PNP 2025-068, Second 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
| ML25266A097 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/23/2025 |
| From: | Fleming J Holtec Palisades |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25266A096 | List: |
| References | |
| PNP 2025-068 | |
| Download: ML25266A097 (1) | |
Text
PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 This letter is decontrolled when separated from Attachment 1 27780 Blue Star Highway, Covert, MI 49043 PNP 2025-068 10 CFR 50.90 September 23, 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:
Second 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), Holtec Palisades, LLC (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) 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 2). Holtec Palisades provided the responses to the RAI in a letter dated May 29, 2025 (Reference 3).
By email received on June 30, 2025, the NRC provided a second RAI regarding the LAR (Reference 4). Holtec provided the responses to the second RAI in a letter dated July 30, 2025 (Reference 5). 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 in to Question 19 in the second RAI regarding the SG inspection frequency.
In a letter dated August 29, 2025 (Reference 6), Holtec Palisades provided a supplement to the second RAI response (Reference 5) that revised the response to RAI Question 19 to address the NRC's request for clarification of the response. The supplement letter included two new commitments pertaining to the post-restart scope and frequency of the PNP SG inspections as agreed during the August 14, 2025 conference call.
PNP 2025-068 Page 2 of 3 By email dated September 8, 2025, the NRC requested two additional Framatome documents regarding the following subjects: Probe Performance Comparison +Point Sleeve Probe vs Standard +Point probe and Site Qualification Performance Verification ODSCC flaw detection at sleeved 05H TSP in SGA. These two documents have been consolidated into Framatome document 51-9397841-000, Consolidated White Paper: +Point Probe Performance Evaluation -
Palisades Sleeve Project, which is provided in Attachment 1 to this letter as a proprietary Framatome document without a non-proprietary version since, per LIC-204, Revision 4, Handling Requests to Withhold Proprietary Information from Public Disclosure (ADAMS Accession No. ML20049A139), these documents contain extensive proprietary information to an extent that a redacted version would be of no value to the public. Attachment 2 provides the associated Framatome Affidavit, Proprietary Information Notice.
In a second email dated September 8, 2025, the NRC notified Holtec Palisades that the two commitments included in the supplement to the second RAI response (Reference 6) would be made license conditions. The email also included two proposed wording changes to the commitments for review. Subsequent correspondence with the NRC led to consensus agreement to amended wording that was deemed acceptable for the license conditions.
Note that the Framatome Condition Monitoring and Operational Assessment (CMOA) for PNP SG Restart Inspection 1D28, which was requested by the NRC in the Reference 4 RAI, was originally intended to be included in this supplement letter. However, completion of the CMOA has been delayed due to Framatome technical reviewers being temporarily unavailable while supporting other plant outages. The CMOA is now expected to be submitted by October 7, 2025.
The Framatome document 51-9397841-000 provided in this second supplement to the Reference 5 second RAI response does not alter the no significant hazards consideration contained in the Reference 1 LAR.
In accordance with 10 CFR 50.91(b), State consultation, Holtec Palisades is notifying the State of Michigan of this second supplement to the Reference 5 second RAI response by transmitting a copy of this letter, with attachments, 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 September 23, 2025.
Respectfully, Jean A. Fleming Vice President, Licensing and Regulatory Assurance Holtec International 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: 2025.09.23 08:14:03 -04'00' Jean A.
Fleming
PNP 2025-068 Page 3 of 3
References:
- 1.
Holtec Palisades, LLC (Holtec Palisades) 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 email to Holtec Palisades, Request for Additional Information RE:
Steam Generator Tube Sleeving Amendment (L-2025-LLA-0036), dated May 7, 2025 (ADAMS Accession No. ML25128A171)
- 3.
Holtec Palisades 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)
- 4.
NRC email to Holtec Palisades, Request for Additional Information RE:
Steam Generator Repair by Sleeving Amendment (L-2025-LLA-0036), dated June 30, 2025 (ADAMS Accession No. ML25182A275)
- 5.
Holtec Palisades 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)
- 6.
Holtec Palisades letter to NRC, 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, dated August 29, 2025 (ADAMS Accession No. ML25241A042)
Attachments:
- 1.
Framatome Document, 51-9397841-000, "Consolidated White Paper:
+Point Probe Performance Evaluation - Palisades Sleeve Project"
[Withhold Under 10 CFR 2.390(a)(4)]
- 2.
Framatome Affidavit, Proprietary Information Notice cc:
NRC Region III Regional Administrator NRC Senior Resident Inspector - Palisades Nuclear Plant NRC Project Manager - Palisades Nuclear Plant Designated Michigan State Official
PNP 2025-068 Framatome Affidavit, Proprietary Information Notice 3 Pages Follow
A F F I D A V I T
- 1.
My name is Philip A. Opsal. I am Manager, Product Licensing for Framatome Inc. (formally known as AREVA Inc.), and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.
- 3.
I am familiar with the Framatome information contained in Framatome Document No. 51-9397841-000, Consolidated White Paper: +Point Probe Performance Evaluation - Palisades Sleeve Project, referred to herein as this Document. Information contained in this Document has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.
- 4.
This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
- 5.
This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) Trade secrets and commercial or financial information.
- 6.
The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:
(a)
The information reveals details of Framatomes research and development plans and programs or their results.
(b)
Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c)
The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.
The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(a), 6(b), 6 (c), 6(d), and 6(e) above.
- 7. Public disclosure of this document would reveal Framatomes method to determine appropriate inspection equipment and range of signal amplitudes for the inspection probe to be used for steam generator tube and sleeve inspections. Due to the extent of Framatome proprietary information in this document, a non-proprietary version would be of no value to the public. Therefore, a non-proprietary version is not being submitted to the NRC.
- 8.
In accordance with Framatomes policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 9.
Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 10.
The foregoing statements are true and correct to the best of my knowledge, information, and belief.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on September 19, 2025.
Philip A. Opsal Manager, Product Licensing, Framatome Inc.
Philip A. Opsal