IR 05000255/2025002
| ML25140A945 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/21/2025 |
| From: | April Nguyen NRC/RGN-III/DORS |
| To: | Mlynarek M Holtec Decommissioning International |
| References | |
| IR 2025002 | |
| Download: ML25140A945 (1) | |
Text
SUBJECT:
PALISADES NUCLEAR PLANT - RESTART INSPECTION REPORT 05000255/2025002
Dear Mike Mlynarek:
On April 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Palisades Nuclear Plant. The enclosed inspection report documents the inspection results, which the inspectors discussed on May 13, 2025, with yourself and other members of your staff.
No violations of more than minor significance were identified during this inspection.
On June 13, 2022, Palisades ceased permanent power operations and subsequently removed all fuel from the reactor, as detailed in the letter from Entergy to the NRC, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, (ADAMS Accession No. ML22164A067). On September 28, 2023, Holtec Decommissioning International, LLC (Holtec) submitted a letter to the NRC requesting exemptions from certain portions of the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(2) to pursue the potential reauthorization of power operations at Palisades (ADAMS Accession No. ML23271A140). The NRCs initial acceptance to review Palisades request for exemptions was documented in ADAMS at Accession No. ML23291A440 on November 3, 2023.
May 21, 2025 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, April M. Nguyen, Lead Palisades Restart Team Division of Operating Reactor Safety Docket No. 05000255 License No. DPR-20 Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Nguyen, April on 05/21/25
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) performed inspections of the licensees activities to verify that the reactor coolant system boundary, reactor vessel head, and risk-significant piping system boundaries are appropriately monitored for degradation and that required repairs and replacements are appropriately examined and accepted; systems, structures, and components (SSCs) are appropriately inspected, maintained, and tested to ensure they can perform their required safety functions for potential restart; the licensed operator requalification training program and operator performance are appropriately performed; and radiation safety activities are appropriately performed.
List of Findings and Violations
None.
Additional Tracking Items
None.
PLANT STATUS
The Palisades Nuclear Plant ceased power operations and subsequently removed all fuel from the reactor, as certified in a letter to the NRC on June 13, 2022. On September 28, 2023, Holtec Decommissioning International, LLC (Holtec) submitted a letter to the NRC requesting exemptions from certain portions of the requirements of 10 CFR 50.82(a)(2) to pursue the potential reauthorization of power operations. The NRC is conducting inspections to evaluate and assess the licensees activities for potential restoration to an operational status.
The resident inspectors, as well as supplemental inspectors, continue to supply daily oversight of the restart activities occurring at the site.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the referenced inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
REACTOR SAFETY
71111.08P - Inservice Inspection Activities (PWR)
From April 28, 2025, to May 1, 2025, the inspectors observed and verified Holtec Palisades nondestructive examination (NDE) and repair/replacement activities of the reactor vessel closure head, Alloy 600 weld mitigation activities, and steam generator in-situ pressure testing, conducted in accordance with the requirements of the ASME Code Section XI. The purpose of these inspections was to verify that the reactor coolant system boundary, reactor vessel closure head, steam generators, and risk-significant piping system boundaries are appropriately monitored for degradation. The inspectors also verified that the examination results were thoroughly reviewed and appropriately evaluated, and that required corrective actions to address identified indications and defects will be appropriately implemented. During this quarter, the licensee completed NDE activities and evaluation of data for the reactor vessel closure head, steam generator tubes, and Alloy 600 welds in the primary coolant system and continued repair/replacement activities in all areas. Further NRC inspections will monitor repair/replacement activities as they are conducted.
The inspectors verified that the following NDE and repair/replacement activities were conducted appropriately per the ASME Code or required standard, and that any potential indications and defects were identified and evaluated at the proper thresholds:
Nondestructive Examination and Welding Activities (IP Section 03.01)
- Safety Injection Cold Leg 1A&B and 2A&B Alloy 600 mitigation Weld Overlay Fabrication
- Reactor Vessel Internal (RVI) indications analysis and NDE procedures Vessel Upper Head Penetration Inspection Activities (IP Section 03.02)
- Alloy 690 reactor head repair nozzle Mill Report and receipt inspection data Steam Generator Tube Inspection Activities (IP Section 03.04)
- Steam generator A in-situ pressure test
- Steam generator A test of sleeving repair methodology and Eddy Current examinations
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program and Licensed Operator Performance
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from February 25, 2025, to March 28, 2025.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Low pressure A and B main turbine rotor lift activities on April 11, 2025
- (2) Primary coolant pump B lift activities on April 1, 2025
- (3) Steam generator A nozzle dam installation and primary coolant system inventory control activities on April 18,
RADIATION SAFETY
Radiation Safety - Occupational From April 21 to April 25, 2025, the inspectors evaluated various ongoing radiologically risk-significant work evolutions, including steam generator primary side work and reactor head work. For these work evolutions, the inspectors observed activities such as extremity dosimetry issuance and use, respiratory protection issuance and use, use of temporary ventilation systems, high radiation area and radiation work permit briefings, and radiation protection job coverage. The inspectors also walked down the auxiliary building and containment to observe radiological postings and controls. The inspectors also reviewed various dose assessments for previous work activities. This review included quality control procedures and records for use of the whole-body counter, whole body count results, internal dose assessments, evaluation of multiple dosimetry use, and evaluation of effective dose equivalence use and calculations.
The inspectors conducted these reviews using IP 71124.01, Radiological Hazard Assessment and Exposure Controls, IP 71124.03, In-Plant Airborne Radioactivity Control and Mitigation, and IP 71124.04, Occupational Dose Assessment, as applicable.
OTHER BASELINE ACTIVITIES
71152 - Problem Identification and Resolution
System Return to Service During the inspection period, the inspectors continued reviews of Phases I and II of the licensees system return to service (SRTS) plans. The SRTS plans document licensee activities to verify that the configuration and condition of Systems, Structures, and Components (SSCs)are consistent with the design and licensing bases to support potential restart. The inspectors reviewed Phases I and II of the SRTS plans, which include areas such as licensing and design-basis functions, system material conditions, reviewing open and deferred work prior to shutdown, and program applicability. The inspectors conducted these reviews using IP 71152, Problem Identification and Resolution, and IP 71111.21M, Comprehensive Engineering Team Inspection (CETI), as applicable.
The inspectors commenced reviews of the SRTS plans for the following systems:
- Containment building and miscellaneous equipment
- Containment purge
- Chemical and volume control
- Circulating water
- High pressure safety injection
- Instrument air and service air
- Main feedwater
- Primary coolant
- Pressurizer pressure and level control
- Safety injection and refueling water tank and containment sump
- Safety injection tanks
- Radiation Monitoring System The inspectors completed initial reviews of the SRTS plans for the following systems:
- Containment and Fuel Pool Cranes
- Control rod drive
- Control room heating, ventilation, and air conditioning (HVAC)
- Dry fuel storage
- Reactor cavity flood
- Spent fuel pool cooling
- Ultimate heat sink These systems were selected based on the importance of the SSCs during normal and emergency plant operating conditions, risk significance and defense-in-depth of the SSCs specific functions and required work/modifications of the SSCs scheduled prior to potential restart.
The inspectors evaluated the initial SRTS plans for each system to identify if planned licensee activities will verify that the configuration and condition of the SSCs are consistent with the proposed operational design and licensing bases to support restart and verify readiness of the SSCs to support a return to service. The inspectors noted that the SRTS plans are intended to be living documents with a phased approach to SRTS. The initial plans were determined to be at a very high level and did not always provide specific details associated with inspection or testing plans. The inspectors understood that this specific level of detail is still in progress and, as the licensee progresses through the SRTS phases, the SRTS plans will undergo additional reviews by NRC inspector to ensure appropriate SSC restoration and operability/functionality.
INSPECTION RESULTS
No additional inspection results.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 13, 2025, the inspectors presented the inspection results to M. Mlynarek, Site Vice President, and other members of the licensee staff.
- On April 14, 2025, the inspectors presented the licensed operator requalification program inspection results to C. Sizemore, Operations Training Superintendent, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
25-0473
A Minor Correction to NDE Report HLSC-350-00-PT-002
Concerning the Material Type
2/21/2025
03-601600
Operating Instructions for In Situ Pressure Testing
010
Procedures
55-OI0033-022
Ambient I.D.T.B Welding of CEDM/CET Penetration of
Reactor Vessel Closure Head Utilizing Modified Local Cavity
Weld Head
03/19/2025
24018714
Framatome Purchase Order QA Data Package SB-167 UNS
N06690 Seamless Tubing
007
Shipping Records
38001288
Holtec Purchase Order QA Data Package for Replacement
CRDM Nozzles and Replacement ICI Nozzles
001
FHS-M-23
Movement of Heavy Loads in the Spent Fuel Pool Area
Revision 42
FHS-M-24
Movement of Heavy Loads in the Containment Building Area
Revision 42
MSM-M-72
Movement of Heavy Loads in the Turbine Building
Revision 42
Procedures
RFL-SG-2
S/G Primary Nozzle Dam Installation and Removal
Revision 11
Work Orders
E-50A INSTALL/REMOVE NOZZLE DAMS PER RFL-SG-2
04/18/2025
250454
ALARA Plans
250454
25-0802
A Steam Generator Platform Survey
04/19/2025
Radiation Surveys
25-0816
A Steam Generator Platform Survey
04/21/2025
250450
Reactor Head, Nozzle Machining, Nozzle Replacement,
Decon and Associated Tasks
Radiation Work
Permits (RWPs)
250454
Steam Generator Primary Side Activities
Miscellaneous
N/A
Grade D breathing Air Quality Test
04/17/2025
N/A
Internal Dose Assessment
09/06/2024
Miscellaneous
N/A
Internal Dose Assessment
09/08/2024
Whole-Body Counting/In-Vitro Bioassay
Procedures
HP 8.11
Whole-Body Counting
Calculations
GWO-
6861CALC2
Proposed Repair Program for the Auxiliary Building SIRW Tank
Cellular Slab at Palisades Nuclear Power Plant
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PAL-05382
Main Control Roof Cellular Slab
2/11/2025
Corrective Action
Documents
PAL-05888
Typographical Error in Report to NRC
03/11/2025
Engineering
Evaluations
PLP-RPT-18-0024
1R26 Refueling Outage Safety Related Containment Coating
Assessment Report
2/06/2019
PLP-SRTSP-CLC
Containment and Fuel Pool Cranes
Draft B
PLP-SRTSP-CLP
Containment Building and Miscellaneous Equipment
Draft B
PLP-SRTSP-CPG
Containment Purge
Draft A
PLP-SRTSP-CRD
Control Rod Drive
Draft A
PLP-SRTSP-CRV
Control Room HVAC
Draft A
PLP-SRTSP-CSS
Containment Spray System
Draft A
PLP-SRTSP-
CVC-CBA
Chemical and Volume Control
Draft A
PLP-SRTSP-CWS
Circulating Water
Draft B
PLP-SRTSP-DFS
Dry Fuel Storage
Draft A
PLP-SRTSP-HPI
High Pressure Safety Injection
Draft A
PLP-SRTSP-IAS
Instrument Air and Service Air
Draft A
PLP-SRTSP-
Main Feedwater
Draft A
PLP-SRTSP-PCS
Primary Coolant
Draft A
PLP-SRTSP-PZR
Pressurizer Pressure and Level Control
Draft A
PLP-SRTSP-RCF
Reactor Cavity Flood
Draft A
PLP-SRTSP-RIA
Radiation Monitoring System Return-To-Service Plan
Draft A
PLP-SRTSP-SFP
Spent Fuel Pool Cooling
Draft A
PLP-SRTSP-SIT
Safety Injection Tanks
Draft A
PLP-SRTSP-SSS
SIRW and Containment Sump system
Draft A
PLP-SRTSP-UHS
Draft A
Miscellaneous
50-Year Containment Tendon Surveillance Inspection
Summary Report
03/03/2025
EA-CAP-047706-
01/0
Palisades Reactor Head Drop Analysis
2/02/2006
MSM-M-13A/9
L-1 Periodic Inspection
09/28/2023
MSM-M-13B/11
L-2 Periodic Inspection
2/05/2024
Procedures
MSM-M-13C/11
L-3 Periodic Inspection
05/13/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
WI-MA-349/0
L-2 Periodic Inspection for Electrical and Mechanical
Components
2/18/2024
Work Orders
WO 50083288-01-
001
Containment Polar Crane
10/17/2023