ML20345A249

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ISFSI Only Security Plan, Training Qualification Plan, Safeguards Contingency Plan
ML20345A249
Person / Time
Site: Oyster Creek
Issue date: 12/08/2020
From: Sterdis A
Holtec Decommissioning International
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
HDI-OC-20-079
Download: ML20345A249 (31)
v • d • e


Text

SAFEGUARDS INFORMATION HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 50.90-10 CFR 50.54(p)

December 8, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission.

Two White Flint North .

11545 Rockville Pike

  • Rockville, MD 20852-2738 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket Nos. 50-219 and 72-15 *

Subject:

Oyster Creek Nuclear Generating Station ISFSI Only Security Plan, Training Qualification Plan, Safeguards Contingency Plan

References:

I 1) Letter, Holtec Decommissioning International, LLC to US NRC, "Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Oyster Creek Nuclear Generating Station," September 28, 2018 (ML H3275A116)

2) Letter, Holtec Decommissioning International, LLC to US NRC, "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage_lnstallations," March 31, 2020 (ML20091M858)
3) The proposed PSP is consistent with the guidance provided by NRC Staff in NSIR/DSPISG-03, Review of Security Exemptions/License Amendment Requests for Decommissioning Nuclear Power Plants," September 28, 2015

. (ML15106A737)

Pursuant to the provisions of 10 CFR 50.4, and 10 CFR 50.90, Holtec Decommissioning International, LLC (HDI) is submitting a request for amendment to the Operating License (OL) for Oyster Creek Nuclear Generating Station (to be referred to as Oyster Creek). Specifically, this_ proposed license amendment requests NRC approval of the Oyster Creek ISFSI Security _

Plan, Training and Qualification Plan and Safeguards Contingency Plan (the Plan) and removes Part 73.55 requirements directly from the OL. The Plan will supersede the current Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan at Oyster Creek, and addresses the protection of material on sit~ that is licensed by the Oyster Creek NOTE: THE ENCLOSURES TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND "SECURITY RELATED INFORMATION". THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

UPON REMOVAL OF THE ENCLOSURES, THIS tETTER AND ITS ATTACHMENTS ARE DECONTROLLED." .

HDI-OC-20-079 Page I of4 SoDI SAFEGUARDS INFORMATION 0rvJS5 zl.p

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SAFEGUARDS INFORMATION HOLTEC DECOMMISSIONING INTERN A r'r ON AL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 License that includes the Independent Spent Fuel Installations (ISFSI) as well as other special nuclear material on site, with the exception of material subject to the requirements of 10CFR 37, "Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material."

.The future site configuration that is reflected in the Plan assumes that the all remaining spent fuel in the spent fuel pool has been moved to the ISFSI and that there is no requirement to return spent fuel to the spent fuel pool ("ISFSI Only" status). Spent fuel movement to the ISFSI is currently scheduled to be completed by November 2021.

The proposed Plan change and License Amendment Request are appropriate for a facility that

. is performing the "DEGON" method of decommissioning and is within the descriptions provided by the Post Shutdown Decommissioning Activities Report submitted to the NRC on September 28, 2018 (Reference 1) as amended by the HDI Annual Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations submitted to the NRC on March 31, 2020 (Reference 2).

The proposed PSP is consistent with the guidance provided by NRC Staff. in NSIR/DSPISG-03, "Review of Security Exemptions/License Amendment Requests for Decommissioning Nuclear Power Plants" (Reference 3).

Pursuant to 10 CFR 50.91 (a)(1 ), HDI has performed an evaluation and determined that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified. Furthermore, HDI has evaluated this proposed license amendment against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21 and has concluded, pursuant to 10 CFR 51.22(b), that no environmental impact statement or environment assessment need be prepared in connection with the proposed amendment.

Attachments to this letter G_ontain non controlled descriptions of the Evaluation of Proposed Changes, License Condition Change, Site Maps for the future ISFSI sight configuration and Kontek CAS layout.

  • Enclosures to this letter contain controlled Safeguards or Security Related information presenting the ISFSI security Plan, Training Qualification Plan, Safeguards Contingency Plan, and supporting information for this request.

NOTE: THE ENCLOSURES TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND "SECURITY RELATED INFORMATION". THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY..

U:PON REMOVAL OF THE ENCLOSURES, THIS LETTER AND ITS ATTACHMENTS ARE DECONTROLLED."

HDI-OC-20-079 Page2 of4 SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 "Safeguards Information" (SGI} as defined by 10 CFR 73.22 and its disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy Act of 1954, as amended, *and must be protected accordingly.

or "Security Related Information'.' (SRI) as defined by 10 CFR 2.390 and must be protected.

accordingly.

In order to support the site transition to "ISFSI only" status, HDI is requesting the NRC approval of this proposed license amendment by July 2021. HDI requests an implementation period of 30 day following HD l's submittal of written notification to the NRC that the remaining spent fuel assemblies have been transferred from the spent fuel pool to the ISFSI. In addition,.

this license amendment will not be implemented if there is a requirement to return spent fuel from the ISFSI to the spent fuel pool.

This letter contains no new regulatory commitments.

If you have* any questions or need further information, please contact me at (856) 797-0900, ext. 3813.

I declare under the penalty of perjury that the forgoing is true and correct.

Executed on December 8, 2020.

Sincerely, Digltally signed by Andrea Sterdfs A nd rea .: ,**' ~~~:~~=m!!:l~~fn~US, 8

  • . lntemational, ou=HDI, SterdIS emaU=a.sten::lls@hollec.com Date: 2020.12.08 12:22:17 --05'00' Andrea L. Sterdis
  • HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC NOTE: THE ENCLOSURES TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND "SECURITY RELATED INFORMATION". THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

UPON REMOVAL OF THE ENCLOSURES, THIS LETTER AND ITS ATTACHMENTS ARE DECONTROLLED."

HDI-OC-20-079 Page 3 of4 SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION HOLTEC DECOMMISSIONING INTER NATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Attachments:

1. Evaluation of Proposed Changes
2. Proposed Operating License Change (Mark-Ups)
3. Proposed Operating License Change (Clean copy)
4. Sight maps depicting the layout of the ISFSI
5. Kontex CAS description (Non-SGI)

Enclosures:

1. ISFSI Security Plan, Training Qualification Plan, Safeguards Contingency Plan (SGI}

~ 2. Programmatic Assumptions for ISFSI Only (SGI)

3. Alternative Measures with attachments (SGI).
4. Compliance Matrix (SRI)
  • cc: (without Enclosures)

USNRC* Regional Administrator, Region I USNRC Project Manager, NMSS - Oyster Creek Nuclear Generating Station USNRC Region I, Lead Inspector - Oyster Creek Nuclear Generating Station Assistant Commissioner, Air Quality, Energy and Sustainability, NJ DEP Assistant Director Radiation Protection Element, NJ Bureau of Nuclear Engineering NOTE: THE ENCLOSURES TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND "SECURITY RELATED INFORMATION". THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

UPON.REMOVAL OF THE ENCLOSURES, THIS LETTER AND ITS ATTACHMENTS ARE DECONTROLLED."

  • HDl-OC-20-079
  • Page4 of4 SAFEGUARDS INFORMATION

--K_r_is_h_n_a_P_.s_*_in_gh_T_ec_h_n_o_lo_g_y_C_a_m_p_us_,_1_H_o_lt_e_c_B_lv_d_.,_C_a_m_d_e_n,_N_J_0_8_1_0_4 HO LT EC Telephone (856) 797-0900 DECOMMISSIONING INTERNATIONAL Fax (856) 797-0909 Docket Nos.: 50-219 and 72-15 Attachment 1 To HDI Letter HDI-OC-20-079 Evaluation of Proposed Changes Rt!quest for Approval of the Oyster Creek Nuclear Generating Station ISFSI Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan and Change to the Security License Condition 1.0 Summary Description 2.0 Detailed Description 3.0 Proposed Changes 4.0 Technical Evaluation

  • 5.0 Regulatory Review 5.1 Applicable Regulatory Requirements/ Criteria 5.2 No Significant Hazards Consideration Determination 5.3 Environmental considerations 5.4 Precedent and Conclusion 6.0 References HDI-OC-20-079 Attachmentl Page 1 of 8

- Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104

HOLTEC Telephone (856) 797-0900 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL Docket Nos.: 50-219 and 72-15 1.0

SUMMARY

DESCRIPTION In accordance with the provisions of 10 CFR 50.4 and 50.90, Holtec Decommissioning International (HDI) is requesting an amendment to Oyster Creek Generating Station (to be referred to as Oyster Creek) Operating License (OL) Physical Protection License Condition 2.C.(4). The proposed license

. amendment would document the approval of the Oyster Creek Nuclear Generating Station ISFSI Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan (the Plan) provided as Enclosure 1.

2.0 DETAILED DESCRIPTION On September 25, 2018, pursuant to 10 CFR.S0.82(a)(l)(ii) and 10 CFR S0.4(b)(9), Exelon provided certification to the NRC that all fuel had been permanently removed from the Oyster Creek reactor vessel and placed in the spent fuel pool (SPF) (Reference 1). Therefore, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for Oyster Creek no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. Currently, spent fuel is stored in the SFP and the Independent Spent Fuel Storage Installation (ISFSI).

Holtec Decommissioning International (HDI) became the license operator of Oyster Creek after the NRC issued the "Order Approving Transfer of the Oyster Creek Nuclear Generating Station and Conforming License Amendment," dated June 20, 2019 (Reference 2.) HDI notified the NRC with the "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations," dated March 31, 2020 (Reference 3) that the schedule to relocate all spent fuel from the SFP the ISFSI pad would be by November 4, 2021.

The current Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan (existing Security Plan) at Oyster Creek contains requirements that provide appropriate protection for the safe storage of spent fuel in the SFP as well as the ISFSI. As such, the existing Security Plan provides a level of_ protection in excess of that required after all the spent fuel is transferred to the ISFSI. The proposed Plan reflects the future site configuration where all the remaining spent fuel in the spent fuel pool has been moved to the ISFSI and that there is no requirement to return spent fuel to the spent fuel pool. Transfer of fuel from the SFP to the ISFSI supports the decommissioning of Oyster Creek, which involves the eventual dismantlement of the SFP and ot_her remaining plant structures.

Therefore, the proposed Plan will supersede the existing Security Plan after the remaining spent fuel in the spent fuel pool has been moved to the ISFSI.

Additional enclosures to this letter contain Security Related Information (SRI) or Safeguards Information (SGI) that support the License change and proposed Security Plan approval.

HDI-OC-20-079 Attachment! Page 2 of 8

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104

HOLTEC Telephone (856) 797-0900 .

DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL Docket Nos.: 50-219 and 72-15

3.0 PROPOSED CHANGE

The proposed amendment would modify the Oyster Creek OL by referencing 10 CFR 72.212(b)(9},

removing requirements for 10 CFR 73.55 and replacing the plan name.

  • Existing License Condition 2.C.(4}

Holtec Decommissioning International shall fully implement and maintain *in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, submitted by letter dated May 17, 2006, is entitled: "Oyster Creek Nuclear Generating Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 5."

The set contains Safeguards Information protected under 10 CFR 73.21.

Proposed License Condition 2.C.(4}

Holtec Decommissioning _lnt~mational shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 72.212(b)(9) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21 is entitled; "Oyster Creek Nuclear Generating Station ISFSI Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, (Revision O)", approved (date of amendment approval).

HDI-OC-20-079 Attachmentl Page 3 of 8

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HOLTE C Telephone (856) 797-0900 DECOMMISSIONING INTERNATIONAL Fax (856) 797~0909 Docket Nos.: 50-219 and 72-15

4.0 TECHNICAL EVALUATION

The Plan The Plan addresses the protection' of material on site that is licensed by the Oyster Creek Operating License. That includes the ISFSI as well as other special nuclear material on site, with the exception of material subject to the requirements of 10 CFR 37, "Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material." Oyster Creek has a general licensed ISFSI with

. security requirements in 10 CFR 72.212(b)(9). These security requirements also provide an appropriate level of protection for the other special nuclear material on site. The Plan reflects the

  • configuration of Oyster Creek with the remaining spent fuel in the spent fuel pool moved to the ISFSI and no requirement to return spent fuel to the spent fuel pool. The security functions for an ISFSI are to detect threats, assess those threats and call for assistance from the local law enforcement agency (LLEA).

10 CFR 72.212(b)(9) requires licensees to comply with 10 CFR 73.55, with six (6) additional conditions and exceptions. Therefore, the Plan was based on the NRC endorsed template for .

Operating Nuclear Plants, NEI 03-12, Revision 7, and modified to incorporate the six (6) additional conditions and exceptions. In addition, other requirements are not applicable for an ISFSI such as certain sections of the design basis threat, cyber security, target sets, 10 CFR 26, and portions of the insider mitigation program, and therefore are not included in the Plan.

Pursuant to 10 CFR 73.SS(r), eight (8) alternative measures have been incorporated into the Plan.

These alternative measures address the replacement ofthe Secondary Alarm Station (SAS) with an off-site Remote Monitoring Station (RMS),*searches, vital areas, illumination, suspension of security measures, Reduction of contingency OJT, owner controlled area Monitoring and Physical Fitness*

Test removal. Evaluations ofthese alternative measures are provided in Enclosure 3.

General licensed ISFSI requirements are not clearly defined in the Code of Federal Regulations.

Oyster Creek has taken a methodical approach to integrating 10 CFR 72.212(b}(9) requirements with various other Code of Federal Regulation requirements. The Plan complies _with these requirements except where alternative measures have been requested. The Plan protects against the design basis threat of radiological sabotage and ensures the health and safety of the public.

HDI-OC-20-079 Attachment I Page 4 of 8

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HOLTE C Telephone (856) 797-0900 DECOMMISSIONING INTERNATIONAL Fax (856) 797-0909 Docket Nos.: 50-219 and 72-15

5.0 REGULATORY EVALUATION

5.1 APPLICABLE REGULATORY REQUIREMENTS/ CRITERIA Pursuant to 10 Code of Federal Regulations (CFR) 50.54(p) and 10 CFR 50.90, Holtec Decommissioning International, LLC (HDI) is requesting approval of proposed Oyster Creek Physical Security Plan (the Plan) and an amendment for a conforming change to Oyster Creek.*

Renewed Facility License Condition 2.c.(4). In accordance with 10 CFR 72.212(b)(9), the proposed Plan is required to protect spent fuel against the design basis threat of radiological sabotage in accordance with the same provisions set forth in the physical security requirements of 10 CFR 73.55 with certain conditions and exceptions as specified. in the regulation. This submittal includes requests for alternative measures pursuant to 10 CFR 73.SS(r), 10 CFR 50.90 and 10 CFR 50.54 that support the proposed Plan.

5.2 SIGNIFICANT HAZARDS CONSIDERATION The proposed Plan addresses the physical protection of material on site that is licensed under the Oyster Creek Renewed Facility License, as well as the general license for the Oyster Creek ISFSI. The Plan reflects the configuration of Oyster Creek with all the spent nuclear fuel stored at the ISFSI. The 10 CFR Part 50 license for Oyster Creek no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.

HDI has evaluated the proposed amendment to determine if a significant hazards consideration is involved by focusing on the three standards set forth in io CFR 50.92, "Issuance of Amendment,"

as discussed below:

1. The proposed change does not involve a significant increase in the probability or consequfi!nce~ of an accident previously evaluated.

Response: No.

The irradiated fuel at Oyster Creek is currently stored in the SFP and at the Independent Spent Fuel Storage Installation (ISFSI). In this condition, the number of credible accidents/transients is significantly smaller than for a P,lant authorized to operate the reactor or emplace or retain fuel in the reactor vessel. Accidents/transients that are no longer applicable in a permanently defueled condition have been deleted from the Oyster Creek Updated Safety Analysis Report (USAR) Chapter 14. The remaining USAR Chapter 14 accident is the Fuel Handling Accident (FHA) and is described in Chapter 6 of the Decommissioning Safety Analysis Report (DSAR).

However, as previously discussed, the Plan reflects the future site configuration that assumes all the remaining spent fuel in the SFP has been moved to the ISFSI. Therefore, the FHA is no longer credible after the spent fuel pool is no longer storing spent fuel.

HDI-OC-20-079 Attachment! Page 5 of 8

  • * * *
  • __ K_ris_h_n_a_P_._S_in_g_h_T_e_ch_n_o_lo_g_y_C_a_m_p_us_,_1_H_o_lt_e_c_B_lv_d_.,_C_a_m_d_e_n_,N_J_0_8_1_0_4 HO LT EC Telephone (856) 797-0900 DECOMMISSIONING Fax (856) 797-0909 INTER NATIONAL Docket Nos.: 50-219 and 72-15
  • No change is being made to conditions of storage of fuel in the General Licensed ISFSI systems.

The proposed license amendment has no effect on plant systems, structures, and components (SSCs} and no effect on the capability of any plant SSC to perform its design function. The proposed amendment would not increase the likelihood of the malfunction of any plant SSC.

Therefore, the proposed amendment does not involve a significant increase in the probability of a previously e.valuated accident.

2. The proposed change does not create the possibility of a new or different "ind of accident from any accident previously evaluated.

Response: No.

The proposed amendm*ent does not involve any physical alteration of any facility SSCs or Cask System components required to mitigate or prevent any accident previously evaluated, and

  • does not have a significant effect on the capability of any facility SSC or Cask System component to perform its design functions.

Minor modifications are associated with this proposed license amendment (e.g., wiring changes in security equipment, the addition of telecommunications equipment, and software changes to the security computer system.} The proposed license amendment would not physically change any SSCs involved in the mitigation of any postulated accident. Thus, no new initiators or precursors of a new or different kind of accident are created. Furthermore, the proposed amendment does not create the possibility of a new failure mode associated with any equipment or personnel failures. The credible events for the ISFSI remain unchanged.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. The proposed change does not involve a significant reduction in a ma{gin of safety.

Response: No.

Pursuant to 10 CFR 50.82(a)(2}, the 10 CFR Part 50 lice.nse for Oyster Creek no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, therefore, the occurrence of any postulated accidents associated with an operating nuclear reactor is no longer credible.

After all fuel is removed from the pool and safely stored in dry casks in either ISFSl*pad location, a postulated fuel handling accident is no longer credible in this configuration. The proposed amendment does not involve a significant change in any facility SSC or Cask System component's design, configuration, or operation. Therefore, the modifications associated with HDI-QC-20-079 Page 6 of 8

-_K_r_is_h_n_a_P_._S_in_g_h_T_ec_h_n_o_lo_g_y_C_a_m_p_us_,_1_H_o_lt_e_c_B_lv_d_.,_C_a_m_d_e_n_,N_J_0_8_1_0_4 HOLTE C *. Telephone (856) 797-0900 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL Docket Nos.: 50-219 and 72-15 this proposed amendment do not significantly affect the capability or manner in which facility SSCs or Cask System components perform their safety functions, or the safety margins associated with their design and function.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above, HDI concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR S0.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified:

5.3 ENVIRONMENTAL CONSIDERATION

HDI has evaluated this proposed amendment against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21, and determined that it meets the criteria for categorical exclusion set forth in 10 CFR SL22(c)(12). The .

proposed amendment is being submitted under the provisions of 10 CFR Part 50 for approval of a safeguards plan and changes to the PNPS Renewed Facility License, and in accordance with 10 CFR Part 72.

Activities associated with the proposed amendment do not involve any significant construction impacts, and are consistent with the plan for future reduction in the security area that focuses primarily on the storage for spent fuel, described in NUREG-0586, "Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," as a general activity expected to occur during decommissioning. The proposed amendment is confined to (i) organizational and procedural matters; (ii) modifications to systems used for security; and (iii) administrative changes. The proposed amendment also addresses security organizationaJ changes and describes procedural and other administrative changes.

Therefore, pursuant to 10 CFR Sl.22(b), an environmental assessment or impact statement is not required to be prepared in connection with the proposed amendment.

HDI-OC-20-079 Attachmentl Page 7 of 8

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HO LT EC Telephone (856) 797-0900 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL Docket Nos.: 50-219 and 72-15 5.4 .PRECEDENT and CONCLUSION Many nuclear power plants have transitioned to ISFSI only Security Plans and updated their License Condition. Oyster Creek is requesting a security plan change that is similar to approved ISFSI Only Security Plans.

Based on the considerations discussed above, (i) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed changes, (2) activities consistent with the approved changes will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 REFERENCES

1. Exelon Letter to NRC, "Certification of Permanent Removal of Fuel from the Reactor Vessel for Oyster Creek Nuclear Generating Station," September 25, 2018 (ML18268A258)
2. Letter from US NRC to Exelon Generation Company, LLC, "Order Approving Transfer of the Oyster Creek Nuclear Generating Station and Conforming License Amendment," June 20, 2019 (ML19095A458)
3. Letter, Hdltec Decommissioning International, LLC to US NRC, "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations," March 31, 2020 (ML20091M858)

HDI-OC-20-079 Attachment! Page 8 of 8

HOLTEC DECOMMISSIONING INTERNATIONAL -

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (656) 797-0900 Fax(856)797-0909 Docket Nos.: 50-219 and 72-15 Attachment 2 To HDI Letter HDI-OC-20-079 License Condition Revision for Security Plan Requirements Proposed Facility Operating License Change (Mark-Up)

OCNGS Operating License Page 3 HDI-OC-20-079 , page 1 of 3

,~~~~ __K_r_is_h_n_a_P_._S_in~g_h_T_ec_h_n_o_lo~gy~C_a_m~p_us_,_1_H_o_lt_e_c_B_lv_d_.,_C_a_m_d_e_n,_N_J_0_8_1_0_4 0EcoMM1ss10N1Nc INTERNATIONAL Telephone (856) 797-0900

  • Fax (856) 797-0909 Docket Nos.: 50-219 and 72-15 (4) Hallee Decommissioning International pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, or special nuclear materials as sealed neutron sources that were used for reactor startup, sealed sources that were used for calibration of reactor instrumentation and are used in radiation monitoring equipment, and as fission detectors In amounts as required; *

(5) Holtec Decommissioning International pursuant to the Act and 10CFR_

Parts 30, 40, and 70, to receive, possess and use in amounts as required any'byproduct, source, or special nuclear materials without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) Holtec Decommissioning lntern!!tlonal pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate such byproduct, source, or special nuclear materials that were produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR'Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below: *

(1) DELETED (2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. ~. are hereby Incorporated in the license. Holtec Decommissioning International shall possess, maintain; and decommission the facility in accordance with the Permanently Defueled Technical Specifications (POTS).

(3) DELETED (4) Holtec Decommissioning International shall fully il"!lplement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans Including amendments made pursuant to provisions of the Miscellaneous Amendments and

  • Search Requirements revisions to 10 ci;:R 73.55 {51 i;'.R 271117 SRG 271122), aREI Yle a1:1YleFity ef 1Q CFR liQ.8Q aml 1Q CFR 5Q.54fp). Ttle eemllinee set ef plans'. s1:1llmittee by letter ealee May 17, 2QQ6, is eRtiliee: "Oysler Creek N1:1elea*r GeRerating* Slatien See1:1rily Plan, TraiRing SRB Q1:1alifieatieR PlaR, SRB Safeg11aFEls CeRtiRgeRey PlaR, Re*llsieR a."

The set eeRlains Safeg1:1ares lnfeF1Ratien pFeleolee 1:1Reer 1Q CFR 73.21.

l The TraiRiRg ane Q1:1alifieaUeR Plan anel Safeg1:1aFEls Centingeney Plan are ,!\ppenEliees le tlle See1:1ril)* Plan.

  • Renewed License No. DPR-16 Amendment No.~

HDI-OC-20-079 , page 2 of 3

HOLTEC Krishna p. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 DECOMMISSIONING INTERNATIONAL Telephone (856) 797-0900 Fax(856)797-0909 Docket Nos.: 50-219 and 72-15 add following to C. (4):

10 CFR 72.212(b)(9} and to the authority of 10 CFR 50.90 and 10 CFR ~0.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21 is entitled; "Oyster Creek ISFSI Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, (Revision O)", approved (date of amendment approval).

HDI-OC-20-079 , page 3 of3

HOLTEC . Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 DECOMMISSIONING INTERNATIONAL Telephone (856) 797-0900 Fax (856) 797-0909 Docket Nos.: 50-219 and 72-15 Attachment 3 To HDI Letter HDI-OC-20-079 License Condition Revision for Security Plan Requirements Proposed Facility Operating License Change (Retyped)

OCNGS Operating License Page 3 HDI-OC-20-079 , page 1 of2

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K_ris_h_n_a_P_._S_in~g_h_T_e_ch_n_o_lo~g~y_C_a_m~p_u_s,_1_H_o_lt_e_c_B_lv_d_.,_C_a_m_d_e_n_,N_J_0_8_1_0_4 Telephone (856) 797-0900 Fax(856)797-0909 Docket Nos.: 50-219 and 72-15 (4) Holtec Decommissioning International pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, or special nuclear materials as sealed neutron sources that were used for reactor startup, sealed sources that were used for calibration of reactor instrumentation and are used in radiation monitoring equipment, and as fission detectors in amounts as required; *

(5) Hollec Decommissioning International pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use in amounts as required any byproduct, source, or special nuclear materials without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) Holtec Decommissioning International pursuant to the Act arid 10 CFR Parts 30, 40, and 70, to possess, but not separate such byproduct, source, or special nuclear materials that were produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified In the Commission's regulations set forth In 10 CFR Chapter I and Is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below:

(1) DELETED (2) Technical Specifications The Technical Specifications contained in Appendices A and 8, as revised through Amendment No. ~ . are hereby incorporated in the license. Holtec Decommissioning International shall possess, maintain, and decommission the facility in accordance with the Permanently Defueled Technical Specifications (POTS).

(3) DELETED (4) Hollec Decommissioning International shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments

  • made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 72.212(b)(9) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21 is entitled; "Oyster Creek ISFSI Security Plan. Training and Qualification Plan, and

Renewed License No. DPR-16 Amendment No. 298 HDI-OC-20-079 , page 2 of2

HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax(856)797-0909 Docket Nos.: 50-219 and 72-15 Attachment 4 To HDI Letter HDI-OC-20-079 Sight Maps Depicting the layout of the ISFSI HDI-OC-20-079 , page 1 of3

HOLTEC Krishna P. Singh Technology Campus, 1_ Holtec Blvd., Camden, NJ 08104 DECOMMISSIONING INTERNATIONAL Telephone (856) 797-0900 Fax (856) 797-0909 Docket Nos.: 50-219 and 72-15 f

J HDI-OC-20-079 ,_ page 2 of 3

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f HDI-OC-20-079 , page 3 of 3

HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Docket Nos.: 50-219 and 72-15 Attachment 5 To HDI Letter HDI-OC-20-079 Kontex CAS description HDI-OC-20-079 , page 1 of 7

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Ho LT E c DECOMMISSIONING 1NTERNAT10NAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104

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IIIMUST HDI-OC-2 0-079 , page 7 of?

SAFEGUARDS INFORMATION HOLT EC Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 DECOMMISSIONING Telephone (856) 797-0900 INTERNAT.IONAL Fax (856) 797-0909 Docket Nos.: 50-219 and 72-15 Enclosure 1 To HDI Letter HDI-OC-20-079 ISFSI Security Plan, Training and Qualification Plan, Safeguards Contingency Plan (93 pages)

NOTE: THE ENCLOSURES TO THIS LETTRER CONTAIN "SAFEGUARDS INFORMATION', AND "SECURITY RELATED INFORMATION'. THE ENCLOSURES MUST BE.PROTECTED ACCORDINGLY.

UPON REMOVAL OF THE ENCLOSURES, THIS LETTER AND ITS ATTACHMENTS ARE DECONTROLLED."

HDI-OC-20-079 SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION HOLTEC Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 DECOMMISSIONING Telephone (856) 797-0900 INTERNATIONAL Fax (856) 797-0909 Docket Nos.: 50-219 and 72-15 Enclosure 2 To HDI Letter HDI-OC-20-079 Programmatic Assumptions for ISFSI Only (4 pages)

NOTE: THE ENCLOSURES TO THIS LETTRER CONTAIN "SAFEGUARDS INFORMATION', AND "SECURITY RELATED INFORMATION'. THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

UPON REMOVAL OF THE ENCLOSURES, THIS LETTER AND ITS ATTACHMENTS ARE DECONTROLLED."

HDI-OC-20-079 SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION

HOLTEC Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 DECOMMISSIONING INTERNATIONAL Fax (856) 797-0909 Docket Nos.: 50-219 and 72-15 Enclosure 3 To HDI Letter HDI-OC-20-079 Alternative Measures AM# # of Pages

1. 7
2. 5

. 3. 4

4. 3

. 5. 4

6. 4
7. 15
8. 8 NOTE: THE ENCLOSURES TO THIS LETTRER CONTAIN "SAFEGUARDS INFORMATION', AND "SECURITY RELATED INFORMATION'. THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

UPON REfyfOVAL OF THE ENCLOSURES, THIS LETTER AND ITS ATTACHMENTS ARE DECONTROLLED."

HDI-OC-20-079 SAFEGUARDS INFORMATION '

r Security Related Information Withhold under 10 CFR 2.390 HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Docket Nos.: 50-219 and 72-15 Enclosure 4 To HDI Letter HDI-OC-20..079 Compliance Matrix Review # of Pages

  • Appendix C 9 Alternative Measures 1 NOTE: THE ENCLOSURES TO THIS LETTRER CONTAIN "SAFEGUARDS INFORMATION', AND "SECURITY RELATED INFORMATION'. THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

UPON REMOVAL OF THE ENCLOSURES, THIS LETTER AND ITS ATTACHMENTS ARE DECONTROLLED."

HDI-OC-20-079 Security Related Information Withhold under 10 CFR 2.390

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