PNP 2025-063, Supplement to Response to Second Request for Additional Information Regarding License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving
| ML25241A042 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/29/2025 |
| From: | Fleming J Entergy Nuclear Operations, Holtec, Holtec Palisades |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| PNP 2025-063 | |
| Download: ML25241A042 (1) | |
Text
27780 Blue Star Highway, Covert, MI 49043 1 Holtec Palisades, LLC ("Holtec Palisades") is the licensed owner of the Palisades Nuclear Plant (PNP). Pursuant to the license transfer amendment received in connection with the PNP restart (Reference 2), licensed operating authority has transferred from Holtec Decommissioning International, LLC ("HDI") to Palisades Energy, LLC ("Palisades Energy").
PNP 2025-063 10 CFR 50.90 August 29, 2025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Palisades Nuclear Plant NRC Docket No. 50-255 Renewed Facility Operating License No. DPR-20
Subject:
Supplement to Response to Second Request for Additional Information Regarding License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving By letter dated February 11, 2025 (Reference 1), Holtec1 requested U.S. Nuclear Regulatory Commission (NRC) review and approval of a license amendment request (LAR) to revise the Palisades Nuclear Plant (PNP) Permanently Defueled Technical Specifications (PDTS) to allow use of Framatome Alloy 690 sleeves to repair defective steam generator (SG) tubes as an alternative to removing the tubes from service by plugging.
By electronic mail (email) received on April 14, 2025, the NRC forwarded a draft request for additional information (RAI) regarding the LAR. A clarification call with the NRC reviewers was held on April 29, 2025 to discuss the LAR, and the NRC provided the final RAI in an email dated May 7, 2025 (Reference 3). Holtec provided the responses to the RAI in a letter dated May 29, 2025 (Reference 4).
By email received on June 30, 2025, the NRC provided a second RAI regarding the LAR (Reference 5). Holtec provided the responses to the RAI in a letter dated July 30, 2025 (Reference 6). On August 14, 2025, NRC staff representatives and representatives from Holtec and Framatome participated in a conference call to discuss the PNP SG tube inspections.
Included in the discussion topics was an NRC request to clarify the response to RAI Question 19 in Reference 6 regarding the SG inspection frequency.
The Enclosure to this letter provides a supplement to the second RAI that revises the response to RAI Question 19 to address the NRC's request for clarification of the response. The attachment to the Enclosure provides two new commitments pertaining to the scope and frequency of the SG inspections as discussed in the revised RAI response.
Neither the revised RAI response nor the new commitments provided in this letter alter the no significant hazards consideration contained in the Reference 1 LAR.
PNP 2025-046 Page 2 of 3 In accordance with 10 CFR 50.91(b), State consultation, Holtec is notifying the State of Michigan of the revised RAI response by transmitting a copy of this letter, with Enclosure, to the designated State of Michigan official.
If you have any questions regarding this submittal, 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 August 28, 2025.
Respectfully, Jean A. Fleming Vice President, Licensing and Regulatory Assurance Holtec International
References:
- 1.
Holtec Palisades, LLC (Holtec) letter to U.S. Nuclear Regulatory Commission (NRC), License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving, dated February 11, 2025 (ADAMS Accession Nos.
ML25042A692 and ML25043A348)
- 2.
NRC letter to Holtec, Palisades Nuclear Plant - Order Approving Direct Transfer of Renewed Facility Operating License and Independent Spent Fuel Storage Installation General License and Issuance of Conforming Amendment No. 275 (EPID L-2023-LLM-0005), dated July 24, 2025 (ADAMS Accession No. ML25167A243)
- 3.
NRC email to Holtec, Request for Additional Information RE: Steam Generator Tube Sleeving Amendment (L-2025-LLA-0036), dated May 7, 2025 (ADAMS Accession No. ML25128A171)
- 4.
Holtec letter to NRC, Response to Request for Additional Information Regarding License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving, dated May 29, 2025 (ADAMS Accession No. ML25149A013) 5.
NRC email to Holtec, Request for Additional Information RE: Steam Generator Repair by Sleeving Amendment (L-2025-LLA-0036), dated June 30, 2025 (ADAMS Accession No. ML25182A275)
- 6.
Holtec letter to NRC, Response to Second Request for Additional Information Regarding License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving, dated July 30, 2025 (ADAMS Accession No. ML25211A324)
Digitally signed by Jean A. Fleming DN: cn=Jean A. Fleming, c=US, o=Holtec Decommissioning International, LLC, ou=Regulatory and Environmental Affairs, email=J.Fleming@Holtec.com Date: 2025.08.29 08:02:13 -04'00' Jean A.
Fleming
PNP 2025-046 Page 3 of 3
Enclosure:
Supplement to Response to Second Request for Additional Information - License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving Enclosure
Attachment:
List of Regulatory Commitments cc:
NRC Region III Regional Administrator NRC Senior Resident Inspector - Palisades Nuclear Plant NRC Project Manager - Palisades Nuclear Plant Designated Michigan State Official
PNP 2025-063 Enclosure Page 1 of 4 PNP 2025-063 Enclosure Supplement to Response to Second Request for Additional Information License Amendment Request to Revise Selected Permanently Defueled Technical Specifications to Support Repairing of Steam Generator Tubes by Sleeving
PNP 2025-063 Enclosure Page 2 of 4 Supplement to Response to Second Request for Additional Information
=
Background===
By letter dated February 11, 2025 (Reference 1 of cover letter), Holtec Palisades requested U.S.
Nuclear Regulatory Commission (NRC) review and approval of a license amendment request (LAR) to revise the Palisades Nuclear Plant (PNP) Technical Specifications (TSs) to allow the use of Framatome Alloy 690 sleeves to repair defective steam generator (SG) tubes as an alternative to removing the tubes from service by plugging. Specifically, the LAR proposed changes to the following PNP TSs:
Surveillance Requirement (SR) 3.4.1.3, Verify PCS [primary coolant system] total flow rate within the limit specified in the COLR [core operating limits report]
Technical Specification (TS) 3.4.17, "Steam Generator (SG) Tube Integrity" TS 5.5.8, "Steam Generator (SG) Program" TS 5.6.8, "Steam Generator Tube Inspection Report."
By email received on June 30, 2025, the NRC provided a request for additional information (RAI) regarding the LAR (Reference 5 of cover letter). This was the second RAI received regarding this LAR. Holtec provided the responses to the second RAI in a letter dated July 30, 2025 (Reference 6 of cover letter). On August 14, 2025, NRC staff representatives and representatives from Holtec and Framatome participated in a conference call to discuss the PNP SG tube inspections. Included in the discussion topics was an NRC request to clarify the response to RAI Question 19 in Enclosures 1 and 2 of the July 30, 2025 RAI response regarding the scope and frequency of the SG inspections. Question 19 and the response are restated below for context:
Question 19 Confirm that all in-service tube/sleeve assemblies will be inspected each outage that SG tube inspections are performed.
Holtec Response to Question 19 Holtec cannot confirm this statement with the stipulated conditions because it deviates from the provisions of TS 5.5.8.d as previously provided in Enclosures 2 and 3 of the LAR. This position and basis are further discussed below.
During installation, all tube/sleeve assemblies are examined. A sampling program consistent with inspection requirements is used for subsequent examinations to inspect some, but not all, in-service tube/sleeve assemblies during each outage that SG tube inspections are performed. Future inspections of the in-service tube/sleeve assembly are controlled by TS 5.5.8.d. The specific wording under TS 5.5.8.d.2 allows for a sampling inspection to assure that 100% of the tubes are inspected within a 60 effective full power month period and that no SG shall operate for more than 24 effective full power months or one refueling outage (whichever is less) without being inspected. If defects are found in the tube/sleeve assemblies during the sample inspection, the sample inspection is expanded to include additional tube/sleeve assemblies per industry guidelines.
PNP 2025-063 Enclosure Page 3 of 4 As expected, during the clarification call the NRC reviewers requested clarification regarding Holtec's position and basis for the scope and frequency of the in-service SG tube/sleeve assembly inspections provided in the response to Question 19. Holtec's previous position was that it could not confirm the statement in Question 19 with the stipulated conditions that all in-service tube/sleeve assemblies will be inspected each outage that SG tube inspections are performed because the statement deviates from the provisions of TS 5.5.8.d as previously provided in Enclosures 2 and 3 of the LAR.
As requested, a Framatome representative presented a clarification of the previous response to Question 19, which included a discussion of the planned inspection of all the SG in-service tube/sleeve assemblies at the next scheduled refueling outage (1R29) and the assessments to be performed in accordance with the Electric Power Research Institute (EPRI) Steam Generator Integrity Assessment Guidelines (ID #3002020909) to comply with the TS 5.5.8.d.2 requirements for the in-service tube/sleeve assembly inspections beyond 1R29.
Following the presentation, an NRC reviewer commented that Beaver Valley 2 performs inspections of all SG tube/sleeve assemblies every refueling outage. The NRC reviewer also commented that their assessment using the Integrity Assessment Guidelines indicated that Holtec should be inspecting about 50% of the SG tube/sleeve assemblies each refueling outage. Further discussions of the provisions of TS 5.5.8.d with consideration of some additional NRC comments and suggestions led to a consensus agreement that Holtec would perform an inspection of 100% of the SG in-service tube/sleeve assemblies at 1R29 with sample inspections of a minimum of 50% of the in-service tube/sleeve assemblies after 1R29 with scope expansions in accordance with industry guidelines. Accordingly, please replace in its entirety the Holtec Response to Question 19 provided in Enclosures 1 and 2 of the July 30, 2025 RAI response (Reference 6 of cover letter) with the following response:
Holtec Response to Question 19 The minimum SG tube inspection requirements are governed by compliance with TS 5.5.8.d. The specific wording under TS 5.5.8.d.2 allows for a sampling inspection to assure that 100% of the tubes are inspected at sequential periods of 60 effective full power months (EFPM) and that no SG shall operate for more than 24 EFPM or one refueling outage (whichever is less) without being inspected. The term tubes refers to the pressure boundary portion of the tubing including associated sleeve assemblies where applicable.
TS 5.5.8.d also requires that the inspection scope, inspection methods, and inspection intervals be such as to ensure that SG tube integrity is maintained until the next SG inspection. This requirement is met by performing degradation assessments prior to each inspection and operational assessments after each inspection in accordance with the Steam Generator Program (SR 3.4.17.1) and industry guidelines. The degradation assessment will establish the required inspection scope and methods. The operational assessments will be used to establish the maximum operating interval before the next inspection. These assessments will include evaluations of both existing and potential degradation of the SG in-service tube/sleeve assemblies.
All of the SG tube/sleeve assemblies were inspected after sleeve installation during the PNP decommissioning outage (1D28) prior to plant restart. At the next scheduled refueling outage (1R29), all of the SG in-service tube/sleeve assemblies will be inspected.
PNP 2025-063 Enclosure Page 4 of 4 After 1R29, sample inspections of a minimum of 50% of all SG in-service tube/sleeve assemblies will be performed. Establishing a minimum sample size follows the recommendations in EPRI Steam Generator Integrity Assessment Guidelines, Appendix F.
For the SG in-service tube/sleeve assemblies at Palisades after 1R29, a 50% sample size provides sufficient probability of detecting at least one flaw at the tube/sleeve assembly locations of interest (i.e., an outboard expansion joint). If a flaw is identified at an outboard expansion location of an in-service tube/sleeve assembly in the initial 50% inspection sample, a scope expansion will be applied to the remaining 50% of the in-service tube/sleeve assemblies per the EPRI Integrity Assessment Guidelines.
See the list of regulatory commitments in the Attachment to this Enclosure for the commitments associated with the above RAI response.
Enclosure Attachment PNP 2025-063 List of Regulatory Commitments 1 Page Follows
List of Regulatory Commitments The table below identifies actions discussed in this letter for which, upon approval, Holtec commits to perform. Any other actions discussed in this submittal are described for U.S.
Nuclear Regulatory Commission (NRC) information and are not commitments.
Commitment Proposed Completion Date
- 1. Holtec will perform an inspection of 100 percent of the steam generator (SG) in-service tube/sleeve assemblies.
End of Cycle 29 refueling outage (1R29)
- 2. Holtec will perform an inspection of a minimum of 50 percent of all SG in-service tube/sleeve assemblies. If a flaw is identified at an outboard expansion location of an in-service tube/sleeve assembly in the initial 50 percent inspection sample, a scope expansion will be applied to the remaining 50 percent of the in-service tube/sleeve assemblies. The Electric Power Research Institute (EPRI) Steam Generator Integrity Assessment Guidelines (ID 3002020909) will be used to select the minimum expansion scope.
End of each refueling outage after 1R29