ML24304A857

Draft Request for Additional Information: Palisades Operating Final Safety Analysis Report

ML24304A857
Person / Time
Site:	Palisades
Issue date:	10/29/2024
From:	Marlayna Vaaler Doell Plant Licensing Branch III
To:	Miksa J Holtec Decommissioning International
Wall S
References
Download: ML24304A857 (5)

Text

From: Marlayna Doell To: James Miksa Cc: Justin Poole (He/Him); Gary Nyberg; Johann Britting; Amy Filbrandt

Subject:

DRAFT Request for Additional Information: Palisades Operating Final Safety Analysis Report Date: Tuesday, October 29, 2024 10:52:00 PM Attachments: DRAFT REQUEST FOR ADDITIONAL INFORMATION - Palisades Operating TS License Amendment Request.docx

Dear Jim,

By letter dated December 14, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23348A148), Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Palisades, LLC, requested changes to Renewed Facility Operating License (RFOL) No.

DPR20 for the Palisades Nuclear Plant (PNP). Specifically, HDI requested U.S. Nuclear Regulatory Commission (NRC) approval of a license amendment request (LAR) to revise selected sections of the Permanently Defueled Technical Specifications (PDTS) to reflect the proposed resumption of power operations at PNP.

The NRC staff has determined that additional information is needed to support its review. The attached is the NRC staffs draft request for additional information (RAI). Please contact me to schedule a clarification discussion if any of these correspond to the availability of your staff. If no clarification is required, then the attached draft RAI will be considered a final RAI and the NRC staff will expect a response 30 days from this message. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-3175 or marlayna.doell@nrc.gov. Thank you and I hope you have a great week!

Cheers, Marlayna

Marlayna Vaaler Doell

~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Decommissioning Project Manager U.S. Nuclear Regulatory Commission NMSS/DUWP/RDB

Phone: 301.415.3178 Mobile: 440.668.7399 E-mail: marlayna.doell@nrc.gov Office Location: Fulltime Telework from Rapid City, South Dakota!

Mail Stop: T-5A10

DRAFT REQUEST FOR ADDITIONAL INFORMATION

RELATED TO THE LICENSE AMENDMENT REQUEST TO REINSTATE

THE OPERATING TECHNICAL SPECIFICATIONS

HOLTEC DECOMMISSIONING INTERNATIONAL, LLC

PALISADES NUCLEAR PLANT

DOCKET NO. 50-255

INTRODUCTION

By application dated December 14, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23348A148), Holtec Decommissioning International, LLC (HDI ), on behalf of Holtec Palisades, LLC, requested changes to Renewed Facility Operating License (RFOL) No. DPR-20 for the Palisades Nuclear Plant (PNP). Specifically, HDI requested U.S. Nuclear Regulatory Commission (NRC, the Commission) approval of a license amendment request (LAR) to revise selected sections of the RFOL, the Permanently Defueled Technical Specifications (PDTS), and the Environmental Protection Plan to reflect the proposed resumption of power operations at PNP.

The LAR proposes changes to selected sections of the technical specifications ( TS) listed in paragraph (c) of section 5 0.36, Technical specifications, of Ti tle 10 of the Code of Federal Regulations (10 CFR) related to TS requirements that are related to power operations. In the LAR, HDI states that the proposed changes are consistent with the previously approved PNP power operations technical specifications, which were in effect just prior to permanent shutdown and defueling of the plant in May 2022.

To complete its review of the proposed operating TS changes for PNP, the NRC staff has determined that additional information is needed. The regulatory basis and the requested information are below. Timely and accurate responses to these questions are requested.

REGULATORY BASES FOR REQUEST

Section 50.90, Application for amendment of license, construction permit, or early site permit, of 10 CFR requires that whenever a licensee desires to amend the license, an application for an amendment must be filed with the Commission fully describing the changes desired and following, as far as applicable, the form prescribed for original license applications.

The NRC regulatory requirements related to the content of the TS are contained in 10 CFR 50.36. Specifically, 10 CFR 50.36(a)(1) states,in part, that [e]ach applicant for a license authorizing operation of a production or utilization facility s hall include in his application proposed technical specifications in accordance with the requirements of this section. In accordance with this requirement, TS will include items in the following five c ategories:

(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements ( SRs); (4) design features; and (5) administrative controls.

Paragraph (b) of 10 CFR 50.34, Contents of applications; technical information, states, in part, that each operating license shall include a final safety analysis report (FSAR). The final safety analysis report must include information that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components and of the facility as a whole. Furthermore, 10 CFR 54.37, Additional records and recordkeeping requirements, addresses the recordkeeping requirements related to the FSAR as it pertains to the extended period of operation.

Part 54, Requirements for Renewal of Operating Licenses for N uclear Power Plants, of 10 CFR governs the issuance of renewed operating licenses. The provisions of 10 CFR 54.21, Contents of application--technical information, establish the aging management requirements for structures, systems, and components (SSCs) that are important to safety, among other considerations. In addition, 10 CFR 54.33, Continuation of CLB [current licensing basis] and conditions of renewed license, discusses the requirements for a renewed license to contain conditions and limitations, including technical specifications, that are deemed appropriate and necessary to help ensure that SSCs subject to review in accordance with 10 CFR 54.21, or associated with any time-limited aging analyses, will continue to perform their intended functions for the period of extended operation.

Finally, 10 CFR 54.29, Standards for issuance of a renewed license, states that the Commission may issue a renewed license up to the full term if the Commission finds that

[a]ctions have been identified and have been or will be taken with respect to the matters identified in Paragraphs (a)(1) and (a)(2) of this section, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the CLB, and that any changes made to the plant's CLB in order to comply with this paragraph are in accord with the Act and the Commission's regulations.

REQUESTS FOR ADDITIONAL INFORMATION

1. In Section 2.2, Description of Proposed Change, of the Enclosure to the LAR, the licensee explains that the Updated Final Safety Analysis Report (UFSAR), currently titled the Defueled Safety Analysis Report (DSAR), will be updated via the 10 CFR 50.59, Changes, tests and experiments, process to reflect the docketed version that was in effect just prior to the 10 CFR 50.82(a)(1) certifications being docketed. This document would closely mirror PNP UFSAR Revision 35 (ML21125A344 ), with no substantial material changes.

Updating the PNP UFSAR to reflect a facility in a power operating condition is necessary to support returning PNP to a power operations licensing basis. In addition, PNP UFSAR Revision 35 contains the analyses and evaluations from which the PNP power operations TS were derived. The licensee states that reinstating the PNP power operations licensing basis to that which was in effect just prior to shutdown in May 2022 would ensure that the PNP operating TS are derived from the same analyses and evaluations included in the safety analysis report that supported PNP power operations.

The licensee goes on to state that the PNP UFSAR is a licensee-controlled document that is subject to the change control provisions of 10 CFR 50.59. Under 10 CFR 50.59, licensees are allowed to make changes in the facility and procedures as described in the FSAR, as updated, and conduct tests or experiments not described in the FSAR, without obtaining a

license amendment, provided specific criteria are met. Updates to the PNP UFSAR that require license amendment are expected to be provided as separate licensing activities.

In support of the resumption of power operations at PNP, the NRC staff needs to verify that the purportedly minimal changes that will be implemented between PNP UFSAR Revision 35 and the operating version of the PNP UFSAR will not impact the safety conclusions reached in PNP UFSAR Revision 35 as they relate to power operations.

Accordingly, please provide (1) a summary or listing of the specific changes that will take place between the two versions of this document; (2) a summary or listing of the specific UFSAR changes that require a license amendment and associated NRC approval; (3) a justification for any changes that are more than administrative in nature (i.e., name changes to reflect the current licensee); and (4) a description of the process that will be used to combine the changes or additions between PNP UFSAR Revision 35 and the DSAR into the operating version of the PNP UFSAR that will be implemented after restart.

2. By letter dated January 17, 2007 (ML070100476), the NRC issued the renewed facility operating license for PNP, which stated that the technical basis for issuing the renewed license is set forth in NUREG-1871, Safety Evaluation Report Related to the License Renewal of the Palisades Nuclear Plant, (LR SER) dated December 2006 (ML062710074).

The renewed facility license also directs the licensee to include the UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), in the next scheduled update to the PNP UFSAR. Section 1.9, Renewed Facility Operating License, of PNP UFSAR Revision 35 contains summary descriptions of the programs used to manage the effects of aging during the period of extended operation, as well as summaries of the Time-Limited Aging Analyses applicable to the period of extended operation. This section also includes the commitments for future actions made by the licensee during the license renewal application review.

Under the renewed operating license, Aging Management Programs are also applied to certain non-safety related SSCs. To ensure appropriate controls are provided for non-safety related aging management activities, the licensee made a commitment to apply certain Quality Assurance Program provisions to Aging Management Programs. These provisions apply to the program elements of corrective action, confirmation process, and administrative controls. Section 15.1.2 of PNP UFSAR Revision 35 describes the generic quality assurance requirements to be applied to the Aging Management Programs.

In support of the resumption of power operations at PNP, the NRC staff needs to verify that (1) Section 1.9 of the PNP UFSAR Revision 35 will be included in the operating version of the PNP UFSAR in its entirety; and (2) the provisions for the associated Aging Management Programs, including the periodic inspection requirements, will be implemented by the licensee who will be operating PNP in the same manner as that evaluated by the NRC staff during the initial review of the license renewal application.

Accordingly, please provide a confirmation that Section 1.9 of the PNP UFSAR Revision 35 will be included in the operating PNP UFSAR and provide any changes that will be made to this section between the two versions. In addition, please provide a discussion or description of how the licensee intends to meet the commitments for Aging Management Programs outlined in the original license renewal application, which was submitted by Entergy Nuclear Operations, Inc., the previous licensee for PNP during power operations, as revised in the LR SER (ML062710074). This discussion should contain information on the status and

recordkeeping for the Aging Management Programs and license renewal commitments.

3. The operating TS LAR was supplemented on July 9, 2024 ( ML24191A422), to correct several editorial errors. However, three additional minor errors were introduced by these changes and should be addressed in the final version of the operating TS for PNP.

Specifically, Attachment 2, Updated Retyped Pages for the Palisades Plant, of Enclosure 2 (begins on p age 23 of 111 of the supplemental information) contains the following errors:

Item TS Page Number Error in Enclosure 2 Attachment 2 1 3.4.15-2 Enclosure 2, Attachment 2 is missing replacement page 3.4.15-2.

Replacement page instructions (enclosure page 12 of 14) identified that page 3.4.15-2 was to be updated, which the NRC staff verified is correct. However, page 3.4.15-2 was not included in Enclosure 2, Attachment 2.

2 3.4.16-1 Enclosure 2, Attachment 2 should not have included replacement page 3.4.16-1.

Replacement page instructions (enclosure page 12 of 14) did not include replacing page 3.4.16-1, which the NRC staff verified is correct. However, page 3.4.16-1 was included in Enclosure 2, Attachment 2 and introduced an editorial error.

Specifically, this page was not missing the expression

"(continued)" after ACTIONS but "(continued)" was added in the supplemental information. This is an error because it is the beginning of the Actions Table, not a continuation (see page 55 of 111 of the supplemental information).

3 3.8.1-7 The font color for the whole page appears to be a light gray rather than black, and should be corrected in the final version of the operating TS.