PNP 2025-086, Request for Additional Information Regarding Second Request for Exemption from Requirements of 10 CFR 26.205, Fitness for Duty Programs - Work Hours

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Request for Additional Information Regarding Second Request for Exemption from Requirements of 10 CFR 26.205, Fitness for Duty Programs - Work Hours
ML25360A002
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/26/2025
From: Fleming J
Holtec, Holtec Palisades
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
PNP 2025-086
Download: ML25360A002 (0)
v • d • e


Text

27780 Blue Star Highway, Covert, MI 49043 PNP 2025-086 10 CFR 26.9 December 26, 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:

Request for Additional Information Regarding Second Request for Exemption from Requirements of 10 CFR 26.205, "Fitness for Duty Programs - Work Hours" By letter dated August 12, 2025 (Reference 1), in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 26, Fitness for Duty Programs, Section 26.9, Specific exemptions, Palisades Energy, LLC (Palisades Energy) requested U.S. Nuclear Regulatory Commission (NRC) approval of a one-time exemption from the specific requirements of 10 CFR 26.205, Work hours. The proposed exemption, as supplemented by the letter dated October 15, 2025 (Reference 2), would allow the use of the less restrictive work hour limitations specified in 10 CFR 26.205(d)(4) and (d)(5) in lieu of the requirements of 10 CFR 26.205(d)(3) and (d)(7) for an additional 60-day period to support outage activities for restart of the Palisades Nuclear Plant (PNP).

On October 24, 2025 (Reference 3), the NRC granted the requested one-time exemption to use the less restrictive outage work hour controls in 10 CFR 26.205(d)(4) and (d)(5) for a period not to exceed 60 days to support restart activities during the period of the proposed exemption. The exemption period commenced on November 3, 2025 and will expire on January 1, 2026.

By letter dated December 12, 2025 (Reference 4), Palisades Energy requested a second request for a one-time exemption from the specific requirements of 10 CFR 26.205. This proposed exemption would allow use of the less restrictive outage work hour controls in 10 CFR 26.205(d)(4) for an additional period of 60 days, to commence on January 2, 2026, after a two week rest and reset period. The proposed exemption would apply to personnel performing duties specified in 10 CFR 26.4(a)(2) [Health Physics and Chemistry] and 10 CFR 26.4(a)(4) [Maintenance and Projects].

On December 17, 2025, Palisades Energy received a draft Request for Additional Information (RAI) by electronic mail (email). On December 22, 2025, the NRC staff and representatives of Palisades Energy held a clarification call to discuss the draft RAI and upcoming response submittal. During the call, Palisades Energy agreed to attempt to provide the RAI response by December 26, 2025. The final RAI was forwarded in an email dated December 22, 2025, following the call (Reference 5).

The Enclosure to this letter provides Palisades Energys responses to the RAI. The attachment to the Enclosure provides one revised commitment (Commitment 1) and one new commitment

PNP 2025-086 Page 2 of 2 (Commitment 2) regarding the controls on work hours in a concerted effort to manage and mitigate individual and cumulative worker fatigue. The revised commitment provided in this letter supersedes and replaces the commitment provided in Attachment 2 to the Reference 4 Enclosure. Palisades Energy requests approval of the exemption request no later than January 1, 2026 to support the ongoing activities that are critical for the successful completion of the current outage and restart of PNP.

If you have any questions regarding this submittal, please contact Kami Miller, Regulatory Assurance Manager, at (269) 764-2375.

Respectfully, Jean A. Fleming Vice President, Licensing and Regulatory Assurance Holtec International

References:

1.

Holtec Palisades, LLC (Holtec Palisades) letter to U.S. Nuclear Regulatory Commission (NRC), Request for Exemption from Requirements of 10 CFR 26.205, "Fitness for Duty Programs - Work Hours," dated August 12, 2025 (ADAMS Accession No. ML25224A206)

2.

Holtec Palisades letter to NRC, Supplement and Response to Request for Confirmatory Information Regarding Request for Exemption from Requirements of 10 CFR 26.205, dated October 15, 2025 (ADAMS Accession No. ML25288A074)

3.

NRC letter to Holtec Palisades, Palisades Nuclear Plant - One-Time Exemption from the Requirements of 10 CFR 26.205(d)(3) and (d)(7) (EPID L-2025-LLE-0022), dated October 24, 2025 (ADAMS Accession Nos.

ML25293A005 and ML25293A007)

4.

Holtec Palisades letter to NRC, Second Request for Exemption from Requirements of 10 CFR 26.205, "Fitness for Duty Programs - Work Hours,"

dated December 12, 2025 (ADAMS Accession No. ML25346A199)

5.

NRC email to Holtec Palisades, Request for Additional Information RE:

Request for Second Exemption from Part 26 Work Hours (LL-2025-LLE-0032), dated December 22, 2025

Enclosure:

Response to Request for Additional Information 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 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: 2025.12.26 11:17:50 -05'00' Jean A.

Fleming

PNP 2025-086 Enclosure Page 1 of 11 PNP 2025-086 Enclosure Response to Request for Additional Information Second Request for Exemption from Requirements of 10 CFR 26.205

PNP 2025-086 Enclosure Page 2 of 11 Response to Request for Additional Information NRC Introduction By letter dated December 12, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25346A199), the Palisades Energy LLC (Palisades) requested an exemption from Title 10 of the Code of Federal Regulations (10 CFR) Section 26.205(d)(3) and (d)(7) to use the less restrictive work hour limitations described in 10 CFR 26.205(d)(4) for a duration of 60 days starting January 2, 2026 to support plant restart activities.

The U.S. Nuclear Regulatory Commission (Commission, NRC) staff is reviewing your submittal and has identified areas where additional information is needed to complete its review.

Request for Additional Information (RAI):

1. Section 26.9 of 10 CFR states, in part, that the Commission may grant an exemption from the requirements in 10 CFR Part 26 as it determines are authorized by law and will not endanger life or property or the common defense and security, and are otherwise in the public interest.

Section 26.23(e) of 10 CFR states, in part, that Fitness-for-duty programs must provide reasonable assurance that the effects of fatigue and degraded alertness on individuals' abilities to safely and competently perform their duties are managed commensurate with maintaining public health and safety.

The "Mitigating Strategy" section of the submittal proposes the following actions:

"Since the start of the original exemption period on November 3, 2025, the covered workers in groups 10 CFR 26.4(a)(2) [Health Physics and Chemistry] and 10 CFR 26.4(a)(4) [Maintenance and Projects] have maintained work hours compliant with 10 CFR 26.205(d)(1), (d)(2), and (d)(4). In addition to complying with these requirements, Palisades Energy is committing the individuals identified in groups (a)(2) [Health Physics and Chemistry] and (a)(4) [Maintenance and Projects]

to a two-week rest and reset period prior to the start of the proposed 60-day extended exemption period. During the two-week rest and reset period (from December 19, 2025 through January 1, 2026), an average of 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per week or less for the covered workers in the Health Physics department, Chemistry department, Maintenance department, and Projects department will be maintained."

"In addition to maintaining the requirements in 10 CFR 205(d)(1), (2), and (4), and observing the two-week rest and reset period, cognizant supervisors will assess employees for fatigue and mental alertness during the proposed exemption period."

As indicated in the Statements of Consideration for Part 26 on the Federal Register, the Commission elaborated on the objective of § 26.205(d)(4) which is to ensure that individuals performing the duties described in § 26.4(a)(1) through (a)(4) have sufficient periodic long-duration breaks to prevent cumulative fatigue from degrading their ability to safely and competently perform their duties. In addition, in setting the 60-day period, the NRC considered that by the end of the 60-day period, individuals performing the duties in

PNP 2025-086 Enclosure Page 3 of 11

§ 26.4(a)(1) through (a)(4) would have missed 17 normally scheduled days off which represents a 60% reduction in the time available to recover and prevent cumulative fatigue.

Furthermore, the Statements of Consideration indicate that in establishing § 26.205(d)(4),

the NRC considered it appropriate to allow flexibility within the work hour requirements to accommodate limited periods of more intensive work schedules, such as unit outages.

However, the NRC limits this flexibility to infrequent circumstances, such as unit outages, to limit the potential for cumulative fatigue.

Given that the subsequent proposed exemption request seeks an additional 60-day period where the less restrictive work hour limitations will be utilized, which would shortly follow the initial 60-day outage period and the previously approved 60-day exemption period ending on January 1, 2026, extension of the less restrictive work hour limitations from 120 days to 180 days since August 24, 2025 could continue to substantively increase the potential for cumulative fatigue and fatigue-related personnel errors. Therefore, based on the docketed information, the staff is unable to determine if the proposed mitigating actions continue to provide reasonable assurance of adequate protection of public health and safety.

Provide additional details that address the following:

RAI 1.a:

a. The proposed exemption stated that Palisades re-assessed restart activities and determined that a second exemption period would be needed. Explain why this subsequent exemption would be in the interest of the public and safety in accordance with 10 CFR 26.9. Explain how cumulative fatigue will be prevented and bounded in the case of subsequent exemptions given the likelihood of additional outage time.

Palisades Energy Response to RAI 1.a:

Palisades Energy is in a unique situation in transitioning Palisades Nuclear Plant (PNP) from decommissioning back to a power operations licensing basis, which requires outage activities to restore safety-related equipment as well as activities to support plant restart and power ascension. This unique situation requires rigorous restart-related inspections and repair activities during the outage to ensure the plant will be safe prior to restarting. As the restart project progresses, additional scope has been identified requiring an expansion of required maintenance activities. This maintenance must be performed prior to plant startup to ensure safety and reliability. The proposed exemption will provide more flexibility for scheduling personnel and the ability to schedule additional covered individuals affords more opportunity to promptly and efficiently identify and address issues that may arise. The potential impact of a delay due to the NRC not granting the proposed exemption would result in a delay in providing the electrical power needed to ensure the stability and reliability of the region's electrical transmission grid and the powering of hundreds of thousands of homes and businesses at affordable electric rates. Therefore, the public will benefit from the additional resources that would be allowed by the exemption because the availability of these resources ensures that the restart of PNP is safe, effective, efficient, and provides the expected economic benefits for the region and the state of Michigan in a timely manner.

PNP 2025-086 Enclosure Page 4 of 11 RAI 1.b

b. Provide the work schedules, average weekly work hours, and the highest maximum average for individuals described in 10 CFR 26.4(a)(2) and (a)(4) for each subsequent 6-week shift cycle starting from November 3, 2025 through March 2, 2026. For example, see precedent from Watts Bar (ML22117A195) or Palisades (ML25224A206, ML25288A074).

Palisades Energy Response to RAI 1.b:

Palisades Energy utilizes the Certrec Fatigue Rule Management System (FRMS) to prepare work schedules and to track covered work hours. The FRMS individual work schedule reports for each group identified in the exemption request from November 3, 2025 through December 18, 2025 are available for NRC review upon request. Please note that the affected individuals are currently observing a maximum 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from December 19, 2025 to January 1, 2026. A description of each group's typical work schedule and highest calculated average work hours are provided below.

During the clarification call conducted on December 22, 2025, Palisades Energy informed the NRC reviewers that it is unable to provide work hour schedules for the entire period from November 3, 2025 through March 2, 2026 because the FRMS schedules for next year have not been prepared yet. Instead, the schedules for the last exemption period, which commenced on November 3, 2025 and expired on December 18, 2025 are provided. The schedules are not expected to change for the proposed exemption period from January 2, 2026 through March 2, 2026 since the schedules will continue to be required to be in compliance with 10 CFR 26.205(d)(1), (d)(2), and (d)(4). As such, the schedule descriptions provided below can be used as a reasonable method for estimating the planned work hours for each affected group during the proposed exemption period.

Fatigue Management - Affected Group: 10 CFR 26.4(a)(2) 10 CFR Position Schedule 11/03 to 12/18/2025 26.4(a)(2)

Chemistry The majority of the individuals in the Chemistry department worked between 8 and 9-hour shifts for 5 consecutive days followed by 2 consecutive days off.

Additional days off were provided where practicable to support fatigue management.

This schedule was in compliance with 10 CFR 26.205(d)(1), (d)(2) and (d)(7),

and resulted in a cumulative average of 37.92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br /> per week.

The highest weekly average was 50.29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> per week.

PNP 2025-086 Enclosure Page 5 of 11 Fatigue Management - Affected Group: 10 CFR 26.4(a)(2) 10 CFR Position Schedule 11/03 to 12/18/2025 There are no current plans to increase work hours until primary system passivation activities commence. The date for the start of passivation is not yet determined.

The Chemistry department is currently observing a rest and reset period in which no individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(2)

Health Physics The majority of the individuals in the Health Physics department worked 12-hour shifts for 4 consecutive days followed by 1 day off.

Additional days off were provided where practicable to support fatigue management.

This schedule was in compliance with 10 CFR 26.205(d)(1), (d)(2) and (d)(4),

and resulted in a cumulative average of 63.79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> per week.

The highest weekly average was 70.38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> per week.

The Health Physics department does not plan to deviate from this work schedule during the proposed exemption period.

The Health Physics department is currently observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

Summary As described in the Group 10 CFR 26.4(a)(2) table above, to support the ongoing PNP outage activities and subsequent plant restart, the covered individuals in Chemistry and Health Physics work different schedules. The schedules will remain in compliance with 10 CFR 26.205(d)(1), (d)(2), and (d)(4). To ensure an adequate reset before continuing outage activities, the individuals in this Group are currently observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from December 19, 2025 through January 1, 2026.

PNP 2025-086 Enclosure Page 6 of 11 Fatigue Management - Affected Group: 10 CFR 26.4(a)(2) 10 CFR Position Schedule 11/03 to 12/18/2025 The Group 10 CFR 26.4(a)(2) table includes the scheduled 30-minute shift turnover time as part of the work hour averaging calculation. This is conservative because shift turnover time may be excluded from the calculation of an individual's work hours (

References:

Nuclear Energy Institute (NEI) 06-11, Section 8.1, and NRC Regulatory Guide 5.73, Appendix B, page B-11).

Fatigue Management - Affected Group: 10 CFR 26.4(a)(4) 10 CFR Position: Maintenance /

Projects Schedule 11/03 to 12/18/2025 26.4(a)(4)

Framatome Projects 12-hour shifts, 6 days on, 1 day off.

Additional days off provided where practicable.

Cumulative average: 57.36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> per week.

Highest weekly average: 75.00 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per week.

Observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Alloy 600 Mitigation Project 12-hour shifts, 6 days on, 1 day off.

Cumulative average: 70.63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br /> per week.

Highest weekly average: 72.28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> per week.

Observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Mechanical Maintenance 12-hour shifts, 4 days on, 3 days off.

Cumulative average: 48.30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> per week.

Highest weekly average: 56.38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> per week.

Observing a rest and reset period in which no covered individual will work

PNP 2025-086 Enclosure Page 7 of 11 Fatigue Management - Affected Group: 10 CFR 26.4(a)(4) 10 CFR Position: Maintenance /

Projects Schedule 11/03 to 12/18/2025 more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Electricians 10-hour shifts, 5 days on, 2 days off.

Cumulative average: 51.58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> per week.

Highest weekly average: 51.73 hours8.449074e-4 days <br />0.0203 hours <br />1.207011e-4 weeks <br />2.77765e-5 months <br /> per week.

Observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Fuel Handling Equipment (FHE) Upgrade Project 12-hour shifts, 6 days on, 1 day off.

Additional days off provided where practicable.

Cumulative average: 61.58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> per week.

Highest weekly average: 71.21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> per week.

Observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Tesco Projects 12-hour shifts, maximum of 6 days on, 1 day off.

Additional days off provided where practicable.

Cumulative average: 58.81 hours9.375e-4 days <br />0.0225 hours <br />1.339286e-4 weeks <br />3.08205e-5 months <br /> per week.

Highest weekly average: 67.56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> per week.

Observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Electrical Maintenance 12-hour shifts, 4 days on, 3 days off, or 5 days on, 2 days off.

PNP 2025-086 Enclosure Page 8 of 11 Fatigue Management - Affected Group: 10 CFR 26.4(a)(4) 10 CFR Position: Maintenance /

Projects Schedule 11/03 to 12/18/2025 Cumulative average: 53.89 hours0.00103 days <br />0.0247 hours <br />1.471561e-4 weeks <br />3.38645e-5 months <br /> per week.

Highest weekly average: 60.87 hours0.00101 days <br />0.0242 hours <br />1.438492e-4 weeks <br />3.31035e-5 months <br /> per week.

Observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Instrumentation and Controls (I&C) Maintenance 12-hour shifts, 4 days on, 3 days off.

Cumulative average: 46.99 hours0.00115 days <br />0.0275 hours <br />1.636905e-4 weeks <br />3.76695e-5 months <br /> per week.

Highest weekly average: 52.04 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per week.

Observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Insulators 10-hour shifts, 5 days on, 2 days off.

Cumulative average: 51.73 hours8.449074e-4 days <br />0.0203 hours <br />1.207011e-4 weeks <br />2.77765e-5 months <br /> per week.

Highest weekly average: 51.73 hours8.449074e-4 days <br />0.0203 hours <br />1.207011e-4 weeks <br />2.77765e-5 months <br /> per week.

Observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Pipefitters 10-hour shifts, 5 days on, 2 days off.

After a very light schedule in the month of November, transitioned into 12-hour shifts with a maximum of 6 days on, 1 day off.

Cumulative average: 26.37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> per week.

Highest weekly average: 40.32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> per week.

Observing a rest and reset period in which no covered individual will work

PNP 2025-086 Enclosure Page 9 of 11 Fatigue Management - Affected Group: 10 CFR 26.4(a)(4) 10 CFR Position: Maintenance /

Projects Schedule 11/03 to 12/18/2025 more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Boilermakers 10-hour shifts, 5 days on, 2 days off.

Cumulative average: 51.58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> per week.

Highest weekly average: 53.56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> per week.

Observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

26.4(a)(4)

Master Lee Projects 8-hour, 10-hour and 12-hour shifts with sufficient days off to effectively mitigate cumulative fatigue.

Cumulative average: 49.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br /> per week.

Highest weekly average: 53.18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> per week.

Observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from 12/19/2025 to 01/01/2026.

Summary As described in the table above, to support the ongoing PNP outage activities and subsequent plant restart, the covered individuals in Group 10 CFR 26.4(a)(4) will be required to work various schedules. All schedules will remain compliant with 10 CFR 26.205(d)(1), (d)(2), and (d)(4). To ensure an adequate reset before continuing outage activities, the individuals in this Group are currently observing a rest and reset period in which no covered individual will work more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week, averaged over the two-week span from December 19, 2025 through January 1, 2026.

The Group 10 CFR 26.4(a)(4) table includes the scheduled 30-minute shift turnover time as part of the work hour averaging calculation. This is conservative because shift turnover time may be excluded from the calculation of an individual's work hours (

References:

NEI 06-11, Section 8.1, and NRC Regulatory Guide 5.73, Appendix B, page B-11).

PNP 2025-086 Enclosure Page 10 of 11 RAI 1.c:

c. The mitigating strategy enclosed in the proposed subsequent exemption is insufficient because the affected personnel 1) will miss a significant number of days off compared to the normal work hour controls; 2) will continue to work higher than average work hours beyond the initial 60-day outage; 3) will work successive periods of outage work controls that extend beyond considerations and intent of the 10 CFR 26 Subpart I rule.

Provide information that clearly addresses the insufficiencies above, including providing additional administrative controls that reduce the concerns about cumulative fatigue. For example, implementing a minimum days off schedule that aligns more with normal work hours or extending the duration of the commitment to 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per week averaged over 4 weeks.

Palisades Energy Response to RAI 1.c:

Palisades Energy provided a list of mitigating strategies in the December 12, 2025 exemption request Enclosure (ADAMS Accession No. ML25346A199) to help manage cumulative fatigue. To further reduce the concerns about cumulative fatigue, the following additional mitigation measures are provided:

During the two-week rest and reset period that commenced on December 19, 2025, the average hours per week is reduced from 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per week or less to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or less per week. Applying the guidance in 10 CFR 26.205(d)(6) to the PNP restart outage exemption, each individual working on outage activities may be extended in 7-day increments for each 7-day period the individual has worked not more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during the outage. This implies that an individual working 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or less for 7 days reduces cumulative fatigue concerns as is evident from not placing any subsequent restrictions on the individual's work hours. The attachment to the Enclosure to this letter provides a revised commitment (Commitment 1) to limit the individuals covered by 10 CFR 26.4(a)(2) [Health Physics and Chemistry] and (a)(4)

[Maintenance and Projects] to an average of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week or less for the two-week period from December 19, 2025 to January 1, 2026.

The Human Performance Program error prevention tools will be enhanced to include self-awareness of fatigue as a potential proficiency obstacle that will be assessed during pre-job briefings. Proficiency is assessed for each job, along with methods to address proficiency concerns. The attachment to the Enclosure to this letter provides a new commitment (Commitment 2) to incorporate the enhancement to the Human Performance Program prior to the January 2, 2026 start date of the 60-day exemption period requested in this letter.

RAI 1.d:

d. Describe the effectiveness of the mitigating actions, as supplemented, used during the Palisades exemption period that was approved on October 23, 2025. Provide the number of waivers issued, the number and nature of fatigue assessments conducted, including any assessments tied to specific operational events or concerns from August 24, 2025 through the current exemption period expiring on January 1, 2026.

PNP 2025-086 Enclosure Page 11 of 11 Palisades Energy Response to RAI 1.d:

The underlying purpose of 10 CFR 26.205(d)(4) is to provide licensees flexibility in scheduling required days off while accommodating the more intense work schedules associated with a unit outage, while assuring that cumulative fatigue does not compromise the abilities of individuals to safely and competently perform their duties. The increased flexibility has provided additional opportunities to identify and address issues that could affect plant safety. Promptly identifying and correcting issues provides additional safety margin to plant personnel and outage craft resources. Cognizant supervisors assess and will continue to assess employees for fatigue and mental alertness to effectively manage fatigue in accordance with the Fatigue Management Program for all covered individuals affected by the extended outage period. No waivers were required for covered workers exceeding the work hour limits during the period of less restrictive work hour limits from August 24, 2025 to date. There were three fitness for duty fatigue assessments performed for cause during the period from August 24, 2025 to date, and none of the assessments concluded that individual fatigue was a factor. Note that, although no waivers or fatigue assessments are expected, it is not possible to have conclusive knowledge of any that are issued in the future (i.e., between the date of this RAI response letter and January 1, 2026).

Enclosure Attachment PNP 2025-086 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. Palisades Energy will ensure that no individual covered by 10 CFR 26.4(a)(2) and (a)(4) works more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per week averaged over the two-week period prior to the effective date of the exemption.

01/01/2026

2. Palisades Energy will enhance the Human Performance Program error prevention tools to include self-awareness of fatigue as a potential proficiency obstacle that will be assessed during pre-job briefings.

01/01/2026

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