ML25043A108
| ML25043A108 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/11/2025 |
| From: | Justin Poole Plant Licensing Branch III |
| To: | Britting J, Schultheis M Entergy Nuclear Operations |
| Wall S | |
| References | |
| EPID L-2024-LLA-0060 | |
| Download: ML25043A108 (12) | |
Text
From:
Justin Poole To:
Michael Schultheis; Johann Britting Cc:
Subject:
Request for Additional Information RE: Emergency Preparedness Plan Amendment L-2024-LLA-0060 Date:
Tuesday, February 11, 2025 3:47:00 PM Attachments:
Palisades Restart Request for Additional Information.pdf
- Mike,
By application dated May 1, 2024, as supplemented by letter dated July 24, 2024 (Agencywide Documents Access and Management System Accession Nos. ML24122C666 and ML24206A187, respectively), Holtec Decommissioning International, LLC on behalf of Holtec Palisades LLC (HDI, or the licensee), requested U.S. Nuclear Regulatory Commission (Commission, NRC) review and prior approval of a proposed license amendment request (LAR) to revise the Palisades Nuclear Plant (PNP) pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR). The proposed LAR would revise the PNP Site Emergency Plan and emergency classification scheme to reflect the resumption of power operations at PNP. HDI states that the proposed PNP Site Emergency Plan was developed using the guidance contained in Revision 2 of NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (ML19347D139),
and is in accordance with 10 CFR 50.47, Emergency plans, and Appendix E to 10 CFR Part 50.
On January 27, 2025, the NRC staff sent the licensee DRAFT RAIs to ensure that the questions are understandable, the regulatory basis is clear, there is no proprietary information contained in the RAIs, and to determine if the information was previously docketed. On February 6, 2025, the NRC and the licensee held a clarification call to discuss the DRAFT RAIs.During the call, the NRC staff decided that the first DRAFT RAI was no longer necessary, and as such, the question has been removed in the final RAIs and the remaining questions have been re-numbered. In a subsequent call with the project manager, a 30-day timeframe to respond to the RAIs was agreed upon. The attached is the final version of the RAIs. These RAIs will be put in ADAMS as a publicly available document.
Justin C. Poole Senior Project Manager Palisades, TMI, Duane Arnold Restart NRR/DORL/LPL 3 U.S. Nuclear Regulatory Commission (301)415-2048
REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE THE EMERGENCY PLAN HOLTEC DECOMMISSIONING INTERNATIONAL, LLC PALISADES NUCLEAR PLANT DOCKET NO. 50-255 By application dated May 1, 2024, as supplemented by letter dated July 24, 2024 (Agencywide Documents Access and Management System Accession Nos. ML24122C666 and ML24206A187, respectively), Holtec Decommissioning International, LLC on behalf of Holtec Palisades LLC (HDI, or the licensee), requested U.S. Nuclear Regulatory Commission (Commission, NRC) review and prior approval of a proposed license amendment request (LAR) to revise the Palisades Nuclear Plant (PNP) pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR). The proposed LAR would revise the PNP Site Emergency Plan and emergency classification scheme to reflect the resumption of power operations at PNP.
HDI states that the proposed PNP Site Emergency Plan was developed using the guidance contained in Revision 2 of NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (ML19347D139), and is in accordance with 10 CFR 50.47, Emergency plans, and Appendix E to 10 CFR Part 50.
Responses to the following requests for additional information (RAI) are needed for the NRC staff to complete its review.
RAI 1
Requirement:
Issue: Attachment 2, Section B.1.a, Emergency Response Organization, of the LAR states, The minimum on-shift staff required to conduct routine and immediate emergency operations are maintained as described in Chapter 13 of the PNP Updated Final Safety Analysis Report (UFSAR).
The staff was unable to find the information in Chapter 13 of Revision 35 of the UFSAR.
However, the minimum on-shift staff required to conduct routine and immediate emergency operations is located and discussed in Holtecs letter dated February 9, 2024, License Amendment Request to Revise Selected Permanently Defueled Technical Specifications Administrative Controls to Support Resumption of Power Operations (ML24040A089).
Request: Provide clarification on what is the correct reference for the minimum on-shift staffing for the proposed PNP Site Emergency Plan.
RAI 2
Issue: Attachment 2, Table B-1, On-Shift and Augmenting ERO Staffing Plan, of the LAR, contains the following:
Table B-1 indicates that the proposal will have two remote dose assessors to relieve the on-shift dose assessor within 60 minutes of an Alert or greater emergency classification.
However, Attachment 6, On-Shift and Augmentation Emergency Response Organization Staffing Plan Comparison Table, of the LAR indicates that there is only one Remote Dose Assessor to relieve the on-shift dose assessor within 60 minutes of an Alert or greater emergency classification.
Request: Provide clarification on whether there are one or two Remote Dose Assessor(s) providing relief to the on-shift dose assessor within 60 minutes of an Alert or greater emergency classification in the proposed PNP Emergency Plan.
RAI 3
Issue: Section 4.4.1 IT [information technology] Technician ERO Positions of the LAR states, PNP evaluated EP [emergency preparedness]-related digital assets as part of implementation of the Cyber Security Rule, 10 CFR 73.54(b). In accordance with NEI [Nuclear Energy Institute]13-10, Cyber Security Control Assessments, EP Critical Digital Assets have been assessed and controls have been put in place to protect the assets against cyber-attack.
However, Section 7.0 References, of the LAR does not include NEI 13-10 and which revision of NEI 13-10 was used for this evaluation.
Request: Clarify what revision was used for the NEI 13-10 analysis indicated in section 4.4.1 and confirm that the evaluation was performed in accordance with that version.
RAI 4
Requirement:
Issue: Attachment 2, Section O.1 2, Radiation Protection of the LAR states in part, b) ERO Radiation Protection Personnel position is task qualified to perform the following:
However, there is no further discussion of how these task qualified individuals will be used as part of the ERO, nor are they assigned as positions in Table B-1 of the proposed PNP Emergency Plan.
Request: Provide additional information that clarifies the role of the task-qualified ERO Radiation Protection Personnel as part of the ERO (on-shift and/or augmenting), and specify what emergency plan functions they would be assigned to perform and what procedures/guidance directs the assignment of these emergency plan functions.
RAI 5
Issue: Attachment 2, Section B.1.b of the LAR states, The remote emergency response organization (ERO) positions are defined.
Resources necessary to perform the functions and tasks assigned to the remote response positions, as well as a backup capability, are described.
Section 4.4.2, Remote Response of Engineering and Dose Assessment Function, of the LAR states in part, If a remote ERO member cannot perform the function due to a personal or technology issue, standard/current processes would be utilized to replace the ERO member as soon as possible or the remote ERO member can relocate to resolve any technical issues.
and The remote ERO personnel will have multiple means of communication (phones, standard conference bridges, internet, video conferencing software, and/or any additional technology advancements) available to them to effectively interface and communicate.
Additionally, it states in part, In the event that remote responders are unable to access information remotely, they would respond to their designated reporting facility (either the TSC
[Technical Support Center] or EOF [Emergency Operations Facility]).
However, Attachment 2, Section B.1.b of the LAR does not provide sufficient detail to ensure the remote responder functions and backup capabilities are maintained.
Request: Provide additional information that specifies the backup capabilities and intended actions for remote responders who cannot perform the function due to a personal or technology issue and clarify how this function is maintained in the proposed PNP Site Emergency Plan.
RAI 6
Issue: Attachment 2, Section E.2 of the LAR states in part, Detailed information regarding ANS capabilities is maintained in the ANS design report.
IPAWS-Wireless Emergency Alerts (WEA) is the primary alert method and IPAWS-Emergency Alert System (EAS) is the primary method to disseminate information regarding an emergency at PNP. Van Buren County incorporates IPAWS (WEA and EAS) into its public warning structure through a Memorandum of Agreement (MOA), which governs the relationship between the state-level Collaborative Operating Groups (COG), Van Buren COG, and FEMA. IPAWS provides Van Buren County with the capability to integrate alert and warning systems with the national alert and warning infrastructure.
However, Revision 32 of the PNP Site Emergency Plan, dated September 25, 2018, (ML19312A447) states in part, the public warning system composed of two components, alert and notification.
(1) The alert component is comprised of a siren system which provides coverage for a 10 mile radius around the plant, and allows the resident and transient populations to be warned within 15 minutes of the issuance of a protective action.
Request: Provide documentation of FEMA approval of the PNP IPAWS ANS Design Report.
RAI 7
PNP emergency equipment and kits are inventoried to verify adequate supplies and materials, and to inspect condition semi-annually and following each use.
However, Attachment 2, Section H.11.a of the LAR states in part, Emergency Planning is responsible for ensuring the quarterly inventory and/or seal inspection is performed for designated emergency supplies and equipment.
Section H.11 of the proposed PNP Site Emergency Plan specifies two different frequencies for performing an inventory of emergency equipment and supplies.
Request: Provide additional information that clarifies the frequency of testing and maintenance of emergency equipment and supplies.
RAI 8
PNP has developed PARs, in accordance with agreements made with the state agencies, for the plume exposure pathway EPZ that include evacuation, sheltering, and recommendations for radioprotective KI use based on the following:
NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Guidance for Protective Action Strategies, November 2011.
EPA-400/R-17/001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, January 2017.
Additionally, it states in part, Protective Action Guides for the Environmental Protection Agency and the State of Michigan are shown on Tables J-1 and J-2.
However, the values contained in Tables J-1 and J-2 are the values contained in EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, May 1992 instead of the 2017 revision.
Example:
Table J-2 Early Plume PAGs indicates that administration of stable iodine would occur at 25 rem thyroid. However, 2017 revision to the PAG manual updated that to 5 rem (50 mSv) projected child thyroid dose from exposure to radioactive iodine.
RAI 9
Issue: Attachment 2, Section O.1 of the LAR states in part, This procedure describes the responsibilities for conducting and administering initial and continuing emergency preparedness training; provides clarification and details to implement a remediation process; and follows the guidance for the SAT
[systematic approach to training] Process. The SAT process determines the necessary periodicity of the retraining (continuing training) on a task-specific basis.
However, the description does not specify that retraining will be conducted at least annually as specified in NUREG-0654 Rev. 2.
Additionally, Attachment 2, Section O.2.a of the LAR states, Changes to the training program are continually identified from trainee feedback and by critique items captured during drills and incorporated per the principles of the SAT process. In addition to continuous training evaluation through drill and exercise critique process that identifies performance issues and initiates training reviews for particular tasks, the SAT process includes provisions for training program review.
However, the description does not specify that the ERO training program will be reviewed and revised at least annually.
Request: Provide additional information to show how emergency responders and other appropriate individuals with operational roles receive annual retraining and how the ERO training program is reviewed at least annually and meets the intent of the guidance of NUREG-0654, Revision 2.
RAI 10
Requirement:
Issue: Attachment 3, Proposed Power Operations Emergency Action Level Technical Bases, Section 6.1, Emergency Action Level Bases, Table A-1 Effluent Monitor Classification Thresholds of the LAR contains radiation monitor values that have changed since PNP EAL scheme was approved by the NRC on May 26, 2011 (ML111300431) and the subsequent revisions to the NRC-approved scheme made by PNP using the 10 CFR 50.54(q) change process.
Request: Provide additional information that shows the basis and associated calculations for the proposed radiation monitor threshold values for the gaseous effluent radiation monitors for Table A-1.
RAI 11
Requirement:
Issue: By letter dated August 22,2016 (ML16014A318), the NRC concluded:
In its letter dated December 16, 2015 [ML15351A126], the licensee stated that they would meet the requirements of Order EA-12-051 by following the guidelines of NEI 12-02, as endorsed by JLD-ISG-2012-03. In the [conclusion section 4.4 of NRC letter dated August 22, 2016 (ML16014A318)], the NRC staff finds that, if implemented appropriately, the licensee has conformed to the guidance in NEI 12-02, as endorsed by JLD ISG-2012-03. In addition, the NRC staff concludes that if the SFP [spent fuel pool] level instrumentation is installed at Palisades Nuclear Station according to the licensee's proposed design, it should adequately address the requirements of Order EA-12-051.
By inspection report dated December 2, 2016 (ML16337A098), the NRC assessed in part:
the inspectors determined the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-051.
Additionally, Section 4.1, Technical Advancements and Program Enhancements of the LAR states in part that, Supporting the overall conclusion that PNP can effectively respond to an emergency, the proposed PNP POSEP reinstates these capabilities as they existed in PNP SEP Revision 32, including historical enhancements to emergency preparedness in response to Three Mile Island, Chernobyl, the September 11th terrorist attacks, and Fukushima that address:
The proposed EAL scheme in Attachment 3, Section 6.1, Emergency Action Level Technical Bases, does not include EALs based on the installed SFP instrumentation.
Request: Provide emergency action levels with technical bases or provide a technical justification that demonstrates how the PNP site emergency plan addresses emergency classifications for SFP levels to address the requirements of 10 CFR 50.47(b)(4) and 50.155(e).
RAI 12
Requirement:
Issue: Attachment 3, Section 6.1, of the LAR contains a proposed EAL EU1.1 that is based on NEI 99-01, Revision 6 and includes a Table E-1 Cask Dose Rates, with different sets of dose rates that equate to two-times the cask-specific technical specification allowable radiation value for the Ventilated Storage Cask System (VSC-24); the NUHOMS Horizontal Modular Storage System (32PT and 24PTH); and the HI-STORM Flood/Wind (FW) Multipurpose Canister (MPC)
Cask System.
The proposed EAL EU1.1 values for the VSC-24 are two times the amounts listed in the VSC certificates of compliance, revisions 1 through 3, however the VSC-24 certificates of compliance revisions 4 through 6 contained values of 100 mrem per hour on the sides and 200 mrem per hour on the top with dose rates at the air inlets below 350 mrem per hour and air outlets below 100 mrem per hour. This may result in an incorrect Unusual Event emergency declaration for the ISFSI casks under certificates of compliance revisions 4 through 6.
Request: Provide documentation or analysis that shows how the PNP EAL EU1.1 will provide the correct emergency classification for the different revisions and dose rates for the different casks and amendments.
RAI 13
Requirement:
Issue: Attachment 3, Section 6.1, EAL EU1.1 of the LAR there is an incorrect reference to EALs ICs [initiating condition] PD-HU1 and PD-HA1. These EALs do not exist in the proposed PNP EAL scheme.
Request: Provide clarification of EAL EU1.1 with updated references to the proposed PNP EAL scheme.
RAI 14
Requirement:
Issue: The proposed EALs CU1.1, CA1.1, SA1.1, SS1.1 and SG1.1 are based on NEI 99-01, Revision 5 and include tables with identified power sources. However, the primary point of emphasis for EALs CA1.1, SS1.1, SG1.1 is a complete loss of power, and a list of readily available power sources may lead to event declarations even if mitigative strategies using other power sources are effective. This issue was addressed in Emergency Preparedness Frequently Asked Question (EPFAQ) 2015-015 (ML16166A191).
Additionally, in section 3.2.3.6, Electrical Analysis, of NRC letter dated August 22, 2016 (ML16014A318), it appears that Palisades has additional electrical sources that could provide power that were not available during the approval of NEI-99-01, Revision 5 EALs.
The EAL and/or Technical Basis section may specify the use of a non-safety-related power source provided the source is maintained in a formal maintenance program and able to power the bus loads associated with ECCS and decay heat removal functions. This includes sources that support implementation of strategies required by 10 CFR 50.155, Mitigation of beyond-design-basis events.
Request: Provide an analysis or technical justification to demonstrate that a loss of all onsite and offsite AC power does not result in a Site Area Emergency or General Emergency based on the loss of the listed power sources when other power sources may be available to power to the Vital AC safeguards buses or implement the guidance in EPFAQ 2015-015.