ML25175A275

Palisades Nuclear Plant - License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications

ML25175A275
Person / Time
Site:	Palisades
Issue date:	06/24/2025
From:	Fleming J Holtec Palisades
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
PNP2025-040
Download: ML25175A275 (1)

Text

27780 Blue Star Highway, Covert, MI 49043 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 1),

licensed authority will transfer from HDI to Palisades Energy, LLC (Palisades Energy) upon NRCs approval of the transition from decommissioning back to power operations. Holtec Palisades will remain the licensed owner of PNP.

PNP 2025-040 10 CFR 50.90 June 24, 2025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Palisades Nuclear Plant Docket No. 50-255 Renewed Facility Operating License No. DPR-20

Subject:

License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Application for amendment of license, construction permit of early site permit, Holtec1 hereby requests U.S.

Nuclear Regulatory Commission (NRC) review and approval of a license amendment request (LAR) to change the full compliance date for the fire protection program transition license condition in order to allow an extension for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805.

This LAR is to revise the Palisades Nuclear Plant (PNP) Renewed Facility Operating License (RFOL) DPR-20 license condition 2.C.(3) and transition license condition 2.C.(3)(c)2. The approval of this LAR is contingent upon the prior approval of the LAR, dated December 14, 2023 (Reference 2), to reflect the resumption of power operations at PNP, which is currently under NRC review. Holtec requests the NRC to review and approve this LAR by October 24th, 2025.

In Reference 3, Entergy Nuclear Operations (ENO) submitted a LAR to the NRC to adopt new fire protection licensing basis for PNP which complied with the requirements in 10 CFR 50.48, Fire Protection, paragraph (a), 10 CFR 50.48(c), and the guidance in Regulatory Guide 1.205, Revision 1, Risk-Informed, Performance Based Fire Protection for Existing Light-Water Nuclear Power Plants.

In Reference 4, the NRC issued ENO Amendment No. 254 to the PNP RFOL regarding Reference 3 and its supplements.

In Reference 5, ENO submitted a LAR to change the PNP full compliance implementation date for the fire protection program transition license condition 2.C.(3)(c)2.

In Reference 6, the NRC issued ENO Amendment No. 265 to the PNP RFOL regarding Reference 5 and its supplement.

HOLTEC PALISADES

PNP 2025-040 Page 2 of 4 In Reference 7, ENO submitted a LAR to the NRC to clarify and cancel some of the modifications associated with NFPA 805.

In Reference 8, ENO submitted a LAR to the NRC to change the PNP full compliance implementation date for the fire protection program transition license condition 2.C.(3)(c)2.

In Reference 9, the NRC issued ENO Amendment No. 269 to the PNP RFOL regarding Reference 7, Reference 8, and its supplement.

The Enclosure to this letter provides an evaluation of the proposed License Amendment and the significant hazards considerations. Attachment 1 to the Enclosure of this letter provides a marked-up copy of the PNP RFOL pages which are proposed. Attachment 2 to the Enclosure of this letter provides a clean typed copy of the PNP RFOL pages which are proposed.

The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a), Notice for public comment, subparagraph (1), using the standards in 10 CFR 50.92, Issuance of amendment, paragraph (c), and it has been determined that the changes involve no significant hazards consideration.

In accordance with 10 CFR 50.91 (b), State consultation, Holtec is notifying the State of Michigan of this proposed license amendment by transmitting a copy of this letter, with its enclosures, to the designated State of Michigan official.

This letter identifies no new regulatory commitments and no revisions to existing regulatory commitments.

If you have any questions or require additional information, please contact Frank Sienczak, Regulatory Assurance Manager, at 269-764-2263.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 24, 2025.

Respectfully, Jean A.

Fleming Jean 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@Holtec.com Date: 2025.06.24 13:22:12 -04'00' Vice President of Licensing and Regulatory Affairs Holtec International

Enclosure:

Evaluation of the Proposed Change Attachments to

Enclosure:

1) Renewed Facility Operating License Page Markups

PNP 2025-040 Page 3 of 4

2) Operating License Page Change Instructions and Retyped Renewed Operating License Pages References:

1) 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)

2) Holtec Decommissioning International, LLC (HDI) letter to U.S. Nuclear Regulatory Commission (NRC), "License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations," dated December 14, 2023 (ADAMS Accession No. ML23348A148)

3) ENO letter to the NRC, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, dated December 12, 2012 (ADAMS Accession No. ML12348A455)

4) NRC letter, "Palisades Nuclear Plant - Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c) (TAC No. MF0382)," dated February 27, 2015 (ADAMS Accession No. ML15007A191)

5) ENO letter to the NRC, License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications, dated November 1, 2017 (ADAMS Accession No. ML17306A086)

6) NRC letter, " Palisades Nuclear Plant-Issuance of Amendment RE: License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications (EPID L-2017-LLA-0369), dated February 27, 2018 (ADAMS Accession No. ML18039A244)

7) ENO letter to NRC, License Amendment Request to Revise Existing Facility Operating License Conditions Regarding NFPA 805 Modifications, dated November 1, 2018 (ADAMS Accession No. ML18305B320, ML18305B321, ML18305B322, ML18305B323)

8) ENO letter to NRC, License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications, dated March 8, 2019 (ADAMS Accession No. ML19067A004)

9) NRC letter, Palisades Nuclear Plant - Issuance of Amendment No. 269 Regarding Changes to NFPA 805 Modifications and Change to Full Compliance Implementation Date for the Fire Protection Program (EPIDS L-2018-LLA-0296 AND L-2019-LLA-0049), dated August 20, 2019 (ADAMS Accession No. ML19198A080)

PNP 2025-040 Page 4 of 4 cc:

NRC Region III Regional Administrator NRC Senior Resident Inspector - Palisades Nuclear Plant NRC Project Manager - Palisades Nuclear Plant Designated Michigan State Official

Enclosure to PNP 2025-040 Evaluation of the Proposed Change 7 pages follow

Enclosure to PNP 2025-040 Page 2 of 8 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 10),

licensed authority will transfer from HDI to Palisades Energy, LLC (Palisades Energy) upon NRCs approval of the transition from decommissioning back to power operations. Holtec Palisades will remain the licensed owner of PNP.

EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION The proposed amendment would modify the Palisades Nuclear Plant (PNP) Renewed Facility Operating License (RFOL) DPR-20 by revising the full compliance date for the fire protection program transition license condition to allow an extension for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805. The proposed amendment is contingent upon the prior approval of the license amendment request (LAR), December 14, 2023 (Reference 11), to reflect the resumption of power operations at PNP, which is currently under U.S. Nuclear Regulatory Commission (NRC) review. The requested change involves no significant hazards consideration.

2.0 DETAILED DESCRIPTION 2.1 Reason for the Proposed Change In Reference 1, the NRC issued Entergy Nuclear Operations, Inc. (ENO) Amendment No. 254 to the PNP RFOL for transition to a risk-informed, performance-based fire protection program in accordance with 10 CFR 50.48(c). In Reference 2, Holtec1 requested the NRC approve an amendment to the PNP RFOL to support resumption of power operations at PNP. In Reference 3, ENO submitted a license amendment request (LAR) to change the full compliance implementation date for the fire protection program transition license condition for required modifications. In Reference 4, the NRC issued the safety evaluation for Reference 3. In Reference 5, ENO submitted a LAR to change the PNP full compliance implementation date for the fire protection program transition license condition 2.C.(3)(c)(2). In Reference 6, the NRC issued ENO Amendment No. 265 to the PNP RFOL regarding Reference 5 and its supplement.

In Reference 7, ENO submitted a LAR to the NRC to clarify and cancel some of the modifications associated with NFPA 805. In Reference 8, ENO submitted a LAR to the NRC to change the PNP full compliance implementation date for the fire protection program transition license condition 2.C.(3)(c)(2). In Reference 9, the NRC issued ENO Amendment No. 269 to the PNP RFOL regarding Reference 7, Reference 8, and its supplement.

Holtec Palisades expects to complete the remaining NFPA 805 modifications prior to the restart of the Palisades Nuclear Plant in the Fall of 2025. Two of the modifications that were previously identified as having a medium risk impact were reviewed during the planning of plant changes to implement Table S2 under the current risk model as having no more than minimal risk impact to core damage frequency (CDF), as summarized below.

Enclosure to PNP 2025-040 Page 3 of 8 Table S2-13, component cooling water (CCW) Heat Exchangeer Temperature Control Valve modification, probabilistic risk assessment (PRA) demonstrates a minimal risk reduction under the current PRA model with a Delta CDF <1E-08/yr.

Table S2-15, Reactor /Pressurizer Head Vent Valve Modification also demonstrated a negligible risk reduction under the current PRA model with a Delta CDF <1E-11/yr.

Holtec Palisades is proposing a revision to the full compliance date for the fire protection program transition license condition to allow an extension of the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c) to further assess the need to complete the two modifications that demonstrate a reduced risk significance.

2.2 Description of Proposed Change Holtec proposes to revise the PNP RFOL fire protection program license condition 2.C.(3) and transition license condition 2.C.(3)(c)2.

Currently, license condition 2.C.(3) proposed per Reference 2 reads as follows:

3.

[Palisades Energy] shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated December 12, 2012, November 1, 2017, November 1, 2018, and March 8, 2019, as supplemented by letters dated February 21, 2013, September 30, 2013, October 24, 2013, December 2, 2013, April 2, 2014, May 7, 2014, June 17, 2014, August 14, 2014, November 4, 2014, December 18, 2014, January 24, 2018, and May 28, 2019, as approved in the safety evaluations dated February 27, 2015, February 27, 2018, and August 20, 2019. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Holtec is proposing to revise the license condition 2.C.(3) to make reference to this license amendment request, dated June 24, 2025, and subsequent NRC safety evaluation.

Holtec is proposing to revise the license condition 2.C.(3) as follows:

3.

[Palisades Energy] shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated December 12, 2012, November 1, 2017, November 1, 2018, March 8, 2019, and June 24, 2025, as supplemented by letters dated February 21, 2013, September 30, 2013, October 24, 2013, December 2, 2013, April 2, 2014, May 7, 2014, June 17, 2014, August 14, 2014, November 4, 2014, December 18, 2014, January 24, 2018, and May 28, 2019, as approved in the safety evaluations dated February 27, 2015, February 27, 2018, August 20, 2019, and XXX. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require

Enclosure to PNP 2025-040 Page 4 of 8 prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Currently, transition license condition 2.C.(3)(c)(2) proposed per Reference 2 reads as follows:

2. The licensee shall implement the modifications to its facility, as described in Table S-2, Plant Modifications Committed, of Entergy Nuclear Operations, Inc.

(ENO) letter PNP 2019-028 dated May 28, 2019, to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the refueling outage following the fourth full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

The current transition license condition would require Holtec to fully implement the NFPA 805 modifications before the end of 1R28. Holtec is proposing to revise the transition license condition 2.C.(3)(c)2 as follows:

2. The licensee shall implement the modifications to its facility, as described in Table S-2, Plant Modifications Committed, of Entergy Nuclear Operations, Inc.

(ENO) letter PNP 2019-028 dated May 28, 2019, to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the refueling outage following the fifth full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

The proposed transition license condition would require the NFPA 805 modifications to be fully implemented before the end of the planned refueling outage scheduled for Spring 2027.

3.0 TECHNICAL EVALUATION

Due to the planned restart of the Palisades Nuclear Plant in 2025, Holtec is proposing a revision of the full compliance date for the fire protection program transition license condition to allow an extension for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c).

Holtecs approach to the implementation of NFPA 805 modifications at PNP has been to install all remaining modifications prior to the end of the current refueling outage (Fall 2025) which will result in restart of the plant. Two of the modifications have been reassessed to demonstrate a reduced risk to core damage frequency and that would no longer require implementation and therefore would not be installed prior to the end of the current refueling outage. All other remaining modifications are planned and funded to be completed prior to the end of the current refueling outage.

In addition, the proposed change has no impact on the defense-in-depth (DID) echelons, which are: (1) prevent fires from starting, (2) rapidly detect, control, and extinguish promptly those fires that do occur thereby preventing fire damage, and (3) provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being

Enclosure to PNP 2025-040 Page 5 of 8 performed, because changing the full compliance implementation date for fire protection program transition license condition 2.C.(3)(c)2 is not considered a change in methods. The proposed schedule change does not impact the level of fire protection provided so that a fire will not prevent essential safety functions from being performed.

The proposed change continues to maintain adequate safety margins because the change does not impact any codes and standards, or their alternatives accepted for use by the NRC, and because the change does not impact any safety analysis acceptance criteria in the licensing basis.

Therefore, this extension is acceptable given that the majority of the planned modifications characterized as High risk have already been installed, most of the remaining modifications will be installed prior to the end of the restart refueling outage (Fall 2025), and the fire protection transition license conditions that remain in effect during this period, including the continuation of compensatory measures. This proposed change is administrative in nature and has no impact on DID echelons or safety margins. Additionally, the license condition for making risk-informed changes without prior NRC approval is not effective until Holtec has implemented all of the NFPA 805 modifications and PNP is in full compliance with 10 CFR 50.48(c).

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria On July 16, 2004, the NRC amended 10 CFR 50.48, Fire Protection, to add a new subsection, 10 CFR 50.48(c), which establishes alternative fire protection requirements. 10 CFR 50.48 endorses, with exceptions, NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition (NFPA 805), as a voluntary alternative for demonstrating compliance with 10 CFR 50.48 Section (b), concerning Appendix R, and Section (f), concerning decommissioning.

The voluntary adoption of 10 CFR 50.48(c) by Holtec does not eliminate the need to comply with 10 CFR 50.48(a) and 10 CFR 50, Appendix A, and General Design Criteria (GDC) 3, Fire Protection. The new rule provides actions that may be taken to establish compliance with 10 CFR 50.48(a), which requires each operating nuclear power plant to have a fire protection program plan that satisfies GDC 3, as well as specific requirements in that section. The transition process described in 10 CFR 50.48(c)(3)(ii) provides, in pertinent parts, that a licensee intending to adopt the new rule must, among other things, "modify the fire protection plan required by paragraph (a) of that section to reflect the licensee's decision to comply with NFPA 805." Therefore, to the extent that the contents of the existing fire protection program plan required by 10 CFR 50.48(a) is inconsistent with NFPA 805, the fire protection program plan must be modified to achieve compliance with the requirements in NFPA 805. All other requirements of 10 CFR 50.48(a) and GDC 3 have corresponding requirements in NFPA 805.

4.2 No Significant Hazards Consideration Analysis Holtec has evaluated the proposed changes to the RFOL DPR-20 using the criteria in 10 CFR 50.92, Issuance of amendment, and has determined that the proposed changes do not involve a significant hazard consideration.

Holtec is requesting an amendment to the Palisades Nuclear Plant (PNP) renewed facility operating license (RFOL) to revise the full compliance date for the fire protection program

Enclosure to PNP 2025-040 Page 6 of 8 transition license condition to allow an extension for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c).

Basis for no significant hazards consideration determination: as required by 10 CFR 50.91(a),

Notice for public comment, Holtec analysis of the issue of no significant hazards consideration is presented below:

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change to the PNP RFOL to change the full compliance date for the fire protection program transition license condition to allow additional time for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c) is administrative in nature. This change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents and has no impact on the probability or consequences of an accident previously evaluated.

Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change to the PNP RFOL to change the full compliance date for the fire protection program transition license condition to allow additional time for the implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c) is administrative in nature. This proposed change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents and does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Therefore, this change does not create the possibility of a new or different kind of accident from an accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change to the PNP RFOL to change the full compliance implementation date for the fire protection program transition license condition to allow additional time for

Enclosure to PNP 2025-040 Page 7 of 8 implementation of the remaining modifications necessary to achieve full compliance with 10 CFR 50.48(c) is administrative in nature. Plant safety margins are established through limiting conditions for operation, limiting safety system settings, and safety limits specified in the technical specifications. Because there is no change to established safety margins as a result of this change, the proposed change does not involve a significant reduction in a margin of safety.

Therefore, this change does not involve a significant reduction in a margin of safety.

4.3 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION The proposed change revises the PNP RFOL to change the NFPA 805 full compliance implementation date for the fire protection program transition license condition associated with implementation of NFPA 805 modifications. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 REFERENCES

1.

NRC letter, Palisades Nuclear Plant - Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c) (TAC No. MF0382), dated February 27, 2015 (ADAMS Accession No. ML15007A191)

2.

Holtec Decommissioning International, LLC (HDI) letter to U.S. Nuclear Regulatory Commission (NRC), "License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations," dated December 14, 2023 (ADAMS Accession No. ML23348A148)

3.

ENO letter, License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications, dated November 1, 2017 (ADAMS Accession No. ML17306A086)

4.

NRC letter, Palisades Nuclear Plant - Issuance of Amendment RE: License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications (EPID L-2017-LLA-0369),

dated February 27, 2018 (ADAMS Accession No. ML18039A244)

Enclosure to PNP 2025-040 Page 8 of 8

5.

ENO letter to the NRC, License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications, dated November 1, 2017 (ADAMS Accession No. ML17306A086)

6.

NRC letter, " Palisades Nuclear Plant-Issuance of Amendment RE: License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications (EPID L-2017-LLA-0369),

dated February 27, 2018 (ADAMS Accession No. ML18039A244)

7.

ENO letter to NRC, License Amendment Request to Revise Existing Facility Operating License Conditions Regarding NFPA 805 Modifications, dated November 1, 2018 (ADAMS Accession No. ML18305B320, ML18305B321, ML18305B322, ML18305B323)

8.

ENO letter to NRC, License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications, dated March 8, 2019 (ADAMS Accession No. ML19067A004)

9. NRC letter, Palisades Nuclear Plant - Issuance of Amendment No. 269 Regarding Changes to NFPA 805 Modifications and Change to Full Compliance Implementation Date for the Fire Protection Program (EPIDS L-2018-LLA-0296 AND L-2019-LLA-0049), dated August 20, 2019 (ADAMS Accession No. ML19198A080)

10. 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)

11. Holtec Decommissioning International, LLC (HDI) letter to U.S. Nuclear Regulatory Commission (NRC), "License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations," dated December 14, 2023 (ADAMS Accession No. ML23348A148)

ATTACHMENTS

1. Renewed Facility Operating License Page Markups

2. Operating License Page Change Instructions and Retyped Renewed Operating License Pages

Enclosure Attachment 1 to PNP 2025-040 Renewed Facility Operating License Page Markups 4 pages follow Renewed License No. DPR-20 Amendment No. 272, 273, XXX (2)

[Palisades Energy], pursuant to the Act and 10 CFR Parts 40 and 70, to receive,

possess and use source and special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3)

[Palisades Energy], pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use byproduct, source and special nuclear material as sealed sources for reactor startup, reactor instrumentation radiation monitoring equipment calibration, and that were used as fission detectors in amounts as required; (4)

[Palisades Energy], pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material for sample analysis or instrument calibration, or associated with radioactive apparatus or components; and (5)

[Palisades Energy], pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operations of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act; to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

[Palisades Energy] is authorized to operate the facility at steady-state reactor core power levels not in excess of 2565.4 Megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2)

The Technical Specifications contained in Appendix A, as revised through Amendment No. XXX, and the Environmental Protection Plan contained in Appendix B are hereby incorporated in the license. [Palisades Energy] shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Fire Protection

[Palisades Energy] shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated December 12, 2012, November 1, 2017, November 1, 2018, and March 8, 2019, and June 24, 2025, as supplemented by letters dated February 21, 2013, September 30, 2013, October 24, 2013, December 2, 2013, April 2, 2014, May 7, 2014, June 17, 2014, August 14, 2014, November 4, 2014, December 18, 2014, January 24, 2018, and May 28, 2019, as approved in the safety evaluations dated February 27, 2015, February 27, 2018, and August 20, 2019, and XXX. Except where NRC approval for changes or

Renewed License No. DPR-20 Amendment No. 272, 273, XXX deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

(a)

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1.

Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

2.

Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b)

Other Changes that May Be Made Without Prior NRC Approval 1.

Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard.

The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical Page included for continuity [

]

Renewed License No. DPR-20 Amendment No. 272, 273, XXX requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is adequate for the hazard. Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

Fire Alarm and Detection Systems (Section 3.8);

Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and

Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2.

Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated February 27, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

(c)

Transition License Conditions 1.

Before achieving full compliance with 10 CFR 50.48(c), as Page included for continuity

(

]

Renewed License No. DPR-20 Amendment No. 272, 273, XXX specified by 2, below, risk-informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2.

The licensee shall implement the modifications to its facility, as described in Table S-2, Plant Modifications Committed, of Entergy Nuclear Operations, Inc. (ENO) letter PNP 2019-028 dated May 28, 2019, to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the refueling outage following the fifth fourth full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3.

The licensee shall implement the items listed in Table S-3, Implementation Items, of ENO letter PNP 2014-097 dated November 4, 2014, within six months after NRC approval, or six months after a refueling outage if in progress at the time of approval with the exception of Implementation Items 3 and 8 which will be completed once the related modifications are installed and validated in the PRA model.

(4)

[deleted]

(5)

[deleted]

(6)

Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

a.

Fire fighting response strategy with the following elements:

1.

Pre-defined coordinated fire response strategy and guidance 2.

Assessment of mutual aid fire fighting assets 3.

Designated staging areas for equipment and materials 4.

Command and control 5.

Training of response personnel b.

Operations to mitigate fuel damage considering the following:

1.

Protection and use of personnel assets 2.

Communications 3.

Minimizing fire spread 4.

Procedures for implementing integrated fire response strategy 5.

Identification of readily-available pre-staged equipment 6.

Training on integrated fire response strategy 7.

Spent fuel pool mitigation measures c.

Actions to minimize release to include consideration of:

1.

Water spray scrubbing 2.

Dose to onsite responders

Enclosure Attachment 2 to PNP 2025-040 Operating License Page Change Instructions and Retyped Renewed Facility Operating License Pages 3 pages follow

Page Change Instructions ENCLOSURE ATTACHMENT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-20 DOCKET NO. 50-255 Remove the following pages of the renewed facility operating license (RFOL) and replace them with the attached revised pages. The revised pages are identified by amendment number and contain a line in the margin indicating the area of change.

RFOL pages:

REMOVE INSERT RFOL pages 3, and 6 RFOL pages 3, and 6 Renewed License No. DPR-20 Amendment No. 272, 273, XXX (2)

[Palisades Energy], pursuant to the Act and 10 CFR Parts 40 and 70, to receive,

possess and use source and special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3)

[Palisades Energy], pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use byproduct, source and special nuclear material as sealed sources for reactor startup, reactor instrumentation radiation monitoring equipment calibration, and that were used as fission detectors in amounts as required; (4)

[Palisades Energy], pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material for sample analysis or instrument calibration, or associated with radioactive apparatus or components; and (5)

[Palisades Energy], pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operations of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act; to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

[Palisades Energy] is authorized to operate the facility at steady-state reactor core power levels not in excess of 2565.4 Megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2)

The Technical Specifications contained in Appendix A, as revised through Amendment No. XXX, and the Environmental Protection Plan contained in Appendix B are hereby incorporated in the license. [Palisades Energy] shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Fire Protection

[Palisades Energy] shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated December 12, 2012, November 1, 2017, November 1, 2018, March 8, 2019, and June 24, 2025, as supplemented by letters dated February 21, 2013, September 30, 2013, October 24, 2013, December 2, 2013, April 2, 2014, May 7, 2014, June 17, 2014, August 14, 2014, November 4, 2014, December 18, 2014, January 24, 2018, and May 28, 2019, as approved in the safety evaluations dated February 27, 2015, February 27, 2018, August 20, 2019, and XXX. Except where NRC approval for changes or Renewed License No. DPR-20 Amendment No. 272, 273, XXX specified by 2, below, risk-informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2.

The licensee shall implement the modifications to its facility, as described in Table S-2, Plant Modifications Committed, of Entergy Nuclear Operations, Inc. (ENO) letter PNP 2019-028 dated May 28, 2019, to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the refueling outage following the fifth full operating cycle after NRC approval. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3.

The licensee shall implement the items listed in Table S-3, Implementation Items, of ENO letter PNP 2014-097 dated November 4, 2014, within six months after NRC approval, or six months after a refueling outage if in progress at the time of approval with the exception of Implementation Items 3 and 8 which will be completed once the related modifications are installed and validated in the PRA model.

(4)

[deleted]

(5)

[deleted]

(6)

Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

a. Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel

b. Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures

c. Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders

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