ML25115A011

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RIC 2025: Technical Session T1 - Palisades and Beyond: Regulatory Perspectives on the Potential Restart of Facilities in Decommissioning
ML25115A011
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Site: Palisades Entergy icon.png
Issue date: 03/11/2025
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T1-Palisades and Beyond:

Regulatory Perspectives on the Potential Restart of Facilities in Decommissioning 2

Jason Kozal Director, Division of Operating Reactor Safety, Region III Co-Chair, Palisades Restart Panel Opening Remarks 3

Jamie Pelton, Deputy Director, Division of Operating Reactor Licensing, US NRC Co-Chair, Palisades Restart Panel Philip McKenna, Deputy Director, Division of Reactor Oversight, US NRC Co-Chair, Palisades Restart Panel April Nguyen, Lead, Palisades Restart Team, US NRC Michael Schultheis, Director, Regulatory and Site Strategies, Holtec International Dr. Adam Stein, Director, Nuclear Energy and Innovation, The Breakthrough Institute Panelists 4

  • Opening Remarks
  • Deciding to Restart a Reactor in Decommissioning
  • Creating the Regulatory Roadmap
  • Ensuring Safety-The Mission
  • Creating an Open and Transparent Process
  • Impacts on the Future of Nuclear Power Agenda 5
  • Palisades is the first plant in decommissioning that a licensee has requested authorization to restart.
  • Palisades shut down in May 2022 and, in June 2022, fully transitioned to a decommissioning licensing basis.
  • The plant is a Combustion Engineering pressurized-water reactor located in Covert, Michigan.
  • The reactors operating licensed power level was 2,565.4 megawatts-thermal.
  • The Atomic Energy Commission issued a provisional operating license in 1971, allowing commercial operation. The NRC issued a full-term operating license in 1991 and in 2007 the operating license was renewed until March 24, 2031.

First-of-a-Kind Activity 6

  • Palisades certified that it permanently ceased power operations and fuel was permanently removed from the reactor vessel under 10 CFR 50.82(a)(1).
  • The 10 CFR Part 50 license has not been terminated but was amended to reflect decommissioning status.
  • To restart Palisades, Holtec would need to-
  • Gain NRC approval to restore the licensing basis of the plant to an operational status.
  • Return plant components to a status that supports safe operation.
  • Make any upgrades necessary to meet the proposed operational licensing basis.

What Does Restart Mean?

7

Deciding to Restart a Reactor in Decommissioning 8

www.holtec.com Repowering the Palisades Plant Mike Schultheis, Holtec Palisades Director, Regulatory & Site Strategies 9

www.holtec.com Palisades Restart - Early Considerations Regulatory Feasibility Evaluation

  • Comparable scenarios for precedent
  • Potential for necessary rulemaking
  • Unwinding decommissioning license basis changes
  • Deferral of related items for decommissioning Technical Challenges
  • SSC Reclassification and functional restoration, current layup
  • Short-and long-term upgrades
  • Stakeholder support (local/regional/state)
  • Likely critical path to define early start activities
  • Project funding and power off-taking
  • Recruiting and hiring, supplemental support PCS Chemical Decontamination Staging on SFP Deck 10

Value in Restart of Decommissioning Reactor Improves public benefits Increase clean energy Reduce environmental impact Reduce public health impacts Regulatory oversight should provide reasonable assurance of protection

©Breakthrough Institute 2025 Sources: Energy Information Administration, Net Generation by State by Type of Producer by Energy Source (EIA-906, EIA-920, and EIA-923), 2021 values for Palisades as the last full operation year, is used for renewables as the most recently available data.

11

  • Holtec submitted a Regulatory Path Letter in February 2023. Presubmittal meetings took place in March and May 2023.
  • The NRC previously established that the existing regulatory framework is adequate to evaluate the changes that would be necessary to support restart of a facility in decommissioning (PRM-50-117).
  • The Palisades Restart Panel was formed for coordination and oversight of the project.

NRC Potential Restart Project History 12

  • The NRC chartered a dedicated panel of experienced NRC leaders to oversee and review steps and actions being pursued by Holtec to restart Palisades.
  • The panel guides the staff efforts to review Holtecs licensing and regulatory requests and inspect the facility to ensure it is safe to operate.
  • The primary objective of the panel is to proactively identify and promptly resolve any licensing, inspection, or regulatory challenges that concern the Palisades restart.

NRC Palisades Restart Panel 13

  • Early in the process, the NRC held a retreat to focus the organization in determining regulatory options and pathways for potential restart of a reactor.
  • Agency expertise was sought throughout the organization, including technical, oversight, licensing, and legal analysis.

NRC Regulatory Retreat 14

Creating the Regulatory Roadmap 15

  • The NRC strategy for ensuring safe resumption of power operations at Palisades includes licensing safety reviews, program oversight, and inspection activities.
  • The NRC staff expects to evaluate the plants readiness to restart when Holtec provides assurance that the plant is ready to operate at power.

NRC Regulatory Path 16

  • Palisades existing 10 CFR Part 50 license can be modified using the NRCs standard regulatory processes to reestablish the licensing basis.
  • Holtec submitted licensing actions that would return the plants licensing basis to what it was before shutdown, with only minor changes.
  • The licensee must ask for an exemption from 10 CFR 50.82(a)(2) and make a series of licensing requests requiring NRC approval.

NRC Regulatory Strategy-Licensing 17

  • Holtec has submitted the following licensing and regulatory requests for restart:
  • To revise the operating license and permanently defueled technical specifications to reflect resumption of power operations, including security plans.
  • To revise the site emergency plan to support resumption of power operations.
  • To transfer the operating authority for Palisades from Holtec Decommissioning, Inc.

to Palisades Energy, LLC.

  • If all NRC requirements are met, all licensing and regulatory actions will be issued on the same day, but not immediately implemented.

NRC Regulatory Strategy for Holtec Requests 18

  • Quality Assurance (QA) Plan
  • Holtec submitted a proposed power operations QA program manual as a supplement to the license transfer request.
  • The existing decommissioning QA program was upgraded to address quality activities conducted during the transition to potential restart, known as the Transition QA Program.
  • Environment Assessment (EA)
  • The NRC staff completed a draft EA to assess environmental impacts of potential restart and meet the National Environmental Policy Act obligation associated with the combined actions.
  • The results of the EA directly inform the outcome and schedule for the NRC licensing reviews.

NRC Regulatory Strategy-QA/Environmental 19

www.holtec.com Palisades Restart - Regulatory Roadmap Development No direct precedent

  • Rule making once proposed, though dispositioned as can be done within existing framework
  • Model for entering decommissioning used to bundle and intertwine the required licensing basis changes

Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, or when a final legally effective order to permanently cease operations has come into effect, the 10 CFR part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.

Interdependent and Connected Licensing & Regulatory Submittals

  • Holtec submitted a set of licensing and regulatory requests in support of the reauthorization of power operations at Palisades through March 24,
2031, License Transfer Application - license transfer into decommissioning evaluated Holtec for decommissioning vice operating authority 20

www.holtec.com Palisades Restart - Regulatory Roadmap Public Meeting with NRC Staff, March 2023

  • Allowed for transparent dialogue, staff questions
  • No formal action for the NRC Exemption Request to 50.82 Submittal, Sept 2023 License Transfer Application Submittal, Dec 2023 Technical Specifications Submittal, Dec 2023 TS Admin Controls Submittal, Feb 2024
  • Notification of Significant Change to PSDAR, April 2024 Emergency Plan Submittal, May 2024 Quality Assurance Plan Submittal, May 2024 21

www.holtec.com Palisades Restart - Regulatory & Project Critical Path Tech Spec Implementation & Operator Licensing

  • Operator licenses formally terminated upon entry into decommissioning, June 2022
  • Simulator reconstitution and restoration of formal licensed operator training, Jan 2024
  • Requalification examinations of 26 previously licensed operators and applications to NRC for restored licenses, May 2024
  • Initial Licensed Operator examinations scheduled for June 2025 Allow staffing (with margin) for operating TS implementation Transition to Power Ops License Basis targeted in Aug 2025 22

www.holtec.com 23

Regulatory Roadmap Exemptions must not present undue risk to the public health and safety Must provide sufficient transparency for public confidence Parallel processes for efficiency Must be repeatable for use by other facilities Prompt application of lessons-learned will be important Address uncertainty related to level of inspection required Consideration of existing license and leverage past reviews (e.g., SEIS)

©Breakthrough Institute 2025 24

Ensuring Safety-The Mission 25

  • The NRC staff developed guidance for oversight of potential restart of operating reactor facilities from decommissioning based on similarities to previous plant restarts from extended shutdown and new reactor startups.
  • IMC 2562 describes the restart panel, transition between oversight processes, and development of an inspection plan.
  • The Director of the Office of Nuclear Reactor Regulation and the applicable Regional Administrator will agree on when to transition oversight to the Reactor Oversight Process after considering the panels recommendation based on inspection results and assessment.

NRC Regulatory Strategy-Oversight 26

Ensuring Safety Critical component of the process Return to operation and licensing basis Current status - defueled. Very low safety risk.

License is still valid Transition to operational status should not increase in risk substantially until testing. That step will be post-approvals.

Uncertainty increases roughly proportional to the decommissioning progress

©Breakthrough Institute 2025 27

www.holtec.com Palisades Restart - Ensuring Safety Reconciling Operational Safety and Quality Before Its Required

  • Implement quality controls early in the project
  • Limit and track all deviations to operational safety and quality requirements
  • Enables NRC inspections to be conducted during project work
  • Reduces the risk of additional analyses and potential rework 28
  • Region III developed a high-level, site-specific inspection plan that describes the types of activities that will be inspected as they relate to the cornerstones of safety.
  • Inspectors and technical experts are executing a detailed, risk-informed inspection schedule to ensure assessment of all key areas of operational readiness.
  • The resident inspector office was restaffed in December 2024.

NRC Regulatory Strategy-Inspection 29

  • Increase focus on return-to-service of high-risk systems that can impact the reactor safety strategic performance area.
  • Review system modifications that can impact operational risk.
  • Address historic equipment, design, and regulatory issues, which include open or deferred items before shutdown.
  • Inspect reestablishment of programs, including the corrective action program and safety culture effectiveness.

NRC Regulatory Strategy-Inspection Activities 30

Creating an Open and Transparent Process 31

  • This project requires coordination of licensing, oversight, and inspection activities (both decommissioning and potential restart).
  • The team leverages expertise across all agency offices.
  • The NRC identified a best practice in early coordination of agency resources and stakeholder interests.

Internal Engagement 32

  • Community outreach with local stakeholders provides clarity on activities for potential restart.
  • The Palisades Restart Panel hosts quarterly public meetings to ensure open and timely communications.
  • A public website provides up-to-date information in one location.

External Outreach 33

www.holtec.com Palisades Restart - Public Outreach and Engagement Validating Support and Ensuring Transparency

  • Open Houses Hiring opportunities Project activities Meet our leaders
  • Participation in NRC Quarterly Public Meeting
  • Tours and Site Visits Photo courtesy of Shawn Connors Photo courtesy of Herald Palladium 34

Public Engagement Public engagement is critical to public acceptance Meaningful two-way communication.

NRC needs to respond with clear and factual responses during public interactions There are larger public engagement challenges that should be addressed by the NRC

©Breakthrough Institute 2025 https://thebreakthrough.org/issues/energy/improving-nuclear-regulatory-commission-public-engagement 35

Future Impacts 36

  • Ensure safety, security, and environmental requirements are met.
  • Use the existing regulatory framework to determine whether to reauthorize operation.
  • Minimize undue regulatory burden by focusing on changes to the plant.
  • Document lessons learned from current efforts for future projects.

Regulatory Entrepreneurship-Focus on Efficiency 37

Future Impacts The NRC does not currently have a defined pathway to transition from decommission status to operational status It is in the public interest to enable this transition Additional facilities are expected to seek restart No significant barriers to this approach A robust pathway is needed to enable consistent and efficient processing A new rulemaking would miss the moment and reduce flexibility

©Breakthrough Institute 2025 38

  • Contact us at PalisadesRestartProject@nrc.gov For Further Information 39
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