IR 05000293/2020002
| ML20335A009 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/30/2020 |
| From: | Anthony Dimitriadis Decommissioning Branch I |
| To: | Cowan P Holtec Decommissioning International |
| References | |
| IR 2020002, IR 2020003 | |
| Preceding documents: |
|
| Download: ML20335A009 (16) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BOULEVARD, SUITE 100
SUBJECT:
NRC INSPECTION REPORT NO. 05000293/2020002 & 2020003, HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, PILGRIM NUCLEAR POWER STATION, PLYMOUTH, MASSACHUSETTS
Dear Ms. Cowan:
On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a period of onsite and remote inspections under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program," at the permanently shutdown Pilgrim Nuclear Power Station (PNPS). Onsite inspections were performed on July 13 - 16 and August 17 - 20, 2020.
Additional inspection activities (in office reviews via remote means) were conducted throughout the period as a consequence of the COVID-19 public health emergency (PHE). The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and the conditions of your license. The inspection consisted of observations by the inspectors, interviews with site personnel, and a review of procedures and records. The results of the inspection were discussed with Mr. John Moylan, Site Vice President and other members of the PNPS staff on November 9, 2020, and are described in the enclosed report. No findings of safety significance were identified.
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's Website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays). No reply to this letter is required. Please contact Harold (Harry) Anagnostopoulos at 610-337-5322 if you have any questions regarding this matter.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Nuclear Materials Safety Docket No. 05000293 License No. DPR-35 Enclosure: Inspection Report 05000293/2020002 & 2020003 w/Attachment cc w/encl: Distribution via ListServ
EXECUTIVE SUMMARY
Holtec Decommissioning International, LLC (HDI)
Pilgrim Nuclear Power Station (PNPS)
NRC Inspection Report No. 05000293/2020002 & 2020003 A period of announced decommissioning inspections was completed on September 30, 2020.
Onsite inspections were performed on July 13 - 16 and August 17 - 20, 2020. Remote inspection activities were conducted throughout the period as a consequence of the COVID-19 public health emergency (PHE). The inspections included a review of the fire protection program, inspection of dry fuel storage efforts, organization and management, safety reviews &
design changes, self-assessments, audits, corrective actions, spent fuel pool safety, decommissioning performance and status, maintenance and surveillance, and occupational radiation exposure. The inspections consisted of observations by the inspectors, interviews with PNPS personnel, a review of procedures and records, and plant walkdowns. The NRC's program for overseeing the safe operation of a shutdown nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program."
Based on the results of this inspection, no findings of safety significance were identified.
ii
REPORT DETAILS
1.0 Background June 10, 2019, Entergy Nuclear Operations, Inc. (ENOI) certified cessation of power operations and the permanent removal of fuel from the PNPS reactor vessel (ADAMS Accession Number: ML19161A033). This met the requirements of 10 Code of Federal Regulations (CFR) 50.82(a)(1)(i) and 50.82(a)(1)(ii). On June 11, 2019, the NRC notified PNPS that the Operating Reactor Assessment Program would terminate and that implementation of the Decommissioning Power Reactor Inspection Program would begin (ADAMS Accession No. ML19162A033). On August 27, 2019 an amended license was issued transferring the license from ENOI to Holtec International, LLC HDI (ADAMS Accession No. ML19235A050). PNPS is in active decommissioning with fuel in the spent fuel pool as described in IMC 2561.
2.0 Decommissioning Fire Protection Program
a. Inspection Scope
[Inspection Procedure 64704]
The inspectors performed an inspection of Holtec Decommissioning Internationals (Holtec) Fire Protection Program (FPP) to determine if the program was sufficiently implemented and maintained to satisfy the nuclear safety and radioactive release goals, objectives, and performance criteria. The last performance of Inspection Procedure 71111.05T, Fire Protection (Triennial), at Pilgrim was completed on November 1, 2018.
The results of that inspection were documented in NRC Inspection Report 05000293/2018015 (ADAMS Accession No. ML18339A084). Except for changes to the onsite fire brigade and reliance on offsite fire emergency response organization(s) to respond to an onsite fire, no major changes had been implemented to the Pilgrim Fire Protection Program since that inspection. Therefore, the inspection was limited to reviewing the adequacy of the Fire Protection Program with respect to these changes.
Per Regulatory Guide 1.191, Fire Protection Program for Nuclear Power Plants during Decommissioning and Permanent Shutdown, the licensee of a permanently shut down nuclear power plant is required by 10 CFR 50.48(f) to maintain a Fire Protection Program to address the potential for fires that could result in the release or spread of radioactive materials. The primary focus is protection of the integrity of the spent fuel and preventing or minimizing the release of radioactive materials resulting from fires involving contaminated plant systems or radioactive waste. To accomplish the inspection objectives, the inspectors utilized the guidance provided in Inspection Procedure 64704 and Regulatory Guide 1.191 and assessed the adequacy of the onsite incipient fire brigade and reliance on offsite fire emergency response organization(s) to respond to an onsite fire.
Inspection of the adequacy of the overall Fire Protection Program will be coordinated when additional substantive changes have been made to support the decommissioning effort.
b. Observations and Findings
Based on the inspection results, the inspectors concluded that Holtec appropriately maintained the FPP related to the fire brigade within the NRC requirements of 10 CFR 50.48(f) for plants undergoing decommissioning. Holtec maintained the leadership, staffing, and training of the onsite fire brigade. Agreements were appropriately established with the Town of Plymouth Fire Department, a fully staffed and professional fire department, to be the primary responder for onsite fires. Procedures for response and measures for coordination with offsite responders were appropriately established.
The inspectors verified that Holtec conducted training with offsite responders on facility layout, fire hazards, fire plans, firefighting equipment, radiological hazards, and health physics relevant to firefighting operations. The inspectors confirmed that Holtec maintained applicable onsite firefighting equipment (e.g., fire pumps) and assured compatibility of the plants fire system connections with fire apparatus and equipment of the offsite responders.
c. Conclusions
No findings of significance were identified.
3.0 Independent Spent Fuel Storage Installation 3.1 Pre-operational Testing of an ISFSI (IP 60854)
a. Inspection Scope
On May 11-24, 2020, the inspectors performed a remote inspection (via teleconference and video-feed) of pre-operational dry-run activities that were performed in order to demonstrate proficiency in the implementation of a licensee procedure associated with drying multi-purpose canisters (MPC). This is a new procedure that incorporates the licensees transition from vacuum drying to the use of a Forced Helium Dehydration System (FHD) for the MPC. This procedure implements Engineering Change Order No.
5014-295 and outlines performance of a reverse flow operation to reduce time required to meet the requirements of Certificate of Compliance (CoC) 72-1014, Amendment 12.
In this change, the gas stream enters through the MPC drain access port and exits through the MPC vent access port.
During the dry-run activities, the inspectors observed cask processing activities (via use of a mock MPC) to determine whether the Pilgrim staff and contractors had appropriately developed, implemented, and evaluated preoperational testing activities to safely process an MPC. This included observations of MPC blowdown, FHD, and helium backfilling.
The inspectors also observed Pilgrim pre-job briefings to assess their ability to identify critical steps of the evolution, potential failure scenarios, and the use of human performance tools to prevent errors.
The remote inspection was augmented through in-office review of the licensees 10 CFR 72.212 report, records, and procedures provided for this portion of the inspection.
b. Observations and Findings
The inspectors noted that altering the direction of flow while drying the MPC contents did not affect ability of FHD to reach the CoC required drying or backfill limits.
The inspectors noted the fuel basket of the MPC-68M (versus the previous MPC-68) is fabricated entirely from sectional Metamic (neutron absorbing material). This, combined with the use of fuel spacers, ensures that the active fuel region of fuel assemblies remains within the neutron-poison region of the MPC basket with water in the MPC.
The MPC-68M fuel spacers have square flow holes that are one inch from the bottom of the basket. The previously-used MPC-68 fuel baskets had arced flow holes cut out of the bottom of the panels.
During the dry-run with the new MPC-68M, a fuel assembly seating verification fit-up test was performed by inserting a test (i.e., non-fuel) bundle into five of the MPC fuel channels. In one of the channels, Pilgrim encountered an interference at the bottom of fuel channel F-5. Pilgrim temporarily ceased operation and entered the condition into their corrective action program as PIL-01627. To understand the scope of the issue, all channels were challenged with a test fuel bundle, and it was found that 30 spacers in the fuel basket had failed to seat properly. The cause was determined to be a result of the less ridged neutron-absorbing panels and different flow holes of the MPC-68M.
To complete the dry-run, all MPC-68M fuel channels were re-tested and all fuel spacer fit-up issues were corrected. Pilgrim fabricated a testing-rod that is now used to verify that the proper channel length is present prior to loading a fuel bundle into that channel.
c. Conclusions
No findings of significance were identified.
3.2 Operation of an ISFSI at Operating Plants (IP 60855)
a. Inspection Scope
On May 18-15, 2020, the inspectors performed a remote inspection (via teleconference and video-feed) due to Covid-19 restrictions, to evaluate Pilgrims loading of their first of eleven MPCs of the 2020 dry fuel storage loading campaign. On July 13-16, 2020, the inspectors performed an onsite inspection to evaluate the loading of the ninth MPC.
The inspections encompassed fuel transfer operations from the spent fuel pool to dry storage, using the HI-STORM 100 dry cask storage system.
The inspections included:
- Cask No. 18 (MPC serial number 1021-685), HI-STORM Serial No. 1284, and
- Cask No. 26 (MPC serial number 1021-678), HI-STORM Serial No. 1276
- The inspectors reviewed several major updates to the dry fuel storage efforts, examined the HI-STORM 100 certificate of compliance No. 72-1014 (Amendment 12), and final safety analysis report (FSAR) Revision 17.
The inspectors reviewed Pilgrims program associated with fuel characterization and selection for dry storage. The inspectors reviewed the first cask fuel selection package to verify that the licensee was loading fuel in accordance with the CoC, TS, and procedures. Inspectors reviewed a recording made of the fuel assemblies loaded into the first MPC to ensure the loading was in accordance with Pilgrims loading plan. The inspectors observed fuel assemblies being loaded into the MPC.
The inspectors observed transport and submerging of the HI-TRAC/MPC into the spent fuel pool and onto the cask leveling platform. As part of this review the inspectors observed radiation protection technicians as they performed surveys, decontamination work and provided job coverage for the cask loading workers. This assessment included review of survey data maps and radiological records from the first MPC loading.
The inspectors observed MPC processing activities, including helium backfill, hydrostatic testing, and helium leak testing of the vent and drain port covers. The inspectors observed the set-up of remote equipment (i.e., the robotic weld-head), hydrogen gas purge and monitoring, and MPC lid fit-up and welding. The inspectors observed weld surface pre-cleaning and drying, dye penetrant application, penetrant removal, developer application, and final weld assessment.
The inspectors performed a walk-down of the heavy haul path and toured the ISFSI pad to assess the material condition of the pad and the HI-STORM modules. As part of the movement of the MPC and HITRAC, the inspectors observed HI-TRAC stack-up, download of MPC into the overpack, and transport of overpack with the loaded MPC to ISFSI Pad.
The inspectors also reviewed the licensees planned activities associated with long-term operation and monitoring of the ISFSI.
The inspectors reviewed corrective action reports and the associated follow-up actions that were generated during and after Pilgrims dry-run demonstrations to ensure that issues were entered into the corrective action program, prioritized, and evaluated in a manner that is commensurate with their safety significance.
b. Observations and Findings
Dry fuel storage campaign activities were determined to be in compliance with the MPC-68M CoC, TS, regulatory requirements, and station procedures.
The inspectors noted that welding procedure specifications were qualified in accordance with Holtec welding requirements, and that welders and personnel performing visual examination/NDE of welds were trained and certified under PCI Energy Services (an approved Holtec vendor).
The inspectors noted that ISFSI staff maintained doses associated with dry cask activities as low as reasonably achievable (ALARA). The ionizing radiation exposure for the first MPC evolution was 1,465 mRem, and this was reduced to 803 mRem for the eighth cask. This reduction was attributed to improvements in operations and appropriate adjustments as the campaign progressed.
The inspectors also verified that transient combustibles were not being stored on the ISFSI pad or the vicinity of the HI-STORMS. The inspectors also confirmed that transient combustible materials entry onto the ISFSI pad was controlled in accordance with procedures.
c. Conclusions
No findings of significance were identified.
3.3 Review of 10 CFR 72.212(b) Evaluations (IP 60856)
a. Inspection Scope
The inspectors reviewed a Pilgrim 10 CFR 72.212(b) evaluation (Revision 5). This evaluation allowed the application of changes that were authorized by CoC 1014, Amendment 12 to a storage module that was previously loaded under the initial CoC 1014, Amendment 7.
The inspectors reviewed Holtecs evaluation of Engineering Change (EC) No. 82162, Dry Fuel Storage Licensing & Operations that addressed Phase 1 dry fuel storage (DFS) operations.
b. Observations and Findings
The inspectors verified that Pilgrim was in compliance with CoC 1014, Appendix A, Technical Specifications, and Appendix B, Approved Contents and Design Features" are applicable to the PNPS ISFSI. The inspectors also determined that the storage modules deployed at the PNPS ISFSI complied with all applicable terms, conditions, and specifications in Amendment 7 and/or 12 of HI-STORM CoC.
The inspectors determined that an appropriate regulatory basis was used for loading and transporting eleven HI-STORM 100S Version B storage modules, containing MPC-68M canisters with spent fuel, to the lower ISFSI pad.
Specifically, EC No. 82162 included adequate justification for a number of departures from prior DFS operations including; use of a new tracked vertical cask transporter, placement of HI-TRAC with empty MPC directly on rails, and installation/removal of the HI-STORM lid using a mobile crane. The EC also adequately addressed licensing requirements.
c. Conclusions
No findings of significance were identified.
4.0 Decommissioning Performance and Status Review
a. Inspection Scope
[Inspection Procedures 36801, 37801, 40801, 60801, 62801, 71801, 83750]
The inspectors reviewed a sample of licensee commitments and requirements.
The inspectors evaluated the contribution of the onsite safety review committee and the 10 CFR 50.59 safety review process. The inspectors reviewed plant modifications and plans for any major decommissioning activities.
The inspectors assessed Holtecs ability to identify, resolve, and prevent problems and deficiencies.
The inspectors also reviewed spent fuel pool instrumentation, alarms, and leakage detection, and verified that Pilgrims wet spent fuel storage and handling controls were consistent with regulatory requirements and the applicable safety requirements.
The inspectors evaluated the maintenance and surveillance programs to determine if they supported the safe storage of spent fuel and the reliable operation of radiation monitoring and effluent control equipment. The inspectors examined maintenance work priorities and backlog. The inspectors also conducted conference calls to discuss a historical issue with neutron absorbing materials in the spent fuel pool and how the facility is controlling heavy loads onsite.
The inspectors attended a sampling of licensee meetings and verified that licensee activities were in accordance with licensed requirements. The inspectors performed a walkdown of the main control room and examined the controls and indicators that were currently available to the operating staff. The inspectors performed plant tours and observed the conduct of facility maintenance, repair, and operations. In addition, the inspectors reviewed the organization, experience, and staffing levels of the radiation protection (RP) organization.
The inspectors examined the planning and authorization of radiation work and observed the conduct of radiological work and radiation protection technician work coverage. The inspectors also attended a pre-job briefing for removal of control rod drive mechanisms and observed the work inside the drywell. The inspectors observed the movement of an intermodal container that was posted and controlled as a locked high radiation area and also observed the cutting of local power range monitors on the refueling floor.
The inspectors reviewed the Pilgrim programs for external radiation exposure monitoring and control, internal radiation exposure monitoring and control, radioactive contamination monitoring and control, and radioactive material control. The inspectors also reviewed Pilgrims programs for ionizing radiation exposure optimization.
b. Observations and Findings
The inspectors determined that the quality assurance organization conducted a program of audits and surveillances that were critical and intrusive, and that the organization was active in the follow-up of previous audit observations and findings (in an effort to ensure effective resolution).
The inspectors noted an active involvement by the Pilgrim site industrial safety representative in oversight of the site characterization efforts.
The inspectors noted that the site safety review process did not explicitly call for the reviewer to screen any proposed program change for an impact on UFSAR accidents and accident analysis. The inspectors did further note that the current procedure did accomplish this by implication and that the process could be enhanced (and facilitate review and audit) by calling this out explicitly. This was discussed with the licensee during the inspection period.
The inspectors determined that the pre-planning for removal of the control rod drive mechanisms, which can exhibit elevated radiation exposure levels, was extensive and effective in controlling the work in a safe and efficient manner.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
5.0
Exit Meeting Summary
On November 9, 2020, the lead inspector presented the inspection results to Mr. John Moylan, Site Vice President, and other members of the HDI staff. No proprietary information was retained by the inspectors or documented in this report.
PARTIAL LIST OF PERSONS CONTACTED J. Moylan, Site Vice President A. Sterdis, Regulatory Assurance Vice President J. McDonough, Operations Manager D. Noyes, Senior Compliance Manager L. Berlinski, Nuclear Consultants International - Lead Oversight Manager M. Dagnello, Maintenance Manager J. Frattasio, Fire Marshall, Assistant Operations Manager D. Fucito, Consulting Engineer B. Gailes, Human Resources Manager M. Gatslick, EP Specialist C. Hayes, Holtec Project Manager P. Kristian, Refuel Floor Project Manager M. Lawson, Radiation Protection Manager M. LeFrancois, Demolition Manager F. McGinnis, Regulatory Assurance Specialist P. OBrien, Communications J. ODonnel, Certified Fuel Handler E. Sanchez, RP Supervisor, Refuel Floor Manager A. Steward, RP Supervisor P. Sullivan, Site Oversight P. Tetreault, Security Superintendent ITEMS OPEN, CLOSED, AND DISCUSSED None LIST OF
DOCUMENTS REVIEWED
8.B.14, Fire Protection Technical Requirements, Revision 61
Agreement between Plymouth Fire Department and Holtec Pilgrim, LLC, dated 12/19/2019
20-2022 Emergency Management Comprehensive Grant Agreement between Holtec
Decommissioning International, LLC and the Town of Plymouth, dated 09/19/2019
ALARA Plan 2020-135-AP1
Audit AP-QA-2/6/14/15-2019-PNP-1, dated 3/23/2020
Audit AP-QA-10/12/18/19/-2019-PNP-01, dated 1/24/2020
Defueled Daily Surveillance Log, 2.1.15.1, Revision 2
EC-PNP-2020-018, Incipient Fire Brigade, dated 03/19/2020
EN-PE-210-Rev. 4, BWR Reactor Core and MPC Fuel Verification
Engineering Change PNP-2019-005, Revision 0
Engineering Change PNP-2019-006
Engineering Change PNP-2020-015, Revision 0
Engineering Change PNP-2020-017, Revision 0
Engineering Change PNP-2020-021, Revision 0
Engineering Change PNP-79602, Revision 0
LIST OF DOCUMENTS REVIEWED (Contd)
Engineering Change 40944, Revision 0
Engineering Change 46918, Revision 0
Engineering Change 80693, Revision 0
Engineering Change 80915, Revision 2
Engineering Change 82162, Revision 2
Fuel Handling, 4.3, Revision 146
FQC-ADM-5059, 10 CFR 50.59 Review Program Qualification Card, Revision 4
FQC-ADM-7248, 10 CFR 72.48 Review Program Qualification Card, Revision 2
FQC-ADM-PAD06, Process Applicability Determination Qualification Card, Revision 4
GQP - 9.2 High Temperature Liquid Penetrant Examination and Acceptance Standards for
Weld, Base Materials and Cladding (50° - 350°F)
GQP - 9.6, Rev. 19, Visual Examination of Welds HPP-2877-300
HPP-2877-0100, Rev.0, MPC Preparation for Loading at Pilgrim
HPP-2877-0200, Rev. 0, MPC Loading at Pilgrim
HPP-2877-0300, Rev. 0-3, MPC Sealing, Drying, and Backfilling at Pilgrim
HPP-2877-0400, Rev. 0, MPC Stackup and Transfer at Pilgrim
HPP-2877-0500, Rev. 0, MPC Transport at Pilgrim
HPP-2877-0700, Rev. 0, Response to Abnormal Conditions at Pilgrim
Human Performance Evaluation, PIL-01166
Independent Safety Review, EC PNP-2020-018, dated 10/2/2019
Independent Safety Review, LBDCR 2020-12, dated 5/1/2020
Independent Safety Review, PNPS Permanently Defueled Emergency Plan, dated 3/31/2020
Issue Report PIL-00005
Issue Report PIL-00040
Issue Report PIL-00995
Issue Report PIL-01078
Issue Report PIL-01132
Issue Report PIL-01166
Issue Report PIL-01168
Issue Report PIL-01171
Issue Report PIL-01371
Issue Report PIL-01409
Issue Report PIL-01460
Issue Report PIL-01517
Issue Report PIL-01524
Issue Report PIL-01535
Issue Report PIL-01627
Issue Report PIL-01630
Issue Report PIL-01637
Issue Report PIL-01638
Issue Report PIL-01643
Issue Report PIL-01645
Issue Report PIL-01671
Issue Report PIL-01677
Issue Report PIL-01851
KGO-ENO-HK1-19-058, Pilgrim Rev 0 Response to Boraflex CSA RAI, dated 7/1/2019
List, PNPS Maintenance Rule Basis Documents Listing, dated 8/6/2020
List, Pilgrim Station Engineering Changes (since 01/01/2020)
List, Pilgrim Station Engineering Changes Active (6/15/2019 to 8/7/2020)
List, Qualified Safety Evaluation Screeners and Reviewers
LIST OF DOCUMENTS REVIEWED (Contd)
List, Work Order Backlog, as of 8/12/2020
Logs, RP Supervisor for CRD Removal Project
NEIL Services Letter, Pilgrim Nuclear Power Station Plan for Emergency Response-Transition
from an on-site Fire Brigade to utilization of an off-site Fire Brigade, dated 01/20/2020
O-CH-01-01-01, PNPS Incipient Fire Response Training and PNPS Fire Response Training,
Revision 0
Operator Control Room and Inside Readings datasheet
Operator Inside Tour datasheet
P-EN-DC-115, Engineering Change Process, Revision 28
P-EN-DC-330, Fire Protection Program, Revision 7
P-EN-DC-330, Fire Protection Program, Revision 7
P-EN-NF-200, Special Nuclear Material Control, Revision 15
P-EN-LI-100, Process Applicability Determination, Revision 29
P-EN-LI-101, 10 CFR 50.59 Evaluations, Revision 19
P-EN-LI-102, Performance Improvement Program, Revision 37
P-EN-LI-112, 10 CFR 72.48 Evaluations, Revision 13
P-EN-OM-119, Independent Safety Review, Revision 21
PI-CNSTR-OP-HLTC-H-01, Revision 4, Closure Welding of Holtec Multi-Purpose Canisters -HI-
STORM 100, Hl-STAR 100, HI-STORM FW & UMAX Systems
PIL-1018-02, Self-Assessment - P-EN-LI-100 Process Applicability Reviews, dated 3/12/2020
Pilgrim Defueled Safety Analysis Report, section 7.2.23
Pilgrim Nuclear Power Station Defueled Safety Analysis Report, Section 3.3.9, Fire Protection
System, Revision 0
Pilgrim Nuclear Power Station - Issuance of Amendment No. 250 RE: Permanently Defueled
Technical Specifications, dated 10/28/2019
Pilgrim Nuclear Power Station Procedure 4.3, Rev.146, Fuel Handling Procedure
Pilgrim Nuclear Power Station Procedure 6.1-225, Rev 7, RP Controls for Dry Fuel Storage
Pilgrim Nuclear Power Station Report No. HI-2135753, Fuel Compatibility Report for Entergy
Pilgrim Nuclear Plant
Pilgrim Nuclear Power Station Report No. HI-2188761, Loading Plan Report for Pilgrim
Presentation, Pilgrim Project ALARA Meeting, dated August 6, 2020
Procedure No. 2.01, Station Access Control, Revision 52
Procedure No. 5.3.36, Extensive Damage Mitigation Guidelines (EDMG) Support Procedures
and Strategies, Revision 20
Procedure No. 5.5.1, General Fire Procedure, Revision 28
Procedure No. 5.5.2, Special Fire Procedure, Revision 60
Procedure No. 8.B.1, Fire Pump Test, completed 01/29/2020
Procedure No. 8.B.1, Fire Pump Test, completed 02/24/2020
Procedure No. 8.B.1, Fire Pump Test, completed 03/25/2020
Process Applicability Determination for EC 79602, Revision 0
Process Applicability Determination review for EC 82162 R2, Holtec report HI-2200348 Revision
Processing Liquid Radioactive Discharges, 2.5.2.17, Revision 23
Radiological air sample 2020-99
Radiological air sample 2020-101
Radiological air sample 2020-103
Radiological survey, Map #11, dated 03/02/2020
Radiological survey, Map #17, dated 7/13/2020
Radiological survey, Map #18, dated 7/13/2020
Radiological survey, Map #30, dated 8/14/2020
LIST OF DOCUMENTS REVIEWED (Contd)
Radiological survey, Map #37, dated 8/17/2020
Radiological survey, Map #84, dated 04/05/2020
Radiological survey, Map #166, dated 8/14/2020
Radiological survey, Map #168, dated 05/27/2020
Radiological survey, Map #300, dated 8/18/2020
Radiological survey plan, Free-Release Survey Plan for the Contractor Office, Warehouse &
Ships Buildings, dated 3/25/2020
Radiological survey plan, Free-Release Survey Plan for the Kelly Building, dated 3/2/2020
Radiological survey sheets, CRD removal project
Radiological Work Permit 2020115
Radiological Work Permit 2020135, Revision 01
Report No. 89XM-1-ER-Q-19, Pilgrim Nuclear Power Station Updated Fire Hazards Analysis,
Revision 19
Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel
Storage Installations, dated March 31, 2020.
SEP-FPP-PNP-001, Fire Protection Plan, Revision 6
Spent Fuel Pool Storage Rack Coupon Retrieval, 4.8, Revision 10
Station Daily Status Reports
Training slides, EN-LI-100 Initial Training
Training slides, Process Applicability Determination Refresher Training
Work Order WO-00036441-03-01-000
Work Order WO-52892134-01
Work Order WO-52755646-01
Work Order WO-52756084-01
LIST OF ACRONYMS USED
ADAMS Agencywide Document and Access Management System
CFR Code of Federal Regulations
CoC Certificate of Compliance
DFS Dry fuel storage
EC Engineering Change
ENOI Entergy Nuclear Operations, Inc
FHD Forced helium dehydration
FSAR Final Safety Analysis Report
GPO Government Printing Office
HDI Holtec Decommissioning International, LLC
IMC Inspection Manual Chapter
IP Inspection Procedure
ISFSI Independent Spent Fuel Storage Installation
MPC Multi-purpose canister
NRC U.S. Nuclear Regulatory Commission
PHE Public Health Emergency
PNPS Pilgrim Nuclear Power Station
RP Radiation Protection
SFP Spent Fuel Pool
TS Technical Specifications
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