ML24116A293
| ML24116A293 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/29/2024 |
| From: | Holtec |
| To: | Justin Poole NRC/NRR/DORL/LPL3 |
| Wall S | |
| References | |
| Download: ML24116A293 (18) | |
Text
www.holtec.com Pre-Submittal Meeting Palisades Nuclear Plant Power Operations Quality Assurance Program Manual April 29, 2024
www.holtec.com l Page 2 Meeting Agenda
Introductions
Meeting Purpose & Outcome
Background
Palisades Quality Assurance Program Manual (QAPM) Revision History Submittal Content 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 and Regulatory Affairs
- Michael Schultheis - HDI, Director of Regulatory and Site Strategies at Palisades
www.holtec.com l Page 4 Meeting Purpose & Outcome
Purpose:
- Present the Palisades Energy power operations Quality Assurance Program Manual (QAPM), submitted by Holtec Decommissioning International, LLC, that will support the Palisades power operations licensing basis (POLB).
Primarily organizational changes as a result of the transfer of PNP ownership from Entergy to HDI
Some minor administrative changes Outcome:
www.holtec.com l Page 5
Background
April 20, 2022, The Governor of the State of Michigan voices support for power operations at Palisades Nuclear Plant (PNP)
June 13, 2022, PNP docketed 10 CFR 50.82(a)(1) Certifications of Permanent Cessation Power Operations and Permanent Removal of Fuel from Reactor Vessel (ADAMS Accession No. ML22164A067)
June 15, 2022, Site specific QAPM revised to reflect Certified Fuel Handlers (CFH)
June 28, 2022, PNP ownership and license transferred from Entergy to Holtec Palisades and Big Rock Point (BRP) added to HDI DQAP.
March 20, 2023, Holtec holds a public meeting to present a proposed regulatory path for return of PNP to power operations
May 24, 2023, Holtec holds a 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)
www.holtec.com l Page 6
Background
June 28, 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
September 28, 2023, HDI submitted Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82 on (ADAMS Accession No. ML23271A140)
December 6, 2023, HDI submitted License Transfer Application for PNP Operational Authority on (ADAMS Accession No. ML23340A161)
December 14, 2023, HDI submitted License Amendment Request Power Operations Technical Specifications (ADAMS Accession No. ML23348A148)
December 27, 2023, NRC approves Permanently Defueled Emergency Plan (PDEP) and Revised Emergency Action Levels (EALs) for Decommissioning (ADAMS Accession No. ML23236A004)
www.holtec.com l Page 7
Background
February 9, 2024, HDI submitted License Amendment Request to Revise Selected Permanently Defueled Technical Specifications Administrative Controls to Support Resumption of Power Operations (ADAMS Accession No. ML24040A089)
March 27, 2024, Holtec secured a $1.5 Billion USD loan from the US Department of Energy to support the repowering of the Palisades Nuclear Plant.
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)
www.holtec.com l Page 8 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 9 Submittal Content Proposed Power Operations Quality Assurance Program Manual 50.54(a) Change Evaluation Purpose Discussion Conclusion Table of Changes and Associated Evaluation Entergy Power Operations Quality Assurance Program Implemented at Palisades.
www.holtec.com l Page 10 50.54(a) Purpose Proposed Power Operations Quality Assurance Program Manual 50.54(a) Change Evaluation Purpose Discussion Conclusion Table of Changes and Associated Evaluation Entergy Power Operations Quality Assurance Program Implemented at Palisades.
www.holtec.com l Page 11 50.54(a) Table of Changes
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 Deleted reference to Nuclear Oversight and replaced with Quality Assurance.
Changes Owner Description and 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)
Consolidated the function of the Entergy Oversight Manager and QA Supervisor into one position at Palisades; the Quality Assurance Manager.
www.holtec.com l Page 12 50.54(a) Discussion 50.54(a) Change Evaluation 10 CFR 71.106 Questions Yes, No or N/A Is the change editorial in nature?
No Does the change represent a reduction in commitment?
No Is the change a change to a QA standard?
No Does the change use generic organizational titles, rather than specific titles?
No Does the change use descriptive text to describe functional relationships?
Yes Does the change eliminate QA program information duplicating language in QA Reg Guides and QA Standards?
No Does the change continue to ensure persons or organizations performing QA functions continue to have requisite authority and organizational freedom, including sufficient independence from cost and schedule?
Yes
www.holtec.com l Page 13 50.54(a) Conclusion
- Since the change is not considered editorial and does not utilize generic organizational changes, the change requires an LAR.
- To note, no reduction of commitments exist.
www.holtec.com l Page 14 Power Operations QAPM - What is not changing With the exception of the organizational and administrative changes, the body of the QAPM remains the same in terms of wording, grammar and sequence.
www.holtec.com l Page 15 Schedule Title Submit Request Approval Effective Exemption Sep 2023 Dec 2024 Aug 2025 License Transfer Dec 2023 Jan 2025 Aug 2025 Power Ops Tech Specs Dec 2023 Jan 2025 Aug 2025 Power Ops Admin Tech Specs Feb 2024 Mar 2025 Aug 2025 10 CFR 50.82(a)(7) - Post-Shutdown Decommissioning Activities Report (PSDAR)
Mar 2024 N/A Mar 2024 Notification of Intent to Pursue Subsequent License Renewal April 2024 N/A N/A Transition Date - Palisades Transitions from Facility in Decommissioning to Power Operations Plant
www.holtec.com l Page 16 Schedule - Continued Title Submit Request Approval Effective Emergency Plan - Power Ops May 2024 Jun 2025 Aug 2025 Power Operations Quality Assurance Plan - POLB May 2024 June 2025 Aug 2025 Supplement Power Ops Tech Specs to docket Physical Security Plan for Power Operations June 2024 Jan 2025 Aug 2025 Notification of Readiness to Transition - POLB Jul 2025 N/A N/A Notification of Transition - POLB Aug 2025 N/A Aug 2025 Transition Date - Palisades Transitions from Facility in Decommissioning to Power Operations Plant
www.holtec.com l Page 17 Questions NRC Staff Questions or Comments?
www.holtec.com l Page 18 Thank You Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104 Tel: (856) 797-0900 www.holtec.com