ML25231A149

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Slides - External - Palisades Restart Informational Briefing - August 21, 2025 - Sc
ML25231A149
Person / Time
Site: Palisades 
Issue date: 08/21/2025
From:
Division of Operating Reactor Licensing
To: Quynh Nguyen
Advisory Committee on Reactor Safeguards
References
Download: ML25231A149 (1)
v • d • e


Text

Palisades Restart Informational Briefing August 21, 2025 Advisory Committee on Reactor Safeguards Full Committee Meeting

Agenda

  • Restart Evaluation Process
  • Update on Licensing Actions
  • Status of Inspection Activities
  • Palisades Restart Activities
  • Update on Inspection and Technical Topics of Interest 1

Licensing Basis and Actions Palisades Restart Marlayna Doell, Project Manager Palisades Restart NRR/DORL 2

Evaluation Criteria for Restart

  • Leveraged existing operating license to make changes under normal NRC processes (i.e., amendments and exemptions)
  • General approach was to review requested changes for consistency with previous licensing basis and focus on any areas of change from previous approaches or analyses
  • Focus on meeting the same safety, security, and environmental requirements that were applicable to the previously operating plant, with changes as needed 3

Licensing Actions Completed

  • July 24, 2025 - Issued the licensing bundle to restore the operational licensing basis at Palisades

- License transfer, exemption, four license amendments

  • August 25 - Planned implementation date for the bundle

- Will serve as the official transition date from decommissioning to operations for licensing, inspections to the ROP, fee billing, etc.

  • Post-August 25 - Palisades will continue restart activities under the operational TS requirements 4

Submittal Licensing Action Implementation Sept. 28, 2023 Exemption from 10 CFR 50.82(a)(2)

Aug. 25, 2025 Dec. 6, 2023 License Transfer Jul. 24, 2025 Dec. 14, 2023 Operating License Technical Specifications Aug. 25, 2025 Feb. 9, 2024 Operating License Administrative Technical Specifications Aug. 25, 2025 May 1, 2024 Emergency Plan Aug. 25, 2025 May 23, 2024 Quality Assurance Plan (supplement to license transfer)

Aug. 25, 2025 May 24, 2024 Update to MSLB Analysis Methodology Aug. 25, 2025 Licensing Actions Bundle 5

Licensing Actions in Progress

  • Relief Requests for Certain ISI Activities 6

The NRC conducted numerous public meetings throughout the potential restart project, allowing the opportunity to speak directly to NRC inspectors and technical staff. Additional meetings are still underway for the items still under review.

0 5

10 15 20 25 Public Meetings Inspection Reports Licensing Actions NRC Actions Since 2023 The NRC dedicates over 35 direct staff hours to each public meeting 7

Public Outreach 49%

38%

13%

Inspections Licensing Reviews Public Meetings

Steam Generators Palisades Restart Paul Klein, Senior Materials Engineer Corrosion and Steam Generator Branch NRR/DNRL 8

Special Technical Topic - Steam Generators Combustion Engineering Model 2530 Steam Generators (SGs)

8219 tubes per SG, installed in 1990

Alloy 600 mill annealed tubing

Nominal 0.75 inch diameter, 0.042 inch wall thickness

Rows 1-18 U-bend, Rows19-138 square bend design

Horizontal stainless steel lattice type eggcrate support plates September 3, 2024 phone call between NRC Staff and Holtec to discuss ongoing SG inspections (ML24267A296). Palisades experienced significant increase in axial outside diameter stress corrosion cracking indications (ODSCC) at the eggcrate supports.

The NRC released a Preliminary Notification on September 18, 2024 (ML24262A092)

During 2025, in-situ pressure testing (ISPT) of 17 tubes in SG A and 5 tubes in SG B was performed to confirm tube integrity as part of condition monitoring.

All tubes passed ISPT.

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Special Technical Topic - Steam Generators

  • The licensee submitted an LAR in Feb. 2025 requesting approval for use of a Framatome Alloy 690 leak limiting sleeve to repair hot leg support plate ODSCC locations. This LAR is under review, RAI responses (ML25211A324, public)
  • NRC technical staff performed an audit at Framatome in May 2025 to better understand the sleeve design, installation process, and eddy current qualification work
  • Sleeve installation (in lieu of tube plugging) would maintain the SGs heat transfer capability to operate Palisades at full power 10

Emergency Preparedness Palisades Restart Jeffrey Herrera, Senior EP Specialist Reactor Licensing Branch NSIR/DPR 11

Emergency Preparedness Timeline Palisades shutdown May 2022 Entergy certified permanent cessation of operations June 2022 Decommissioning emergency plan approved Dec 2023 License amendment request to restore operating emergency plan May 2024 Operating emergency plan approved with license condition July 2025 Emergency exercise with offsite participation (NRC and FEMA evaluation)

July 2025 12

Holtec Emergency Plan Request

  • License amendment request

- Restore operating emergency plan prior to shutdown revision 32 (using NUREG-0654, Rev. 2)

- Restore emergency action level scheme prior to shutdown (using NEI 99-01, rev. 5)

  • Requested timeline

- May 1, 2024 - license amendment request submitted.

- Holtec requested completion prior to fuel load (4th Quarter 2025) 13

Emergency Plan Requirements License Amendment

  • NRC Regulatory requirements

- 10 CFR 50.47 and Appendix E

  • 16 planning standards
  • Applicable sections of Appendix E
  • Guidance Documents:

- NUREG-0654/FEMA REP-1 Revision 2 Criteria for Preparation and Evaluation of Radiological Emergency response Plans and Preparedness in Support of Nuclear Power Plants (ML19347D139)

- NEI 99-01 Development of Emergency Action Levels for Non-Passive Reactors Revision 5 and 6 (one EAL)

[ML080450149 and ML12326A805 respectively]

  • Additional regulatory requirements

- Submit updated annual population estimate (Part 50 Appendix E.IV.5)

- FEMA requirements under 44 CFR 350

- FEMA to review offsite emergency plans and evaluate offsite actions during exercise

- FEMA reviews the alert and notification system design report and submits results to the NRC 14

Emergency Plan Review

  • Reactor Licensing Branch (RLB) staff reviewed Holtecs emergency plan in two parts:

- Review of the emergency plan

- Review of the emergency action levels (EALs)

- Review of submitted emergency plan using guidance. Previous emergency plan (Rev. 32) was compared to ensure there were no additional changes.

- NUREG-0654/FEMA REP-1 Revision 2

- Reviewed submitted emergency action levels using NEI Guidance document 99-01, Revision 5

  • FEMA Interim finding

- FEMA provided an interim finding to the NRC on June 27, 2025, which allowed the NRC to issue the license amendment with a license condition pending a FEMA final finding of reasonable assurance 15

Emergency Plan Deviations

  • Emergency Action Levels (EALs)

- Added EALs to address lessons learned from Fukushima added to NEI 99-01, Revision 6

- Modified EAL associated with Independent spent fuel storage installation (based on draft NEI 99-01, Revision 7)

- Three deviations from NUREG-0654 Revision 2

  • Remote staffing of augmenting engineers (Rx, Mechanical, Electrical) as well as EOF Dose Assessor
  • Information Technology services not necessarily being in the emergency response facilities
  • No TSC dose assessor due to EOF dose assessor staffing at same time 16

Evacuation Time Estimates (ETE)

  • Palisades submitted an updated ETE on September 7, 2022, using the 2020 Census data in accordance with Appendix E to Part 50 Section IV

- Section 1.4 - Permanent resident population decreased by 4.5% (2010 to 2020 Census Data)

- Section M.3 - 107% change in permanent resident population within the 2-mile region would require an updated ETE study

  • Completeness review of ETE study completed in February 2023

- Reviewed in accordance with NUREG/CR-7002 Criteria for Development of Evacuation Time Estimate Studies Revision 1 (ML21013A504)

  • Reviewed and found to be generally consistent with the guidance in NUREG/CR-7002 Revision 1 and, as such, found to be complete
  • Holtec completed an annual population estimate in August 2024 17

Emergency Exercise

- This exercise was led by Region III Emergency Preparedness inspectors

- Two Reactor Licensing Branch Members (Emergency Preparedness Specialist and Branch Chief) supported the exercise evaluation at the TSC and EOF

  • FEMA conducted the evaluation of the offsite response capabilities as part of their ability to issue a final finding

- FEMA conducted a public meeting after the exercise and there were no issues that rose to the level of a FEMA finding 18

Inspection and Site Activities Palisades Restart Jason Kozal, Division Director April Nguyen, Team Lead Region III/DORS 19

Palisades Site Activities Update

  • Inspection Activities
  • Staffing
  • Overview of Startup Sequence
  • Technical Topics of Interest 20

Inspection Activities Completed In Progress Planned Simulator System Return to Service Cybersecurity (Pre-Fuel Load &

Post-Fuel Load)

Biennial Problem Identification and Resolution Plant Modifications Fire Protection Team Inspection Emergency Preparedness Exercise In-service Inspection Repair Activities License Renewal Phase IV Physical Security Inspections are being conducted using mostly baseline procedures to ensure programs, procedures, and SSCs meet regulatory requirements and industry standards for normal plant operations. Some reactor startup procedures are being utilized, as well as newly created procedures for Cyber Security.

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Inspection Focus Item - System Return to Service Reviews SRTS Plans Completed initial reviews of 70% of the 75 System Return to Service (SRTS) plans Plans document activities performed to verify configuration & condition of systems, structures, & components (SSCs)

Plans identify required maintenance and testing, including modifications Plans prioritize repairs, open corrective action items, & system enhancements Inspection Phased approach for review of plans and associated activities Risk-informed in-field walkdowns and observations of maintenance and testing Inspection based on licensee schedule &

when systems needed for plant operations Verification of operability/functionality by reviewing work orders, technical specifications, and code requirements 22

Examples of SRTS Inspection Activities Emergency Diesel Generators Review of plan identified critical preventive maintenance activities and prior deficiencies that needed to be addressed In-field inspection observed maintenance activities and verified system material condition Work also included corrective maintenance to address discovery items Test starts and 24-hour endurance run for post-maintenance testing Additional Follow-Up Inspection and cleaning of safety-related Fuel Oil Tank Evaluation of any issues identified during maintenance that may impact operability Dedication of safety-related parts Operators and Inspectors conduct system walkdowns/alignment prior to transitioning to Mode of Applicability for EDGs 23

Inspection Focus Items - Modifications for Longer-Term Reliability

  • On-Site and Off-site Power maintenance

- Replace Station Batteries

- Replace Generator Output Breaker

- Address prior issue with coordination of DC Breakers

  • Implementation of modifications for Digital I&C and to address obsolescence issues

- Auxiliary Feedwater Actuation System

- Replacement of Rosemont Transmitters

- Core Monitoring System Upgrade 24

Inspection Focus Items - Inspection &

Verification of Mechanical Reliability

  • Inspect and repair known susceptible areas of buried piping

- Service Water System, Condensate Storage Tank outlet piping, Radwaste piping to external hold tanks

  • Verification of Containment Structural Integrity

- Inspection, testing, and cleaning of containment tendons

- Containment penetration maintenance and verification

- Internal containment concrete structural inspections and repairs 25

Inspection Focus Item -

Program Re-implementation

  • Inspectors have reviewed plans for re-implementation of required programs
  • Focus on verifying guidance documents and implementing procedures are revised for normal plant operations and meets regulatory requirements and current industry standards Examples include the Corrective Action Program, Fire Protection Program, and Cyber Security Program 26

Staffing - Licensed Operators Simulator restored as a plant-reference simulator in February 2024 Full accreditation of Licensed Operator Training in March 2025 NRC inspection of licensed operator training found that training has shown to be effective Re-licensed Operators

  • 7 ROs 2025 Initial Licensed Operator Class

Staffing - Other Site Groups

  • The sites organizational structure, functions and responsibilities were reviewed as part of the license transfer application using applicable guidance in NUREG-0800
  • Total permanent site staff 600 individuals across all departments. Open positions are supplemented by contractors.
  • Full accreditation of Maintenance and Technical Training in May 2025
  • Emergency Response Organization teams are fully staffed and qualified to meet the requirements for license transition to operations 28

Process for Startup

  • Once Holtec implements their licensing bundle and other licensing actions, they are required to follow the operating license to meet NRCs safety requirements
  • Implementation of actions will allow Holtec to commence moving through the startup process
  • Holtecs Licensed Operators are licensed by the NRC and are personally responsible for safe operation of the nuclear reactor
  • NRC inspectors are onsite to observe how they meet the requirements 29

Overview of Startup Sequence Transition to Reactor Oversight Process and Operational Licensing Basis Receive New Fuel Load Fuel into Reactor Core Close Reactor Vessel and Start Systems needed to restore Primary Side parameters Start Secondary Side systems Reactor Critical Start Turbine and Synchronize to Grid Power Ascension Testing and slow increase in power to 100%

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Inspection Topics of Interest -

Steam Generators Additional Activities

  • Secondary side repairs
  • Secondary side cleaning and flushes What has been completed?
  • Visual examinations of the secondary side
  • FOSAR and sludge lancing
  • SG Tube In-Situ pressure testing for selected tubes in both generators
  • Sleeving of SG tubes to repair identified indications
  • Post-sleeving ECT 31

Inspection Topics of Interest -

Reactor Pressure Vessel and Head What has been completed?

  • Visual examination of RPV interior surface, supports, core shroud plates, core support plate, and fuel alignment plate
  • NDE and evaluation of Core Shroud Bolts and Clevis Bolts
  • Inspections completed per ASME Code and MRP-227 Activities in Progress
  • RPV Head CRDM Half Nozzle repairs to address Alloy 600 weld issue
  • Reactor Vessel evaluations for power operations
  • Currently, no issues of safety significance have been identified from these activities.

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Inspection Topics of Interest -

Primary Coolant System Alloy 600 Mitigation Activities

  • Full dissimilar metal structural weld overlays completed for specific areas such as Safety Injection piping, branch connections, and Shutdown Cooling system connections
  • Completed an initial PCS decontamination system flush in July 2024
  • Foreign Material Exclusion program is continuously observed by site personnel and inspectors to ensure proper controls are in place for work activities
  • Will conduct PCS flushes with chemical treatment after work completed and prior to restarting reactor 33

Inspection Topics of Interest -

Reactor Fuel

  • Reactor will be loaded with a mix of new and used fuel
  • Used fuel maintained since shutdown in the spent fuel pool
  • Used fuel is inspected and cleaned prior to core load
  • The core configuration will not change
  • New fuel has been ordered and is being manufactured 34

Safety Culture The site has re-established its nuclear safety culture monitoring program, Employee Concerns Program, and management oversight board As part of the Problem Identification and Resolution inspection, safety culture inspectors determined that the licensee has maintained a SCWE where personnel feel free to raise safety concerns Trust seems to permeate the work environment from the top down Assessors conducted focus groups and interviews of over 90 personnel 35

For More Information:

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