ML25260A635
| ML25260A635 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/21/2025 |
| From: | Justin Poole Plant Licensing Branch III |
| To: | Holtec Decommissioning International, Palisades Energy |
| References | |
| EPID L-2025-LLA-0036 | |
| Download: ML25260A635 (1) | |
Text
I October 21, 2025 Site Vice President Palisades Energy, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 490439530
SUBJECT:
PALISADES NUCLEAR PLANT-AUDIT
SUMMARY
REPORT IN SUPPORT OF REVIEW OF LICENSE AMENDMENT REQUEST REGARDING STEAM GENERATOR REPAIR BY SLEEVING (EPID L2025LLA0036)
Dear Sir or Madam:
By letter dated February 11, 2025 (Agencywide Documents Access and Management System Accession No. ML25043A348), as supplemented by letters dated May 29, 2025 (ML25149A013), July 30, 2025 (ML25211A324), August 29, 2025 (ML25241A042),
September 23, 2025 (ML25266A097), and October 7, 2025 (ML25280A083), respectively, Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Palisades, LLC,1,
submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) for the Palisades Nuclear Plant. Specifically, the LAR would revise the Technical Specifications to allow the use of Framatome Alloy 690 sleeves to repair defective steam generator tubes as an alternative to removing the tubes from service by plugging.
By letter dated March 20, 2025 (ML25070A153), the NRC staff stated that it would conduct a regulatory audit to support its review of the LAR in accordance with an audit plan. The audit was conducted using video and teleconferencing and a secure, online portal, as well as an NRC onsite audit on May 20 and 21, 2025 at Framatomes facility in Lynchburg, VA.
The purpose of the audit was to gain understanding, to verify information, and to identify information that would require docketing to support the proposed licensing action. Based on the audit, Holtec provided the necessary information for the NRC staff to complete its review of the LAR. The NRC staffs audit report is enclosed herewith.
1 On July 24, 2025, the NRC issued an order approving and a conforming amendment reflecting the transfer of operating authority from HDI to Palisades Energy, LLC (Package, ML25167A245). Holtec Palisades, LLC, remains the licensed owner of PNP.
If you have any questions, please contact me at 3014152048, or by email to Justin.Poole@nrc.gov.
Sincerely,
/RA/
Justin Poole, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No.: 50255
Enclosure:
Audit Report cc: Listserv
Enclosure REGULATORY AUDIT REPORT PALISADES ENERGY, LLC PALISADES NUCLEAR PLANT DOCKET NO. 50255
1.0 BACKGROUND
By letter dated February 11, 2025 (Agencywide Documents Access and Management System Accession No. ML25043A348), as supplemented by letters dated May 29, 2025 (ML25149A013), July 30, 2025 (ML25211A324), August 29, 2025 (ML25241A042),
September 23, 2025 (ML25266A097), and October 7, 2025 (ML25280A083), Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Palisades, LLC2 (collectively, Holtec), submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) for the Palisades Nuclear Plant. Specifically, the LAR would revise the Technical Specifications 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.
By letter dated March 20, 2025 (ML25070A153), the NRC staff stated that it would conduct a regulatory audit to support its review of the LAR in accordance with an audit plan. The audit would be conducted remotely using video and teleconferencing and a secure, online portal, established by the licensee, as well as an onsite portion.
The purpose of the audit was to gain understanding, to verify information, and to identify information that will require docketing to support the NRC staffs review of the proposed licensing action.
The NRC staff conducted the regulatory audit in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC111, Revision 1, Regulatory Audits (ML19226A274).
2.0 SCOPE AND PURPOSE The purpose of the audit was to help the NRC staff get a better understanding of the information provided by Holtec and its vendor, Framatome. The NRC staff performed a virtual audit of technical references used in the LAR. In addition, the NRC staff performed an onsite audit on May 20 and 21, 2025 at Framatomes facility in Lynchburg, VA to review documents and discuss the staffs draft requests for information.
3.0 AUDIT TEAM The following NRC staff members and contractors participated in the audit:
Paul Klein - Senior Materials Engineer 2 On July 24, 2025, the NRC issued an order approving and a conforming amendment reflecting the transfer of operating authority from HDI to Palisades Energy, LLC (Package, ML25167A245). Holtec Palisades, LLC, remains the licensed owner of PNP.
Andy Johnson - Senior Materials Engineer Sasan Bakhtiari - Argonne National Laboratory Justin Poole - Licensing Project Manager Marlayna Doell-Licensing Project Manager 4.0 AUDIT REPORT The purpose of this regulatory audit was to enhance the NRC staffs technical understanding of the LAR, interact with the licensee and vendor technical staff supporting the LAR, and identify any information that would need to be docketed to support completion of the staffs review.
The NRC staff conducted an onsite audit in accordance with the audit plan on May 20 and 21, 2025, at Framatomes facility in Lynchburg, VA. During both days, the discussions focused on multiple topics, including the sleeve design, mechanical and leakage testing performed to meet the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code; the test plan used for eddy current qualification of the sleeve/tube assembly; the eddy current examination procedures and data from sleeve inspections; the sleeve installation techniques; and the licensees analysis of testing results. The NRC staff also witnessed sleeve installation into a steam generator tube mock-up.
Following the onsite visit, by email dated June 30, 2025 (ML25182A275), the NRC staff issued a request for additional information (RAI). The questions were directly related to the information that was discussed during the onsite portion of the audit. In addition, the RAI identified a list of documents that the NRC staff determined were needed to be docketed to support the completion of the staffs review. On July 31, 2025 (ML25211A324), Holtec submitted its response to the RAI and provided the requested documents on the docket. On August 29, 2025 (ML25241A042), September 23, 2025 (ML25266A097), and October 7, 2025 (ML25280A083),
Holtec supplemented its response to the RAI.
5.0 DOCUMENTS REVIEWED The following documents were reviewed during the audit:
Plugging_Spec_08-9175539-001.pdf Spec_08-9384357-001.pdf Stress_Fatigue_32-9387171-000.pdf Sleeve_Qual_1994_43-10202P-00.pdf Stress_Analysis_32-1233471-00.pdf 32-9386352-000.pdf 1994_Qual_Test_Plan_51-1233793-00.pdf 51-9321652-000.pdf 32-1229541-00.pdf 32-9386119-000.pdf 1241690.pdf Residual stresses associated with the hydraulic expansion of steam generator tubing into tubesheets.pdf 1995_TSP_TTS_Requirements_32-1232725-03.pdf Fatigue_Load_1995_32-1229541-00.pdf 51_9389780-000.pdf 51_9391941-000 Part 1 of 4.pdf 51_9391941-000 Part 2 of 4.pdf 51_9391941-000 Part 3 of 4.pdf 51_9391941-000 Part 4 of 4.pdf Palisades+NPP_DC_51-9385821-000.pdf Palisades Sleeving NRC Audit Visit_May_20_21.pdf
+Point detection performance in parent tube -Sleeve vs Standard.pdf White paper - 05H indications behind sleeve - Proprietary
6.0 CONCLUSION
The purpose of the audit was to gain understanding, verify information, and identify required information for docketing to support the NRC staffs review of the proposed licensing action.
Following the NRC staffs review of documents and presentation of its observations from the audit, Holtec provided the necessary information for the NRC staff to complete its review of the LAR.
- via eConcurrence NRR-106 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DNRL/NCSG/BC NAME JPoole SLent SBloom DATE 09/18/2025 9/18/2025 09/18/2025 OFFICE OGC - NLO w/comments NRR/DORL/LPL3/BC (A)
NRR/DORL/LPL3/PM NAME STurk IBerrios JPoole DATE 09/26/2025 09/30/2025 10/21/2025