ML25099A104
| ML25099A104 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/08/2025 |
| From: | Justin Poole Plant Licensing Branch III |
| To: | Britting J, Schultheis D Entergy Nuclear Operations |
| Wall S | |
| References | |
| EPID L-2024-LLA-0060 | |
| Download: ML25099A104 (1) | |
Text
From:
Justin Poole To:
Michael Schultheis; Johann Britting Cc:
Amy Filbrandt; Marlayna Doell; Ilka Berrios
Subject:
Request for Additional Information RE: Emergency Preparedness Plan Amendment L-2024-LLA-0060 Date:
Tuesday, April 8, 2025 3:32:00 PM Attachments:
Palisades RAIs Clarification Final.pdf Mike/Johann, By application dated May 1, 2024, as supplemented by letters dated July 24, 2024, and March 11, 2025 (Agencywide Documents Access and Management System Accession Nos. ML24122C666, ML24206A187, and ML25070A029 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 April 1, 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 April 7, 2025, the NRC and the licensee held a clarification call to discuss the DRAFT RAIs.During the call, a 30-day from the date of this email 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.
By letter dated March 11, 2025 (ML25070A029), HDI provided a response to an NRC staff request for additional information (RAI) (ML25043A108). The following clarifications to HDIs responses are needed for the NRC staff to complete its review. The NRC staff requests HDI provide a markup of the affected pages for the staffs review as part of the submitted response.
RAI-6
Regulatory requirement:
Appendix E to Part 50 IV.D.3 states in part:
The design objective of the prompt public alert and notification system shall be to have the capability to essentially complete the initial alerting and initiate notification of the public within the plume exposure pathway EPZ within about 15 minutes. The use of this alerting and notification capability will range from immediate alerting and notification of the public (within 15 minutes of the time that State and local officials are notified that a situation exists requiring urgent action) to the more likely events where there is substantial time available for the appropriate governmental authorities to make a judgment whether or not to activate the public alert and notification system. The alerting and notification capability shall additionally include administrative and physical means for a backup method of public alerting and notification capable of being used in the event the primary method of alerting and notification is unavailable during an emergency to alert or notify all or portions of the plume exposure pathway EPZ population. The backup method shall have the capability to alert and notify the public within the plume exposure pathway EPZ, but does not need to meet the 15-minute design objective for the primary prompt public alert and notification system. [emphasis added]
Issue:
The HDI response to RAI-6 indicates that IPAWS-WEA will be the primary Alert and Notification System (ANS) upon implementation of the PNP Emergency Plan. This is based on the intent of the affected offsite response organizations to use this system and the presumption of a finalized and approved Federal Emergency Management Agency Design Report.
With this response to RAI-6, HDI made alterations to section E.2 of the proposed Palisades Nuclear Plant (PNP) Emergency Plan which removed two items required under Appendix E to Part 50 IV.D.3. Specifically, HDI removed the following from the proposed PNP Emergency Plan:
The ANS provides coverage to the PNP EPZ and allows the resident and transient populations to be warned within 15 minutes of the issuance of a protective action. [emphasis added]
And If a backup means of public alerting and notification is necessary, vehicles with mobile public address systems (Route Alerting) and other means as necessary can be utilized.
Request: Provide justification for the removal of the timing element and the description of the backup ANS capability.
RAI-9
Regulatory requirement:
Appendix E to 10 CFR 50 Section IV.F.1 states in part:
The program to provide for: (a) The training of employees and exercising, by periodic drills, of emergency plans to ensure that employees of the licensee are familiar with their specific emergency response duties, and (b) The participation in the training and drills by other persons whose assistance may be needed in the event of a radiological emergency shall be described. This shall include a description of specialized initial training and periodic retraining programs to be provided to each of the following categories of emergency personnel: [emphasis added]
Issue:
The HDI response to RAI-9 indicates that HDI is proposing an alternative to the guidance in NUREG-0654 O.1 and O.2a by utilizing the Systematic Approach to Training (SAT) which is the acceptable process/program to maintain training programs throughout the industry. HDI provided that this meets the intent of NUREG-0654 that emergency responders are initially trained, maintain proficiency, and the training program is maintained current.
Clarification RAI-9(a)
The industry provided a comment for removing annual training and replacing with continuing training during the development of NUREG-0654 Revision 2 (see FEMA-2012-0026-0078-392, Adjudication Report for NUREG-0654/FEMA-REP-1, Rev. 2 Public Comments Sorted by Document Order [ML19350A378]). The resolution of the comment stated:
The term continuing training is not commonly used outside of the industry and therefore would not be appropriate to utilize here. However, the language of evaluation criterion O.1 was modified to clarify that annual training is considered to be the minimum amount of training that should be provided. [emphasis added]
Therefore, HDIs response to RAI 9 proposing alternate guidance using SAT which determines the necessary periodicity of the retraining (continuing training) and includes provisions for training program review. does not meet the approved NRC guidance for the minimum amount of training that should be provided.
Request: Please provide a justification of how the SAT program meets the intent of the minimum for annual retraining or revise the proposed PNP Emergency Plan.
Clarification RAI-9(b)
Guidance of NUREG-0654 O.2.a states, The ERO training program is reviewed at least annually and revised as necessary.
Request: Please provide a justification of how reliance on the SAT program meets the intent for a minimum of at least annual review.
RAI-11
Regulatory requirement:
10 CFR 50.47(b)(4) states:
A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
The HDI response to RAI-11 indicates the following proposed changes:
Specifically, the following EALs [emergency action levels] have been modified to address this RAI:
Revised the technical bases for EAL AU2.1.
Revised the initiating condition, EAL, and technical bases for EAL AA2.2 (previously numbered as EAL AA2.1).
Revised the initiating condition, EAL, and technical bases for EAL AA2.3 (previously numbered as EAL AA2.2) to identify a specific SFP level and to provide the technical bases for the SFP level presented in the EAL.
Additionally, EALs AA2.1, AS2.1, and AG2.1 were added to address uncovery of irradiated fuel and a significant loss of SFP inventory control and makeup capability leading to imminent fuel damage.
Clarification RAI-11(a)
EAL AA2.1:
The basis states:
This EAL addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of watr level within the spent fuel pool.
[emphasis added]
Additionally, the original submission for the proposed PNP Basis information included a statement that was removed in the RAI response:
This EAL is defined by the specific areas where irradiated fuel is located such as the refueling cavity, reactor vessel, or spent fuel pool.
Request: Please provide justification for including the spent fuel pool versus refueling pathway in the basis. Additionally, correct the spelling issue in the EAL of water.
Clarification RAI-11(b)
EAL AA2.2 The basis states:
This EAL addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool. [emphasis added]
Additionally, the original submission for the proposed PNP Basis information included a statement that was removed in the RAI response:
This EAL is defined by the specific areas where irradiated fuel is located such as the refueling cavity, reactor vessel, or spent fuel pool.
Request: Please provide justification for including the spent fuel pool versus refueling pathway in the basis.
Clarification RAI-11(c)
EAL AA2.3 The basis states:
This EAL applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with EAL EU1.1.
Issue: This information should NOT be included in this EAL as it is only applicable to EAL AA2.1 and AA2.2 consistent with the guidance.
Request: Please revise or provide justification why this information is needed. Additionally, correct the spelling issue in the EAL of spent.