ML24353A174

Reauthorization of Power Operations Regulatory Environmental Audit Report

ML24353A174
Person / Time
Site:	Palisades  (DPR-020)
Issue date:	01/24/2025
From:	Richmond M NRC/NMSS/DREFS/EPMB3
To:	Fleming J Holtec
References
Download: ML24353A174 (1)

Text

Jean A. Fleming Vice President, Licensing, Regulatory Affairs, and Probabilistic Safety Analysis Holtec International, LLC Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104

SUBJECT:

PALISADES NUCLEAR PLANT AUDIT

SUMMARY

REPORT FOR THE PROPOSED REAUTHORIZATION OF POWER OPERATIONS UNDER RENEWED FACILITY OPERATING LICENSE NUMBER DPR-20

Dear Jean A. Fleming:

Holtec Decommissioning International, LLC (HDI), submitted a series of licensing and regulatory requests that are necessary to reauthorize power operations at the Palisades Nuclear Plant (PNP) through March 24, 2031, the end of the current operating license term under PNPs Renewed Facility Operating License No. DPR-20. Collectively, these requests (including any revisions or supplements thereto or other regulatory or licensing requests submitted to the U.S.

Nuclear Regulatory Commission (NRC) that are necessary to reauthorize power operations of PNP) define the proposed NRC Federal actions, that is, for the NRC to determine whether to grant or deny the requests necessary to reauthorize power operations at PNP. Enclosure 1 is a table which lists the submittals received, the NRCs acceptance letters, and the associated Agencywide Documents Access and Management System (ADAMS) accession numbers.

In a letter dated, June 18, 2024, the NRC stated it had accepted the last submittal in for review (ML24169A434), and on June 27, 2024, the NRC published a Notice of Intent (NOI) (ML24149A002) in the Federal Register (89 FR 53659) informing stakeholders, including the public, that the NRC intended to conduct a 30-day scoping period to gather the information necessary to prepare an environmental assessment (EA), thereby initiating NRCs environmental review under the National Environmental Policy Act of 1969, as amended.

On June 27, 2024, the NRC provided HDI a notice of the environmental regulatory audit along with the environmental regulatory audit plan and a list of draft requests for additional information (RAI) (ML24248A056). The environmental regulatory audit was conducted in accordance with the environmental regulatory audit plan, Enclosure 2 of the June 27, 2024, correspondence.

January 24, 2025

J. Fleming During the environmental audit, the NRC reviewed documents that were made available on the applicants electronic information portal in response to the NRC draft RAIs. The NRC also participated in site visits and breakout sessions for each resource area with applicant personnel to gather information that will likely be used in the EA. This information assisted the NRC staff in identifying subsequent requests for confirmatory information (RCIs), issued while the audit remained open, or finalizing the draft RAIs and any newly identified RAIs that were needed to allow the staff to conduct a complete review and to prepare the EA.

The NRC continued examination of supporting documents (available either publicly or through HDIs electronic SharePoint site), held follow-up virtual audit discussions, and interacted with other agencies. A total of 25 RAIs and 13 RCIs were issued to HDI to receive the necessary information to evaluate environmental impacts:

Two sets of RCIs were transmitted to HDI, on September 4, 2024, (ML24248A261),

and on November 1, 2024, (ML24306A222). Responses were received by the NRC on September 12, 2024, (ML24260A354) and November 12, 2024, (ML24319A053).

RAIs were transmitted to HDI on September 20, 2024, (ML24263A171), with responses received by the NRC on October 4, 2024, (ML24278A027).

One further clarifying email was transmitted with responses received on October 17, 2024, (ML24319A123).

The audit remained open until December 10, 2024, where an audit closeout session was held with HDI. The regulatory audit summary is enclosed (Enclosure 2). If you have any questions regarding this matter, please contact Mary Richmond via email at Mary.Richmond@nrc.gov or Laura Willingham via email at Laura.Willingham@nrc.gov.

Sincerely, Mary Richmond, Environmental Project Manager Environmental Project Management Branch 3 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Materials Safety and Safeguards

Enclosures:

As stated cc w/encls: GovDelivery Signed by Richmond, Mary on 01/24/25

ML24353A174 (Letter)

OFFICE LA:REFS/EPM3 PM:REFS/EPMB3 OGC BC:EPMB3 PM:REFS NAME MCampestrin MRichmond MASpencer

- NLO DBarnhurst MRichmond DATE 01/21/2025 01/21/2025 01/24/2025 01/24/2025 01/24/2025

- Licensing and Regulatory Requests for the Reauthorization of Power Operations at Palisades Nuclear Plant DOCUMENT DESCRIPTION ADAMS Accession No. (Submittal)

ADAMS Accession No. (Acceptance Review)

Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82, dated September 28, 2023.

ML23271A140 ML23291A440 Application for Order Consenting to Transfer of Control of License and Conforming License Amendments, dated December 6, 2023.

ML23340A161 ML24012A242 Request to Revise Operating License and Technical Specifications to Support Resumption of Power Operations, dated December 14, 2023.

ML23348A148 ML24022A117 Request to Revise the Administrative Technical Specifications to Support Resumption of Power Operations, dated February 9, 2024.

ML24040A089 ML24060A221 Request to Reinstate the Palisades Emergency Plan to Support Resumption of Power Operations, dated May 1, 2024.

ML24122C666 ML24141A119 Request to Update the Main Steam Line Break Analysis Methodology, dated May 24, 2024.

ML24145A145 ML24169A434

- Regulatory Audit Summary Report Palisades Nuclear Plant Reauthorization of Power Operations Project Environmental Regulatory Audit Summary Report 1.0 Overview Holtec Decommissioning International, LLC (HDI) submitted a series of licensing and regulatory requests that are necessary to reauthorize power operations at the Palisades Nuclear Plant (PNP) through March 24, 2031, the end of the current operating license term under PNPs Renewed Facility Operating License (RFOL) No. DPR-20. Collectively, these requests (including any revisions or supplements thereto or other regulatory or licensing requests submitted to the U.S. Nuclear Regulatory Commission (NRC) that are necessary to reauthorize power operations of PNP) define the proposed NRC Federal actions, that is, for the NRC to determine whether to grant or deny the requests necessary to reauthorize power operations at PNP.

As part of its environmental review under the National Environmental Policy Act of 1969, as amended (NEPA), the NRC is preparing an environmental assessment (EA). An audit was conducted from July 2, 2024, to December 10, 2024, to support the environmental review of the licensing and regulatory requests. This report presents a summary of the audits objectives and activities, and information that was obtained as a result of audit activities as described in the staffs audit plan (ML24248A056).

1.1. Background PNP, located along the shoreline of Lake Michigan in Covert Township, Van Buren County, Michigan, consists of a single unit pressurized water nuclear reactor. The U.S. Atomic Energy Commission originally granted PNP a provisional operating license for operation on March 24, 1971, with the NRC granting a full-term operating license on February 21, 1991, and subsequently issuing a PNP RFOL No. DPR-20, on January 17, 2007, with the term expiring on March 24, 2031.

On June 13, 2022 (ML22164A067), the licensee at the time, Entergy Nuclear Operations, Inc.

(Entergy), submitted certifications under Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(1) that operation had permanently ceased on May 20, 2022, and that fuel had been permanently removed from the reactor on June 10, 2022. In accordance with 10 CFR 50.82(a)(2), the docketing of these certifications means that the 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. As part of the transition from an operating reactor to a reactor in decommissioning, the NRC issued Amendment Nos. 266, 267, and 272 to the PNP RFOL (DPR-20) on June 4, 2018, (ML18114A410), September 24, 2018, (ML18170A219), and May 13, 2022, (ML22039A198),

respectively, to reflect a permanently defueled status. PNP remains in this licensing state, where the PNP RFOL exists and is still only authorized for decommissioning and associated activities.

Subsequent to the cessation of power operations and the commencement of decommissioning at PNP, HDI began to pursue a path to resume power operations. On February 1, 2023, (updated on March 13, 2023), HDI (on behalf of Holtec Palisades, LLC) submitted a letter to the NRC

2 outlining a proposed regulatory path for the reauthorization of power operations at PNP (ML23032A399; ML23072A404). Throughout 2023 and 2024, HDI engaged with the NRC and submitted a set of requests for NRC approval to support the reauthorization of power operations at PNP through March 24, 2031, the end of the current PNP RFOL. The set of requests include:

The September 28, 2023, request for an exemption from the 10 CFR 50.82(a)(2)

(TN249) restriction that prohibits reactor power operations and emplacement and retention of fuel in the reactor vessel by allowing for a one-time rescission of the docketed 10 CFR 50.82(a)(1) certifications.

The December 6, 2023, license transfer request for PNP, which seeks NRC consent to, and a conforming amendment for, a transfer of operating authority from HDI to Palisades Energy, LLC under the PNP RFOL No. DPR-20 and the general license for the Palisades Independent Spent Fuel Storage Installation.

Approval of requisite license amendment requests (LARs) to the PNP RFOL.

Both the NRC and a cooperating agency, the U.S. Department of Energy (DOE), have proposed Federal actions related to the potential reauthorization of power operations at PNP. To facilitate an effective NEPA process (40 CFR 1501.8), the NRC and DOE signed a Memorandum of Understanding (MOU) in June 2024 to guide their distinct regulatory authorities and reviews (ML24172A001). The PNP NEPA review will thus implement the MOU guidance.

The NRCs proposed actions are decisions on whether to grant or deny HDIs interdependent, connected licensing and regulatory requests that if approved, would collectively support reauthorizing refueling and power operations of the PNP reactor.

1.2. Site Location The PNP site, located at 27780 Blue Star Highway on the eastern bank of Lake Michigan in Covert Township, Michigan (figure 1) is on approximately 432 acres, which consists primarily of forested sand dunes. The area surrounding PNP is primarily rural with agriculture and wooded sand dunes along the Lake Michigan shoreline. The in-person, on-site portion of the audit was held at the PNP site.

3 Figure 1. Palisades Nuclear Plant Site Location (see ML062710300) 2.0 Audit Scope and Objectives The environmental regulatory audit was a hybrid audit consisting of two components or phases. Phase 1 consisted of a virtual environmental regulatory audit. The focus of the virtual environmental regulatory audit was on those resource areas that were not anticipated to need detailed analysis in the EA and did not necessitate of a site visit. Phase 2 consisted of an on-site environmental regulatory audit that focused on resource areas that were anticipated to require detailed analysis in the EA and warranted a site visit.

The audit was conducted by a team consisting of NRC environmental staff along with its contractor, the Pacific Northwest National Laboratory (PNNL). In preparation for the audit, the

4 team reviewed HDIs Environmental New and Significant Review, Proposed Resumption of Power Operations, Palisades Nuclear Plant report that was enclosure 2 to HDIs exemption request in support of restart (ML23271A140) and identified draft requests for additional information (draft RAIs) that would promote a better understanding of HDIs baseline condition (i.e., a plant in decommissioning) and any additional information required to complete the environmental assessment. These draft RAIs were provided to HDI in the audit plan on June 27, 2024, (ML24248A056), in advance of the audit.

The objectives of the audit were to:

Become familiar with the baseline status (decommissioning), activities planned for reauthorization, and the environs that could be affected by reauthorization of reactor operation.

Interact with Federal and State agencies to discuss their concerns and understand their regulatory authorities for resources that could be affected by the potential reauthorization of reactor operation.

Obtain additional information as set forth in the draft RAIs presented to HDI in the audit plan and any additional data identified during site tours and meetings with Federal and State agencies.

Identify whether subsequent RAIs would be needed to allow the NRC staff to conduct a complete EA.

The tours, discussions, and document reviews conducted during the audit covered a wide range of environmental matters as presented in the audit plan. These activities assisted the environmental review team and HDI in resolving many of the draft RAIs. For items that the review team was not able to resolve through document reviews and audit discussions, the NRC staff issued RAIs and requests for confirmatory information (RCI) throughout the duration of the audit.

Appendix A, table A.1 to this report presents a list of the review team members participating in the audit and the associated EA review areas. Appendix A, table A.2 presents a list of HDI staff and its contractor, Enercon, who participated in the audit. Representatives from other agencies and organizations participating in audit discussions are identified in appendix A, table A.3.

3.0 Audit and Trip Logistics The first audit meeting was held virtually on July 2, 2024, with additional virtual meetings between July 22 and December 5, 2024. The in-person, on-site portion of the audit was held during the week of July 8, 2024, primarily at the PNP site in Covert, Michigan. In addition to discussions with HDI staff and their contractors in conference rooms at PNP, staff participated in HDI-led tours of the site. The review team also conducted several self-guided tours of the surrounding area and met with State agencies in their local offices. The socioeconomics/environmental justice (EJ) reviewers also conducted field tours and interviewed local officials and charitable organizations regarding economic and demographic conditions.

Table 1 of this report provides a list of activities conducted during both the in-person portion of the audit (held in Michigan) and all virtual sessions. Section 4 of this report provides a summary of in-person tours. Section 5 summarizes the meetings and discussions that were held with other agencies.

5 Table 1. Summary of Daily Activities and Breakout Sessions for the Palisades Environmental Audit Format/Date Summary of Activities Virtual (7/2/2024)

Overview of the General Draft RAIs In-Person Day 1 (7/8/2024)

Introductions and Entrance Meeting; General Tour; Water Resources (Surface and Groundwater) and Ecology (Aquatic and Terrestrial)

Breakout Session; NRC Staff Closeout; Exit Briefing with NRC/HDI and Contractors In-Person Day 2 (7/9/2024)

Plan of the Day; Water Resources, Ecology, and Historic/Cultural Site Tour; Socioeconomic/Environmental Justice Breakout Session; Radiological and Non-Radiological Human Health/Waste, Decommissioning, Transportation, Fuel Cycle Breakout Session; Water Resources and Ecology Breakout Session; Historic/Cultural Breakout Session; NRC Staff Closeout; Exit Briefing with NRC/HDI and Contractors In-Person Day 3 (7/10/2024)

Plan of the Day; Water Resources and Ecology Site Tour; Historic/Cultural Breakout Session; Overview of all draft RAIs; NRC Staff Closeout; Exit Briefing with NRC/HDI and Contractors In-Person Day 4 (7/12/2024)

Historic/Cultural Site Tour Virtual (7/22/2024)

Air Quality/Meteorology Breakout Session Virtual (8/7/2024)

Historic and Cultural Breakout Session Virtual (8/9/2024)

Radiological Human Health Breakout Session Virtual (8/7/2024)

Accident Breakout Session Virtual (8/15/2024)

Overview of the General Draft RAIs Virtual (8/29/2024)

Water Resources Breakout Session and Exit Briefing Virtual (9/19/2024)

Discussion of Cabling Project and Final RAIs Virtual (10/9/2024)

Historic and Cultural Follow Up Virtual (10/28/2024)

Historic and Cultural and Other Environmental Follow Up Virtual (11/04/2024) 401 Certification Follow Up Virtual (12/05/2024)

Historic and Cultural and Critical Dune Permit Status On June 27, 2024, the NRC staff provided HDI 65 draft RAIs that the review team planned to cover during the audit. These were organized into 14 categories, which generally align with the EA review areas presented in appendix B. On July 10, 2024, at the end of the in-person audit discussions, a status briefing was held to ensure there was a common understanding between the review team and HDI as to the status of the draft RAIs as the group prepared to transition to the subsequent phase of the audit.

6 The NRC continued examination of supporting documents (available either publicly or through HDIs electronic SharePoint site), held follow-up virtual audit discussions, and interacted with other agencies. A total of 25 RAIs and 13 RCIs were issued to HDI to receive the necessary information to evaluate environmental impacts:

The RCIs were transmitted to HDI on September 4, 2024, (ML24248A261) and on November 1, 2024, (ML24306A222). Responses were received by the NRC on September 12, 2024, (ML24260A354) and November 12, 2024, (ML24319A053).

The RAIs were transmitted to HDI on September 20, 2024, (ML24263A171), with responses received by the NRC on October 4, 2024, (ML24278A027).

One further clarifying email was transmitted with responses received on October 17, 2024, (ML24319A123).

Appendix B presents a tabular summary of the resolution for the draft RAIs that were identified in the audit plan along with additional requests. The audit remained open until responses were provided from the applicant on all issued RAIs and RCIs, which occurred on December 5, 2024.

4.0 Summary of Tours Four tours of the PNP site were conducted during the on-site audit.

General Overview of the Site Monday, July 8, 2024, in-person The first tour, held on July 8, 2024, provided a general overview of the site. During the tour, HDI focused on the southwest portion of the site, identifying the protected area and delay fences, waste storage building, turbine generator building, trash racks and traveling screens, and the water discharge area. Discussion included:

New Fence and Road: HDI explained to the review team that a new sand-filled fence was planned that would replace the current fence line and that a new road would be constructed on the southwest portion of the site. Some of this construction activity would impact the dunesHDI is working with the Michigan Department of Environment, Great Lakes, and Energy (EGLE) on a critical dune permit.

Waste Storage Building: HDI indicated plans to replace the waste storage building inside the protected area, with the intent to consolidate the waste from the East Waste Storage Facility, outside the protected area, into one location.

Perimeter Monitoring and Temporary Wells: PNP site staff identified some of the perimeter monitoring and temporary wells that are monitored by HDI quarterly for water levels and quality.

Intake and Discharge: HDI explained that personnel in scuba inspect the discharge pipe once per year and the trash racks/basins twice per year. There is annual zebra mussel treatment and biannual debris removal. Debris is largely vegetative and mussel shells (dead). The intake, 3,300 feet (ft) into Lake Michigan, is within the site exclusion area.

Intake inspection occurs once a year in summer, with the next one scheduled for August 2024. Any repairs are made at that time. The intake was never completely shut down during decommissioning and one pump continues to draw water at 6,000 gallons per minute (gpm) to cool spent fuel.

Condensate Storage Tanks: Review staff observed the condensate storage tanks.

Tritium and gamma activity is monitored with a detection limit of 500 picocuries per liter (pCi/L). Review staff also observed the area with multiple monitoring wells that trace

7 leaks. The highest measured tritium concentration level recorded were approximately 100,000 pCi/L.

Employment: HDI also indicated that current on-site employment is about 420 employees with an expected future total 570-600 workers. HDI has a labor agreement in place with 17 unions, though they are not supplying employees to support the plant in a regular cadence.

Water and Ecological Resources - Tour 1 Tuesday, July 9, 2024, in-person An additional two tours were conducted that focused on water and ecological resources. For the first tour on July 9, 2024, the review team and HDI walked alongside the current fence line and further discussed the future construction of the new fence and road:

The review team was informed that construction of the road will extend 10-15 ft past the existing road curb into the dune and will require a retaining wall to maintain dune integrity. The dune that may be cut into to make the road was reconstructed after being disturbed during original construction of the plants cooling towers. Dust control and other best management practices are planned to be used.

There was no milkweed or pitchers thistle observed along the roadway/dune.

The team also walked the path for the proposed new power cables, which will connect the cooling towers:

This project will consist of a 20 inch wide by 16 inch deep channel with two to three, 4-inch conduits that run along the fence line to the manmade shoreline dune and to the south, to each of the two cooling towers, where the channel then branches inland and runs along existing disturbed gravel roadway.

There are currently temporary cable runs to the cooling towers transformers, and HDI intends to leave them in place.

There were no milkweed, snakes, shorebirds, or pitchers thistle observed in the area during the audit.

Stormwater runoff is split between the two cooling towers because of high terrain between the two tower banks. Stormwater may run off into adjoining area from the high point to the south of cooling tower B. There are no stormwater drains in this area and no catch basins were observed.

The review team also visited the temporary barge area that was used to bring in replacement steam generators but has not been used since the 1980s. The team observed two stormwater outfalls on the south side of the discharge location and an additional three stormwater outfalls on the north side of the discharge. HDI plans to inspect these outfalls for degraded pipes.

Currently emplaced riprap will be removed, repairs made from the shore, and riprap will be replaced. The review team was informed that there is no need to perform repair work in the waters of Lake Michigan.

This tour continued, driving to the proposed location for the small modular reactor (SMR) site:

There are currently two anthropogenic wetlands nearby the proposed site that were created by storm water drainage.

A machinery storage building, a fire protection equipment building, and the leach field for wastewater are also in this area.

There is a natural wetland between the plant and the state park.

8 The proposed SMR site will be constructed by removing existing buildings on the northeast side of the site and will require tree removal to build cooling towers.

Approximately 3 acres of vegetation/tree clearing would be required.

It was noted during this tour that the meteorological tower has no guy lines and there is a single red light at the top.

The review team observed the discharge pipes, overflow weir, and intake pipes.

Water and Ecological Resources -Tour 2 Tuesday, July 10, 2024, in-person The second ecological/water resource tour, held on July 10, 2024, focused on PNPs water intake and discharge. On the tour, reviewers viewed the discharge pipes and discharge weir:

The review team learned that sediments accumulate in the weir, which will need to be suctioned and removed prior to the resumption of power operations.

There was discussion over how much water will be discharged into the lake. There was previously 86,000 gpm of water discharged, but HDI estimates 6,000 to 12,000 gpm upon resumption of power operations.

There was also discussion about how far into the lake the thermal mixing zone extends.

The tour continued to view the trash racks without the covering grate:

The racks are inspected by divers twice per year.

Typically, dead mussel shells are removed from the basins after the annual zebra mussel treatment. This is completed by using divers and a suction truck.

HDI will also need to remove shells from the basin when the intake is ramped up to support resumption of power activities, as dead mussel shells from the intake crib and intake pipe are pushed through.

The rotating traveling screens and trash basket were also viewed. These are checked twice per day (once each shift) and are emptied, as needed. Biocides are used on the plant side of the traveling screens a few times a year, per the National Pollutant Discharge Elimination System (NPDES) permit.

Historic and Cultural Resources Thursday, July 12, 2024, in-person An NRC-only historic and cultural tour was held on July 12, 2024, to view locations outside of the PNP site to identify if there were areas where the public can visually see physical components of the plant from offsite. The tour included a stop at Covert Township Park, a drive past the PNP entrance/road, along with a stop near the transmission line corridor on Michigans Blue Star Highway. The NRC staff visited additional locations within Van Buren State Park. PNP was only visible from the beach at Van Buren State Park.

5.0 Summary of Meetings with Other Agencies A meeting was held with the Michigan EGLE both virtually and in-person at 525 West Allegan in Lansing, Michigan on July 10, 2024. Discussions at this meeting addressed the NPDES permit that is currently under review and will be issued for public comment, the necessity of a 325 permit (Great Lakes Submerged Lands Construction Permit), Clean Water Act (CWA) Section 401 Water Quality Certification, and the requirements for the Coastal Zone Management Act (CZMA) and 353 permit (Critical Dune Permit).

9 A meeting was also held with the Michigan State Historic Preservation Office (SHPO) at 300 North Washington Square in Lansing, Michigan on July 10, 2024. Discussions with the SHPO included an explanation of the PNP site and licensing history, the current expected area of potential effects (APE), status of archaeological and architectural surveys, and the PNP site-specific procedures, among other items related to compliance and processes under the National Historic Preservation Act of 1966, as amended (NHPA).

Additional meetings were also held with community organizations to ascertain the community outreach programs in the area and the potential impacts on facility operations. Table 2 provides a list of the agencies that were consulted. Community observations from the meetings held were as follows:

Decommissioning did not cause noticeable shifts in community needs, especially since it occurred during COVID. This makes it difficult to delineate community challenges caused by the pandemic versus the plant shutdown. Although there was an exodus of donors and volunteers from a few organizations, there were no changes in community needs. The plant also provided relocation packages for workers, so jobs did not seem to be significantly impacted.

During operation, Entergys level of community engagement was consistent, but has fluctuated because HDI does not currently have a strong outreach or engagement track record. There is an expectation that HDI will continue with Entergys trend of significant community support if reactor operations resume.

The economic aspects of PNP were the focal point of impact discussions. The area's power plants are the dominant industries, and many residents and organizations look forward to the trickle-down effects of tax revenue and worker spending. Housing availability and quality were cited as major concerns for an incoming workforce.

As much of the area faces economic challenges, many organizations support the community based on need rather than income. This means that organizations match their services to requests rather than advertising specific types of support.

The most prominent areas of community concern with the potential restart were housing, transportation, job training, and food security.

The area has a large population of elderly residents who contribute to the volunteer needs of many local organizations and are recipients of community support programs.

10 Table 2. List of Community Agencies Agency Contact Location WE Care Inc.

Erika Morrison 1301 M-43 Suite 2B South Haven, MI 49090 South Haven Rotary Club Angelica Gallegos 06321 Blue Star Memorial Highway, South Haven, MI 49090 Covert Township Daywi Cook 73943 Lake St, Covert, MI 49043 Southwest Michigan Community Action Agency Kim L. Smith Oldham 185 E Main St, Benton Harbor, MI 49022 Cornerstone Alliance Christina Frank 80 W Main St, Benton Harbor, MI 49022 Benton Harbor (MI)

Community Water Council Rev. Edward Pickney 275 Pipestone St, Benton Harbor, MI 49022 United Way of Southwest Michigan Anna Murphy, Retta Curneal 2015 Lakeview Ave., Saint Joseph, MI 49085 Berrien Community Foundation United Way of Southwest Michigan 2900 S State St # 2E, St Joseph, MI 49085 Mosaic Christian Community Development Association Andrew Robinson 1804 M-139, Benton Harbor, MI 49022 Lake Michigan College Al Pscholka 2755 E Napier Ave Benton Harbor, MI 49022 City of Benton Harbor Alex Little 200 E Wall St, Benton Harbor, MI 49022 Southwest Michigan Regional Chamber Arthur Havlicek 811 Ship St Ste 303 Saint Joseph, MI 49085

11 Appendix A: Attendees Table A.1. List of Review Team Members Function or Review Area NRC Staff PNNL Staff Team Leads Laura Willingham, Mary Richmond Cyler Conrad, Leah Hare Accidents Jerry Dozier, Don Palmrose Jon Napier, Michael Smith Advisor Dan Barnhurst, Madelyn Nagel Bob Schaff Air Quality and Meteorology Brian Glowacki Saikat Ghosh Alternatives Bob Hoffman Cyler Conrad Benefit Cost-Need for Power Jeffrey Rikhoff Dave Anderson, Lin Zeng Climate Change Brian Glowacki Phil Meyer, Becka Bence Cultural and Historic Jennifer Davis Cyler Conrad Cumulative Don Palmrose Cyler Conrad Ecology - Terrestrial Peyton Doub Caitlin Wessel Ecology - Aquatic Peyton Doub Tracy Fuentes Environmental Justice Jeffrey Rikhoff Kendall Parker, Dave Anderson Geology Gerry Stirewalt Becka Bence, Phil Meyer Hydrology - Groundwater Gerry Stirewalt Becka Bence, Phil Meyer Hydrology - Surface Water Brian Glowacki Rajiv Prasad, Kazi Tamaddun Land Use/Visual Resources Jeffrey Rikhoff Cyler Conrad Non-Radiological Human Health/Waste Rao Tammara Leah Hare Radiological Human Health/Waste Don Palmrose Jon Napier, Michael Smith Socioeconomics Jeffrey Rikhoff Dave Anderson, Lin Zeng Transportation Rao Tammara Jon Napier, Michael Smith Decommissioning, Fuel Cycle Don Palmrose Jon Napier, Michael Smith Table A.2. List of Holtec Staff and Contractors Tim Basham c Adam Hall b Bill Noval a Kevin Block b Richard Hankins b Steve Overway b Jeff Borah b Jay Hemmis c Benjamin Reynolds a Johann Britting b Mary Hoganson c Jerry Riggs c Richard Burroni a Joe Jerz b Mike Schutheis b Tim Crocker b Mike Lee b Scott Summer b Nick Culp b Rebecca Levack b William Turco b Nate Demaster b Salena Long b Rachel Turney c Adam Eastridge b Jennifer Meek c Steve Vonk b Amy Filbrandt b James Miksa b Doug Watkins b Jean Fleming a Mike Mlynarek b Gerry Wright b Mike Ginzel b Matthew Montz c

a. Holtec Decommissioning International, LLC

b. Holtec Palisades, LLC

c. Enercon

12 Table A.3. List of Representatives from State Organizations Name Organization Jeremy Rubio EGLE Mariah Scott EGLE Betsy McKay EGLE Zachary Harrison EGLE Jennifer Laudazio EGLE Jennifer Klang EGLE Tarek Buckmaster EGLE Kyle Alexander EGLE Phil Argiroff EGLE Cheri Meyer EGLE Christe Alwin EGLE Theodore Wentworth EGLE Jay Paquette EGLE Cici Weibert EGLE Mike Sanders DNR Don Poppe DNR Brian Gunderman DNR Matthew Diana DNR Jay Wesley DNR Scott Slagor SHPO Kate Frederick SHPO Cassandra Nelson SHPO Katie Kolokithas SHPO EGLE = Michigan Department of Environment, Great Lakes, and Energy; DNR = Department of Natural Resources, State of Michigan; SHPO = Michigan State Historic Preservation Office

13 Appendix B: Summary of Audit Information Need Resolution Palisades Nuclear Plant (PNP) Reauthorization Environmental Audit Draft Request for Additional Information and Resolution List Draft RAI ID Information Needed Resolution Status Generic:

GEN-1 Provide a detailed list of activitiesall activities related to the Federal actionsplanned for the PNP to support resumption of power operations (planned restart-related activities). Including:

For any ground disturbing activities, or any refurbishment activities, (e.g.:

building or demolition, etc.) provide:

Location of activity.

Number of acres disturbed.

Whether the disturbance is temporary or permanent.

A figure or drawing indicating location of all planned restart-related activities, including, laydown areas, and extent of ground disturbance on an updated site map.

This request for additional information intersects multiple resource areas and Federal regulations as the details of any activities may influence environmental evaluations of a variety of processes and functions., Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, of Holtecs exemption request did not provide a detailed list of activities planned to support the resumption of power operations.

Holtec provided requested information, along with additional requests in the response to the final RAI:

Historical construction disturbance photographs and maps detailing the extent of previously disturbed areas; Radwaste Building move; Discussion on filling cooling tower basins and repairing stormwater outfalls; Digital Staging Testing Building; Blast Resistant structures.

Closed, addressed by RAI-GEN-1

14 Draft RAI ID Information Needed Resolution Status GEN-2 Provide a properly supported purpose and need statement for the proposed Federal actions. Include any applicable related analyses and studies informed by Holtecs purpose and need statement, e.g., alternatives. The purpose and need statement is the foundation of the environmental analysis on which the rest of the environmental assessment is built., Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, did not provide a NEPA-based purpose and need statement - while the submittals describe the project and purposes, an overall purpose and need statement as it relates to the NEPA analysis is needed for the lead agency to respond to the proposed Federal actions before them. That is, a purpose and need statement should be provided that briefly specifies the underlying purpose and need to which the agency is responding as it provides the foundation for determining which alternatives will be considered.

A properly supported purpose and need statement, which should incorporate the applicants objectives and not be too narrowly defined, provides a focused limit on the range of alternatives to be considered and allows an agency to dismiss without detailed study any alternative that fails to meet the proposed purpose and need.

In requesting this information, the NRC is guided by the following Council on Environmental Quality (CEQ) regulations:

40 CFR 1501.5 requires Environmental Assessments to briefly describe the purpose and need for the proposed agency action.

Holtec provided purpose and need statement and supporting documentation.

Closed, addressed by RAI-GEN-2 GEN-3 Provide a status for all necessary environmental permits, licenses, approvals, and other entitlements required for the proposed actions to resume and continue operations of the PNP (e.g., permits issued under the Clean Water Act, Clean Air Act, Coastal Zone Management Act, etc.).

Include any permits required for any planned restart-related activities in support of the proposed Federal actions. Describe the status of compliance with these requirements and any consultations with State or local agencies.

Holtec provided a status list of permits and the NRC staff has met with the Michigan EGLE.

Closed, addressed by RAI-GEN-3

15 Draft RAI ID Information Needed Resolution Status The NRC staff is preparing an environmental assessment and will assess whether there have been any changes to operating permits or other requirements. Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, table 1.3-1, did not provide a complete listing and status, e.g., the Low-Level Radioactive Waste permit expires August 2024, the Maintenance Dredging permit expires April 2025, the Scientific Collectors Permit expired December 2023, and consistency with the CZMA was not included.

This information is necessary for the NRC staff to assess the status of permits and the environmental impacts of the proposed Federal actions. In requesting this information, the NRC is guided by the following CEQ regulations:

40 CFR 1501.5, Environmental assessments: (k) As appropriate to improve efficiency and effectiveness of environmental assessments, agencies may apply the other provisions of part 1502 and 1503 of this subchapter, including §§ 1502.24 to environmental assessments.

40 CFR 1502.24 Environmental review and consultation requirements: (b)

The draft environmental impact statement shall list all Federal permits, licenses, and other authorizations that must be obtained in implementing the proposal. If it is uncertain whether a Federal permit, license, or other authorization is necessary, the draft environmental impact statement shall so indicate.

GEN-4 Provide a detailed list of past, present, and reasonably foreseeable future projects in the geographic area of interest surrounding the site that would affect the same resources affected by the proposed Federal actions.

CEQ defines cumulative impacts (also known as cumulative effects) in 40 CFR 1508.1(i) as effects on the environment that result from the incremental effects of the action when added to the effects of other past, present, and reasonably foreseeable actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions.

Holtec provided that they were not aware of new offsite future projects planned. Holtec stated that it is studying future development of small modular reactor units and will pursue a subsequent license renewal for PNP

Closed, addressed by RAI-GEN-4

16 Draft RAI ID Information Needed Resolution Status Cumulative effects can result from actions with individually minor but collectively significant effects taking place over a period of time.

The goal of the analysis is to introduce environmental considerations into the planning process as early as needed to improve decision-making. While Section 4.12 of Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, provided a brief description of building activities, there was not a detailed list of past, present, and reasonably foreseeable projects or enough information to make a determination, e.g., are structures such as the day care center to be constructed in an already disturbed area.

1.

The NRC staff worked with local and staff facilities regarding potential offsite projects.

Alternatives:

ALT-1 Holtec has included the no-action alternative in Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant:

The no-action alternative is that PNP would not receive authorization to resume power operations, and the plant would continue decommissioning in accordance with NRC regulations. PNPs Post Shutdown Decommissioning Activities Report (PSDAR) provides the environmental impact assessment for this no-action alternative (Holtec 2020).

However, an analysis of other alternative categories was not provided.

Provide an analysis of the following alternative categories, as they relate to Holtecs purpose and need statement; if Holtec believes alternatives in these categories should be dismissed from further consideration, please provide the bases:

Energy Alternatives System Alternatives Holtec provided limited information on alternative analyses. The NRC staff performed additional alternative analysis.

Closed, addressed by RAI-ALT-1 Water Resources, Surface Water:

17 Draft RAI ID Information Needed Resolution Status SW-1 To adequately discuss the baseline affected environment, provide any NPDES permit exceedances or violations that have occurred since PNP was shut down on May 20, 2022. If there were any violations, provide details of all such occurrences. Surface water quality can be adversely affected by exceedances of NPDES permit limits or other violations.

Holtec provided update regarding NPDES permit exceedances with publicly available information. No additional information from Holtec was necessary.

Closed during Audit discussion SW-2 The Michigan EGLE-issued Stormwater Management Industrial Site Certification, I-18257, is set to expire on July 1, 2026.

Describe if this certification applies to the current, in-decommissioning state of the PNP (affected environment), planned restart-related activities, and also during reactor operation, if authorized. Are any changes expected to this Certification to support a return to reactor operation? (See also GEN-3)

Surface water quality can be adversely affected by discharges of pollutants and sediments with stormwater from a nuclear power plant.

Holtec provided requested information.

Closed during audit discussion SW-3 The Michigan EGLE-issued dredging permit expires April 16, 2025. Provide an explanation if this permit applies to the current, in-decommissioning state of the PNP and whether dredging is necessary for the planned restart-related activities, e.g., intake structure. Also, include if any inspections or studies of the intake structure have taken place. If so, provide copies.

(Section 4.2.2.6 states There is no planned dredging in Lake Michigan should power operations resume at PNP but there are no details related to planned restart-related activities.) (See also GEN-3).

Surface water quality can be adversely affected by dredging activities performed to maintain the performance of nuclear power plant water intakes and discharges.

Under the CWA Section 404, administered and enforced by the U.S.

Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (USACE), a permit is required for discharge of dredged or fill material into wetlands or waters of the U.S. States, and Tribes can also administer Section 404 for some non-navigable waters within their Holtec provided requested information. An RCI was issued and Holtec provided a response to confirm information on intake structure and sediment removal procedures.

Closed, addressed by RCI-SW-3

18 Draft RAI ID Information Needed Resolution Status jurisdictions.

SW-4 Provide the location, on an appropriate map, where any dredged materials are permitted to be placed during planned restart-related activities and operations should dredging be necessary., Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, Section 4.2.2.6 mentions both unvegetated and vegetated beach areas and the lake where dredged materials were placed.

Surface water quality can be adversely affected by dredging activities performed to maintain the performance of nuclear power plant water intakes and discharges.

Holtec provided requested information.

Closed, addressed by RAI-SW-4 SW-5 To adequately address the current baseline affected environment, provide a description of the surface water use in PNPs current, in-decommissioning state, including water supply sources, and quantities.

Plant surface water use can adversely affect the availability and associated quality of surface water resources for other users of the resource.

Holtec provided requested information. RCI SW-5, 6 and 7 issued and Holtec provided a response to confirm water resource baseline condition (6,000 gpm withdrawal from Lake Michigan; 16,000 cubic feet of potable water use per month from South Haven Municipal Water Authority; along with information on retention/detention ponds).

Closed, addressed by RCI-SW-5, 6, and 7

19 Draft RAI ID Information Needed Resolution Status SW-6 To adequately address the current baseline affected environment, provide a description of any surface water discharges from PNP in its current, in-decommissioning state and any planned discharges during PNP restart-related activities including any plant process water, equipment cleaning, sanitary and wastewater, and stormwater. Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, discusses discharges related to operations.

Surface water quality can be adversely affected by discharges of pollutants and sediments with stormwater from a nuclear power plant.

This request is being combined with SW-5.

Closed, addressed by RCI-SW-5, 6, and 7 SW-7 Provide a description of any water treatment systems in use at PNP in its current, in-decommissioning state, including any retention and/or detention ponds and any planned water treatment to occur during restart-related activities and operations. (For operations, indicate if there would be any changes to water treatment systems or chemicals used that may alter the discharge characteristics).

Surface water quality can be adversely affected by discharges of pollutants and sediments with stormwater from a nuclear power plant.

This request is being combined with SW-5.

Closed, addressed by RCI-SW-5, 6, and 7 SW-8 Provide a description of any changes in surface water use and users in the vicinity of the PNP since PNP was shut down on May 20, 2022. Please describe any changes to authorized wastewater discharges in the vicinity of the PNP since PNP was shut down on May 20, 2022.

Plant surface water use can adversely affect the availability and associated quality of surface water resources for other users of the resource.

The Michigan EGLE provided requested informationpublicly available link. No additional information from Holtec was requested.

Closed during audit discussion SW-9 Provide a description of any changes, or planned changes, to plant structures, systems, components, or equipment related to surface water use and effluent discharge since PNP was shut down on May 20, 2022. Are any alterations to plant structures, systems, components, or equipment related to surface water use and effluent discharge expected during restart-related activities, e.g., refurbishment and/or repairs to support PNPs proposed This request has been addressed in connection with GEN-1 and SW-6.

Closed, addressed by GEN-1 and SW-6

20 Draft RAI ID Information Needed Resolution Status return to operations or once operations resume? If yes, provide a description of these activities, their locations, and any associated local, State and/or Federal permits and/or authorizations needed to perform these activities.

Include any water use changes anticipated during operations that would alter previous operation water use evaluations. (The October 2006 Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 27, Regarding Palisades Nuclear Plant - Final Report (hereafter License Renewal EIS Supplement") discusses impacts for continued operations; therefore, there would be no anticipated change.

However, the PNP potential reauthorization of power operations would be going from a decommissioning state to an operations state and the impact on water use should be evaluated as such.)

Restart-related activities necessary to resume power operations at PNP such as refurbishment activities that impact surface water use or discharge-related plant structures, systems, components, and equipment can adversely affect quality of the surface water resources and may require Federal, State, or local authorizations and/or permits.

Water Resources, Groundwater:

GW-1 Sections 3.2.1 and 4.2.1.5 of Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, of Holtecs exemption request states the PNP Groundwater Protection Initiative (GPI) began in 2008. Does Holtec have a site-specific Groundwater Protection Plan that supports the GPI? If yes, provide a copy of the plan and any updates to the plan for review by NRC staff.

NEI 07-07 was developed to describe the industry's GPI. The GPI identifies actions to improve utilities' management and response to instances where the inadvertent release of radioactive substances may result in low but detectible levels of plant-related materials in subsurface soils and water.

Holtec provided the groundwater protection plan that was revised in 2024. No additional information from Holtec was requested.

Closed during audit discussions GW-2/

Provide an updated geologic cross-section of the site that includes current Holtec provided

Closed,

21 Draft RAI ID Information Needed Resolution Status RCI-GW-2a building foundations and site infrastructure elevations.

An updated geologic cross-section depicting pertinent water-bearing units that can transport potential releases of radioactive and nonradioactive material offsite was not provided. The NRC staff assesses the modified environment around the plant to determine the potential for offsite transportation of contaminants.

information for review. An RCI was issued as part of the second set of RCIs, and Holtec provided a response to confirm additional information in the September 2023 Updated Hydrogeologic Investigation Report.

addressed by RAI-GW-2 and RCI-GW-2a GW-3 Figure 3.2-1 of Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, of Holtecs exemption request depicts groundwater contours. Provide the year and month that the elevation data were collected that were used to generate the contours. Provide recent contour maps or groundwater elevation data that capture seasonal variation (if any) of site groundwater levels.

The present-day hydraulic characterization of the site is needed to inform baseline conditions that may be impacted by the proposed actions. Recent groundwater elevation data and seasonal variability inform groundwater flow patterns at the site that may impact offsite groundwater users and groundwater quality.

Holtec provided the 2023 potentiometric map.

Closed, addressed by RAI-GW-3 GW-4 To appropriately characterize the baseline affected environment, provide data on whether any radionuclides were detected in groundwater between January 2023 and April 2024, and include details of all such occurrences.

Inadvertent releases of radionuclides to onsite groundwater can adversely affect the quality and associated use of offsite groundwater resources. The NRC staff assess potential pathways from plant systems and infrastructure into the environment to determine the impact of operations on groundwater quality. The requisite information was not provided in Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant.

Information requested is found primarily in the Annual Effluent Release Report in ADAMS, which is publicly available. RCI issued and Holtec provided a response to confirm statements related to the 2024 radiological releases to groundwater.

Closed, addressed by RCI-GW-4

22 Draft RAI ID Information Needed Resolution Status GW-5 Section 3.2.1.2 of Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, of Holtecs exemption request states Holtecs plans to undertake remediation and repairs as part of the resumption of power operations efforts in response to inadvertent releases of tritium to groundwater. Describe updates (if any) to these plans beyond what is described in the exemption request, including any potential ground disturbance.

Holtec provided requested information.

Closed, addressed by RAI-GW-5 GW-6 Section 3.2.1.1 of Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, of Holtecs exemption request states that all onsite groundwater supply wells were capped and disused in 2019. State if there are any changes expected to groundwater use for PNPs proposed return to operations, including planned restart-related activities. If groundwater use is anticipated in during operations, provide anticipated water consumption rates (maximum, average by month, and average by plant operating status).

Groundwater use (consumptive and non-consumptive) at nuclear plants may impact offsite groundwater users and sensitive ecological receptors.

Planned groundwater use in the re-instated operational mode is needed to assess potential groundwater use conflicts during this term, and Section 3.2.1.1 of Holtec's exemption request does not explicitly state the anticipated groundwater use following the anticipated re-start of operations.

Holtec provided requested information. No additional information from Holtec was requested.

Closed during audit discussions Air Resources (Climate, Air Quality, and Meteorology):

MET-1 Provide recent climatological data, synoptic meteorology and extreme weather events.

A climate summary has been provided in the License Renewal (LR) EIS Supplement based on 2005 data. More recent data should be analyzed and provided and was not included in the Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant submittal.

Holtec provided on-site meteorological data. The NRC staff evaluated recent extreme weather data.

Closed, addressed by RAI-MET-1

23 Draft RAI ID Information Needed Resolution Status MET-2 Provide a discussion regarding radioactive effluents, for the X/Q (short-term and long-term) and cooling tower impact (Seasonal Annual Cooling Tower Impact (SACTI)) analyses, and whether any updates to the analyses have been performed. Also, provide recent meteorological data after the cooling tower replacement. Indicate whether a comparison analysis between the most recent 3 years of meteorological data and that used in the respective X/Q and SACTI analyses has been performed to determine if the current 3 years of meteorological data would affect the X/Qs, the cooling tower impacts, or other analyses.

The Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant document did not provide the vent height through which airborne radioactive materials are emitted. This height is used to calculate X/Qs and consequent airborne radiological dose.

Holtec provided requested information, which is publicly available. No additional information from Holtec was requested.

Closed during audit discussions MET-3 Are there any impacts to the frequency of inversions and analyses of atmospheric stability and mixing height from the most recent 3 years of local meteorological data?

This information was not included in the Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant submittal.

Holtec provided information as part of RAI-MET-1.

Closed during audit discussions

- merged with RAI-MET-1.

MET-4 Describe if there would be any changes to the meteorological monitoring program such as instrumentation, type of data, frequency and averaging technique for data collected onsite. Provide a copy of PNP's Meteorological Monitoring Report or a detailed description thereof.

This information was not included in the Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant submittal.

However, per Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, this information is needed to understand the overall metrological monitoring at the site.

Holtec states that there are no changes to meteorological monitoring. No additional information from Holtec was requested.

Closed during audit discussions

24 Draft RAI ID Information Needed Resolution Status MET-5 If there are any restart-related activities that would produce pollutant emissions (e.g., from construction equipment), then provide information on these emissions, including emissions estimates of fugitive dust and best management practices (BMPs).

This information was not included in the Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant submittal.

Holtec provided requested information.

Closed, addressed by RAI-MET-5 MET-6 Provide annual pollutant emissions (including criteria pollutants) since 2022, if any.

The EPA has set National Ambient Air Quality Standards for criteria pollutants. Air quality emissions for a plant are regulated through permits.

The NRC staff reviews air emissions to verify compliance with permitting to support the NRC staff making environmental impact determinations under NEPA. Permitted annual emissions (including criteria pollutants) have been documented in the Enclosure 2, table 3.7-2 from year 2018-2022. There is no information past 2022 included in the Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant submittal.

Holtec provided requested information.

Closed, addressed by RAI-MET-6 Ecological Resources, Aquatic:

AE-1 Provide a copy of the draft National Pollutant Discharge Elimination System (NPDES) permit with 10/01/2028 expiration date (table 1.3-1) and any verification from the Michigan Department of Environment, Great Lakes and Energy (EGLE) that the existing NPDES permit is valid for both the restart-related activities and reactor operations or if a separate permit is required for these activities. (see also GEN-3)

The NRC staff needs copies of supporting documentation related to NPDES permitting to identify any restrictions in the permit that are placed on temperature, dissolved oxygen (DO), or other chemical constituents from the discharge, along with consequential impacts on aquatic ecology.

Holtec provided requested information, which is publicly available.

Michigan EGLE provided updated permit information.

Closed during audit discussions AE-2 Has the EPA or the Michigan EGLE made a determination about the cooling water intake structure and whether it represents the best technology Holtec provided requested information, which is Closed during audit

25 Draft RAI ID Information Needed Resolution Status available (BTA) (Section 316(b) of the CWA). If yes, please provide a copy of the document.

The NRC staff needs copies of supporting documentation related to CWA 316(b) concerning cooling water intakes used to determine impacts of impingement or entrainment.

publicly available.

discussions AE-3 Have any invasive aquatic species been found during NPDES permit monitoring (table 4.3-1)? If yes, please provide information on which species, numbers, years observed, etc.

, "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide a description of aquatic invasive species found onsite (including cooling water intake and discharge systems).

Holtec provided information, which is in the Michigan EGLE NPDES permit.

Closed during audit discussions AE-4/

RCI-AE-4a Is there any past or current monitoring (or planned monitoring after a return to operations) of the intake and traveling screens for fish or other aquatic organisms? If so, please provide information, if available, on numbers and species entrained. Have there been any fish kills since the PNP entered into decommissioning?, "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide a description of any monitoring plans to assess the numbers of fish or other aquatic organisms found on the intake or traveling screens and impacts were provided for LR (the LR impact determinations assumed a baseline of continued operations).

Holtec provided information in the response to RAI-AE-4.

RCI-AE-4a issued and Holtec provided a response to confirm information in the May 16, 2024, Final Dive Report that was not docketed.

Closed, addressed by RAI-AE-4 and RCI-AE-4a AE-5 Is there any mussel settlement monitoring of plant systems or treatment to prevent mussels settling on water intake or discharge systems? If there is, have any state-listed or invasive mussels been found? If there is not, will active removal of mussels be needed to clear intake or discharge systems prior to plant restart?, "Environmental New and Significant Review Proposed Holtec provided information; zebra mussel information is in the Michigan EGLE NPDES permit.

Closed during audit discussions

26 Draft RAI ID Information Needed Resolution Status Resumption of Power Operations Palisades Nuclear Plant," did not provide a description of mussel settlement on plant systems (either current treatment to prevent settlement or active removal needed prior to restart).

AE-6 Describe what biocides or other water treatment chemicals (including proposed concentrations) will be added to the cooling water in the CWS or used for restart-related activities and if there will be any changes in the water treatment from past operations. Include any treatment or discharge limitations (see also SW-7).

The NRC staff needs copies of supporting documentation to determine effects of non-radiological contaminants on aquatic organisms.

Holtec provided information; water treatment chemical information is in the Michigan EGLE NPDES permit.

Closed Ecological Resources, Terrestrial Ecology:

TE-1 The 2013 LR Generic Environmental Impact Statement (GEIS), NUREG-1437 Rev. 1, stated that cooling system changes were made at PNP to address sulfate deposition and temporary excessive icing conditions that resulted in the conversion of about 5 acres of dune forest near the mechanical draft cooling tower to dense scrub-shrub. a) Summarize the changes made to mechanical cooling towers (operational, infrastructure) to address the vegetation impacts from drift. Include whether the cooling towers have drift eliminators. b) Provide a map showing location of drift impacted vegetation from previous operations. c) If operational changes have occurred to the cooling towers that resulted in dune forest establishment, provide a description. d) Summarize any differences in predicted drift from cooling tower operations (see also MET-2)., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide an updated analysis of drift impacts from resumed operations.

Holtec provided requested information.

Closed, addressed by RAI-TE-1 TE-2 An early successional dune specialist species, Pitchers thistle (Federally Threatened) is known to have been present at the PNP site near the cooling towers up until the 1990s but were not found again at that location in 2005.

However, a new location was found in 2005 on the northern end of the site, near the state park boundary. a) Provide updated information regarding the Holtec provided requested information. RCI issued and Holtec provided a

Closed, addressed by RCI-TE-2

27 Draft RAI ID Information Needed Resolution Status location(s) and population size(s) of the Federally threatened plant, Pitchers thistle. b) Provide correspondence or reports with the U.S. Fish and Wildlife Service (FWS) and the Michigan EGLE, regarding this species., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide current information regarding locations or population sizes of the Federally listed Pitcher's thistle, which is known to occur within PNP site boundaries.

Endangered Species Act (ESA) Section 7; 16 U.S.C. § 1456.

response to confirm status of Pitchers Thistle.

TE-3 The entire PNP site is protected under the CZMA and Michigans Coastal Zone Management Program. Provide the most recent copies of the Michigan EGLE permits relating to CZMA for the PNP site. Provide updated maps of critical dunes within the PNP site, along with correspondence with the Michigan EGLE regarding CZMA compliance (see also GEN-3).

The NRC staff needs maps, permits, and correspondence with the Michigan EGLE to assess the status of permits and to evaluate consistency with CZMA under 16 USC § 1456(c) Consistency of Federal activities with State management programs; Presidential exemption; certification".

In requesting this information, the NRC is guided by the following Council on Environmental Quality (CEQ) regulations:

40 CFR 1501.5, Environmental assessments: "(k) As appropriate to improve efficiency and effectiveness of environmental assessments, agencies may apply the other provisions of part 1502 and 1503 of this subchapter, including §§ 1502.24 to environmental assessments."

40 CFR 1502.24 - Environmental review and consultation requirements-

"(b) The draft environmental impact statement shall list all Federal permits, licenses, and other authorizations that must be obtained in implementing the proposal. If it is uncertain whether a Federal permit, license, or other authorization is necessary, the draft environmental impact statement shall so indicate."

Holtec provided requested information, which is publicly available.

Closed, addressed by RAI-GEN-3

28 Draft RAI ID Information Needed Resolution Status TE-4 Provide an analysis of the effect of resuming operations on the Federally endangered piping plover, which occurs within 6 miles of the PNP site., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide an analysis of the proposed action on piping plover.

ESA Section 7.

Holtec provided requested information, which is publicly available.

Closed during audit discussions TE-5 Milkweeds are monarch butterfly larval habitat. Are any milkweeds known to occur on the PNP site? Provide a recent plant species list., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," states that milkweeds may be present in unmowed areas of the PNP site. The NRC staff needs to confirm whether any are known to be present on site.

ESA Section 7.

Holtec provided requested information. RCI issued and Holtec provided a response to confirm that restart activities would not impact milkweed habitat.

Closed, addressed by RCI-TE-5 TE-6 Section 3.3.3.1 of Enclosure 2, "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," states that suitable roosting and maternity habitat for northern long-eared bat and tricolored bat is potentially present near the PNP site. Confirm that habitat is limited to forested areas onsite. Confirm these areas will not be disturbed.

The NRC staff needs to confirm whether any are known to be present on site to complete its evaluation.

ESA Section 7.

Holtec provided requested information. This request has been addressed in connection with RAI-GEN-1.

Closed, addressed by RAI-GEN-1 TE-7 Provide a description of avian, wildlife, and landscape management practices and provide copies of relevant plans and procedures for the NRC staff review.

The NRC staff will need to review avian, wildlife, and landscape management practices to assess the impacts of the proposed actions on Federally protected resources and terrestrial resources in general.

ESA Section 7.

Holtec provided requested information. RCI issued and Holtec provided a response to confirm that there will be no changes to current management practices, plans, and procedures for restart activities.

Closed, addressed by RCI-TE-7

29 Draft RAI ID Information Needed Resolution Status TE-8 Provide a list of environmental studies in progress at the site (if any), along with the estimated completion date, and draft report date. This includes any surveys for Federally listed species, State-listed species, critical dune habitat mapping, wetland delineations, invasive species surveys, or any other terrestrial species or habitat studies on the PNP site. Provide copies of any survey plans or completed reports for any of these terrestrial studies.

The NRC staff would need to review the most current information about terrestrial species, habitats, and surveys when evaluating effects.

Closed based on site audit discussion and walkdowns.

Closed during audit discussions TE-9 Does Holtec hold a Special Purpose Utility Permit (SPUT) for migratory birds from the FWS?

Table 1.3-1 of Enclosure 2 "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," lists environmental authorizations for current PNP operations but does not list a SPUT for migratory birds.

This information is necessary for the NRC staff to assess the status of permits.

Holtec stated there is no SPUT permit. No additional information from Holtec requested.

Closed during audit discussions TE-10 Provide a summary, if available, of bird mortalities and injuries on the PNP site (species, date, cause if known) in chronological order from 2013-2024., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide summary of bird mortalities or injuries on the PNP site.

Holtec provided information. No additional information from Holtec requested.

Closed during audit discussions TE-11 Provide any updates to the site-specific environmental administrative procedures, controls, and BMPs that are to be in place during potential restart activities., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide summary of on-site administrative, controls, and BMPs and how they would change with a restart to plant operations.

This request has been addressed in connection with RCI-TE-7.

Closed, addressed by RCI-TE-7

30 Draft RAI ID Information Needed Resolution Status TE-12 Describe any noxious weeds or other invasive terrestrial species known to occur on the PNP site? How are invasive species managed onsite?, "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide a summary of invasive terrestrial species with potential to occur on site, nor did it describe any invasive species management.

Closed based on site audit discussion and walkdowns.

Closed during audit discussions Socioeconomics:

SE-1 As briefly indicated in Section 3.4, the planned restart-related activities will likely require a significant number of temporary workers. Provide more information about the temporary workforce, including the number and residence of the temporary workers, work schedule/duration, etc.?, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, did not completely address this aspect of socioeconomics.

Holtec provided requested information.

Closed, addressed by RAI-SE-1 SE-2 Provide a description and breakdown of projected plant employment during operations (similar to Palisades Permanent Employee Residence Information from the 2006 LR EIS Supplement table 2-3)., Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, did not completely address this aspect of socioeconomics.

Holtec provided requested information.

Closed, addressed by RAI-SE-2 Environmental Justice:

EJ-1 Has Holtec engaged with any local communities or groups with EJ concerns? If so, provide summaries of any engagements to help inform the NRC staffs EJ review., Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, did not provide this information.

Holtec provided requested information.

Closed, addressed by RAI-EJ-1 Historic and Cultural Resources:

31 Draft RAI ID Information Needed Resolution Status HCR-1 Is the APE the same as the 2006 LR EIS Supplement APE? Provide a description of, and a map of, the direct, and indirect APE., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide a description of the APE.

A determination and description of the APE is required per 36 CFR 800.4 (see definition in 36 CFR 800.16(d)).

This request has been addressed in connection with RAI-GEN-1.

Closed, addressed by RAI-GEN-1 HCR-2 Provide the details and results of all archaeological surveys conducted on the PNP site. Provide copies of all reports., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide a description of a physical archaeological survey of the PNP, only a Michigan SHPO literature review conducted on September 11-13, 2023.

An evaluation of potential effects requires a known identification of historic properties within the APE as defined by 36 CFR 800.4.

Holtec provided requested information. RCI issued and Holtec provided a response to confirm details of archeological survey.

Closed, addressed by RCI-HCR-2 HCR-3 Since the issuance of the 2006 LR EIS Supplement, the PNP buildings are over 50 years old. Have any built environment (i.e., buildings) surveys been conducted? If so, provide them to the NRC staff., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide a description of a physical built environment survey of the PNP, only a Michigan SHPO literature review conducted on September 11-13, 2023.

An evaluation of potential effects requires a known identification of historic properties within the APE as defined by 36 CFR 800.4.

Holtec provided requested information. RCI issued and Holtec provided a response to confirm details related to historical architectural survey.

Closed, addressed by RCI-HCR-3 HCR-4 Provide a description of potential effects to any identified historic and cultural resources and historic properties at PNP. This includes potential impacts to archaeological sites, buildings, and structures as a result of This request has been addressed in connection with HCR-2 and HCR-3.

Closed during audit discussions

32 Draft RAI ID Information Needed Resolution Status refurbishment activities., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide a description of the effects determinations for identified historic properties at PNP.

An evaluation of potential effects is required as part of 36 CFR 800.4 and 36 CFR 800.5.

HCR-5 Provide all records of engagement and communication with the Michigan SHPO, Tribal Historic Preservation Office (or Native American Tribes) and/or other parties as they relate to Section 106 of the NHPA or cultural resources considered under NEPA., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide a description of communications or engagement with the State, Tribes, or other interested parties as it relates to cultural resources, only reference to a Michigan SHPO literature review conducted on September 11-13, 2023.

Holtec provided requested information; NRC staff received additional communications from Michigan SHPO.

Closed, addressed by RAI-HCR-5 HCR-6 Provide details and results of identification efforts for historic properties of traditional religious and cultural importance (Traditional Cultural Properties and/or Traditional Cultural Landscapes) at PNP., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide reference to the identification or evaluation of historic properties of traditional religious and cultural importance (Traditional Cultural Properties or Traditional Cultural Landscapes) at PNP.

Identification of historic properties must take into account historic properties of traditional religious and cultural importance as part of 36 CFR 800.2(c)(2)(ii).

Holtec provided requested information.

Closed, addressed by RAI-HCR-6

33 Draft RAI ID Information Needed Resolution Status HCR-7/

RCI-HCR-7a Provide copies of existing historic and cultural resource procedures (e.g.,

environmental review, archaeological, cultural & historic resources procedures, excavation and trenching control procedures, inadvertent discovery, stop work and notification procedures) for the PNP site., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide reference to, or copies of, cultural resource procedures for operations of PNP.

As identified in the 2006 LR EIS Supplement, cultural resources procedures were in place at the site (see Section 4.4.5). These procedures were required by the Michigan SHPO as part of LR (see ML061920480). See also, 36 CFR 800.13.

Holtec provided requested information, which is publicly available. RCI-HCR-7a issued as part of second group of RCIs and Holtec provided a response to confirm adoption of cultural resources procedures and incorporation of Michigan SHPO recommendations.

Closed, addressed by RCI-HCR-7a HCR-8 Provide an updated, cultural history of the PNP area (including the APE) since the 2006 LR EIS Supplement., "Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant," did not provide an updated cultural history of PNP.

Holtec provided requested information.

Closed, addressed by RAI-HCR-6 Non-radiological Health:

N-1 Provide additional information regarding noise levels resulting from the restart-related activities as the facility transitions to operations.

In the exemption request, Enclosure 2, Section 4.8, there is no discussion of noise impact levels resulting from the potential restart-related activities.

This request has been addressed in connection with RAI-GEN-1.

Closed during audit discussions Radiological Health:

RH-1 Provide a description of the current radiological conditions (baseline affected environment). Please include descriptions of known radiological hazards and workflow for mitigating identified unknown radiological hazards, a process for estimating dose in varied radiological conditions, an expected cumulative dose to workers during the refurbishment process, and a determination on if decommissioning-related activities have changed the Holtec provided requested information.

Closed, addressed by RAI-RH-1

34 Draft RAI ID Information Needed Resolution Status potential emissions and exposure pathways for workers.

RH-2 Please provide a summary of the past 5 years of environmental and effluent reports.

A description of the baseline affected environment is needed to determine the impacts of the proposed actions.

Holtec provided requested information, which is publicly available.

Closed Radiological and Non-radiological Waste Management:

WM-1 To adequately characterize the baseline affected environment, describe the current waste management strategy, including disposal plans, and quantity of wastes (radioactive, non-radioactive, and mixed). Also describe expected waste to be generated at PNP during restart-related activities and operation., Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, did not provided a description of the expected wastes generated to make a determination of the waste management impacts related to the proposed actions. For example, it is expected that Holtec will be performing chemical cleaning of various reactor systems during restart-related activities, such as the primary system loops and reactor vessel. Such activities, including refurbishment activities, may generate mixed wastes in greater quantities than during prior operational years.

Holtec provided requested information.

Closed, addressed by RAI-WM-1 WM-2 Will any processes regarding facility refurbishment or other restart-related activities and operations require any modification to waste management practices? If so, please describe and quantify the changes that will occur.

(For operations, indicate if there would be any changes that may alter the determination)., Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, did not provided a description of the expected wastes generated to make a determination of the waste management impacts related to the proposed actions.

Holtec provided information. No additional information from Holtec requested.

Closed Fuel Cycle, Transportation, and Decommissioning:

35 Draft RAI ID Information Needed Resolution Status FC-1 Provide a status and intention of use of the fuel currently stored at PNP along with initial re-loading strategy. This information should include fuel enrichment level, re-loading plans for fuel onsite, additional fresh fuel to be shipped to the site for the first re-loading, and the expected burnup level(s)., Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, did not provided a description of intended fuel characteristics to be used to make a determination of the uranium fuel cycle impacts related to the proposed actions. Part of the information being requested is in connection to draft RAI TR-2 and TR-3.

Holtec provided requested information.

Closed, addressed by RAI-FC-1 TR-1 Please describe how Holtec will conform to the assumptions listed in 10 CFR 51.52 table S-4. How is Holtec meeting the conditions required in 51.52(a)(2) and 10 CFR 51.52(a)(3) or assumptions listed in NUREG-1437 Rev. 1 (LR GEIS)?, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, did not provide a discussion on how Holtec intends to meet the requirements in 10 CFR 51.52(a)(2) and (a)(3). This is needed to make a determination on the environmental impacts of the proposed actions.

This request has been addressed in connection with RAI-TR-2.

Closed, addressed by RAI-TR-2 TR-2 Describe the baseline affected environment and impacts of transportation of fresh fuel and spent fuel as they relate to restart-related activities and return to power operations. Please provide expected type and quantity of material that will be transported.

A description of the baseline affected environment and related transportation of fresh fuel is needed to determine impacts of the proposed actions. Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant did not provide this information.

Holtec provided requested information.

Closed, addressed by RAI-TR-2 TR-3 Will fresh fuel be shipped to PNP for the return to operations and subsequent refueling? What is the quantity that will be shipped for these This request has been addressed in connection Closed

36 Draft RAI ID Information Needed Resolution Status actions?

The applicant has not provided a description of current status and intended use of fuel present to make a determination of the transportation impacts related to the proposed actions in Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant.

with TR-2.

DC-1 What decommissioning steps have occurred and will need to be reversed?

Will new technology or techniques be used during and as part of refurbishment or other restart-related activities that may affect future decommissioning efforts? How will these actions related to refurbishment affect or change the assumptions and conclusions when compared to the generic conclusions determined in the Decommissioning GEIS?, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, did not provided a description of the current state of PNP needed to make a determination of the future impacts of decommissioning.

This request has been addressed in connection with GEN-1.

Closed Additional Information Identified during audit and post audit A-1 Based on review of the Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, (Enclosure 2 of the September 28, 2023, exemption request, (ML23271A140)) and information reviewed during the audit, the staff discussed the applicability of the information contained within NUREG-1437, Revision 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, volume 3, appendix E - Environmental Impact of Postulated Accidents (2024 GEIS, Revision 2) (ML24087A133) and within NUREG-1437, Revision 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (1996 GEIS)

(ML040690738).

Please confirm:

1. Any information used to reach a conclusion that the NRC staffs Holtec provided information.

Closed, addressed by RCI-A-1

37 Draft RAI ID Information Needed Resolution Status estimation of the PNP environmental impact of postulated accidents remains applicable.

2. For Design Basis Accidents (DBAs), as indicated during the audit, confirm that due to the requirements for PNP to maintain its licensing basis and implement aging management programs for the resumption of power operations and the remaining licensing renewal period, the environmental impacts following restart are not expected to differ significantly from the 2024 GEIS, Revision 2 DBA assessment, and confirm that the NRCs generic assessment for this issue remains valid for PNP.

3. For, severe accident Impacts and mitigation alternatives, as indicated during the audit, confirm that new information was reviewed to determine if the 2024 GEIS, Revision 2 severe accident impact determination continues to be valid for PNP upon resumption of power operations. That is, the evaluation for the potential resumption of power operations at PNP found no new and significant information regarding severe accidents and severe accident mitigation alternatives (SAMAs) for PNP which demonstrates that impacts due to severe accidents remains consistent with the 2024 GEIS, Revision 2 findings and confirms that the NRCs generic assessment for this issue remains valid for PNP. (Table E.3-1 of the 2024 GEIS, Revision 2 shows that Palisades population dose risk during the 2024 GEIS Revision 2 evaluation was reduced by a factor of 27 from the values used in the 1996 GEIS for which the determination for Palisades probability weighted consequences of a severe accident were small.). Further confirm the following in relation to the evaluation:

a. Confirm that PNP will not be significantly different from the pre-decommissioned plant except for age related replacements and completion of the modifications identified for the National Fire Protection Association 805, risk informed fire protection program and that these improvements are aimed at operational reliability and fire safety, which supports a lower core damage frequency (CDF) than used in the LR SAMA analysis.

b. Confirm, regarding internal event and internal flood risk, that the current updated model of record CDF for PNP is 3.22E-5/yr, which is within the 2024 GEIS, Revision 2 table E.3-2 range of 3.9E-6/yr to 5.6E-5/yr for

38 Draft RAI ID Information Needed Resolution Status pressure water reactors (PWRs) and is a reduction over values used at the time of LR. Confirm, also, that the current internal fire CDF is 6.14E-05/yr, which is within the 2024 GEIS Revision 2 table E.3-6 range of 1.0E-5/yr to 1.05E-4/yr for PWRs. Further confirm that these models are currently being updated and will reflect the as-built plant and state of the art probability risk assessment (PRA) data and methods. Even if the CDF values are higher, the impact determination would not change because PNP population dose risk during the GEIS Revision 2 evaluation is a factor of 27 below the values used in the 1996 GEIS for which the determination for PNP probability weighted consequences of a severe accident were small.

c. Confirm, regarding seismic risk, that there is no current PRA model, but that the ongoing model updates include a seismic PRA release prior to July 2025 and have a lower seismic risk than the NRC safety goal.

Confirm that PNP responded to the NRC request to reevaluate the seismic risk following the Fukushima accident (ML14090A069) and that this evaluation confirmed that the seismic CDF was below the NRC safety goal of 1E-4 which is lower than the highest reported seismic CDF in 2024 GEIS Revision 2 table E.3-6 of 1.3E-4.

SW-10 Based on review of the Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, (Enclosure 2 of the September 28, 2023, exemption request, (ML23271A140)) and information reviewed during the audit, confirm the following information related to establishing a water resources baseline condition:

1. After plant shutdown, the cooling tower basins were drained. Currently, only rainwater is expected to accumulate in the basins. The basins drain by gravity. As part of the restart, water from Lake Michigan would be needed to fill the basins.

2. There are two stormwater outfalls on the south side of the old barge slip area and three on the north side. As part of restart, these stormwater outfalls will be repaired by removing riprap, performing repairs, and replacing the riprap. The repair activities would occur on the shore Holtec provided requested information. RCI SW-10 issued and Holtec provided a response to confirm water resource baseline related to cooling tower basins, stormwater outfalls and herbicide application.

Closed, addressed by RCI-SW-10

39 Draft RAI ID Information Needed Resolution Status adjacent to the access path near the old barge slip. No repair activities would be performed in Lake Michigan waters.

3. Some herbicide application would occur in the cooling tower area. The topography of the terrain between the two cooling tower banks appears to support surface runoff from Cooling Tower B area to drain south to grassy and wooded areas. There are no catch basins, and no stormwater drains near and on the south side of Cooling Tower B.

RAI-SW-11 Holtec is planning to replace both component cooling water (CCW) heat exchangers before restarting PNP. Provide the following information related to the CCW heat exchangers:

• A description of the CCW system heat exchangers and all its interfaces with the surface water environment.

• Changes in the maximum and typical heat loads compared to the old CCW heat exchangers.

• Changes in the flow rate and consumptive use compared to the old CCW heat exchangers.

Holtec provided requested information.

Closed, addressed by RAI-SW-11