ML21036A169

ISFSI Only Security Plan, Training Qualification Plan, Safeguards Contingency Plan Supplemental Information

ML21036A169
Person / Time
Site:	Oyster Creek
Issue date:	01/29/2021
From:	Sterdis A Holtec Decommissioning International
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML21036A167	List: ML21036A169
References
HDI-OC-21-002
Download: ML21036A169 (31)

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 January 29, 2021 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 Faclllty Operating License No. DPR-16 Docket Nos. 50-219 and 72-15 10 CFR 50.90 10 CFR 50.54(p)

Subject:

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

References:

1) Letter, Holtec Decommissioning International, LLC to US NRC, "Oyster ere-ek Nuclear Generating Station ISFSI Only Security Plan, Training Qualification Plan, Safeguards' Contingency Plan" December 8, 2020 (ML20345A249)

2) Letter, US NRC to Holtec Decommissioning International, LLC, "Oyster Creek Nuclear Generating Station Request For Approval of Independent Spent Fuel Storage Installation Only Physical Security Plan - Acceptance Review (L-2020-LLA-0267),"

December-21, 2020 (ML20353A200)

(

By letter dated December 8, 2020 (Reference 1 ), Holtec Decommissioning International, LLC (HDI) submitted a License Amendment Request (LAR) for approval of the proposed Oyster Creek Nuclear Generating Station ISFSI Only Security Plan. On December 21, 2020, HDI received a letter from the US Nuclear Regulatory Commission (NRC),documenting their Acceptance Review (Reference 2). Reference 2 also provided two Requests for Supplemental Information (RSls).

The purpose of this letter is to provide the supplemental information requested by ttie NRC RSls.

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JJr--tSS NOTE: TIIE ENCLOSURES TO TIIIS LEITER CONTAIN "SAFEGUARDS INFORMATION AND "SECURITY RELATED INFORMATION". TIIE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

pPON REMOVAL OF TIIE ENCLOSURES, TIIIS LEITER AND ITS ATTACHMENTS ARE DECONTROLLED."

HDI-OC-21-002 Page I 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 The NRC staff requested that HDI provide the following Information:

1) The OCNGS ISFSI PSP does not address how this PSP will meet the requirements of NRG Order EA-02-104. This information is needed to meet the requirements of NRG Order EA-02-104.

2) The OCNGS PSP contains figures and diagrams of the Oyster Creek JSFSI layout that are blurred. This information is needed to determine compliance with 10 CFR 73.55(a)-

(r), and NRG Order EA-02-104.

This letter provides a revised version of the Oyster Creek ISFSI Only PhysicaJ Security Plan (PSP) LAR package submitted in Reference 1 Including all Attachments and Enclosures. The Attachments and Enclosures have been revised to a*cfdress the information requested in the RSls. In addition, four new Enclosures are contained in~this submittal with supplemental information to address the RSls.

Attachments (Attachments 1-5 are all uncontrolled documents)

1. Evaluation of Proposed Changes

2. Proposed Operating License Change,(Mark-Ups)

3. Proposed Operating License Change (Cle~n copy)

4. Site Maps Depicting the layout of the ISFSI

5. Kontek CAS description Enclosures (Enclosures 1-8 are either Safety Related Information or Safeguards Information,and must be controlled accordingly~ Enclosures 5 through 8 (*~have been added to what was provided In the original LAR.).Encfosur:es 1-3-have been modified where appropriate to address the NRC RSls.

1. ISFSI Only Security Plan, Training and Qualification Plan,*Safeguards Contingency Plan (SGI)

2. Programmatic Assumptions for ISFSI Orily (SGI)

3. Alternative Measures (Includes attachments (SGI))

4. Compliance Matrix (SRI)

5. General Description of Security Features of OCNGS ISFSI Only Security Plan (SRI)*

6. Executive Summary of Proposed Changes (SRI}*

7. Blast Calculations (SGI)*

8. Memorandums of Understanding with local law enforcement (SGI)*

NOTE: THE ENCLOSURES TO TIIIS LEITER CONTAIN "SAFEGUARDS INFORMATION" AND "SECURTIY RELATED INFORMATION. THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

UPON REMOVAL OF THE ENCLOSURES, nns LEITER AND ITS ATTACHMENTS ARE DECONTROLLED."

HDI-OC-21-002 Page 2 of4 SAFEGUARDS INFORMATION

H-o L TEC DECOMMISSIONING INTERNATIONAL SAFEGUARDS INFORMATION Krishna P. Singh Technology Campus, 1 H61tec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 The HDI responses to the NRG RSls provided in Reference 2 are as follows:

RSI 1 HDI Response:

The LAR. package has been revised as provided in the Attachments and Enclosures to address the requirements of EA-02-104. The detailed compliance witf') the requirements is directly addressed in Enclosures 5 and 6. The other Attachments and Enclosures have been revised where necessary to support the compliance with the order.

RSI 2 HDI Response:

Figures and Diagrams in the Attachments and Enclosures have been revised to improve quality and clarity where needed. In addition, the Tables in the Kontek CAS description provided In Attachment 5 are reproduced In Enclosure 7 to provide addi-tional clarity.

To support the schedule for transition of Oyster Creek ISFSI.only status, HDI has requested NRC approval of this proposed LAR by July 2021. HDI has also requested an implementation period of 30 days 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 ISFS,1.

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 infonnation, 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 January 29, 2021.

Slncerely, Andrea Sterdis Andrea L. Sterdis HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC NOTE: THE ENCLOSURES TO THIS LE'ITER CONTAIN "SAFEGUARDS INFORMATION" AND "SECURITY RELATED INFORMATION". THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

_UPON REMOVAL OF THE ENCLOSURES, THIS LEITER AND ITS ATTACHMENTS ARE

'DECONTROLLED."

HDI-OC-21-002 Page 3 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 Attachments (all Attachments are uncontrolled):

1. Evaluation of Proposed Changes

2. Proposed Operating License Change (Mark-Ups)

3. Proposed Operating License Change (Clean copy)

4. Site Maps Depicting the layout of the ISFSI

5. Kontek CAS description

Enclosures:

1. ISFSI Only Security Plan, Training and Qualification Plan, Safeguards Contingency Plan (SGI)

\\

2. Programmatic Assumptions for ISFSI Only (SGI)

3. Alternative Measures*(includes attachments (SGI))

4. Compliance Matrix (SRI)

5. General Description of Se;curity Features of OCNGS ISFSI Only*Security Plan (SRI)

6. Executive Summary of Proposed Changes (SRI)

7. Blast Calculations (SGI)

8. Memorandums of Understanding with local law enforcement (SGI) cc:

(without Enclosures)

USNRC Regional Administrator, Region I USNRC Project Manager, NMSS - Oyster Creek Nuclear Generating Station USNRC Region I, Lea'd Inspector - Oyster Creek Nuclear Generating Station '.

Assistant Commissioner, Air Quality, Energy and S1,1stainabllity, 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 TIIE ENCLOSURES, THIS LETTER AND ITS ATTACHMENTS ARE DECONTROLLED."

HDI-OC-21-002 Page 4 of 4 SAFEGUARDS INFORMATION

HOLTEC DECOMMISSIONING IN-TERNATIONAL 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 To HDI Letter HDI-OC-21-002 Evaluation of Proposed Changes Request 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 Detenni,nation 5.3 Environmental considerations 5.4 Precedent and Conclusion 6.0 References HDI-OC-21-002 Attachment! Page 1 of 8

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

. 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 50.82(aX1)(1i) and 10 CFR 50.4(b)(9), Exelon provided certification to the NRC that all fuel had been permanently remqved 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 llcense 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 th.e 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 3~, 2020-(Reference 3) that the*.*

schedule to relocate all spent fuel from the SFP the ISFSI pad would be by November 4, 2021.

r The current Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan (existing Security Plan) at Oyster Creek contains requirements that provide ap'propriate 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 other 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-21-002 Attachment! Page 2 of 8

HOLTEC Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 DECOMMISSIONING I NT E RNAT 101,fA L Docket Nos.: 50-219 and 72-15

3.0 PROPOSED CHANGE

i 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 lntemational shall fully implement and maintain in_

effect all provisions, of the Commission-appro,ved physical security, training and qualification, and ~uards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and

,I 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 1?, 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)

, Ho/tee Decommissioning lntematlonal shall fully implement and maintain in effect all provisions of the Cemmission.:Spproved 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 oy, approved I

(date of amendment approval).

HDI-OC-21-002 Attachment! Page 3 of 8

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HO LT E,C Telephone (856) 797--0900 DECOMMISSIONING Fax (856) 797--0909 INTERNATION),L Docket Nos.: 50-219 and 72-15 4.0 TECHNICAC 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 Prdtection of ~tegory 1 and* ~tegory 2 Quantlties,of Radioactive Material." Oyster Creek has a general licensed ISFSI with security requirem~nts, in 10 CFR 72.212(b)(9). These security requirements also provlde'an appropriate level of protection for the other special nuclear material on site. The Plan reflects the configuration 'of Oyster Creek with the re!llainlng 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 ISF:SI are to detect threats, assess those threats and call for assistance from the local law enforcement agency (LLEA).

I 1

1 O CFR 72.212(b )(9) requires licensees fo 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 ?,,and-modified to incorporate the six (6) additional condiijons 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 73.55(r), eight (8) alternative measur:es have been Incorporated into the Plan. These alternative measures address the replacement of the Secondary Alann Station (SAS) with an off-site Remote Monitoring Station (RMS)',' searches, vital-areas, illumination, suspension of security measures, Reduction of contin:gency OJT, owner controlled area Monitoring and Physical Fitness Test removal. Evaluations of these alternative measures

. are provided in Enclosure 3.

I General licensed ISFSI requirements are not clearly defined in the Code of Federal Regulations. Oyster Creek has taken a. methodical ~pproach 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-21-002 Attachment! Page 4 of 8

HOLTEC DECOMMISSIONING I NT ER N A-T To r,(A-L 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

5.0 REGULATORY EVALUATION

5.1 APPLICABLE REGULA TORY REQUIREMENTS / CRITERIA I

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(bX9), 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 73.55(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 detennine if a significant hazards consideration Is involved by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment,"-as discussed below:

1. The proposed change does not Involve a significant Increase in the probability or consequences of an accident previously evaluated.

I, Response: N~.

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 plant authorized to operate the reactor or emplace or retain fuel in the reactor vessel. Accidents/transients that are no longer applicable in a pennanently defueled condition have been deleted from the Oyster Creek Updated Safety Analysis Report (USAR) Chapter 14. The remaJning USAR Chapter 14 accident is the Fuel Handling Accident (FHA) anq.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-21-002 Attachment! Page 5 of 8

HOLTEC DECOMMISSIONING INTER NA 0

T IC:>"N A[.

Krishna P. Singh )"echnology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797--0900 Fax(856)797-0909 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, structuret?, and components (SSCs)*and.no effect on the capability of.any.plant-SSC to perfonn 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 probablllty of a previously evaluated accident.

2. The proposed change :does not create the possibility of a new or different kind of accident from any accident-.prevlously evaluated.

Response: No.

The proposed amendment 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 perfonn -its design functions.

Minor modifications are associated with-this proposed llcense amendment (e.g., wiring changes in security equipment,-the,addltion 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,pr:ecursors of a new or different kind ofaqcident are created. Furthennore, 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 margin of s~.

Response: No.

• 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, thE3refore, 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 ISFSI pad location, a postulated fuel handllng accident is no longer credible in this HDI-OC-21-002 Attachment! Page 6 of 8

HOLT re DECOMMISSIONING 1 N T{R-NA Tl-0 NAL

/

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 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 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, HOI concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a findin'g 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 environ*mental assessment in accordance with 1 O CFR 51.21, and determined that it meets the criteria for categorical exclusion set forth In 10 CFR 51.22(c)(12). The proposed amendmenfis 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 organizational changes and describes procedural and other administrative changes.

Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment or impact statement is not required to be prepared in connection with the proposed amendment.

HDI-OC-21-002 Attachmentl Page 7 of 8

HO L r*E C DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., ~mden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Docket Nos.: 50-219 and 12:..15 5.4 PRECEDENT and CONCLUSl0N Many nuclear power plants have transitioned to ISFSI only Security Plans and updat~ 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, ( 1 ) 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 amenqment will not be inimical to the common defense and securi_ty or to the health-and ~~fefy, of~~ public.

6:0 REFERENCES

1. Exelon Letter to*NRC, "Certificatlon*of.Permanent Removal of Fuel from the Reactor \\

Vessel for Oyster Creek Nuclear*Gen~ratlng Station/ September 25, 2018 (ML18268A258)

2. Letter from US NRC to Exelon Generation Company, t.LC; "Order Approving Transfer of the Oyster Creek Nuclear Generating Station and Conforming;License Amendment," June 20, 2019 (ML19095A458)

3. Letter, Holtec Decomr,:iissionlng International, LLC to US NRC, "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations,"

~

1 Marci) 31, 2020_(ML20091M858)

HDI-OC-21-002 Attachmentl Page 8 of 8

_)

HOLTEC DECOMMISSIONING

.JNTERNATIONAL 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 To HDI Letter HDI-OC-21-002 License Condition Revision for Security Plan Requirements Proposed Facility Operating License Change {Mark-Up)

OCNGS Operating License Page 3 lIDI-OC-21-002, page 1 of 3

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oecoMM1ss10N1Nc Telephone (856) 797-0900 INTERNATIONAL Fax(856)797-0909 Docket Nos.: 50-219 and 72-15

- (4)

Holtec Decornmlaslonlng lntematlonal pursuant to the Ad. and 10 CFR Pena 30, 40, and 70, lo receive, possess, and use at any time any byproduct. source. or special nuclear materials es 688led neutron 60U1'C8S that were ll89d for reactor ltsrtup, aealed 60Uf'C8S that were used for celbration of reactor lo&trumentatlon and are used In radiation monitoring equipment, end as flAlon detecta's In amounts as required; (5)

Holec Decommlssloolng lntematlonal pursuant to the Ad. and 10 CFR Parts 30, 40, and 70, to receive, possesa and use In 8fT10lOS as required any byproduct, source,.fJ!1 ~

(lUCleer_ ~

_wlthQut f"86trictlon to chemk:aJ or physical form; fOr sample *ana1ys1s or Instrument calbnltlon or associated with radloactlYe apparatus or components; and (6)

Holtec Decommlsslooog lntematloc181 pursuant to the Ad. and 10 CFR Parts 30, 40, and 70, to possess, but not separate such b'Jproduct, aource, or special nuclear materlals that were produced by the operation of the facility.

C.

This license shal be deemed to contain and Is subJed to the condltloml specified In the Commission's regulatlons set fJ;lfth In 10 CFR Chapter I llfld Is subject to aft applicable provlslon,s of the Ad. end to the rules, regulations, and orders of the Commission now or hereaftar In effect and Is subject to the addllonal conditions speclffed or Incorporated below:

(1)

DELETED c2>

TectJJlcal soecfflcatloos The Tectncal Speclllcatlons contamd In Appendices A and B, as revised ttvoogh Amendment No. ~. ere hereby Incorporated In the license. Holtec Decomnisslonlng ln1ematlonal shall possess, malntm, and decommission the facllty In accordance with the Permanently Detueled Technical Specifications (POTS).

(3)

DELETED (4)

Hollec Decommissioning lrmmatlonal sha!l fully inplemerrt and mai'ltail in effect a.a provisions o( the Conmlsslon-appr physical security, training and qualffcatlon, and safeguards conti'lgency plans lncludlng emendments made pt.l'SU8flt to proylslons o( the Mlscellaneous Amendments and Search Requirements revisions to 10 Ci::R 73.55 (51 1-R 211117 8A9

z:1'.~), aoo the~ Bf 19 CFR 69,9Q OREi 19 CFR 69,64(fl), The eemblReEI set et plaflGl, eulllfflleEI by letter ElateEI May 17, 2'l98, 16 8FllitleEI; "Qy6ter Cf:eek ~luelear CeRIIRJtiR(I 8tatieA Se81:dy PlaR, TfelAIRg anEI Q11ailieati8R PlaR, OREi SafegYarde CautlRgeRay Plan, ReYl&IElFI 6."

The set aeRmiA& 8ofejU8I El& IFlfefmMieA Pf9teateEI llREler 19 CFR 73~1.

1 The Tr-alnlRg SM Qll&llllealleA fJten and iafepms C8Fltifl(l8Ray Pim! IIF8.~peRliees HDI-OC-21-002, page 2 of 3 Renewed Ucense No. DPR-16 Amendn}ent No. ;!98

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 add following to C. (4):

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 Safeguards Contingency Plan, (Revision O)", approved (date of amendment approval).

HDI-OC-21-002, 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 To HDI Letter HDI-OC-21-002 License Condition Revision for Security Plan Requirements Proposed Facility Operating License Change (Retyped)

OCNGS Operating License Page 3 IIDI-OC-21-002, page 1 of 2

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0EcoMM1ss10N1NG Telephone (856) 797-0900 INTERNATIONAL Fax(856)797-0909 Docket Nos.: 50-219 and 72-15 (4)

Holtec Decommlaslonlng lntamatlol 181 pursuant to the kt 8lld 10 CFR Parts 30, 40, end 70, kl receive, possess, and use at any time any byproduct, source, or special nuclear mmer1els es sealed neutron sources that were UB8d for reador startup, l8aled ~

that were used for cdbratlon of reactor ln8trumentatlon and &nl used In radiation monitoring equipment, and as fission detectonl In emounta as requi'ed; (5)

Holec Decommlssk>nmg lnlematlonal pursuant to the kt and 10 CFR Parts 30, 40, and 70, to receive, po&8888 and use In amounts as requ.-ed any byproduct. 60l,ll:8, or apeclal'oodeer materials without restriction to chemlcal or physlcai-torm,-for 'Sarnpfe analysla 'or Instrument calbrallon or 86SOCiated with radloactlv& apperatua or componenta; end (6)

Holtac Decormllsslonlng International pursuant to the Act. and 1 0 CFR Pans 30, 40, end 70, to possess, but not separa1e such byproduct.

source, or spaclal nuclw mmer1al8 that ~

procl_µced by the operation of the faclllty.

C.

This llcenH lhaR be deemed to contm 811d Is subject to the conditions ip8Clfied In the Commission's reguJatlona aet1fartf:l,ln, 10 QFR,~ I and Is subject to al epplcable provisions of the kt encfto the nles; ~

anti on:lers of the Co11u11isslon now or hereafter in effect end Is subject to the addltlonel concltlons specified or lncorpol eted below:

(1)

DELETED (2)

Jechn1x81Speclflcatlons The Technical Speclftcatlons C011tai118d In Appendices A and B, as revised through Amendment No. 296, are hereb>/ lncofporated In the lcense. Holtec Dec:ommlsslolVl lntematlonal shall posseaa, maintain, and decommission the fl!lcllty In accordance with the Permanently Defueled Technical Specifications (POTS).

(3)

DB.ETED (4)

Holtec Deoommlsslonlng ln1ematloMJ shall fully inplement and maintain In effect 1111 provisions of the Commlsslon-eppr physical security, tnmlng end quaificatlon, end safeguards contingency plans Including emendments made ptnWlf1l to provisions of the MJscellaneous Amendments and Search Reqwements revisions to 10 CFR 72.212(b )(9) and to the euthor1ty FIDI-OC-21-002, page 2 of2 of 10 CFR 50.90 end 10 CFR 50.~). The combined set of plans, which contelns Safeguarda lllfolnllltion protected under 10 CFR 73.211& entitled; "Oyster Creek ISFSI Secutty Plan, Training and Qualification Plan, and Safeguards Contklgency Plan, (R8Ylslon or. epprowd (data o1 emeitdment approvs/).

Renewed License No. DPR*16 Amendment No. ;l98

HOLTEC DECOMMISSIONING INTERNATIONAL HDI-OC-21-002, page 1 of3 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 To HDI Letter HDI-OC-21-002 Site Maps Depicting the layout of the ISFSI

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HOLTEC DECOMMISSIONING INTERNATION),L SAFEGUARDS INFORMATION 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 To HDI Letter HDI-OC-21-002 Alternative Measures AM#

1. of Pages

1.

7

2.

5

3.

4

4.

3

5.

4

6.

4

7.

15

8.

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

UPON REMOVAL OF THE ENCLOSURES, nns LEITER AND ITS ATTACHMENTS ARE DECONfROLLED."

HDI-OC-21-002 SAFEGUARDS INFORMATION

HOLTEC DECOMMISSIONING INTERNATIONAL Security Related Information Withhold under 10 CFR 2.390 Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

, To HDI Letter HDI-OC-21-002 Compliance Matrix Review 10 CFR 73.55 Appendix B Appendix C

1. of Pages

,40 23 9

Alternative Measures 1

Docket Nos.: 50-219 and 72-15 NOTE: THE ENCLOSURES TO THIS IEITRER CONTAIN "SAFEGUARDS INFORMATION', AND

SECURITY RELATED INFORMATION'. THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

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

HDI-OC-21-002 Security.Related Information Withhold under 10 CFR 2.390.

HOLTEC DECOMMISSIONING INTERNATIONAL Security Related Information Withhold under 10 CFR 2.390 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 To HDI Letter HDI-OC-21-002 General Description of Security Features of OCNGS ISFSI Only Security Plan (SRI)

/

25 Pages NOTE: THE ENCLOSURES TO TIIIS LEITRER CONTAIN SAFEGUARDS INFORMATION', AND "SECURITY RELATED INFORMATION'. THE ENCLOSURES MUST BE PROTECTED ACCORDINGLY.

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

HDI-OC-21-002 Security Related Information Withhold under 10 CFR 2.390

HOLTEC DECOMMISSIONING INTER.NATIONAL Security Related Information Withhold under 10 CFR 2.390 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 To HDI Letter HDI-OC-21-002 Executive Sumrri~ry of Proposed Changes (SRI) 21 Pages NOTE: THE ENCLOSURES TO TIIlS LETIRER CONTAIN "SAFEGUARDS INFORMATION', AND "SECURITY RELATED INFORMATION'. THE ENCLOSURES MUST BE PRO'IECfED ACCORDINGLY.

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

HDI-OC-21-002

• Security Related Information Withhold under 10 CFR 2.390

HOLTEC DECOMMISSIONING INTERNATI-ONAi.

Security Related Information

-Withhold under 10 CFR 2.390 Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 To HDI Letter HDI-OC-21-002 Blast Calculations (SGI)

Review ABS Kontex

1. of Pages 384 58 Docket Nos.: 50-219 and 72-15 NOTE: THE ENCLOSURES TO THIS LEITRER CONTAIN "SAFEGUARDS INFORMATION', AND "SECURITY REIATED INFORMATION'. THE ENCLOSURE.S MUST BE PROTECTED ACCORDINGLY.

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

HDI-OC-21--002 Security Related Information Withhold under 10 CFR 2.390