ML25078A352
| ML25078A352 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/19/2025 |
| From: | Fleming J Holtec, Holtec Palisades |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25078A351 | List: |
| References | |
| PNP 2025-008 | |
| Download: ML25078A352 (1) | |
Text
HOLTEC 27780 Blue Star Highway, Covert, MI 49043 PALISADES PNP 2025-008 March 19, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Docket No. 50-255 Renewed Facility Operating License No. DPR-20 10 CFR 50.71 (e) 10 CFR 50.4(b)(6)
Reference:
Holtec Decommissioning International, LLC letter to U.S. Nuclear Regulatory Commission, Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments, dated December 6, 2023 (ADAMS Accession No. ML23340A161)
Subject:
Final Safety Analysis Report Update Revision 37 In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Sections 50.71, Maintenance of records, making of reports, paragraph (e), 10 CFR 50.71 (e), and 50.4, Written communications, paragraph (b)(6), 10 CFR 50.4(b)(6), Holtec1 on behalf of Holtec Palisades, LLC (Holtec Palisades) is providing the Palisades Nuclear Plant (PNP) Final Defueled Safety Analysis Report (DSAR) update, Revision 37.
All changes, other than those involving typographical corrections, format changes, and removed obsolete information, were made under the provisions of 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, or in accordance with safety evaluations received from the Nuclear Regulatory Commission (NRC). The DSAR update incorporates changes made to the facility or the procedures described in the DSAR, and all other applicable information and analyses submitted to the NRC or prepared pursuant to NRC Requirements, up to February 21, 2025, which is within 6 months of the filing of this letter, and within 24 months since the last Updated Final Safety Analysis Report (UFSAR) submittal, on March 31, 2023, in accordance with 10 CFR 50.71(e)(4). contains an affidavit pursuant to 10 CFR Section 2.390, Public Inspections, exemptions, and requests for withholding, paragraph (d)(1 ), 10 CFR 2.390(d)(1 ), to withhold from public disclosure. contains the list of changes included in DSAR Revision 37.
1 Holtec Palisades, LLC ("Holtec Palisades") is the licensed owner of PNP. Holtec Decommissioning International, LLC ("HDI") is the licensed operator of PNP while the facility is in decommissioning.
Pursuant to the license transfer application submitted in connection with the PNP restart (Reference),
licensed authority will transfer from HDI to Palisades Energy, LLC ("Palisades Energy") upon NRC's approval of the transition from decommissioning back to power operations. Holtec Palisades will remain the licensed owner of PNP.
contains a public version of the updated DSAR (Revision 37), with certain information redacted in accordance with NRC Regulatory Issue Summary (RIS) 2015-17, Review and Submission of Updates to Final Safety Analysis Reports, Emergency Preparedness Documents, and Fire Protection Documents. contains a non-public version (non-redacted) of the updated DSAR (Revision 37). contains security-related information, and Holtec requests that this enclosure be withheld from public disclosure under 10 CFR 2.390(d)(1 ).
For this DSAR update, no information has been removed in accordance with Appendix A to Nuclear Energy Institute (NEI) 98-03, Revision 1, Guidelines for Updating Final Safety Analysis Reports, as endorsed by Regulatory Guide 1.181, Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50. 71 (e).
This letter contains no new regulatory commitments and no revised commitments.
Should you have any questions or require additional information, please contact Amy Filbrandt, Acting Regulatory Assurance Manager at (269) 764-2520.
I declare under penalty of perjury that the foregoing is true and correct. Executed on March 19, 2025.
Respectfully, Jean A.
Fleming Digitally signed by Jean A. Fleming DN : cn=Jean A. Fleming, o=Holtec Decommissioning International, LLC, ou=Regulatory and Environmental Affairs, email=J.Fleming@Hollec.com Date: 2025.03.19 12:29:45 -04'00' Jean A. Fleming Vice President of Licensing and Regulatory Affairs Holtec International Enclosures
- 1. Affidavit Supporting Holtec Request to Withhold Enclosure 4 from Public Disclosure
- 2. Palisades Nuclear Plant Final (Defueled) Safety Analysis Report (DSAR)
Revision 37 List of Changes
- 3. Palisades Nuclear Plant Final (Defueled) Safety Analysis Report (DSAR)
Revision 37 (Public Version)
- 4. Palisades Nuclear Plant Final (Defueled) Safety Analysis Report (DSAR)
Revision 37 (Non-Public Version) - Security Related Information, Withhold Under 10 CFR 2.390 cc:
NRC Region Ill Regional Administrator NRC Decommissioning Inspector - Palisades Nuclear Plant NRC NMSS Project Manager - Palisades Nuclear Plant to PNP 2025-008 Affidavit Supporting Holtec Request to Withhold Enclosure 4 from Public Disclosure
U.S. Nuclear Regulatory Commission ATTN: Document Control Clerk Non-Proprietary Enclosure to Final Safety Analysis Report Update Revision 37 AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, William Noval, being duly sworn, depose and state as follows:
- 1) I have reviewed the information provided in Final Safety Analysis Report Update Revision 37, which is sought to be withheld, and am authorized to apply for its withholding.
- 2) The information sought to be withheld is in Holtec's Final Safety Analysis Report Update Revision 3 7, Enclosure 4, because the information is proprietary, business confidential information, contains personal information, contains information regarding physical protection, or related to an investigation response from Holtec Decommissioning International.
- 3) In making this application for withholding of proprietary information of which it is the owner, Holtec International relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(l) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought contains information or records concerning a licensee's or applicant's physical protection.
- 4) Some examples of categories of information which fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by Holtec' s competitors without license from Holtec International constitutes a competitive economic advantage over other companies;
- b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
Page 1 of 5
U.S. Nuclear Regulatory Commission ATTN: Document Control Clerk Non-Proprietary Enclosure to Final Safety Analysis Report Update Revision 37 AFFIDAVIT PURSUANT TO 10 CFR 2.390
- c. Information which reveals cost or price information, production, capacities, budget levels, or commercial strategies ofHoltec International, its customers or its suppliers;
- d. Information which reveals aspects of past, present, or future Holtec International customer-funded development plans and programs of potential commercial value to Holtec International;
- e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
- f. information or records concerning a licensee's or applicant's physical protection.
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraph 4.f. above.
- 5) The information sought to be withheld is being submitted to the NRC in confidence. The information (including that compiled from many sources) is of a sort customarily held in confidence by Holtec International, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Holtec International. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs ( 6) and (7) following.
- 6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.
Access to such documents within Holtec International is limited on a "need to know" basis.
Page 2 of 5
U.S. Nuclear Regulatory Commission ATTN: Document Control Clerk Non-Proprietary Enclosure to Final Safety Analysis Report Update Revision 37 AFFIDAVIT PURSUANT TO 10 CFR 2.390
- 7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function
( or his designee ), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation.
Disclosures outside Holtec International are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
- 8) The information classified as proprietary was developed and compiled by Holtec International at a significant cost to Holtec International. This information is classified as proprietary because it contains information or records concerning a licensee's or applicant's physical protection. A substantial effort has been expended by Holtec International to develop this information.
- 9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Holtec International' s comprehensive decommissioning and spent fuel storage technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology, and includes development of the expertise to determine and apply the appropriate evaluation process.
The research, development, engineering, and analytical costs comprise a substantial investment of time and money by Holtec International.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
Holtec International's competitive advantage will be lost if its competitors are able to use the results of the Holtec International experience to normalize or Page 3 of 5
U.S. Nuclear Regulatory Commission ATTN: Document Control Clerk Non-Proprietary Enclosure to Final Safety Analysis Report Update Revision 37 AFFIDAVIT PURSUANT TO 10 CFR 2.390 verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to Holtec International would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Holtec International of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.
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U.S. Nuclear Regulatory Commission ATTN: Document Control Clerk Non-Proprietary Enclosure to Final Safety Analysis Report Update Revision 37 AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY )
)
ss:
COUNTY OF CAMDEN
)
William Noval, being duly sworn, deposes and says:
That he has read the foregoing affidavit, and the matters stated therein are true and correct to the best of her knowledge, information, and belief.
Executed at Camden, New Jersey, this 19th day of March 2025.
)
William Noval Holtec Decommissioning International Director of Regulatory Affairs Subscribed and sworn before me this 19th day of March, 2025
~~Qr LAUREN A. PAGAN NotafY Public, State d New Jersey My Commissioo Expires 911312026 Page 5 of 5 to PNP 2025-008 Palisades Nuclear Plant Final (Defueled) Safety Analysis Report (DSAR) Revision 37 List of Changes
PNP 2025-008 Page 2 of 3 Palisades Nuclear Plant Final (Defueled) Safety Analysis Report (DSAR) Revision 37 List of Changes Log Affected DSAR Sections, No.
Figures, and Tables Description of Change The instrument air compressor (C-2A and C-2C) and C-2B aftercooler system flow requirements were not removed from the service water system flow requirements in error after engineering change 73072 abandoned, i.e.17-026 Table 9-1 retired in place, the service water piping and components to and from the instrument air compressor aftercoolers. This error was identified in Palisades corrective action program (tracking number IR PAL-02555). The changes to the DSAR were to remove this equipment from the Table.
Controlled Decommissioning Equipment Change Package CCDECP-PAL-0007 approved the instrument air system to be used as the normal supply 22-018 Figure 9-9 Sheet 1 for the Spent Fuel Pool Bulkhead Gate (Door-950) pneumatic seal which also included adding a cross tie between two valves. The changes to the DSAR were to update the piping and instrument drawing showing the cross tie.
Controlled Decommissioning Equipment Change Package CDECP-PAL-0004 adjusted the standby function of the service water pumps such the 22-019 Section 9.1.2.3 standby pump will start when both of the other two service water pumps have a low discharge pressure. The changes to the DSAR were to update the system operation description.
Section 2.6 Palisades Offsite Dose Calculation Manual was revised in accordance with 23-001 Section 11.5.3 site administrative technical specifications. The changes to the DSAR were Table 2-20 to update descriptions of the radiological effluents and radiological environmental program.
PNP 2025-008 Page 3 of 3 Section 11.5.3 23-002 Table 11-15 Section 7 Appendix C Section 9.6.1 Section 9.6.4 23-005 Section 9.6.4.2.1 Section 12.2.1.9 Section 12.5 Section 9 References Section 12.1.1 Section 12.3.1 24-004 Section 12.4 Section 15.1.1 Section 15.1.2 Section 1.5 Section 9 Reference 24-009 Section 9.11 Section 14.11 24-011 Figure 8.5 Sheet 2 Controlled Decommissioning Equipment Change Package CDECP-PAL-0007 issued the Emergency Action Level (EAL) threshold calculation (ENTGPAL 164-CALC-001) and authorized physical changes to support the Permanently Defueled Emergency Plan (PDEP) for Palisades. The DSAR changes were to update effluent monitoring and sampling descriptions, process radiation service and equipment descriptions, and the Regulatory Guide 1.97 Revision 3 Parameter Summary Table.
A license amendment request to revise the site emergency plan was accepted by the Nuclear Regulatory Commission (NRC) (ML23236A004).
The DSAR changes were to updated the description of the fire protection program and emergency planning program.
The Quality Assurance Program Manual for Palisades was revised in accordance with 10 CFR 50 Appendix B. The DSAR changes were to update the description of the Quality Assurance Program.
Engineering Change 93344 allowed for licensing and operations for HI-STORM FW Version E 1 system to provide additional spent fuel storage space at Palisades independent spent fuel storage installation pad.
Controlled Decommissioning Equipment Change Package CDECP-PAL-0015 allowed for the installation of a new, outdoor, permanent distribution panel to provide power for miscellaneous needs. The DSAR changes were to update the piping and instrument drawing showing the system.
to PNP 2025-008 Palisades Nuclear Plant Final (Defueled) Safety Analysis Report (DSAR) Revision 37 (Public Version) 1183 pages follow