ML24036A108

Pre-submittal Meeting for Palisades Nuclear Plant Power Operations Technical Specifications Administrative Controls and Quality Assurance Program (Presentation)

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 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 2

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 3 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 4

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 5

Background

Holtec attendspublic 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 6

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 7 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 8 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 restorePower 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 9 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 10 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 11 Regulatory Basis

10CFR 50.36, Technical specifications

10CFR 50.54, Conditions of licenses

www.holtec.com l Page 12 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 SupplementalEnvironmental Impact Statement(SEIS)environmental impacts are not significantly changed Resumed power operations conducted under existing environmental permits

www.holtec.com l Page 13 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 14 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 15 Schedule

Title Submit Request Approval Effective

Exemption Sept 28, 2023 Dec 31, 2024 Aug 2025

License Transfer Dec 6, 2023 Dec 31, 2024 Aug 2025

Power Ops Tech Specs Dec 14, 2023 Jan 31, 2025 Aug 2025

Power Ops Admin Tech Specs Feb 2024 Mar 2025 Aug 2025

Emergency Plan -Power Ops Mar 2024 Apr 2025 Aug 2025

10 CFR 50.82(a)(7) -PSDAR Mar 2024 NA NA

Notice of Transition -POLB Aug 2025 NA NA

Effective Date -Transition Date, Palisades Transitions from Facility in Decommissioning to Power Operations Plant

www.holtec.com l Page 16 Questions / Comments

NRC Staff Questions or Comments?

www.holtec.com l Page 17 www.holtec.com

Quality Assurance Program Reinstatement Plan Palisades Nuclear Plant To Support Resumption of Power Operations

February 6,2024 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 2 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 3

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 4 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 5 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 6 Power Operations QAPM

2Q2024 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 Q32025 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 7 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 8 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 9 Submittal Schedule

Submit -April 2024

Request Approval -May 2025

Implement -Q3 2025 (On Transition Date)

www.holtec.com l Page 10 Questions / Comments

NRC Staff Questions or Comments?

www.holtec.com l Page 11 Thank You

Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104 Tel: (856) 797-0900 www.holtec.com

www.holtec.com l Page 12