PNP 2024-033, Response to Request for Additional Information - License Amendment Request to Revise the Palisades Nuclear Plant Site Emergency Plan to Support Resumption of Power Operations

Response to Request for Additional Information - License Amendment Request to Revise the Palisades Nuclear Plant Site Emergency Plan to Support Resumption of Power Operations

ML24206A187
Person / Time
Site:	Palisades
Issue date:	07/24/2024
From:	Fleming J Holtec Decommissioning International
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
HDI PNP 2024-033
Download: ML24206A187 (1)

Text

HOLTEC Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax(856)797-0909 DECOMMISSIONING INTERNATIONAL HDI PNP 2024-033 10 CFR 50.90 10 CFR 50.54(q)

July 24, 2024 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant NRC Docket Nos. 50-255 and 72-007 Renewed Facility Operating License No. DPR-20

References:

1. Holtec Decommissioning International, LLC letter to U.S. Nuclear Regulatory Commission, "License Amendment Request to Revise the Palisades Nuclear Plant Site Emergency Plan to Support Resumption of Power Operations,"

dated May 1, 2024 (ADAMS Accession No. ML24122C666)

2. U.S. Nuclear Regulatory Commission email to Holtec Decommissioning International, "Palisades Nuclear Plant Restart - NRC Request for Additional Information - EP ORO Coordination - June 28, 2024," dated June 28, 2024 (ADAMS Accession No. ML24192A167)

Subject:

Response to Request for Additional Information - License Amendment Request to Revise the Palisades Nuclear Plant Site Emergency Plan to Support Resumption of Power Operations In Reference 1, Holtec Decommissioning International, LLC (HDI) on behalf of Holtec Palisades LLC, submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) for approval of a revision to the Palisades Nuclear Plant (PNP) Site Emergency (SEP) and emergency classification scheme to reflect the resumption of power operations at PNP.

In Reference 2, the NRC requested additional information concerning the LAR.

The Enclosure to this letter provides the HDI response to the NRC request for additional information (RAI).

This RAI response does not require any changes to the information provided in Reference 1 and does not impact the conclusions of the no significant hazards evaluation or the environmental considerations evaluation presented in Reference 1.

This letter contains no new commitments and no revisions to existing commitments.

Enclosure HDI PNP 2024-033 Page 2 of 2 In accordance with 10 CFR 50.91 (b), State consultation, HDI is notifying the State of Michigan of this RAI response by transmitting a copy of this letter, with its enclosure, to the designated State of Michigan official.

If you have any questions regarding this submittal, please contact Jim Miksa, Regulatory Assurance Manager, at (269) 764-2945.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 24, 2024.

Respectfully, Jean A.

Fleming Digitally signed by Jean A. Fleming ON: cn=Jean A. Fleming, c=US.

o=Holtec Decommissioning International. LLC, ou:Regulatoryand Environmental Affairs email=J.Fleming@Holtec.com Date: 2024.07.2411 :38:42-04'00' Jean A. Fleming Vice President of Licensing and Regulatory Affairs Holtec International

Enclosure:

Response to Request for Additional Information - License Amendment Request to Revise the Palisades Nuclear Plant Site Emergency Plan to Support Resumption of Power Operations Enclosure

Attachment:

Offsite Response Organization Acknowledgments cc:

NRC Region Ill Regional Administrator NRC Decommissioning Inspector - PNP NRC Project Manager-PNP Designated Michigan State Official

Enclosure HDI PNP 2024-033 Page 1 of 3 Enclosure HDI PNP 2024-033 Response to Request for Additional Information -

License Amendment Request to Revise the Palisades Nuclear Plant Site Emergency Plan to Support Resumption of Power Operations

Enclosure HDI PNP 2024-033 Page 2 of 3 A U.S. Nuclear Regulatory Commission (NRC) request for additional information (RAI) regarding a license amendment request to revise the Palisades Nuclear Plant (PNP) Site Emergency (SEP) and emergency classification scheme to reflect the resumption of power operations at PNP (Reference 1) was received by Holtec Decommissioning International, LLC (HDI) via electronic mail (email) dated June 28, 2024 (Reference 2).

HDl's response to the RAI is provided below.

NRCREQUEST By letter dated May 1, 2024 (Agencywide Documents Access and Management System Accession No. ML24122C666), Ho/tee Decommissioning International, LLC (HD/), on behalf of Ho/tee Palisades LLC, requested U.S. Nuclear Regulatory Commission (NRC, the Commission) approval of a proposed license amendment for the Palisades Nuclear Plant (PNP) Site Emergency Plan. HD! proposes to revise the PNP Site Emergency Plan and emergency classification scheme to reflect the potential resumption of power operations at PNP The following request for additional information (RA/) is needed to facilitate the technical review being conducted by the Division of Preparedness and Response, Reactor Licensing Branch staff. Timely and accurate response to this draft RA/ is requested. In addition, please note that this RA/ is being provided in advance of other potential questions on the PNP Site Emergency Plan given the need to share this information with the Federal Emergency Management Agency Therefore, additional RA/s may be provided in the future regarding this review.

Requirement 10 CFR 50.47(b)(1) requires that (1) the primary responsibilities for emergency response by the nuclear facility licensee, as well as by State and local organizations within the Emergency Planning Zones, have been assigned, (2) the emergency responsibilities of the various supporting organizations have been specifically established, and (3) each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Section /VA of Appendix E to 10 CFR Part 50 requires that the organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.

Issue: Section 11.A.1.a of Attachment 2, "Proposed Palisades Nuclear Plant Power Operations Site Emergency Plan." of the HO/ application, lists State and County Agencies.

However, the proposed license amendment does not provide documentation that the offsite response organization(s) has concurred with the proposed license amendment to transition from a decommissioned emergency plan to an operating reactor emergency plan to reflect the potential resumption of power operations at PNP.

Request: Please provide documentation from the respective offsite response organizations that have responsibilities for emergency response within the Emergency Planning Zones for PNP

Enclosure HDI PNP 2024-033 Page 3 of 3 that describes their concurrence with the proposed transition to reflect the potential resumption of power operations at PNP.

HDI Response to RAI The Michigan State Police Emergency Management and Homeland Security Division (MSP/EMHSD) is the lead state agency for emergency response planning and operations. This agency operates under the direction of the State Director of Emergency Management.

The Van Buren County Office of Domestic Preparedness, the Berrien County Sheriff's Office Emergency Management and Homeland Security Division, and the Allegan County Office of Emergency Management are the lead county agencies responsible for coordinating the offsite response to a radiological emergency at the Palisades Nuclear Plant (PNP).

PNP is coordinating periodic meetings with each of these agencies to discuss the emergency planning efforts necessary to support the transition from decommissioning to a power operations plant. These discussions include the planned transition to the Integrated Public Alert and Warning System (IPAWS) - Wireless Emergency Alerts (WEA) as the primary alerting method and !PAWS - Emergency Alert System (EAS) as the primary method to disseminate information regarding an emergency at PNP, and PNP's plan to revise the emergency action level scheme to a scheme that supports power plant operations.

The Attachment to this Enclosure provides acknowledgment from each of these agencies that each is aware of Holtec's plans to restart PNP; is engaged in discussions with PNP regarding the onsite and offsite emergency planning efforts necessary to restart PNP; and intends to participate in planning efforts that support restart, including any required field demonstrations.

References:

1.

Holtec Decommissioning International, LLC letter to U.S. Nuclear Regulatory Commission, "License Amendment Request to Revise the Palisades Nuclear Plant Site Emergency Plan to Support Resumption of Power Operations," dated May 1, 2024 (ADAMS Accession No. ML24122C666)

2.

U.S. Nuclear Regulatory Commission email to Holtec Decommissioning International, "Palisades Nuclear Plant Restart - NRC Request for Additional Information - EP ORO Coordination - June 28, 2024," dated June 28, 2024 (ADAMS Accession No. ML24192A167)

HDI PNP 2024-033 Enclosure Attachment Offsite Response Organization Acknowledgments 4 pages follow

HOLTEC INTERNATIONAL Palisades Nuclear Plant Emergency Plan Acknowledgment The Michigan State Police, Emergency Management and Homeland Security Division is aware of the Palisades Nuclear Plant's (PNP) intent to resume power.

Michigan State Police, Emergency Management and Homeland Security Division acknowledges that:

it is aware of Holtec's plans to restart PNP; it is engaged in discussions with PNP regarding the onsite and offsite emergency planning efforts necessary to restart PNP; and it intends to participate in planning efforts that support restart, including any required field demonstrations.

It is my understanding that the specific nature of arrangements in support of emergency preparedness for operation of PNP are still in development and will be clearly established in a properly executed and binding letter of agreement that will be documented in the PNP Site Emergency Plan associated with PNP resuming power operations.

Kevin Sweeney Print Name (AGENCY REPRESENTATIVE)

Signature Digitally signed by Capt. Kevin Sweeney Date: 2024.07.02 11 :32:00-04'00' Commander, Emergency Management and Homeland Security Division Title 7/2/2024 Date

HOLTEC INTERNATIONAL Palisades Nuclear Plant Emergency Plan Acknowledgment The Van Buren County EMERGENCY MANAGEMENT AGENCY is aware of the Palisades Nuclear Plant's (PNP) intent to resume power.

Van Buren County EMERGENCY MANAGEMENT AGENCY acknowledges that:

it is aware of Holtec's plans to restart PNP; it is engaged in discussions with PNP regarding the onsite and offsite emergency planning efforts necessary to restart PNP; and it intends to participate in planning efforts that support restart, including any required field demonstrations.

It is my understanding that the specific nature of arrangements in support of emergency preparedness for operation of PNP are still in development and will be clearly established in a properly executed and binding letter of agreement that will be documented in the PNP Site Emergency Plan associated with PNP resuming power operations.

Sheriff, Van Buren County Title

HOLTEC INTERNATIONAL Palisades Nuclear Plant Emergency Plan Acknowledgment The ALLEGAN COUNTY EMERGENCY MANAGEMENT is aware of the Palisades Nuclear Plant's (PNP) intent to resume power.

ALLEGAN COUNTY EMERGENCY MANAGEMENT acknowledges that:

it is aware of Holtec's plans to restart PNP; it is engaged in discussions with PNP regarding the onsite and offsite emergency planning efforts necessary to restart PNP; and it intends to participate in planning efforts that support restart, including any required field demonstrations.

It is my understanding that the specific nature of arrangements in support of emergency preparedness for operation of PNP are still in development and will be clearly established in a properly executed and binding letter of agreement that will be documented in the PNP Site Emergency Plan associated with PNP resuming power operations.

Sarah A. Clark Print Name (AGENCY REPRESENTATIVE)

Signature Date Allegan County July 7, 2024 Emergency Management Coordinator Title

HOLTEC INTERNATIONAL Palisades Nuclear Plant Emergency Plan Acknowledgment The BERRIEN COUNTY EMERGENCY MANAGEMENT AGENCY is aware of the Palisades Nuclear Plant's (PNP) intent to resume power.

BERRIEN COUNTY EMERGENCY MANAGEMENT AGENCY acknowledges that:

it is aware of Holtec's plans to restart PNP; it is engaged in discussions with PNP regarding the onsite and offsite emergency planning efforts necessary to meet emergency planning requirements should Holtec restart PNP; and it intends to participate in planning efforts that support meeting NUREG 0654 criteria for the restart, including any required field demonstrations.

It is my understanding that the specific nature of arrangements in support of emergency preparedness

• for operation of PNP are still in development and will be clearly established in a properly executed and binding letter of agreement that will be documented in the PNP Site Emergency Plan associated with PNP resuming power operations.

CPT Rockey J. Adams Print Name (AGENCY REPRESENTATIVE)

(?T.(4'1~~

Signature Emergency Management Coordinator Title 7/8/2024 Date