PNP 2024-032, Supplement to License Amendment Request to Revise Selected Permanently Defueled Technical Specifications Administrative Controls to Support Resumption of Power Operations

Supplement to License Amendment Request to Revise Selected Permanently Defueled Technical Specifications Administrative Controls to Support Resumption of Power Operations

ML24213A082
Person / Time
Site:	Palisades
Issue date:	07/31/2024
From:	Fleming J Holtec Decommissioning International
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
HDI PNP 2024-032
Download: ML24213A082 (1)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 HOLTEC Telephone (856) 797-0900 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL

HDI PNP 2024-032 10 CFR 50.90

July 31, 2024

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Palisades Nuclear Plant NRC Docket No. 50-255 Renewed Facility Operating License No. DPR-20

References:

1. Holtec Decommissioning International, LLC letter to U.S. Nuclear Regulatory Commission (HDI PNP 2024-001), "License Amendment Request to Revise Selected Permanently Defueled Technical Specifications Administrative Controls to Support Resumption of Power Operations," dated February 9, 2024 (ADAMS Accession No. ML24040A089)

2. U.S. Nuclear Regulatory Commission Email to Holtec Decommissioning International, LLC, "DRAFT Request for Additional Information: Palisades Administrative TS License Amendment Request," dated June 28, 2024 (ADAMS Accession No. ML24192A147)

Subject:

Supplement to License Amendment Request to Revise Selected Permanently Defueled Technical Specifications Administrative Controls to Support Resumption of Power Operations

In Reference 1, Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Palisades, LLC, requested U. S. Nuclear Regulatory Commission (NRC) review and approval of a proposed license amendment request (LAR) to revise the Palisades Nuclear Plant (PNP)

Renewed Facility Operating License (RFOL) DPR-20. The proposed LAR would revise the RFOL and Appendix A selected Permanently Defueled Technical Specifications (PDTS)

Section 5.0, "Administrative Controls, " to reflect the resumption of power operations at PNP.

In Reference 2, the NRC informed HDI of draft requests for additional information (RAIs) associated with items in HDI PNP 2024-001 that require clarification or administrative corrections. HDI has reviewed the NRC draft RAIs and is submitting this supplemental information to address the identified items.

The enclosure to this letter provides supplemental information to the HDI PNP 2024-001 enclosure titled "Evaluation of Proposed Changes, " that addresses the draft RAIs. Enclosure to this letter provides updated Proposed Changes (mark-up) to the PNP RFOL DRP-20 and Appendix A PDTS. Enclosure Attachment 2 to this letter provides updated retyped PNP RFOL DPR-20 and Technical Specifications pages.

HDI PNP 2024-032 Page 2 of 2

This supplement does not alter the no significant hazards consideration or environmental evaluation contained in Reference 1.

In accordance with 10 CFR 50.91(b), State consultation, HDI is notifying the State of Michigan of this LAR supplement by transmitting a copy of this letter, with its enclosure, to the designated State of Michigan official.

This letter contains no new regulatory commitments and no revisions to existing regulatory commitments.

If you have any questions regarding this submittal, please contact Jim Miksa, Manager of Regulatory Assurance, Palisades, at (269) 764-2945.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 31, 2024.

Respectfully,

Digitally signed by Jean A. Fleming Jean A. DN: cn=Jean A. Fleming, c=US, o=Holtec Decommissioning International, LLC, ou=Regulatory and Environmental Affairs, Fleming email=J.Fleming@Holtec.com Date: 2024.07.31 09:24:22 -04'00'

Jean A. Fleming Vice President of Licensing and Regulatory Affairs Holtec International

Enclosure:

Updates to License Amendment Request (LAR) Evaluation of Proposed Changes

Enclosure Attachments:

1. Updated Proposed Changes (mark-up) to Palisades Plant Renewed Facility Operating License DPR-20, Appendix A Permanently Defueled Technical Specifications

2. Updated Retyped Pages for the Palisades Plant Renewed Facility Operating License DPR-20, Appendix A Technical Spec ifications

cc: NRC Region III Regional Administrator NRC Senior Resident Inspector - PNP NRC Project Manager PNP Designated Michigan State Official HDI PNP 2024-032 Enclosure Page 1 of 12

HDI PNP 2024-032

Enclosure

Updates to License Amendment Request (LAR) Evaluation of Proposed Changes

HDI PNP 2024-032 Enclosure Page 2 of 12

Updates to License Amendment Request (LAR) Evaluation of Proposed Changes

In Reference 1, Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Palisades, LLC, requested U.S. Nuclear Regulatory Commission (NRC) review and approval of a proposed license amendment request (LAR) to revise the Palisades Nuclear Plant (PNP)

Renewed Facility Operating License (RFOL) DPR-20. The proposed LAR would revise the RFOL and Appendix A selected Permanently Defueled Technical Specifications (PDTS)

Section 5.0, "Administrative Controls," to reflect the resumption of power operations at PNP.

In Reference 2, the NRC informed HDI of draft requests for additional information (RAIs) associated with items in HDI PNP 2024-001 that require clarification or administrative corrections. HDI has reviewed the NRC draft RAIs and is submitting the below supplemental information and administrative updates to provide further clarity and administrative corrections to HDI PNP 2024-001.

The supplemental information and administrative updates are listed as items and are arranged in the order in which they appear in HDI PNP 2024-001. For each item, the section affected in HDI PNP 2024-001, the original text (if applicable), the updated text, and the reason for the change are provided.

Item 1 - Draft RAI 2, HDI PNP 2024-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, Technical Specification (TS) 5.1.1, Basis for change, Page 6 of 24

Updated text:

Insert as 3rd paragraph:

The term "responsibility during absences" in the first paragraph of TS 5.1.1 is not changed back to "responsibility during his absence." The term "or designee" in the second paragraph of TS 5.1.1 is not changed back to "or his designee". The pronoun "his" was removed in Amendment 266 (Reference 11) to make the TS gender neutral and will be retained.

Reason:

The term "his" was deleted in Amendment 266 (Reference 2). This wording is proposed to be retained to maintain reference to PNP TS organizational positions gender neutral. The retained wording is consistent with the previously proposed and approved RFOL Amendment 266. Therefore, this administrative change is acceptable.

HDI PNP 2024-032 Enclosure Page 3 of 12

Item 2 - Draft RAI 3 and 4, HDI PNP 2024-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, TS Section 5.2.2, Basis for change, Page 11 of 24

Updated text:

Replace the first paragraph with the following paragraph:

The proposed change revises Amendment 266 (Reference 11) TS Section 5.2.2 title from "Facility Staff" to "Plant Staff," to reinstate the title that was in effect prior to the 10 CFR 50.82(a)(1) certifications.

TS Section 5.2.2 introductory text, "The plant facility staff organization shall include the following:," added in Amendment 266 (Reference 11) is retained. Further, the retained introductory text is revised to replace "facility" with "plant" to clearly differentiate between a plant that is licensed for power operation and a facility with a reactor that is permanently defueled.

Reason:

The proposed revision changes the title of TS Section 5.2.2 back to "Plant Staff" from "Facility Staff" to clearly differentiate between a plant that is licensed for power operation and a facility with a reactor that is permanently defueled. This title change is administrative in nature because the intent of the TS requirements is not affected.

The proposed revision also retains the TS Section 5.2.2 introductory text, "The plant facility staff organization shall include the following:," added for TS Amendment 266 (Reference 2).

Further, the retained introductory text is revised to replace "facility" with "plant" to clearly differentiate between a plant that is licensed for power operation and a facility with a reactor that is permanently defueled. The introductory text clarifies that the subsections that follow list plant staff organization requirements.

Therefore, these administrative changes are acceptable.

Item 3 - Draft RAI 5, HDI PNP 202 4-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, TS 5.2.2.c, Page 13 of 24

HDI PNP 2024-032 Enclosure Page 4 of 12

HDI PNP 2024-001 text: Updated text:

5.2.2a 5.2.2.a

Reason:

The change to TS 5.2.2.c corrects a missing period between the last numeral and letter in the referenced TS 5.2.2.a. This change is editorial in nature.

Item 4 - Draft RAI 6, HDI PNP 202 4-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, TS 5.2.2.f, Basis for change first paragraph, Page 15 of 24

HDI PNP 2024-001 text: Updated text:

This TS is proposed for reinstatement in its This TS is proposed for reinstatement in its entirety with revision to that which entirety to that which

Reason:

The term "with revision" is deleted because the TS is proposed to be reinstated in its entirety.

This change is administrative in nature.

Item 5 - Draft RAI 6, HDI PNP 202 4-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, TS 5.2.2.g, Basis for change first paragraph, Page 15 of 24

HDI PNP 2024-001 text: Updated text:

This TS is proposed for reinstatement in its This TS is proposed for reinstatement in its entirety with revision to that which entirety to that which HDI PNP 2024-032 Enclosure Page 5 of 12

Reason:

The term "with revision" is deleted because the TS is proposed to be reinstated in its entirety.

This change is administrative in nature.

Item 6 - Draft RAI 7, HDI PNP 202 4-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, TS Section 5.3, Page 16 of 24

Updated text:

Insert the table provided below for TS Section 5.3 at the top of page 16

Reason:

The title of TS Section 5.3 is being changed back to "Plant Staff Qualifications" from "Facility Staff Qualifications," to clearly differentiate between a plant that is licensed for power operation and a facility with a reactor that is permanently defueled.

Current TS 5.3 Title Proposed TS 5.3 Title

5.3 Facility Staff Qualifications 5.3 Plant Staff Qualifications

BASIS The title of TS Section 5.3 is proposed for reinstatement to that which was in effect prior to the 10 CFR 50.82(a)(1) certifications to restore the PNP power operations RFOL. PNP proposes to revise the title of TS Section 5.3 by replacing "Facility Staff Qualifications" with

Plant Staff Qualifications" to clearly differentiate between site staff at a facility with a permanently defueled reactor and site staff at a licensed power production plant.

The proposed TS wording changes are considered administrative because the organizational term "plant staff" is analogous to "facility staff."

Item 7 - Draft RAI 8, HDI PNP 202 4-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, TS 5.3.1, Page 16 of 24 HDI PNP 2024-032 Enclosure Page 6 of 12

Updated text:

Replace the table on Page 16 describing the proposed change to TS 5.3.1 with the table provided below.

Reason:

HDI PNP 2024-001 did not specifically document retaining Amendment 266 (Reference 2) deletion of the word "Entergy" which was located just prior to the Quality Assurance Program Manual (QAPM). Deletion of the word "Entergy" supports the basis statement, "This TS is proposed for reinstatement in its entirety with revision to that which was in effect prior to the 10 CFR 50.82(a)(1) certifications...," which was questioned in draft RAI 8.

Current TS 5.3.1 Proposed TS 5.3.1

Each member of the facility staff shall meet or Each member of the plant facility staff exceed the minimum qualifications of shall meet or exceed the minimum ANSI/ANS 3.1-1978 for comparable positions qualifications of ANSI/ANS 3.1-1978 for with exceptions specified in the Quality comparable positions with exceptions Assurance Program Manual (QAPM). specified in the Entergy Quality Assurance Program Manual (QAPM).

BASIS This TS is proposed for reinstatement in its entirety with revision to that which was in effect prior to the 10 CFR 50.82(a)(1) certifications to restore the PNP power operations RFOL.

Upon recission of the 10 CFR 50.82(a)(1) certifications, as conditioned by the exemption to 10 CFR 50.82(a)(2) (Reference 3), this TS is reinstated substantially, as it existed in the previously approved POTS prior to Amendment 266 (Reference 11), to reflect the power operation condition of the plant.

"Facility," which was adopted in Amendment 266 (Reference 11), is replaced with "plant" to clearly differentiate between a plant that is licensed for power operation and a facility with a reactor that is permanently defueled. This is not a change from the revision that was in effect prior to the 10 CFR 50.82(a)(1) certifications to restore the PNP power operations RFOL and is noted here for clarity.

"Entergy" is deleted as a descriptor of the Quality Assurance Program Manual (QAPM) to allow PNP to transition to a site-specific QAPM.

The proposed TS wording changes are considered administrative because the organizational term "plant staff" is analogous to "facility staff" and an NRC approved QAPM is still required regardless of it being an Entergy corporate QAPM or a PNP site-specific QAPM.

HDI PNP 2024-032 Enclosure Page 7 of 12

Item 8 - Draft RAI 8, HDI PNP 2024-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, TS 5.3.5, Basis for change first paragraph, Page 17 of 24

HDI PNP 2024-001 text: Updated text:

This TS is proposed for reinstatement in its This TS is proposed for reinstatement in its entirety with revision to that which entirety to that which

Reason:

The term "with revision" is deleted because the TS is proposed to be reinstated in its entirety.

This change is administrative in nature.

Item 9 - Draft RAI 9, HDI PNP 202 4-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, TS 5.4.1.a, Basis for change first paragraph, Page 17 of 24

HDI PNP 2024-001 text: Updated text:

This TS is proposed for reinstatement in its This TS is proposed for reinstatement in its entirety with revision to that which entirety to that which

Reason:

The term "with revision" is deleted because the TS is proposed to be reinstated in its entirety.

This change is administrative in nature.

HDI PNP 2024-032 Enclosure Page 8 of 12

Item 10 - Draft RAI 9, HDI PNP 2024-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, TS 5.4.1.b, Basis for change first paragraph, Page 18 of 24

HDI PNP 2024-001 text: Updated text:

This TS is proposed for reinstatement in its This TS is proposed for reinstatement in its entirety with revision to that which entirety to that which

Reason:

The term "with revision" is deleted because the TS is proposed to be reinstated in its entirety.

This change is administrative in nature.

Item 11 - Draft RAI 1, HDI PNP 2024-001 Enclosure, "Evaluation of the Proposed Changes"

Section affected:

HDI PNP 2024-001 Enclosure, Section 3.1.1, Proposed Changes to the Permanently Defueled Technical Specifications, TS 5.5.1.c.2, 5.5.15.b.2, and 5.7.2.a.1, Page 18 of 24

Updated text:

Insert the tables provided below for TS 5.5.1.c.2, 5.5.15.b.2, and 5.7.2.a.1 after the TS 5.4.1.b change

Reason:

HDI PNP 2024-001 did not specifically document retaining the Amendment 266 (Reference 2) TS 5.5.1.c.2, TS 5.5.15.b.2 and TS 5.7.2.a.1 changes to "plant manager" from "plant superintendent," and to "shift manager" from "shift supervisor." Retention of the position title "plant manager" is consistent with standard technical specifications (STS), and previously approved license amendments. Additionally, retention of the position title "shift manager" and "plant manager," will more closely represent the proposed future PNP operating organization position titles.

NOTE: The current TS text is identical to the proposed TS text, therefore; updated markup and/or retyped TS pages are not provided.

HDI PNP 2024-032 Enclosure Page 9 of 12

Current TS 5.5.1.c.2 Proposed TS 5.5.1.c.2

Shall become effective after approval by the Shall become effective after approval by plant manager. the plant manager.

BASIS The term "plant manager" is not changed back to "plant superintendent," which was in effect prior to the 10 CFR 50.82(a)(1) certifications to restore the PNP power operations RFOL, because the terms are equivalent, "plant manager" is consistent with Standard Technical Specifications (STS) position titles, and will more closely represent the proposed future PNP operating organization position titles. Therefore, this administrative change is acceptable.

The retained wording has been previously proposed and approved for use at Palisades in license Amendment 266 (Reference 11).

Current TS 5.5.15.b.2 Proposed TS 5.5.15.b.2

Shall become effective after approval by the Shall become effective after approval by plant manager. the plant manager.

BASIS The term "plant manager" is not changed back to "plant superintendent," which was in effect prior to the 10 CFR 50.82(a)(1) certifications to restore the PNP power operations RFOL, because the terms are equivalent, "plant manager" is consistent with STS position titles, and will more closely represent the proposed future PNP operating organization position titles.

Therefore, this administrative change is acceptable.

The retained wording has been previously proposed and approved for use at Palisades in license Amendment 266 (Reference 11).

Current TS 5.7.2.a.1 Proposed TS 5.7.2.a.1

All such door and gate keys shall be All such door and gate keys shall be maintained under the administrative control of maintained under the administrative control the shift manager, radiation protection of the shift manager, radiation protection manager, or his or her designee. manager, or his or her designee.

BASIS The term "shift manager" is not changed back to "shift supervisor," which was in effect prior to the 10 CFR 50.82(a)(1) certifications to restore the PNP power operations RFOL, because the terms are equivalent, and will more closely represent the proposed future PNP operating organization position titles. Therefore, this administrative change is acceptable.

The retained wording has been previously proposed and approved for use at Palisades in license Amendment 266 (Reference 11).

HDI PNP 2024-032 Enclosure Page 10 of 12

Item 12 - Draft RAI 5, HDI PNP 2024-001 Enclosure Attachment 1, " Proposed Changes (mark-up) to Palisades Plant Renewed Facility Operating License DPR-20 and Appendix A, Permanently Defueled Technical Spec ifications Pages"

Section affected:

HDI PNP 2024-001 Enclosure Attachment 1, " Proposed Changes (mark-up) to Palisades Plant Renewed Facility Operating License DPR-20 and Appendix A, Permanently Defueled Technical Specifications Pages."

Attachment 1 to this enclosure (HDI PNP 2024-032) contains a replacement page that supersedes the one provided in HDI PNP 2024-001. The corresponding page in HDI PNP 2024-001 Attachment 1 (Reference 1) is to be replaced with the page in Attachment 1 to this enclosure.

Remove Page from HDI PNP 2024-001, Insert Page from HDI PNP 2004-032, Enclosure Attachment 1 Enclosure Attachment 1 RFOL Appendix A Technical Specifications RFOL Appendix A Technical Specifications Pages Pages

5.0-3 5.0-3

Missing "." between the last numeral and letter in 5.2.2a and 5.2.2g

Reason:

The inserted page includes an administrative correction and supersedes the removed page from HDI PNP 2024-001.

The change to TS Section 5.2.2.c corrects a missing period between the last numeral and letter in the referenced TS sections. This change is editorial in nature.

HDI PNP 2024-032 Enclosure Page 11 of 12

Item 13 - Draft RAI 5, HDI PNP 2024-001 Enclosure Attachment 2, " Page Change Instructions and Retyped Pages for the Palisades Plant Renewed Facility Operating License DPR-20 and Appendix A Technical Spec ifications"

Section affected:

HDI PNP 2024-001 Enclosure Attachment 2, " Page Change Instructions and Retyped Pages for the Palisades Nuclear Plant Renewed Facility Operating License DPR-20 and Appendix A, Technical Specifications."

Attachment 2 to this enclosure (HDI PNP 2024-032) contains a replacement page that supersedes the one provided in HDI PNP 2024-001. The corresponding page in HDI PNP 2024-001 Attachment 2 (Reference 1) is to be replaced with the page in Attachment 2 to this enclosure.

Remove Pages from HDI PNP 2024-001, Insert Pages from HDI PNP 2004-032, Enclosure Attachment 2 Enclosure Attachment 1 RFOL Appendix A Technical Specifications RFOL Appendix A Technical Specifications Pages Pages

5.0-3 5.0-3

Missing "." between the last numeral and letter in 5.2.2a and 5.2.2g

Chapter Title "5.0 ADMINISTRATIVE CONTROLS," should not be repeated with the continuation of Section 5.2, Organization.

Reason:

The inserted page includes an administrative correction and supersedes the removed page from HDI PNP 2024-001.

The change to TS 5.2.2.c corrects a missing period between the last numeral and letter in the referenced TS 5.2.2a and 5.2.2g. Additionally, the Chapter title "5.0 ADMINISTRATIVE CONTROLS," is deleted because it is repeated at the top of a Section 5.2 Organization continued page. These changes are editorial in nature.

HDI PNP 2024-032 Enclosure Page 12 of 12

References

1. Holtec Decommissioning International, LLC letter to U.S. Nuclear Regulatory Commission (HDI PNP 2024-001), "License Amendment Request to Revise Selected Permanently Defueled Technical Specifications Administrative Controls to Support Resumption of Power Operations," dated February 9, 2024 (ADAMS Accession No. ML24040A089)

2. U.S. Nuclear Regulatory Commission letter to Entergy Nuclear Operations, Inc., "Palisades Nuclear Plant - Issuance of Amendment Regarding Administrative Control for Permanently Defueled Condition (CAC No. MG0021; EPID L-2017-LLA-0266)," dated June 4, 2018 (ADAMS Accession No. ML18114A410)

HDI PNP 2024-032

Enclosure Attachment 1

Updated Proposed Changes (mark-up) to Palisades Plant

Renewed Facility Operating License DPR-20,

Appendix A Permanently Defueled Technical Specifications

Only replacement pages are provided. Please replace the affected page from HDI PNP 2024-001 (Reference 1) with the attached page.

1 page follows Organization 5.2

5.2 Organization/g3

5.2.2 Facility Plant Staff (Continued)

E Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER.(Deleted)

F Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i), and 5.2 2 a. and 5.2.2 g for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements. and all the following are met:

1) No fuel movements are in progress, and

2) No movement of loads over fuel are in progress, and

3) No unmanned shift positions during shift turnover shall be permitted due to an incoming shift crew member being late or absent.

G A radiation protection technician shall be on site during the movement of whenfuel is in the reactor and during the movement of loads over fuel.

The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

H At least one person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the control room when nuclear fuel is stored in the spent fuel pool.(Not Used)

I The shift operations manager or an assistant operations manager shall hold an SRO licensebe a CERTIFIED FUEL HANDLER. The individualholding the SRO license shall be responsible for directing the activities of the licensed operators.

J When in MODES 1, 2, 3, or 4 an individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operations of the plant. This individual shall meet the qualifications specified by ANSI/ANS 3.1 1993 as endorsed by 5*1.8, Rev. 3, 2000. (Deleted)

Palisades Nuclear Plant 5.0-3 Amendment No. 266, XXX HDI PNP 2024-032

Enclosure Attachment 2

Updated Retyped Pages for the Palisades Plant

Renewed Facility Operating License DPR-20,

Appendix A Technical Specifications

Only replacement pages are provided. Please replace the affected page from HDI PNP 2024-001 (Reference 1) with the attached page.

1 page follows Organization 5.2

5.2 Organization

5.2.2 Plant Staff (Continued)

F Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i), and 5.2.2 a and 5.2.2 g for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the requirements.

G A radiation protection technician shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order toprovide for unexpected absence, provided immediate action is taken to fill the required position.

H (Not Used)

I The operations manager or an assistant operations manager shall hold an SRO license. The individual holding the SRO license shall be responsiblefor directing the activities of the licensed operators.

J When in MODES 1, 2, 3, or 4 an individual shall provide advisory technicalsupport to the unit operations shift crew in the areas of thermal hydraulics,reactor engineering, and plant analysis with regard to the safe operationsof the plant. This individual shall meet the qualifications specified by ANSI/ANS 3.1-1993 as endorsed by RG 1.8, Rev. 3, 2000.

Palisades Nuclear Plant 5.0-3 Amendment No. 266, XXX