS Section 5.4 (Current License Basis)
Written procedures shall be established, implemented, and maintained covering the activities referenced below:
The procedures applicable to the safe storage of spent nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Power Operations TS Section 5.4 (Future License Basis)
Written procedures shall be established, implemented, and maintained covering the activities referenced below:
The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
NOTE: Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)
www.holtec.com l Page 10 Submittal Schedule
Submit - April 2024
Request Approval - May 2025
Implement - Q3 2025 (On Transition Date)
www.holtec.com l Page 11 Questions / Comments NRC Staff Questions or Comments?
www.holtec.com l Page 12 Thank You Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104 Tel: (856) 797-0900 www.holtec.com