PNP 2024-045, Milestone Schedule for Generic Letter 2004-02 Remaining Actions
| ML24346A171 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/11/2024 |
| From: | Fleming J Holtec Palisades |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| HDI PNP 2024-045, GL 2004-02 | |
| Download: ML24346A171 (1) | |
Text
27780 Blue Star Highway, Covert, MI 49043 HDI PNP 2024-045 GL 2004-02 December 11, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Renewed Facility Operating License No. DPR-20 NRC Docket Nos. 50-255
Subject:
Palisades Nuclear Plant - Milestone Schedule for Generic Letter 2004-02 Remaining Actions In Reference 1, Entergy Nuclear Operations, Inc., notified the Nuclear Regulatory Commission (NRC) that it had selected the risk-informed version of Option 2 in Commission Paper SECY 0093, Closure Options for Generic Safety Issue - 191 (GSI-191), Assessment of Debris Accumulation on Pressurized-Water Reactor Sump Performance, dated September 13, 2004, for Palisades Nuclear Plant (PNP).
In Reference 2, PNP submitted a schedule for completion of risk-informed GSI-191 resolution activities.
Reference 3 summarizes a public meeting NRC held with PNP to discuss the closure plan for the PNP GSI-191 project. A revised milestone schedule was presented by PNP during the meeting.
In Reference 4, PNP submitted a certification of permanent cessation of power operations with a shutdown date of October 1, 2018. In Reference 5, NRC issued PNP a closure letter for GL 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, citing the planned shutdown date of October 1, 2018 for PNP.
In Reference 6, PNP notified the NRC that PNP would permanently cease power operation no later than May 31, 2022. Due to the postponed shutdown date for PNP, a revised schedule was provided for GSI-191 risk-informed resolution at PNP in Reference 7.
PNP provided a summary of actions taken for GSI-191 resolution in Reference 8, and notified the NRC that PNP did not intend to take additional actions for GSI-191 closure due to plans to permanently cease power operations. The letter also provided notification that PNP was cancelling three (3) related commitments. Cancellation of the three (3) remaining GSI-191 commitments was acknowledged by NRC in Reference 9.
HDI PNP 2024-045 Page 2 of 3 On July 22, 2019, GSI-191 was closed by the NRC based on industry actions demonstrating the low safety significance of the issue. However, a licensee response to GL 2004-02 is still required. With PNP now on a regulatory path to resume power operations, work has resumed to provide a response to GL 2004-02 for PNP. As documented in Reference 10, Holtec Decommissioning International, LLC (HDI) staff met with NRC in a public meeting on October 24, 2024, to inform the NRC of HDI plans to resume work on GL 2004-02 and present closure plan key elements. The presentation included a summary of GL 2004-02 / GSI-191 work completed to date as well as a proposed milestone schedule for closure of GL 2004-02. The closure plan summary and proposed milestone schedule is included as Attachment 1 to this letter.
This letter also notifies the NRC that three (3) GL 2004-02 / GSI-191 related commitments originally put in place per Reference 1 and cancelled in Reference 8 will be reinstated upon transition of PNP to a power operations licensing basis. The reinstated updated commitments are re-introduced in Attachment 2.
Should you have any questions or require additional information, please contact Jim Miksa, Regulatory Assurance Manager at (269) 764-2945.
Respectfully, Jean A. Fleming Vice President, Licensing and Regulatory Affairs Holtec International
References:
- 1) Entergy Nuclear Operations, Inc. (Entergy) letter to Nuclear Regulatory Commission (NRC), PNP 2013-041,"Generic Safety Issue - 191 Closure Option," dated May 15, 2013 (ADAMS Accession No. ML13136A006)
- 2) Entergy letter to NRC, PNP 2013-092, "Schedule for Generic Safety Issue -
191 Resolution," dated December 18, 2013 (ADAMS Accession No. ML13353A567)
- 3) NRC letter to Entergy, "Summary of September 28, 2016, Public Meeting with Entergy Nuclear Operations, Inc. Regarding the Proposed Closure Plan for Generic Safety Issue 191, 'Assessment of Debris Accumulation on Pressurized Water Reactor (PWR) Sump Performance' (CAC No. MF8386),"
dated October 11, 2016 (ADAMS Accession No. ML16277A677)
- 4) Entergy letter to NRC, PNP 2017-001, "Certification of Permanent Cessation of Power Operations," dated January 4, 2017 (ADAMS Accession No. ML17004A062)
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: 2024.12.11 13:11:37 -05'00' Jean A.
Fleming
HDI PNP 2024-045 Page 3 of 3
- 5) NRC letter to Entergy, "Palisades Nuclear Plant-Closure of NRC Generic Letter 2004-02 (CAC No. MC4701)," dated February 22, 2017 (ADAMS Accession No. ML17030A014)
- 6) Entergy letter to NRC, PNP 2017-065, "Supplement to Certification of Permanent Cessation of Power Operations," dated October 19, 2017 (ADAMS Accession No. ML17292A032)
- 7) Entergy letter to NRC, PNP 2018-017, "Milestone Schedule for Generic Safety Issue - 191 Resolution," dated March 29, 2018 (ADAMS Accession No. ML18088A139)
- 8) Entergy letter to NRC, PNP 2019-002, "Status of Remaining Actions for Generic Safety Issue - 191 Resolution," dated March 05, 2019 (ADAMS Accession No. ML19064A089)
- 9) NRC letter to Entergy, "Palisades Nuclear Plant - Response to Status of Remaining Actions for Generic Safety Issue (GSI) - 191 Resolution," dated September 6, 2019 (ADAMS Accession No. ML19246B981)
- 10) NRC Summary of October 24, 2024, Meeting with Holtec Decommissioning International, LLC Regarding Generic Safety Issue 191 Closure Plan to Support Potential Reauthorization of Power Operations at Palisades Nuclear Plant dated November 25, 2024 (ADAMS Accession No. ML24311A165)
Attachments: 1. Closure Plan Summary and Milestone Schedule for Generic Letter 2004-02 Resolution
- 2. 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
HDI PNP 2024-045 Closure Plan Summary and Milestone Schedule for Generic Letter 2004-02 Resolution 1 Page Follows
Closure Plan Summary and Milestone Schedule for Generic Letter 2004-02 Resolution PNP has selected the risk-informed conditional failure probability (CFP) option for resolution of GL 2004-02. The CFP risk informed approach was selected for PNP because it most accurately evaluates PNP post-Loss of Coolant Accident (LOCA) conditions. This approach has been utilized by other licensees for successful resolution of GL 2004-02.
PNP plans to update key GSI-191 calculations and tests performed prior to ceasing power operations after which an assessment will be performed to determine if the CFP option remains preferred or if another option such as the alternate break methodology should be used to evaluate PNP post-LOCA conditions.
PNP plans to evaluate in-vessel effects related to particulate, fibrous and chemical debris utilizing industry guidance documents. PNP will draw off industry operating experience to inform the overall GL 2004-02 assessment.
The schedule provided below contains the major milestones for completion of the GL 2004-02 resolution path activities at PNP.
Milestone Milestone Completion Date1 NRC Public Meeting - Palisades Nuclear Plant GL 2004-02 / GSI-191 Closure Plan Complete October 24, 2024 Submit Updated GL 2004-02 Closure Plan to NRC Complete December 11, 2024 (This letter)
Develop/update GSI-191 calculations (debris generation, transport, chemical effects) 2Q2025 Conduct strainer testing (head loss, penetration) 3Q2025-4Q2025 Decision Point - Use of Conditional Failure Probability or Alternate Break approach 1Q2026 Finalize GSI-191 calculations (strainer structural qualification, in-vessel effects, PRA inputs, risk/uncertainty quantification) 2Q2026 NRC Pre-submittal Meeting 2Q2026 Submit Final Response and Close-out to GL 2004-02 per Revised Content Guide for Generic Letter 2004-02 Supplemental Responses, November 2007 (ML073110278).
2Q2026 1 Milestone dates are subject to change as implementation progresses.
HDI PNP 2024-045 List of Regulatory Commitments 1 Page Follows
Regulatory Commitments This table identifies actions discussed in this letter for which, upon approval, Holtec Decommissioning International, LLC (HDI), Holtec Palisades, LLC (Holtec Palisades), or Palisades Energy, LLC (OPCO) commits to perform. Any other actions discussed in this submittal are described for the U.S. Nuclear Regulatory Commissions (NRC) information and are not commitments.
Original Commitment Type (Check One)
Scheduled Completion Date One-Time Action Continuing Compliance HDI will complete any necessary insulation replacements or remediation, or other identified plant changes.
X During the refueling outage that follows issuance of a [safety evaluation] SE for the risk-informed resolution [license amendment request] LAR for Palisades Nuclear Plant (PNP)
HDI will submit a final updated supplemental response to support closure of [Generic Letter] GL 2004-02 for PNP per Revised Content Guide for Generic Letter 2004-02 Supplemental Responses, November 2007 (ML073110278).
X Within six months of receipt of the SE for the risk-informed resolution LAR for PNP.
If it is determined during the risk-informed process that this option is not viable, HDI will complete a deterministic resolution path that is acceptable to the NRC.
X Within two refueling outages after notifying the NRC that a risk-informed process is not viable.