Text

License Amendment Request to Revise Pilgrim Nuclear Power Station Permanently Defueled Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool
	ML21076A404
Person / Time
Site:	Pilgrim
Issue date:	03/17/2021
From:	Sterdis A; Holtec Decommissioning International
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	HDI-PIL-21-017
	Download: ML21076A404 (90)
	v • d • e

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 50.36 March 17, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket Nos. 50-293 and 72-1044

Subject:

License Amendment Request to Revise Pilgrim Nuclear Power Station Permanently Defueled Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool

References:

[1] Letter, Entergy Nuclear Operations, Inc, to US NRC, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, dated June 10, 2019, (ML19161A033)

[2] Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, March 31, 2020 (ML20091M858)

Pursuant to the provisions of 10 CFR 50.90, Holtec Decommissioning International, LLC (HDI) hereby requests approval of the proposed amendment to Renewed Facility License DPR-35 for Pilgrim Nuclear Power Station (PNPS). The proposed amendment would revise the 10 CFR Part 50 Facility License (FL) and the Technical Specifications (TS) to reflect removal of all spent nuclear fuel from the spent fuel pool (SFP) and its transfer to dry cask storage within a site controlled Independent Spent Fuel Storage Installation (ISFSI).

By letter dated June 10, 2019 (Reference 1), Entergy Nuclear Operations, Inc, submitted certifications for permanent cessation of reactor operations at PNPS and permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1). Therefore, as specified in 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for PNPS no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel. By letter dated March 31, 2020 (Reference 2), HDI provided notification that off-load of the spent fuel pool (SFP) and transfer of the spent fuel to the ISFSI was expected to be completed in January 2022. More recent projections based on efforts to accelerate transfer of all spent fuel to dry cask storage necessitate requesting NRC approval of these proposed TS changes by September 30, 2021. In support of this condition, a revision to the PNPS FL and associated TS is proposed to comport with the requirements for a facility configuration with all spent nuclear fuel in dry storage within an ISFSI.

HDI-PIL-21-017 Page 1 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to this letter provides a description and evaluation of the proposed FL and TS changes.

The evaluation includes the regulatory evaluation, the no significant hazards consideration determination, and the environmental considerations. to the Enclosure contains a markup of the FL and TS pages. to the Enclosure contains the retyped FL and ISFSI Only Technical Specification (IOTS) pages. to the Enclosure identifies the TS administrative controls that are proposed to be relocated from the TS to the Defueled Safety Analysis Report (DSAR).

In order to support the site transition to "ISFSI only" status, HDI is requesting the NRC approval of this proposed license amendment by September 30, 2021. HDI requests an implementation period of 30 days following HDl'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.

Pursuant to 10 CFR 50.91, Notice for public comment; State consultation, paragraph (b), a copy of this submittal is being provided to the Commonwealth of Massachusetts, Emergency Management Agency.

A new regulatory commitment is described in Attachment 4 to letter Enclosure 1.

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

3813.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 17, 2021 Sincerely, Digitally signed by Andrea Sterdis Andrea DN: cn=Andrea Sterdis, c=US, o=Holtec Decommissioning International, ou=HDI, Sterdis email=a.sterdis@holtec.com Date: 2021.03.17 13:19:45 -04'00' Andrea L. Sterdis HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC : Description and Evaluation of Proposed Changes - License Amendment and Technical Specification Revision Request for Permanent Removal of Spent Fuel from the Spent Fuel Pool Attachment 1 Markup of the Facility License and Technical Specification Pages Attachment 2 Retyped Facility License and Technical Specification pages Attachment 3 Technical Specification Administrative Controls to be Relocated to the DSAR Attachment 4 Regulatory Commitments HDI-PIL-21-017 Page 2 of 3

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

NRC Regional Administrator - Region I NRC NMSS Project Manager (Pilgrim Nuclear Power Station)

Director, Massachusetts Emergency Management Agency HDI-PIL-21-017 Page 3 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-017 Enclosure 1 Description and Evaluation of Proposed Changes License Amendment and Technical Specification Request for Permanent Removal of Spent Fuel from the Spent Fuel Pool HDI-PIL-21-017 Page 1 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-017 Enclosure 1 Description and Evaluation of Proposed Changes License Amendment and Technical Specification Request for Permanent Removal of Spent Fuel from the Spent Fuel Pool 1.0 Summary Description 2.0 Proposed Change 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements and Criteria 4.2 No significant Hazard Consideration 4.3 Precedents 4.4 Conclusions 5.0 Environmental Consideration 6.0 References Attachments 1.0 Markup of the Existing License and Technical Specification Pages 2.0 Retyped License and Technical Specifications Pages 3.0 Technical Specification Administrative Controls Relocated to the DSAR 4.0 List of Regulatory Commitments HDI-PIL-21-017 Page 2 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 License Amendment and Technical Specification Request for Permanent Removal of Spent Fuel from the Spent Fuel Pool 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, Holtec Decommissioning International, LLC (HDI) is proposing an amendment to Renewed Facility License DPR-35 for Pilgrim Nuclear Power Station (PNPS).

The proposed amendment would revise the Facility License (FL) and the Technical Specifications (TS) to reflect removal of all spent nuclear fuel from the spent fuel pool (SFP) and completion of the transfer of spent fuel to dry cask storage in an Independent Spent Fuel Storage Installation (ISFSI).

The proposed changes include recognition of the approved HDI Decommissioning Quality Assurance Plan (DQAP) and relocation of existing TS Administrative Controls from Technical Specifications (TS) to the Defueled Safety Analysis Report (DSAR).

By letter dated June 10, 2019 (Reference 1), Entergy Nuclear Operating, Inc submitted certification of permanent cessation of operation pursuant to 10 CFR 50.82(a)(1). Therefore, as specified in 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for PNPS no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

By letter dated March 31, 2020 (Reference 3), HDI provided notification that off-load of the spent fuel pool (SFP) and transfer of the spent fuel to the ISFSI is expected to be completed in January 2022, provided the criteria for transfer are met including certain regulatory approvals. In support of this condition, a revision to the FL and associated TS is proposed to comport with the requirements for a facility configuration with all spent nuclear fuel stored in approved dry storage casks in an ISFSI.

The existing FL and TS contain Limiting Conditions for Operation (LCOs) that provide for appropriate functional capability of equipment required for safe storage and management of irradiated fuel with spent fuel stored in the SFP. As such, the existing FL and TS provide a level of control in excess of that needed for safe storage and management of irradiated fuel with all spent fuel stored in an ISFSI. The majority of the remaining TS are only applicable when irradiated fuel assemblies are stored in the SFP. Once all spent fuel assemblies have been transferred to one of the site controlled ISFSI locations, all remaining LCOs (and associated Surveillance Requirements (SRs) will no longer be applicable and are proposed for deletion. The proposed FL and TS revisions reflect the removal of all spent fuel from the SFP and will become applicable only after the last spent fuel assembly has been removed from the SFP and stored in an ISFSI. The revised TS will be referred to as the ISFSI Only Technical Specifications (IOTS).

Pending Licensing Actions under NRC Review There are two pending licensing actions, currently under NRC review that relate to this LAR.

On March 17, 2021 (Reference 4), HDI requested NRC approval of a proposed revision to the Physical Security Plan (PSP) to address the security requirements applicable to providing protection of spent nuclear fuel stored in the ISFSI Only storage location.

HDI-PIL-21-017 Page 3 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 On February 18, 2021 (Reference 5) HDI requested NRC approval of a proposed revision to the Permanently Defueled Emergency Plan (DPEP) to accommodate transition to an ISFSI Only Emergency Plan (IOEP).

The above referenced License Amendment submittals coordinate with the proposed submittal addressed via this submittal.

2.0 PROPOSED CHANGE

S The proposed amendment would modify the FL and TS to comport to the condition of all irradiated fuel in approved dry casks within either of the site controlled ISFSI storage locations. The proposed amendment would revise the TS to eliminate operational requirements and certain design requirements that involve storage and protection of spent fuel in the SFP. The proposed FL and TS revisions include a new spent fuel pool design requirement which prevents storage of spent fuel in the SFP. The revised TS for Fuel in the ISFSI Only will be referred at ISFSI Only Technical Specifications (IOTS).

The proposed FL and TS revisions also request relocating certain administrative specifications from TS Section 5, Administrative Controls, to the DSAR, and subsequently controlling future changes to the specification requirements in accordance with the 10 CFR 50.59 change review control process.

Proposed changes to the Facility License (FL) are as follows:

Revise License Condition 3.B, Technical Specifications, to incorporate editorial description changes to reflect the incorporation of the TSs into the license condition.

Eliminate License Condition 3.C, Records, to remove the record keeping requirement from the license and relocate to licensee-controlled documents.

Eliminate License Condition 3.K, Mitigation Strategy License Condition, to remove mitigation strategies for large fires and explosions that no longer apply based on permanent removal of fuel from the reactor and the SFP.

Eliminate License Condition 3.L, to remove requirements to implement and maintain reactor vessel protective actions required by Attachment 2 to NRC Order EA-06-137, based on permanent removal of fuel from the vessel.

Eliminate License Condition 7, to remove License Renewal Commitments applicable to operation of the facility in the extended period of operation authorized by the license renewal amendment.

Proposed changes to the Technical Specifications (TS) are as follows:

Editorial revision to Cover Page, Appendix A to TS, to identify that TS bases are no longer included with TS.

Remove Section 1 .0, "Definitions," to eliminated definitions based on proposed changes that eliminate LCO and surveillances.

Remove Sections 3.0/4.0, "Limiting Conditions of Operation and Surveillance Requirement (SR) Applicability," because the spent fuel pool surveillance requirement is proposed to be deleted.

Remove Sections 3/4.10, "Spent Fuel Storage," LCO and Surveillance based on removal of permanent removal of spent fuel from the SFP.

HDI-PIL-21-017 Enclosure 1 Page 4 of 35

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

Revise Specification 4.1, to eliminate the reactor center line location information based on permanently defueled reactor status.

Revise Specification 4.3, requirements for the SFP based on permanent removal of spent fuel from the SFP.

Revise Section 5.0, "Administrative Controls, to either delete requirements that no longer necessary based on defueled SFP status or relocate the specification to a licensee-controlled document.

3.0 TECHNICAL EVALUATION

General Analysis Applicable to the Proposed Changes The proposed amendment would modify the existing FL and TS by deleting requirements that are no longer applicable to a facility due to the revised plant configuration where no spent fuel is stored in the SFP, and all spent fuel is stored in approved dry casks in site controlled ISFSI locations. The proposed changes also involve revision and relocation of existing TS administrative controls that are no longer required to be retained in IOTS. This proposed amendment will be implemented after NRC approval and within 30 days following HDI's notification to the NRC that all spent fuel assemblies have been transferred out of the SFP and placed in dry storage within an ISFSI.

PNPS plans to use a decommissioning method in which most fluid systems are drained and the plant is left in a stable condition until final dismantlement. Administrative controls that are required to be in place when decontamination or dismantling activities of radioactive systems, structures, and components are being performed, are designed to minimize the likelihood of an off-normal or accident event, and thereby the consequences of such an event. The proposed changes to the existing FL and TS do not have an adverse impact on these remaining decommissioning activities or any of their postulated radiological consequences. Spent fuel will be stored in dry casks in an ISFSI, until it is shipped off site consistent with the schedules described in the Post-Shutdown Decommissioning Activities Report (Reference 2 and 3) and the Irradiated Fuel Management Program (Reference 6).

During decommissioning with all spent fuel in dry storage within an ISFSI, there are no installed plant systems relied upon for the safe storage of spent fuel. In this condition, there are no credible accidents whose prevention or mitigation would need to be addressed by IOTS. In addition, the NRC approved spent fuel storage casks and canisters to be used for spent fuel storage are subject to their own Certificate of Compliance and Cask Technical Specifications (CTS).

HDI-PIL-21-017 Page 5 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 The DSAR describes the design basis accidents (DBAs) related to the SFP. Postulated accidents were predicated on spent fuel being stored in the SFP. With the removal of the spent fuel from the SFP, there are no remaining spent fuel assemblies to be monitored and there are no credible accidents that require the actions of a Certified Fuel Handler, Shift Manager, or a Non-certified Operator to prevent occurrence or mitigate the consequences of an accident. 10 CFR 50.2 defines safety-related structures, systems, and components (SSCs) as those that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant boundary, (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in § 50.34(a)(1) or § 100.11 of this chapter, as applicable.

The first two criteria (integrity of the reactor coolant pressure boundary and safe shutdown of the reactor) are not applicable to a plant in a permanently defueled condition.

The third criterion is related to preventing or mitigating the consequences of accidents that could result in potential offsite exposures exceeding limits. However, after all nuclear spent fuel assemblies have been transferred to dry cask storage within an ISFSI, there are no longer any SSCs at PNPS that are required to be relied upon for accident prevention or mitigation, since the only design basis accident described in Section 6.0 to the DSAR involves a fuel handling accident (FHA) analyzed using Alternate Source Term methodology using the applicable guideline exposures specified in § 50.67(b)(2). Since the FHA is predicated on spent fuel stored in the SFP, it is no longer applicable as a design basis accident once all spent fuel is offloaded from the SFP and transferred to dry storage within the ISFSI. Therefore, there are no SSCs at PNPS that meet the definition of a safety-related SSC as defined in § 50.2, and the proposed deletion of requirements in the TS does not involve any SSCs credited in any accident analysis at PNPS after the complete offload of the SFP and transfer of spent fuel to the ISFSI.

10 CFR 50.36, "Technical Specifications," promulgates the regulatory requirements related to the content of Technical Specifications. As detailed in subsequent sections of this proposed amendment, this regulation lists four criteria to define the scope of equipment and parameters that must be included in a plant's Technical Specifications. A discussion of the applicability of these four criteria in the permanently defueled condition with all fuel removed from the spent fuel pool is provided in Section 4.1 of this enclosure. In a permanently defueled condition with all spent fuel in dry storage within the ISFSI, the scope of equipment and parameters that need be included in the IOTS is limited to a description of the site design features and high radiation area administrative controls.

The proposed changes related to the relocation of certain TS administrative controls do not affect operating procedures or administrative controls that have the function of preventing or mitigating any accidents applicable to the safe management of irradiated fuel stored in approved dry casks or decommissioning of the permanently defueled facility.

HDI-PIL-21-017 Page 6 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Detailed Discussion The following identifies each section in the FL and TS that are proposed to be changed, the proposed changes, and the basis for each change. Changes to the FL are listed first, followed by changes to TS. Changes to the existing FL and TS are identified in the markups shown in to this Enclosure. Retyped pages showing the revised FL and IOTS are provided in to this Enclosure.

Editorial changes are proposed to the Cover Page for Appendix A to Technical Specifications (TS) to delete reference to and Bases." A TS change is proposed to remove the existing SFP LCO and Surveillances, and the associated BASES. Additionally, the TS Bases Control Program in TS 5.5.6 is proposed to be deleted for this same reason.

Changes to the TS Table of Contents are proposed to reflect the removal of sections that will be eliminated in this LAR, as well as proposed changes to revise or remove page numbering that is no longer needed. These proposed changes are considered acceptable editorial changes and require no further justification.

Proposed License Condition Changes License Condition 3.B.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 253 are hereby replaced with the Permanently Defueled Technical Specifications. The licensee shall maintain the facility in accordance with the Permanently Defueled Technical Specifications.

The above referenced specification is proposed to be revised to indicate that IOTS were approved and were incorporated into the license. This is an editorial description change that ensures the license condition accurately reflects that IOTS were incorporated into the license. Attachment 1 to this enclosure identifies the proposed markup.

License Condition 3.C, C. Records HDI shall keep facility records in accordance with the requirements of the Technical Specifications.

The license condition identified above, requires HDI to keep facility records in accordance with the requirements of Technical Specifications. However, review of the existing TS does not identify a record process or any specific records that must be captured. Therefore, the license-condition does not provide any specific record keeping requirements other than to keep records.

PNPS identifies specific record keeping requirements in Section 17.0 of the Quality Assurance Program Manual (QAPM) and in Section 5.5 of the Site DSAR. Both documents are maintained for HDI-PIL-21-017 Page 7 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Site decommissioning purposes as required per 10 CFR Part 50 regulatory requirements. These documents are licensee-controlled documents, that have regulatory change control review requirements per the applicable regulation (e.g., § 50.54(a) or § 50.59). These change review requirements ensure that proposed changes are evaluated prior to implementation for potential adverse impacts to either the QA Program requirements or DSAR identified design functions and facility controls, respectively. Additionally, these licensee-controlled documents have periodic update and NRC submittal requirements to ensure that the document is maintained to reflect current facility status, and to keep NRC informed of ongoing changes.

Relocating technical specification requirements to licensee-controlled documents is an acceptable strategy to promote flexibility when implementing organizational changes during decommissioning.

NRC Administrative Letters 95-06 and 96-04 (References 7 and 8) reflect guidance that identifies conditions where it is acceptable to relocate technical specifications to licensee-controlled documents when the license condition or specification is not required, or no longer required, per § 50.36. For decommissioning facilities, that have provided permanent shutdown certifications per § 50.82(a)(1), required specifications will be developed on a case-by case basis.

Additionally, the spent fuel storage cask systems located in an ISFSI are subject to 10 CFR 72.212 regulatory requirements. These requirements address Cask Certificate of Compliance and Cask Technical Specification requirements in addition to site specific requirements for cask design control, quality assurance, and record keeping requirements.

Based on the above, PNPS has appropriate site record keeping controls in-place to ensure that facility records are maintained without reliance on existing TS License Condition 3.C.

License Condition 3.K.

K. Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures HDI-PIL-21-017 Page 8 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders This license condition is proposed for deletion in its entirety.

The license condition was approved in 2007 (Reference 9) and was implemented in response to industry action to improve capabilities to address events related to the September 11, 2001 terrorist threats. The purpose of the mitigating strategies is to develop specific guidance and strategies to maintain or restore reactor core cooling, containment, and spent fuel pool cooling capabilities using existing and readily available resources under circumstances associated with large loss areas of the plant due to explosions or fire.

Based on permanent cessation of reactor operation, permanent removal of reactor fuel from the reactor, and future removal of fuel from the SFP, this license condition will no longer be needed when all fuel is permanently removed from the SFP and stored in an ISFSI.

Related to this license condition is NRC Order EA-02-026. This order was issued by letter dated February 25, 2002 (Reference 10), to ensure that required operating nuclear facilities implement required security measures to protect nuclear fuel resulting from large fires and explosions. The order was the initial NRC response related to the September 11, 2001 terrorist attacks.

Subsequently, industry guidance was further developed and used to establish a specific PNPS license condition to address these mitigating strategies. License Condition 3.K addresses Section B.5.b of Order EA-02-026.

NRC letter dated November 28, 2011 (Reference 11) partially rescinded Order EA-02-026 but indicated that Interim Compensatory Measure (ICM) B.1.a remained in effect at Pilgrim. This ICM action involved operator training for specific security-initiated events that were not covered by regulations or license amendments.

By letter dated October 31, 2018 (Reference 12) Entergy requested rescission of ICM B.1.a to EA-02-026, which was the only remaining ICM EA-02-026 action applicable to PNPS. NRC review of this request is documented in letter dated July 2, 2019 (Reference 13). NRC review was performed and the ICM B.1.a action was rescinded. However, the NRC rescission review credited the protective measures identified in License Condition 3.K as basis to support order rescission and continued protection for nuclear fuel located in the SFP.

By letter dated June 10, 2019, (Reference 1) Entergy certified cessation of power operation and fuel was permanently removed from the reactor. After the fuel is removed from the SFP and stored in dry casks in an ISFSI, the mitigating strategies in License Condition 3.K will no longer perform a required fuel protection function, and therefore the license condition can be deleted.

HDI-PIL-21-017 Page 9 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 License Condition 3.L.

L. The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

This License condition is proposed for deletion in its entirety.

By letter dated June 20, 2006 (Reference 14), the NRC issued Oder EA-06-137, Order Requiring Compliance with Key Radiological Protection Mitigation Strategies, to various operating nuclear power reactor licensees including Pilgrim Station. The order required implementation of a certain key radiological protection strategy for the purpose of allaying the effects of a loss of coolant accident for the reactor vessel. Pilgrim has certified permanent shutdown and defueled the reactor per 10 CFR 50.82(a)(1)(i) and (ii) (Reference 1). Therefore, the effects of a loss of coolant accident in the reactor vessel are precluded and Order EA-06-137 no longer provides a fuel protective function.

Pilgrim Station had previously requested rescission of NRC order EA-06-137 (Reference 12). NRC review of the request identified that the licensee had demonstrated good cause to rescind EA 137 in its entirety (Reference 13). License Condition 3.L no longer provides the nuclear fuel and vessel protection and therefore deletion of this license condition is warranted.

License Condition 7

7. The information in the FSAR supplement, submitted pursuant to 10 CFR 54.21(d), as supplemented by Commitments Nos. 3, 8, 9, 13, 15, 18, 19, 21, 22, 24, 25, 26, 27, 28, 30, 31, 33, 34, 35, 36, 37, 39, 40, 46, 51, and 52 of Appendix A of NUREG-1891, Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station dated June 2007, as supplemented, is henceforth part of the FSAR which will be updated in accordance with 10 CFR 50.71(e).

The licensee may make changes to the programs and activities described in the FSAR supplement and Commitments Nos. 3, 8, 9, 13, 15, 18, 19, 21, 22, 24, 25, 26, 27, 28, 30, 31, 33, 34, 35, 36, 37, 39, 40, 46, 51, and 52 of Appendix A of NUREG 1891, as supplemented, provided the licensee evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section This License condition is proposed for deletion in its entirety.

PNPS documented on June 8, 2012, with Letter from Entergy to US NRC (Reference 19) that Entergy had completed implementation of commitments activities that were required to be completed prior to entering the period of extended operation.

This license condition involves management of license renewal amendment (LRA) commitments.

The purpose of these LRA commitments was to ensure that the aging effects of equipment important to the safe operation of the reactor are managed so that the functionality of SSCs is HDI-PIL-21-017 Page 10 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 maintained during the facility's period of extended operation. For a permanently shutdown facility, most of the equipment subject to aging management programs are no longer in use and functionality does not need to be maintained.

During decommissioning, some equipment functionality, such as for equipment related to the fire protection system to address fire events that could result in radiological hazards per the requirements of 10 CFR 50.48(f), may be required beyond the permanent cessation of operations and therefore may be subject to an aging management program.

Prior to cessation of operations, PNPS license renewal commitments for aging management were incorporated into Section 7, "Aging Management Programs," of the Updated Final Safety Analysis Report (UFSAR), and subsequently were relocated to Section 7, "Aging Management," of the DSAR. The DSAR is updated in accordance with 10 CFR 50.71(e). Changes to these license renewal commitments continue to be evaluated and controlled pursuant to the change review requirement criteria identified 10 CFR 50.59 and 10 CFR 50.71(e). On this basis, the NRC staff has previously found that update and or removal of license renewal commitments identified in the DSAR acceptable per the established controls provided for maintaining the DSAR.

The spent fuel storage cask systems located in an ISFSI are subject to their own Certificate of Compliance and Cask Technical Specification requirements. These cask protection requirements are not referenced or identified License Condition 7. Based on the above, administrative controls for maintaining the DSAR will be used to address and control license renewal commitments and therefore, License Condition 7 can be deleted.

HDI-PIL-21-017 Page 11 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Technical Specification Changes TS Cover Page.

The proposed change addresses an editorial change to add the ISFSI Only descriptor and remove the wording that Permanently Defueled Technical Specification and BASES are included in Appendix A. The proposed change reflects a plant condition where the reactor is permanently defueled and shutdown, and all fuel has been removed from and permanently prevented from being stored in the spent fuel pool. The revision to the Appendix A cover page is consistent with the proposed changes to remove operational specifications and associated BASES.

TS Section 1 .0, "Definitions."

The succeeding frequently used terms are explicitly defined so that a uniform interpretation of the specifications may be achieved.

ACTION ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.

CERTIFIED FUEL A CERTIFIED FUEL HANDLER is an individual who complies with the HANDLER provisions of the CERTIFIED FUEL HANDLER Training and Retraining Program.

IMMEDIATE IMMEDIATE means that the required action will be initiated as soon as practicable considering the safe maintenance of the facility and the importance of the required action.

LIMITING The LIMITING CONDITIONS FOR OPERATION specify the minimum CONDITIONS FOR acceptable levels of system performance necessary to assure safe OPERATION (LCO) maintenance of the facility. When these conditions are met, the facility can be maintained safely and abnormal situations can be safely controlled.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be considered a failure to meet the LCO.

NON-CERTIFIED A NON-CERTIFIED OPERATOR is a non-licensed operator who OPERATOR complies with the qualification requirements of Specification 5.3.1 but is not a CERTIFIED FUEL HANDLER.

SURVEILLANCE Each Surveillance Requirement shall be performed within the specified FREQUENCY SURVEILLANCE INTERVAL with a maximum allowable extension not to exceed 25 percent of the specified SURVEILLANCE INTERVAL.

The SURVEILLANCE FREQUENCY establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance schedule and consideration of facility conditions that may not be suitable for conducting the surveillance, e.g., transient HDI-PIL-21-017 Page 12 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 conditions or other ongoing surveillance or maintenance activities. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified.

This limitation of this definition is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

SURVEILLANCE The SURVEILLANCE INTERVAL is the calendar time between INTERVAL surveillance tests to be performed to confirm that a parameter is within limits.

As stated in the specification above, the purpose of the definitions is to provide uniform interpretation of frequently used terms in the TS. The proposed changes to other TS sections as reflected in this submittal, either eliminate or relocate the information that references these terms.

Since these terms are no longer needed after spent fuel has been removed from the SFP and transferred to an ISFSI, it is acceptable to delete these definitions from the IOTS.

TS Sections 2 .0 Technical Specification 2.0 was previously deleted from TS. The proposed change is to remove the pages that was retained in TS after Section 2.0 was deleted. This is an editorial change to eliminate pages that no longer contain TS requirements. See Attachment 1 for removal detail.

TS Section 3.0 /4.0 4.0.3 If it is discovered that a Surveillance was not performed within its specified Surveillance Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Surveillance Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

All information in Section 3.0 was previously deleted, and the only remaining specification located in this TS section is specification SR 4.0.3. SR 4.0.3 provides general requirements applicable to actions to take if it is discovered that a required surveillance was not performed within its specified Surveillance Frequency. After the transfer of spent fuel from the SFP to an ISFSI is complete, there HDI-PIL-21-017 Page 13 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 will no longer be any Limiting Conditions for Operation or Surveillance Requirements to perform.

Therefore, there are no surveillance requirements remaining to apply these general missed surveillance controls. Deleting these sections in their entirety is acceptable and has no impact on continued safe storage and maintenance of spent fuel located dry casks in a site controlled ISFSI.

TS Section 3.10 / 4.10, Spent Fuel Storage LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.10 SPENT FUEL STORAGE 4.10 SPENT FUEL STORAGE Applicability: Applicability:

Applies to the storage of spent fuel. Applies to the parameter which monitors the storage of spent fuel.

Objective: Objective:

To ensure safe storage of spent fuel. To verify that spent fuel is being stored safely.

Specification: Specification:

A. Not Used A. Not Used B. Not Used B. Not Used C. Spent Fuel Pool Water Level C. Spent Fuel Pool Water Level Whenever irradiated fuel is stored Whenever irradiated fuel is stored in in the spent fuel pool, the pool the spent fuel pool, the water level water level shall be maintained at shall be recorded daily.

or above 33 feet.

The requirements in this section are related to assuring the functional capability of equipment required for safe storage and maintenance of spent fuel stored in the SFP. TS 3.10 / 4.10 do not apply when there are no fuel assemblies stored in the SFP. Therefore, these specifications will no longer be needed following the transfer of all spent fuel assemblies from the SFP to an ISFSI. As such, these TS will be deleted in their entirety.

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Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 TS Section 4.0, Design Features.

TS Specification 4.1, Site Location 4.1 Site Location Pilgrim Nuclear Power Station is located on the western shore of Cape Cod Bay in the Town of Plymouth, Plymouth County, Massachusetts and contains approximately 517 acres owned by Holtec Pilgrim as shown on FSAR Figures 2.2-1 and 2.2-2. The site boundary is posted and a perimeter security fence provides a distinct security boundary for the protected area of the station.

The reactor (center line) is located approximately 1800 feet from the nearest property boundary.

The proposed change to TS 4.1 involves deletion of the site location information that describes reactor center line location. The minimum distance from the center line of the reactor containment to the site exclusion radius is based on requirements contained in § 100.3 regarding reactor accident dose analyses. Based on submittal of § 50.82(a)(2) certification, the PNPS 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel. As a result, Site location information described in TS 4.1 no longer needs to describe reactor center line location.

The proposed content of IOTS 4.1 describing the site location is consistent with the level of detail provided in the comparable design features site location descriptions in the TS for Kewaunee approved by the NRC on June 7, 2017 (Reference 15) and the TS for Vermont Yankee (Reference 16)

TS Specification 4.3, Spent Fuel Storage 4.3 Spent Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum k-infinity of 1.32 for standard core geometry, calculated at the burnup of maximum bundle reactivity, and an average U-235 enrichment of 4.6 %

averaged over the axial planar zone of highest average enrichment; and

b. Keff 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in the applicable section of the FSAR.

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Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 4.3.2 Drainage The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 115 ft.

4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 3859 fuel assemblies.

4.3.4 Heavy Loads

a. Loads in excess of 2000 lb. shall be prohibited from travel over fuel assemblies in the spent fuel storage pool with the exception that heavy load handling over irradiated fuel in the Multi-Purpose Canister is permitted using a single-failure-proof handling system.

b. No fuel which has decayed for less than 200 days shall be stored in racks within an arc described by the height of the cask around the periphery of the leveling platform during cask handling operations in the spent fuel pool or when a cask is in the spent fuel pool.

TS Specification 4.3 describes design features associated with spent fuel storage in the SFP. This TS section requires modification to eliminate the existing SFP protection requirements and to replace them with a new requirement. After all spent fuel is removed from the SFP, the existing requirements of TS 4.3 are no longer applicable and may be replaced with Spent fuel shall not be stored in the Spent Fuel Pool. This specification change will permanently preclude storage of fuel in the pool after the spent fuel is removed during the final off-load campaign.

Section 5.0, "Administrative Controls.

The Administrative Controls section of Technical Specifications will be deleted or relocated to licensee-controlled documents. Section 5.7, High Radiation Area will be retained to control on-going decommissioning activities.

TS Section 5.1 Responsibility 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect nuclear safety.

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Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 5.1.2 The control room supervisor (CRS) shall be responsible for the control room command function.

TS Section 5.1.1 provides a description and requirements regarding certain key operational management responsibilities. The proposed change is to delete these sections from the TS and relocate them to the PNPS DSAR. A new DSAR administrative controls section will be created to retain the relocated Administrative Controls specifications. The title of the "plant manager" position in TS 5.1.1 will be revised to "manager responsible for overall operational activities" when it is relocated to the DSAR. This title change does not change any requirements, qualifications, or responsibilities of the individual in this position, and is strictly an administrative change to provide flexibility in the event of organization changes. This change is consistent with previously approved changes to the position titles in the TS to allow facility specific titles to be identified in licensee-controlled documents.

After these administrative controls are incorporated into the DSAR, any future changes are controlled in accordance with§ 50.59. This will provide adequate control for the facility with all spent fuel located within the ISFSI. The relocation of administrative controls for responsibility requirements to the DSAR is consistent with NRC Administrative Letter 95-06 and 96-04 (References 7 and 8) guidance and will have no impact on safe storage and maintenance of spent fuel in the ISFSI.

Administrative controls proposed to be relocated to the DSAR are as shown in Attachment 3 to this letter.

Existing TS 5.1.2 addresses the requires the shift supervisor to be responsible for the shift command function. This requirement is proposed to be eliminated. As described in the existing TS 5.1.2 the shift command function is focused on operations involving the storage or movement of spent nuclear fuel within the SFP. After all spent fuel is permanently removed from the SFP, the need for the shift supervisor and shift command function for spent fuel management no longer exists. The position of shift supervisor described in TS 5.1.2 is a holdover from the control room function of supervising multiple functions of an operating nuclear power plant. With the limited requirements for supervision of the passive dry fuel storage system utilized within the ISFSI or with respect to the decommissioning of the former power generation facility, the shift supervisor position and shift command function are no longer required, therefore the proposed deletion of TS 5.1.2 is acceptable.

HDI-PIL-21-017 Page 17 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 TS Section 5.2, "Organization This section describes the Onsite and Offsite Organizations, and the Facility Staff functions.

TS 5.2.1, Onsite and Offsite Organizations 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear fuel.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical specifications shall be documented in the Pilgrim Station shall be documented in the Pilgrim Station Final Safety Analysis Report (FSAR);

b. The plant manager shall be responsible for overall safe operation of the facility and shall have control over those onsite activities necessary for safe storage and maintenance of the nuclear fuel;

c. The specified corporate officer for Pilgrim shall have corporate responsibility for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure safe management of nuclear fuel, and

d. The individuals who train the CERTIFIED FUEL HANDLERs, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions Revisions to these sections will be incorporated as follows.

TS Section 5.2.1 administrative controls describe organizational lines of authority, responsibilities, and requirements for organizational freedom for certain personnel including those performing health HDI-PIL-21-017 Page 18 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 physics or quality assurance functions are provided sufficient organizational freedom. The administrative controls provided in the TS 5.2.1 will be incorporated in the DSAR verbatim, with the following exceptions:

TS 5.2.1.(b), reference to "plant manager" will be revised to "manager responsible for overall operational activities" in order to conform to the description of the corresponding management position in Section A, "Management," of the existing QAPM. This does not change any requirements, qualifications, or responsibilities of the individual in this position, and is strictly an administrative change. This change is consistent with previously approved changes to the position titles in the TS to allow facility specific titles to be identified in licensee-controlled documents such as the QAPM or DSAR (Reference 7).

TS 5.2.1.(d) reference to individuals who "train the Certified Fuel Handlers" will not be incorporated into the DSAR. After all fuel is stored within the ISFSI and storage of spent fuel in the SFP is prohibited, there will no longer be an organizational need for Certified Fuel Handlers or the associated training program. Therefore, this change will have no impact on continued safe storage and maintenance of spent fuel stored in the ISFSI.

After these administrative controls are incorporated into the DSAR, any future changes are controlled in accordance with§ 50.59. This will provide adequate control for the facility with all spent fuel located within the ISFSI. The relocation of administrative controls for organizational requirements to the DSAR is consistent with NRC Administrative Letter 95-06 and 96-04 (References 7 and 8) guidance and will have no impact on safe storage and maintenance of spent fuel in the ISFSI.

Administrative controls proposed to be relocated to the DSAR are as shown in Attachment 3 to this enclosure.

TS Section 5.2.2, "Unit Staff

5.2.2 Facility Staff The facility staff organization shall include the following:

a. Each day shift shall be composed of at least one control room supervisor and one NON-CERTIFIED OPERATOR. The NON-LICENSED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER.

b. At least one person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the Control Room when nuclear fuel is stored in the spent fuel pool.

c. Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER.

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

d. Shift crew composition may be less than the minimum requirement of 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements and all of the following conditions are met:

1) No fuel movements are in progress;

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

3) No unmanned shift positions during shift turnover shall be permitted while the shift crew is less than the minimum.

e. Not Used

f. An individual qualified in radiation protection procedures shall be on site during fuel handling operations and during movement of heavy loads over the fuel storage racks. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position

g. Not Used

h. The control room supervisor shall be a CERTIFIED FUEL HANDLER.

i. Not Used TS 5.2.2 is proposed to be deleted in its entirety. These administrative controls pertain to the facility staff organization and requirements when spent fuel is stored or moved within the SFP. Once all spent fuel is located within the ISFSI and spent fuel storage in the SFP is prohibited, it is not necessary to retain these spent fuel handling administrative controls. Therefore, the deletion of TS 5.2.2 after the fuel has been moved from the spent fuel pool to the ISFSI will have no impact on sate storage and maintenance of spent fuel in the ISFSI and is acceptable.

TS Section 5.3, "Facility Staff Qualifications 5.3 Facility Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Quality Assurance Program Manual (QAPM).

5.3.2 An NRC approved training and retraining program for CERTIFIED FUEL HANDLERs shall be maintained.

HDI-PIL-21-017 Page 20 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 The proposed change is to delete TS 5.3.1 from the TS and to relocate the requirements to the DSAR. After these administrative controls are incorporated into the DSAR, any future changes are controlled in accordance with§ 50.59. This will provide adequate control for the facility with all spent fuel located within the ISFSI. The relocation of administrative controls for facility staff qualification requirements to the DSAR is consistent with NRC Administrative Letter 95-06 and 94-06 (References 7 and 8) guidance and will have no impact on safe storage and maintenance of spent fuel in the ISFSI.

Administrative controls proposed to be relocated to the DSAR are as shown in Attachment 3 to this enclosure.

Existing TS 5.3.2 specifies that a Certified Fuel Handler training program shall be maintained. As described in the existing TS 5.3.2, the shift command function is focused on operations involving the storage or movement of spent nuclear fuel within the SFP. Following the transfer of all spent fuel to the ISFSI, storage of spent fuel in the SFP will be prohibited upon implementation of this amendment, thus there will no longer be a need for Certified Fuel Handlers or the associated training programs. Therefore, this proposed deletion will have no impact on safe storage and maintenance of spent fuel in the ISFSI and is acceptable.

TS Section 5.4, "Procedures addresses procedure requirements to ensure Quality Assurance requirements for operation of nuclear power plants, Quality Assurance for effluent and environmental monitoring, fire protection program implementation, and all programs referenced in technical specification 5.5.

5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. The procedures applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978

b. Not Used

c. Quality assurance for effluent and environmental monitoring;

d. Fire Protection Program implementation; and

e. All programs specified in Specification 5.5.

The administrative controls identified for procedures in section 5.4.1, will be relocated to the DSAR.

TS 5.4 requires written procedures to be established, implemented, and maintained for certain activities. The proposed change is to delete TS 5.4 from the TS in its entirety, and to relocate the requirements to the DSAR administrative controls section with the exception of TS 5.4.1.(a) which HDI-PIL-21-017 Page 21 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 involves fuel handling operations in the SPF. As discussed above, following the transfer of the spent fuel to the ISFSI, the proposed change to TS 4.3 will prohibit the storage of spent fuel in the SFP.

After these administrative controls are incorporated into the DSAR, any future changes are controlled in accordance with§ 50.59. This will provide adequate control for the facility with all spent fuel located within the ISFSI. The relocation of administrative controls for procedure requirements to the DSAR is consistent with NRC Administrative Letter 95-06 and 96-04 (Reference 7 and 8) guidance and will have no impact on safe storage and maintenance of spent fuel in the ISFSI.

Administrative controls proposed to be relocated to the DSAR are as shown in Attachment 3 to this enclosure.

TS Section 5.5, "Programs and Manuals, addresses the programs and manuals that are required to be established and maintained. This section identifies that the Offsite Dose Calculation Manual (ODCM), the Radioactive Effluent Controls Program and the Technical Specifications (TS)

Bases Control Program are required to be maintained.

TS Section 5.5.1, Offsite Dose Calculation Manual 5.5.1 Offsite Dose Calculation Manual (ODCM)

a. The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and

b. The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities and descriptions of the information that should be included in the Annual Radiological Environmental Operating, and Radioactive Effluent Release, reports required by Specification 5.6.2 and Specification 5.6.3.

c. Licensee initiated changes to the ODCM:

1. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:

a. sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and

b. a determination that the change(s) maintain the levels of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;

2. Shall become effective after the approval of the plant manager; and HDI-PIL-21-017 Page 22 of 35

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

3. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

TS 5.5.1 specifies how to document, review, and approve changes to the OOCM. The proposed change is to delete TS 5.5.1 from the TS and relocate the requirements verbatim to the DSAR with the following exceptions:

References to Specification 5.6.2 and 5.6.3 are deleted. This is an administrative change since these will no longer reside in the TS once relocated to the DSAR and the references are not necessary to describe the administrative requirements.

A reference to the "plant manager" position will be revised to "manager responsible for overall operational activities". This editorial change does not alter any requirements, qualifications, or responsibilities of the individual in this position, and is strictly an administrative change. This change is consistent with previously approved changes to the position titles in the TS to allow facility specific titles to be identified in licensee-controlled documents.

The proposed change is to delete TS 5.5.1 from the TS and to relocate the requirements to the DSAR.

After these administrative controls are incorporated into the DSAR, any future changes are controlled in accordance with§ 50.59. This will provide adequate control for the facility with all spent fuel located within the ISFSI. The relocation of administrative controls for programs and manual requirements to the DSAR is consistent with NRC Administrative Letter 95-06 and 96-04 (Reference 7 and 8) guidance and will have no impact on safe storage and maintenance of spent fuel in the ISFSI.

Administrative controls proposed to be relocated to the DSAR are as shown in Attachment 3 to this enclosure.

TS Section 5.5.4, Radioactive Effluent Controls Program 5.5.4 Radioactive Effluent Controls Program This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

a. Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; HDI-PIL-21-017 Page 23 of 35

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

b. Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas, conforming to ten times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402;

c. Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM;

d. Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released to unrestricted areas, conforming to 10 CFR 50, Appendix I;

e. Determination of cumulative contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days.

Determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM at least every 31 days;

f. Limitations on the functional capability and use of the liquid and gaseous effluent treatment systems to ensure that appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a period of 31 days would exceed 2% of the guidelines for the annual dose or dose commitment, conforming to 10 CFR 50, Appendix I;

g. Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site boundary to areas at or beyond the site boundary conforming to the following:

1. For noble gases: Less than or equal to 500 mrem/yr to the whole body and less than or equal to 3000 mrem/yr to the skin, and

2. For Iodine-131, Iodine-133, Tritium, and all radionuclides in particulate form with half lives greater than 8 days: Less than or equal to 1500 mrem/yr to any organ.

h Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; i Limitations on the annual and quarterly doses to a member of the public from Iodine-131, Iodine-133, Tritium, and all radionuclides in particulate form with half lives > 8 days in gaseous effluents released to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; and j Limitations on the annual dose or dose commitment to any member of the public, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.

HDI-PIL-21-017 Page 24 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 TS 5.5.4 specifies administrative requirements for the program to control radioactive effluents and for maintaining doses to the public to within the specified limits. The proposed change is to delete TS 5.5.4 from the TS and relocate the requirements to the DSAR with the following exceptions:

References to iodine-131 and iodine-133 in 5.5.4.g.2 and 5.5.4.i will not be relocated to the DSAR due to the radioactive decay and short half-lives (approximately 8 days and 20.83 hours9.606481e-4 days 0.0231 hours 1.372354e-4 weeks 3.15815e-5 months , respectively) and time since permanent cessation of reactor operation. This is consistent with changes to the ODCM implemented under 10 CFR 50.59.

References to 5.5.4.g.1 and 5.5.4.h will not be relocated to the DSAR since after all spent fuel is transferred to the ISFSI and contained within dry storage casks, there will no longer be a requirement to monitor for noble gases released from the facility.

References to "gaseous" effluents and monitoring will be revised to "airborne effluents and monitoring will be incorporated based on conditions applicable to post fuel removal from spent fuel pool to dry casks located in the ISFSI. This editorial change does not alter monitoring requirements previously identified and is strictly an administrative change.

The proposed change is to delete TS 5.5.4 from the TS and to relocate the requirements to the DSAR.

After these administrative controls are incorporated into the DSAR, any future changes are controlled in accordance with§ 50.59. This will provide adequate control for the facility with all spent fuel located within the ISFSI. The relocation of administrative controls for Radioactive Effluents Control Program requirements to the DSAR is consistent with NRC Administrative Letter 95-06 and 96-04 (References 7 and 8) guidance and will have no impact on safe storage and maintenance of spent fuel in the ISFSI.

Administrative controls proposed to be relocated to the DSAR are as shown in Attachment 3 to this enclosure.

TS Section 5.5.6 Technical Specifications (TS) Bases Control Program 5.5.6 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. change in the TS incorporated in the license; or

2. a change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

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

d. Proposed changes that meet the criteria of Specification 5.5.6b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

TS 5.5.6. describes the TS Bases Control Program and is proposed to be deleted in its entirety from the TS. Based on the proposed deletion of all LCOs and Surveillances in other TS sections referenced in this LAR, there is no longer any TS Bases needed to provide surveillance guidance. As such, there is no need to maintain the TS Bases control program. Therefore, the proposed deletion of TS 5.5.6 is acceptable.

TS Section 5.6, "Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the facility during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include a summary of the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the facility shall be submitted in accordance with 10 CFR 50.36a by May 15th of each year.

The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the facility. The material provided shall be consistent with the objectives outlined in the ODCM and HDI-PIL-21-017 Page 26 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 process control procedures and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

TS 5.6 addresses radiological reporting requirements. The proposed change is to delete TS 5.6 from the TS in its entirety and relocate the requirements verbatim to the DSAR. After these administrative controls are incorporated into the DSAR, any future changes are controlled in accordance with§ 50.59. This will provide adequate control for the facility with all spent fuel located within the ISFSI. The relocation of administrative controls for reporting requirements to the DSAR is consistent with NRC Administrative Letter 95-06 and 96-04 (References 7 and 8) guidance and will have no impact on safe storage and maintenance of spent fuel in the ISFSI, and therefore is acceptable.

Administrative controls proposed to be relocated to the DSAR are as shown in Attachment 3 to this enclosure.

HDI-PIL-21-017 Page 27 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements 10 CFR 50.2, Definitions. Safety-Related Structures. Systems and Components 10 CFR 50.2 defines safety-related structures, systems, and components (SSCs) as those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in § 50.34(a)(1) or § 100.11 of 10 CFR, as applicable.

10 CFR 50.36. Technical Specifications In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of Technical Specifications (TS). In doing so, the Commission placed emphasis on those matters related to the prevention of accidents and mitigation of accident consequences; the Commission noted that applicants were expected to incorporate into their TS "those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity" (Statement of Consideration, "Technical Specification for FLs; Safety Analysis Reports," 33 FR 18610, December 17, 1968). Pursuant to§ 50.36, TS are required to include items in the following five categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plant's TS.

The final Commission Policy Statement established four criteria to define the scope of equipment and parameters to be included in the improved Standard Technical Specifications. These criteria were developed for licenses authorizing operation (i.e., operating reactors) and focused on instrumentation to detect degradation of the reactor coolant system pressure boundary, process variables and equipment, design features , or operating restrictions that affect the integrity of fission product barriers during design bases accidents or transients. A fourth criterion refers to the use of operating experience and probabilistic risk assessment to identify and include in the Technical Specifications structures, systems, and components (SSCs) shown to be significant to public health and safety. These criteria, which were subsequently codified in changes to Section 36 of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50.36) (60 FR 36953), also pertain to the Technical Specification requirements for safe storage of spent fuel. A general discussion of these considerations is provided below.

Criterion 1 of 10 CFR 50.36(c)(2)(ii)(A) states that Technical Specification limiting conditions for operation must be established for "installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary."

Since the certifications of § 50.82(a)(1) have been docketed for PNPS, under § 50.82(a)(2) the PNPS 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, therefore this criterion is not applicable. Criterion 2 of 10 HDI-PIL-21-017 Page 28 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 CFR 50.36(c)(2)(ii)(B) states that Technical Specification limiting conditions for operation must be established for a "process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier." The purpose of this criterion is to capture those process variables, design features, or operating restrictions that involve an initial condition assumed in the design basis accident and transient analyses, and which are monitored and controlled during power operation. Since PNPS is no longer licensed to operate, and the existing design basis accident is a fuel handling accident predicated on the storage of spent fuel in the SFP, with all spent fuel stored in the ISFSI, there are no remaining design basis accidents which are credible, and therefore this criterion is not applicable.

Criterion 3 of 10 CFR 50.36(c)(2)(ii)(C) states that Technical Specification limiting conditions for operation must be established for SSCs that are part of the primary success path and which function or actuate to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The intent of this criterion is to capture into Technical Specifications only those SSCs that are part of the primary success path of a safety sequence analysis. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function. The primary success path of a safety sequence analysis consists of the combination and sequences of equipment needed to operate (including consideration of the single failure criterion), so that the plant response to design basis accidents and transients limits the consequences of these events to within the appropriate acceptance criteria. Since fuel will have been removed from the SFP at the PNPS facility prior to implementation of this amendment, this criterion is not applicable. Criterion 4 of 10 CFR 50.36(c)(2)(ii)(D) states that Technical Specification limiting conditions for operation must be established for SSCs that operating experience or probabilistic risk assessment has shown to be significant to public health and safety. The intent of this criterion is that risk insights and operating experience be factored into the establishment of Technical Specification limiting conditions for operation. Since fuel will have been removed from the spent fuel pool at the PNPS facility prior to implementation of this amendment, this criterion is not applicable.

Addressing administrative controls, 10 CFR 50.36(c)(5) states that they " ... are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner." The particular administrative controls to be included in the TS, therefore, are the provisions that the Commission deems essential for the safe operation of the facility that are not already covered by other regulations. Accordingly, the NRC staff determined that administrative control requirements that are not specifically required under Section 50.36(c)(5), and which are not otherwise necessary to obviate the possibility of an abnormal situation or an event giving rise to an immediate threat to the public health and safety, may be relocated to more appropriate documents (e.g., Quality Assurance Program Manual, Technical Requirements Manual, Security Plan, or Emergency Plan), which are subject to regulatory controls. Similarly, while the required content of TS administrative controls is specified in 10 CFR 50.36(c)(5), particular details may be relocated to licensee-controlled documents, where other regulations including § 50.59 and Appendix B to 10 CFR Part 50 provide adequate regulatory control.

10 CFR 50.36(c)(6), "Decommissioning," applies only to nuclear power reactor facilities that have submitted the certifications required by § 50.82(a)(1 ). For such facilities, Technical Specifications involving safety limits, limiting safety system settings, and limiting control system settings; limiting HDI-PIL-21-017 Page 29 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 conditions for operation; surveillance requirements; design features; and administrative controls will be developed on a case-by-case basis.

Administrative Letter (AL) 95-06 and 96-04 The Quality Assurance Program Manual is an appropriate candidate for relocations of administrative controls due to the controls imposed by such regulations as Appendix B to 10 CFR Part 50, the existing NRC-approved QA plans and commitments to industry QA standards, and the established QA program change control process of 10 CFR 50.54(a).

The Defueled Safety Analysis Report (former FSAR) is also an appropriate candidate for relocation of administrative controls due to the controls imposed by 10 CFR 50.59 and requirements to review changes, tests, and experiments.

NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance" (Reference 7), and NRC Administrative Letter (AL) 96-04, Efficient Adoption of Improved Standard Technical Specifications (Reference 8), provide guidance to licensees requesting amendments that relocate administrative controls to licensee controlled documents for which there are regulatory requirements for future change review (i.e., 50.54(a) for the Quality Assurance Program; and 50.59 for the Final Safety Analysis Report).

10 CFR 50.51. Continuation of License 10 CFR 50.51 (b) states "Each license for a facility that has permanently ceased operations, continues in effect beyond the expiration date to authorize ownership and possession of the production or utilization facility, until the Commission notifies the licensee in writing that the license is terminated. During such period of continued effectiveness, the licensee shall:

(1) "Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility, including, where applicable, the storage, control and maintenance of the spent fuel, in a safe condition, and (2) Conduct activities in accordance with all other restrictions applicable to the facility in accordance with the NRC regulations and the provisions of the specific 10 CFR part 50 license for the facility."

10 CFR 50.82. Termination of License 10 CFR 50.82(a)(2) states "Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, or when a final legally effective order to permanently cease operations has come into effect, the 10 CFR part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel."

4.2 No Significant Hazards Consideration Determination In accordance with 10 CFR 50.90, Entergy Nuclear Operations, Inc. (HDI) is proposing an amendment to Renewed Facility License DPR-28 for Pilgrim Nuclear Power Station (PNPS). The proposed amendment would revise the Facility License (FL) and revise the Technical Specifications (TS) to reflect removal of all spent nuclear fuel from the spent fuel pool (SFP) and its transfer to dry cask storage within an Independent Spent Fuel Storage Installation (ISFSI) and the relocation of various TS requirements to the PNPS Defueled Safety Analysis Report (DSAR).

HDI-PIL-21-017 Page 30 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 By letter dated June 10, 2019 (Reference 1), Entergy Nuclear Operations, Inc. submitted certifications for permanent cessation of reactor operations and permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1 ). Therefore, as specified in 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for PNPS no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. By letter dated March 30, 2020 (Reference 3), HDI provided notification that off-load of the spent fuel pool (SFP) and transfer to the ISFSI is expected to be completed in January 2022, provided the criteria for transfer are met, including certain regulatory approvals. In support of this condition, a revision to the FL and associated TS is proposed to comport with the requirements for a facility configuration with all spent nuclear fuel in dry storage within an ISFSI.

The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed amendment would modify the PNPS Renewed Facility License (FL) and Technical Specifications (TS), or Technical Specifications (TS), by deleting the portions of the FL and TS that are no longer applicable to a facility with no spent nuclear fuel stored in the SFP, while modifying the remaining portions to correspond to all nuclear fuel stored within an ISFSI. This amendment will be implemented within 30 days following HDI's notification to the NRC that all spent fuel assemblies have been transferred out of the SFP and placed in dry storage within the ISFSI.

The definition of safety-related structures, systems, and components (SSCs) in 10 CFR 50.2 states that safety-related SSCs are those relied on to remain function al during and following design basis events to assure:

(1) The integrity of the reactor coolant boundary; (2) The capability to shutdown the reactor and maintain it in a safe shutdown condition; or (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in 10 CFR 50.34(a)(1) or 100.11.

The first two criteria (integrity of the reactor coolant pressure boundary and safe shutdown of the reactor) are not applicable to a plant in a permanently defueled condition. The third criterion is related to preventing or mitigating the consequences of accidents that could result in potential offsite exposures exceeding limits. However, after all nuclear spent fuel assemblies have been transferred to dry cask storage within an ISFSI, none of the SSCs at PNPS are required to be relied on for accident mitigation. Therefore, none of the SSCs at PNPS meet the definition of a safety-related SSC stated in 10 CFR 50.2. The proposed deletion of requirements in the TS does not affect systems credited in any accident analysis at PNPS.

Section 6 of the Defueled Safety Analysis Report (DSAR) described the design basis accidents (DBAs) related to the SFP. These postulated accidents are predicated on spent fuel being stored in the SFP. With the removal of the spent fuel from the SFP, there are no remaining spent fuel HDI-PIL-21-017 Page 31 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 assemblies to be monitored and there are no credible accidents that require the actions of a Certified Fuel Handler, Shift Manager, or a Non-certified Operator to prevent occurrence or mitigate the consequences of an accident.

The proposed changes do not have an adverse impact on the remaining decommissioning activities or any of their postulated consequences. The proposed changes related to the relocation of certain administrative requirements do not affect operating procedures or administrative controls that have the function of preventing or mitigating any accidents applicable to the safe management of irradiated fuel or decommissioning of the facility. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes eliminate the operational requirements and certain design requirements associated with the storage of the spent fuel in the SFP and relocate certain administrative controls to the Quality Assurance Program Manual or other licensee-controlled process.

After the removal of the spent fuel from the SFP and transfer to the ISFSI, there are no spent fuel assemblies that remain in the SFP. Coupled with a prohibition against storage of fuel in the SFP, the potential for fuel related accidents is removed. The proposed changes do not introduce any new failure modes. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The removal of all spent nuclear fuel from the SFP into storage in casks within an ISFSI, coupled with a prohibition against future storage of fuel within the SFP, removes the potential for fuel related accidents. The design basis and accident assumptions within the DSAR and the TS relating to safe management and safety of spent fuel in the SFP are no longer applicable. The proposed changes do not affect remaining plant operations, systems, or components supporting decommissioning activities.

The requirements for systems, structures, and components (SSCs) that have been removed from the PNPS TS are not credited in the existing accident analysis for any applicable postulated accident; and as such, do not contribute to the margin of safety associated with the accident analysis. 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 50.92(c) , and, accordingly, a finding of "no significant hazards consideration" is justified.

HDI-PIL-21-017 Page 32 of 35

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

4.3 Precedents

This proposed amendment is consistent with recently approved Amendments issued for Kewaunee Power Station on June 7, 2017 (Reference 15), Vermont Yankee Power Station on August 15, 2018 (Reference 16), Crystal River Nuclear Plant on June 27, 2017 (Reference 17) and Fort Calhoun Station on December 11, 2019 (Reference 18).

4.4 Conclusion Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public and will not be endangered by operation in the proposed manner, (2) such activities 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.

5.0 ENVIRONMENTAL CONSIDERATION

S This proposed amendment is to the PNPS license issued under 10 CFR Part 50 and includes changes to requirements involving the installation or use of a facility component located within the protected area and changes to recordkeeping, reporting, or administrative procedures or requirements. As such, HDI has evaluated this proposed amendment against the criteria for identification of licensing and regulatory actions requiring an environmental assessment in accordance with 10 CFR 51.21, and determined that it meets the eligibility criteria for categorical exclusions set forth in § 51 .22(c)(9) and § 51.22(c)(10)(ii). With respect to the criteria set forth in § 51.22(c)(9), this determination is made as follows:

(i) The amendment involves no significant hazards consideration.

As described in Section 3.2 above, the proposed change involves no significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed amendment does not involve any physical alterations to the facility configuration that could lead to a change in the type or amount of effluent that may be released offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed amendment does not involve any physical alterations to the facility configuration and does not involve any changes to regulatory requirements or programs and procedures related to controls for limiting radiation exposure that could lead to a significant increase in individual or cumulative occupational radiation exposure.

Based on the above, HDI concludes that the proposed amendment involves changes that meets the eligibility criteria for categorical exclusion as set forth in § 51.22(c)(9) or § 51.22(c)(10)(ii).

HDI-PIL-21-017 Page 33 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this proposed amendment.

6.0 REFERENCES

(1) Letter, Entergy Nuclear Operations, Inc, to US NRC, , Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, dated June 10, 2019, (Accession No. ML19161A033)

(2) Letter from Holtec Decommissioning International, LLC to U.S. Nuclear Regulatory Commission

- Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Pilgrim Nuclear Power station, dated November 16, 2018 (ML18320A040)

(3) Letter from Holtec Decommissioning International, LLC to U.S. Nuclear Regulatory Commission

- Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, dated March 31, 2020 (ML20091M858)

(4) Letter from Holtec Decommissioning International, LLC to U.S. Nuclear Regulatory Commission

- Physical Security Plan Revision and License Amendment Request to Incorporate Independent Spent Fuel Storage Installation Only, dated March 17, 2021 (5) Letter, Holtec Decommissioning International, Inc. to USNRC, License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Spent Fuel Storage Installation Only Emergency Plan, dated February 18, 2021 (ML21049A192)

(6) Letter Entergy Nuclear Operations, Inc, to U.S. Nuclear Regulatory Commission, Update to Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb) Pilgrim Nuclear Power Station, dated November 16, 2018 (ML18320A036)

(7) NRC Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12, 1995 (ML031110271)

(8) NRC Administrative Letter 96-04, "Efficient Adoption of Improved Standard Technical Specifications, dated October 9, 1996 (ML031110087)

(9) Letter, USNRC to Entergy Nuclear Operations, Inc., Pilgrim Nuclear Power Station -Conforming License amendment to Incorporate the Mitigating strategies required by Section B.5.b of Commission Order EA-02-026 and The Radiological Protection Mitigation Strategies Required by commission Order EA-06-137 (Tac No MD4555)- dated August 23, 2007 (ML072270571)

(10) Letter, USNRC to Holders of Licenses for Operating Power Reactors, Order for Interim Safeguards and Security Compensatory Measures, For - Pilgrim Nuclear Power Station, Unit No.1 (EA-02-026) Order EA-02-026, dated February 25, 2002 (ML020490027)

(11) Letter, USNRC to Holders of Licenses for Operating Power Reactors as Listed in the Enclosure, "Rescission or Partial Rescission of Certain Power Reactor Security Orders (EA-02-026)

Applicable to Nuclear Power Plants," dated November 28, 2011 (ML111220447)

(12) Letter from Entergy Nuclear Operations, Inc.to U.S. Nuclear Regulatory Commission Request for Rescission of Security Orders, dated October 31, 2018 (ML18309A036)

HDI-PIL-21-017 Page 34 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 (13) Letter, USNRC to Entergy Nuclear Operations, Inc., Pilgrim Nuclear Power Station -

Rescission of Interim Compensatory Measure B1.a in EA-02-026, Order for Interim Safeguards and Security Compensatory Measures, and Rescission of EA-06-137, Order Requiring Compliance with Key Radiological Mitigation Strategies (EPIDL-2018-LLL-0030). Date July 2, 2019 (ML19115A229).

(14) Letter, USNRC to Operating Licensees, Order Requiring Compliance with Key Radiological Protection Mitigation Strategies (EA-06-137), dated June 20, 2006 (ML061600023)

(15) Letter, USNRC to Dominion Energy Kewaunee, Inc., "Kewaunee Power Station Issuance of Amendment for Proposed Changes to License and Technical Specifications to Reflect Permanent Removal of Spent Fuel from Spent Fuel Pool (CAC No. L53079)," dated June 7, 2017(ML17123A031)

(16) Letter, USNRC to Entergy Nuclear Operations, Inc, "Vermont Yankee Nuclear Power Station -

Issuance of Amendment to Change the Permanently Defueled Technical Specifications to Reflect Permanent Removal of Spent Fuel From the Spent Fuel Pool (EPID NO. L-2017-LLA-0125), dated August 15, 2018, 2003 (ML8156A179)

(17) Letter, USNRC to Crystal River Nuclear Plant, "Crystal River Unit 3 Nuclear Generating Plant -

Issuance of Amendment 255 for the License and Permanently Defueled Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pools (TAC No. L53146) ," dated June 27, 2017 (ML17027A160)

(18) Letter, USNRC to Omaha Public Power District, "Fort Calhoun Station, Unit No. 1- Issuance of Amendment to Revise the Permanently Defueled Technical Specifications to Align the Requirements For Permanent Removal of Spent Fuel From the Spent Fuel Pool (EPID NO. L-2018-LLA-0274), dated December 11, 2019 (ML19297D677)

(19) Letter from Entergy Nuclear Operations, Inc.to U.S. Nuclear Regulatory Commission, Pilgrim Nuclear Power Station - Completion of Activities to Support Entry into the Period of Extended Operation, dated June 8, 2012 (ML12164A334)

HDI-PIL-21-017 Page 35 of 35

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-017 Enclosure 1 Attachment 1 Markup of the Existing License and Technical Specification Pages (33 Pages including cover page)

HDI-PIL-21-017 Attachment 1 Page 1 of 33

TECHNICAL SPECIFICATIONS PILGRIM NUCLEAR POWER STATION

LIST OF EFFECTIVE PAGES:

Page# Revision LOEP-1 313 XXX LOEP-2 312 INDEX OF CHANGES:

Page# Revision Amendment No.

313 XXX 253 XXX INDEX OF TECHNICAL SPECIFICATION CLARIFICATIONS:

Page# Revision C-i 249 MATERIALS LICENSE:

Material License Page# Revision Amendment No.

NRC Materials License #20-07626-04 (1 pg.) -- 08 Massachusetts Materials License #07-6262 termination (1 pgs.) 17 Massachusetts Materials License #49-0078 (1 pg.) -- 09 RENEWED FACILITY LICENSE:

Page# Revision Amendment No.

1 -- 250 2 -- 250 3 -- 253 4 -- 250 XXX 5 -- 250 6 -- 250 APPENDIX A:

(Listed here for convenience)

Page# Revision Amendment No.

1 -- 250 Revision 313 XXX LOEP-1

TABLE OF CONTENTS: Revision Amendment No.

i -- 250 XXX DEFINITIONS:

1.0-1 -- 250 SAFETY LIMITS:

2.0-1 -- 250 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY:

3/4.0-1 -- 250 3/4.0-2 -- 229 B3/4.0-1 311 --

B3/4.0-2 311 --

Spent Fuel Storage:

3/4.10-1 -- 250 B3/4.10-1 311 --

DESIGN FEATURES:

4.0-1 -- 250 xxx ADMINISTRATIVE CONTROLS:

5.0-1 -- 246 xxx 5.0-2 -- 246 5.0-3 -- 250 5.0-4 -- 246 5.0-5 -- 250 5.0-6 -- 250 5.0-7 -- 250 5.0-8 -- 250 5.0-9 -- 250 5.0-10 -- 250 5.0-11 -- 250 5.0-12 -- 250 Revision 312 xxx LOEP-2

INDEX OF CHANGES NRC License Effective Revision Amendment Date Reason for Revision Pages Affected Note: License and Technical Specification amendments and revisions issued prior to plant shutdown and defueled certification were removed from the Index of Changes to consolidate listings. Contact Site Regulatory Assurance if information relative to previous License / TS amendments or revisions is required.

309 246 6/20/19 Issuance of Amendment to Page iii, 1-1, 1-4, Renewed Facility Operating License 1-5, 4.0-1, 5.0-1, Re: Certified Fuel Handler and other 5.0-2, 5.0-3, 5.0-4, Staffing/Administrative Changes 5.0-5, 5.0-7, 5.0-12, 5.0-13, 5.0-15, 5.0-16 310 --- 8/27/19 Massachusetts Materials License MA Mtl. License

07-6262 termination #07-6262 (4 pages) 310 249 8/27/19 Issuance of Amendment to Renewed FOL Renewed Facility Operating License Page 1, 2, 3, 4, 5, Re: License Transfer Application to Appendix A, B, Holtec Pilgrim and HDI 4.0-1 311 250 10/28/19 Issuance of Amendment to Renewed FOL Renewed Facility Operating License Pages 1 thru 6 Re: Permanently Defueled Technical Appendix A Specifications All pages 312 251 10/28/19 Issuance of Amendment to None Renewed Facility Operating License Re: Permanently Defueled Emergency Plan 312 252 10/28/19 Issuance of Amendment to Renewed FOL Renewed Facility Operating License Page 3 Re: Remove Cyber Security Plan License Condition 313 253 12/01/20 Issuance of Amendment to Revise the Renewed FOL Physical Security Plan To Incorporate Page 3 An Additional Independent Spent Fuel Storage Installation (PSP Rev 19A)

XXX XXX XXX Issuance of Amendment to Renewed Facility Renewed FL License Re: ISFSI Only Technical Specifications Page 3, 4, 5, and 6 Appendix A All pages Revision 313 xxx i

HOLTEC PILGRIM, LLC And HOLTEC DECOMMISSIO~ING INTERNATIONAL, LLC

{PILGRIM NUCLEAR POWER STATION)

DOCKET NO. 50-293 RENEWED FACILITY LICENSE Renewed License No. DPR-35 The Nuclear Regulatory Commission (the Commission) has found that:

a. DELETED

b. The facility will be maintained in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; and

c. There is reasonable assurance (i) that the activities authorized by the renewed license can be conducted without endangering the health and safety of the public, and (ii} that such activities will be conducted in compliance with the rules and regulations of the Commission; and

d. Holtec Pilgrim, LLC (Holtec Pilgrim) is financially qualified and Holtec Decommissioning International, L4C (HDI) Is technically and financially qualified to engage In the activities

. authorized by this renewed license, In accordance with the rules and regulations of the Commission; and

e. Holtec Pilgrim and HDI have satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements" of the Commission's regulations; and

f. The issuance of this renewed license will not be Inimical to the common defense and security or to the health and safety of the public; and

g. After weighing the environmental, economic, technical, and other benefits of the facility against environmental costs and considering available alternatives, the issuance of this renewed license (subject to the condition for protection of the environment set forth herein) is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements of said regulations have been satisfied.

h. DELETED Amendment No. 250 Renewed License No. DPR-35

Facility Operating License No. DPR-35, dated June 8, 1972, issued to the Boston Edison Company (Boston Edison) is hereby amended in Its entirety, pursuant to an Initial Decision dated September 13, 1972, by the Atomic Safety and Licensing Board, to read as fo.llows:

1. This renewed license applies to the Pilgrim Nuclear Power Station, a single cycle, forced circulation, boiling water nuclear reactor and associated electric generating equipment (the facility), owned by Holtec Pilgrim and maintained and operated for decommissioning by HDI. The facility is located on the western shore of Cape Cod Bay in the town of Plymouth on the Holtec Pilgrim site in Plymouth County, Massachusetts, and is described in the "Final Safety Analysis Report," as supplemented and amended.

2. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses:

A.

Pursuant to the Section 104b of the Atomic Energy Act of 1954, as amended (the Act) and 10 CFR Part 50, "Licensing of Production and Utilization Facilities," a)

Holtec Pilgrim to possess, a.nd b) HDI to possess, maintain, and decommission the facility at the designated location on the Pilgrim site;

8. HDI, pursuant to the Act and 10 CFR 70, to possess at any time special nuclear material that was used as reactor fuel, in accordance with the limitations for storage, as described in the Final Safety Analysis Report, as supplemented and amended; C. HDI, 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 material 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; D. HDI, 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 material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components;

.and E. HDI, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations; 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50 and Section 70.32 of 10 CFR Part 70; and is subject to all applicable Amendment No. 250 Renewed License No. DPR-35

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 below:

A. DELETED B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 252, are hereby incorporated in the renewed license. The licensee shall maintain the facility in accordance with the Permanently Defueled Technical Specifications.

ISFSI Only C. Records DELETED HDI shall keep facility records in accordance with the requirements of the Technical Specifications.

D. DELETED E. DELETED F. DELETED G. Physical Protection The licensee 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 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 contain Safeguards Information protected under 10 CFR 73.21, is titled: Pilgrim Nuclear Power Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Pilgrim ISFSI II Physical Security Plan, Revision 19A," supplemented by letter dated April 2, 2020, (Accession No. ML20122A055) as supplemented by letters dated, June 25, 2020 (ML20188A061), July 21, 2020 (ML20213C031, nonpublic), July 22, 2020 (ML20213B743, nonpublic), and July 30, 2020 (ML20220A351 and ML20220A352, nonpublic).

H. DELETED I. DELETED J, Conditions Related to the Sale and Transfer (1) Deleted (2) Deleted (3) Deleted (4) Deleted (5) The Decommissioning Trust agreement(s) shall be in a form which is acceptable to the NRC and shall provide, in addition to any other clauses, that:

a) Investments in the securities or other obligations of Holtec Pilgrim, Holtec International, their affiliates, subsidiaries or associates, or their successors or assigns shall be prohibited. In addition, except for Investments tied to market indexes or other non-nuclear sector mutual funds, investments in any entity owning one or more nuclear power plants Is prohibited.

b) The Director, Office of Nuclear Reactor Regulation, shall DELETED be given 30 days prior written notice of any material amendment to the trust agreement(s).

K. Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on Integrated {ire response strategy

7. Spent fuel pool mitigation measures Amendment No. 250 Renewed License No. DPR-35 XXX

. (c) Actions to minimize release to include consideration of:

DELETED 1. Water spray scrubbing

2. Dose to onsite responders L. The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, Issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

M. DELETED

4. DELETED

5. DELETED DELETED 6. DELETED

7. The Information in the FSAR supplement. submitted pursuant to 10 CFR 54.21(d), as supplemented by Commitments Nos. 3, 8, 9, 13, 15, 18, 19, 21, 22, 24, 25, 26, 27, 28, 30, 31, 33, 34, 35, 36, 37, 39, 40, 46, 51, and 52 of Appendix Aof NUREG-1891, "Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station" dated June 2007, as supplemented, is henceforth part of the FSAR which will be upd~ted in accordance with 10 CFR 50.71(e).

The licensee may make changes to the programs and activities described in the FSAR supplement and Commitments No~. 3, 8, 9, 13, 15, 18, 19, 21, 22, 24, 25, 26, 27, 28, 30, 31, 33, 34, 35, 36, 37, 39, 40, 46, 51, and 52of AppendixAofNUREG-1891, as supplemented, provided the licensee evaluates such changes pursuant to the criteria set forth In 10 CFR 50.59 and otherwi_se complies with the requirements in that section.

8. DELETED

9. DELETED Amendment No. 250 XXX Renewed License No. DPR-35

10. This license Is effective as of the date of issuance and until the Commission notifies the licensee in writing that the license Is terminated. .I FOR THE NUCLEAR REGULATORY COMMISSION IRA/

Elie J. Leeds, Director Office of Nuclear Reactor Regulation ISFSI Only

Attachment:

Appendix A- Permanently Defueled Technical Specifications (Radiological)

Date of Issuance: May 29, 2012 Amendment No. 250 XXX Renewed license No. DPR-35

APPENDIX A TO RENEWED FACILITY LICENSE DPR-35 PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS AND BASES ISFSI Only FOR PILGRIM NUCLEAR POWER STATION PLYMOUTH,MASSACHUSETTS Holtec PIigrim, LLC and Holtec Decommissioning lnternatlonal, LLC Amendment No. 250 XXX

TABLE OF CONTENTS 1.0 DEFINITIONS 1.0-1 2.0 NOT USED 2.0-1 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.0 LIMITING CONDITION FOR 4.0 3/4.0-1 OPERATION (LCO)

APPLICABILITY BASES 83/4.0-1 3.10 SPENT FUEL STORAGE 4.10 3/4.10-1 C. Spent Fuel Pool Water Level C. 3/4.10-1 BASES 83/4.10-1 4.0 DESIGN FEATURES 4.0-1 4.1 Site Location 4.0-1 4.2 Not Used 4.0-1 4.3 Soent Fuel Storaae 4.0-1 4.3.1 Criticalitv 4.0-1 4.3.2 Drainaae 4.0-2 4.3.3 Caoacitv 4.0-2 4.3.4 HeawLoads 4.0-2 5.0 ADMINISTRATIVE CONTROLS 5.0-1 5.1 ResoonsibllitY 5.0-1 5.2 Oraanization 5.0-2 5.3 Facilitv Staff Qualifications 5.0-4 5.4 Procedures 5.0-5 5.5 Proarams and Manuals 5.0-6 5.6 Reoortina Reauirements 5.0-10 5.7 Hiah Radiation Area 5.0-11 Amendment No. 250 XXX

1.0 DEFINITIONS The succeeding frequently used terms are explicitly defined so that a uniform Interpretation of the specifications may be achieved.

ACTION ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.

CERTIFIED FUEL A CERTIFIED FUEL HANDLER is an individual who complies with the HANDLER provisions of the CERTIFIED FUEL HANDLER Training and Retraining Program.

IMMEDIATE IMMEDIATE means that the required action will be initiated as s_oon as practicable considering the safe maintenance of the facility and the importance of the required action.

LIMITING CONDITIONS The LIMITING CONDITIONS FOR OPERATION specify the minimum FOR OPERATION (LCO) acceptable levels of system performance necessary to assure safe maintenance of the facility. When these conditions are met, the facility can be maintained safely and abnormal situations can be safely controlled.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be considered a failure to meet the LCO.

NON-CERTIFIED A NON-CERTIFIED OPERATOR is a non-licensed operator who OPERATOR complies with the qualification -requirements of Specification 5.3.1, but is not a CERTIFIED FUEL HANDLER.

SURVEILLANCE Each Surveillance Requirement shall be performed within the specified FREQUENCY SURVEILLANCE INTERVAL with a maximum allowable extension not to exceed 25 percent of the specified SURVEILLANCE INTERVAL.

The SURVEILLANCE FREQUENCY establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance schedule and consideration of facility conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified.

This limitation of this definition is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

SURVEILLANCE The SURVEILLANCE INTERVAL is the calendar time between INTERVAL surveillance tests to be performed to confirm that a parameter is within limits.

Amendment No. 250 XXX 1.0-1

2.0 NOT USED Not Used Amendment No. 250 2:0-1

3.0 NOT USED Not Used Amendment No. 250 3/4.0-1

4.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 4.0.1 Not Used 4.0.2 Not Used 4.0.3 If it is discovered that a Surveillance was not performed within its specified Surveillance Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Surveillance Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Amendment ~ . a++, 229 3/4.0-2

BASES 3.0 Limiting Condition For Operation (LCO) Applicability Not Used Revision No. 311 B3/4.0-1

BASES 4.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 4.0.1 Not Used 4.0.2 Not Used 4.0.3 TS 4.0.3 establishes the flexibility to defer declaring an affected variable outside the specified limits when a Surveillance has not been completed within the specified Surveillance Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Surveillance Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with the definition of "Surveillance Frequency" and not at the time that the specified Surveillance Frequency was not met.

This delay period provides adequate time to complete Surveillances that have been missed.

This delay period permits the completion of a Surveillance before complying with required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of the facility conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

Failure to comply with specified Frequencies for surveillance intervals is expected to be an infrequent occurrence. Use of the delay period established by TS 4.0.3 is a flexibility which is not intended to be used as a convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Surveillance Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on facility risk (from delaying the Surveillance as well as any facility configuration changes required to perform the Surveillance) and impact on any (continued) analysis assumptions, in addition to facility conditions, planning, availability of personnel, and the time required to perform the Surveillance.

All missed Surveillances will be placed in the licensee's Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the variable is considered outside the specified limits and the completion times or the required actions for the applicable LCO Actions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the variable is outside the specified limits and the completion times of the required actions for the applicable LCO Actions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the completion time of the Actions, restores compliance with "Surveillance Frequency."

Revision No. 311 B3/4.0-2

3/4.10 SPENT FUEL STORAGE LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.10 SPENT FUEL STORAGE 4.1 O SPENT FUEL STORAGE Applicability: Applicability:

Applies to the storage of spent fuel. Applies to the parameter which monitors the storage of spent fuel.

Objective: Objective: .

To ensure safe storage of spent fuel. To verify that spent fuel is being stored safely.

Specification: Specification:

A. NotUsed A. Not Used B. Not Used B. Not Used C. Spent Fuel Pool Water Level C. Spent Fuel Pool Water Level Whenever irradiated fuel is stored Whenever irradiated fuel is stored in in the spent fuel pool, the pool the spent fuel pool, the water level water level shall be maintained at shall be recorded daily.

or above 33 feet.

Amendment No. 250 3/4.10-1

BASES 3/4.1 O SPENT FUEL STORAGE C. Spent Fuel Pool Water Level To ensure there is adequate water to shield and cool the irradiated fuel assemblies stored in the pool, a minimum pool water level is established. The minimum water level of 33 feet is established because it would be a significant change from the normal level (-1 foot) and is well above the level to assure adequate cooling.

The fuel handling accident evaluates the dropping of an irradiated fuel assembly into the spent fuel pool. The water level in the spent fuel pool provides for absorption of water soluble fission product gases and transport delays of soluble and insoluble gases that must pass through the water before being released to the atmosphere. This absorption and transport delay reduces the potential radioactivity of the release during a fuel handling accident.

The spent fuel pool water level satisfies Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii).

Revision No. 311 83/4.10-1

4.0 DESIGN FEATURES 4.1 Site Location Pilgrim Nuclear Power Station is located on the western shore of Cape Cod Bay in the Town of Plymouth, Plymouth County, Massachusetts and contains approximately 517 acres owned by Holtec Pilgrim as shown on FSAR Figures 2.2-1 and 2.2-2. The site boundary is posted and a perimeter security fence provides a distinct security boundary for the protected area of the station.

The reactor (center line) is located approximately 1800 feet from the nearest property boundary.

4.2 Not Used Insert: "Spent Fuel shall not be stored in the Spent Fuel Pool" 4.3 Spent Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum k-infinity of 1.32 for standard core geometry, calculated at the burnup of maximum bundle reactMty, and an average U-235 enrichment of 4.6 % averaged over the axial planar zone of highest average enrichment; and

b. ~ s; 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in the applicable section of the FSAR.

4.3.2 Drainage The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 115 ft.

4.3.3 Capacity The spent fuel storage pool ls designed and shall be maintained with a storage capacity limited to no more than 3859 fuel assemblies.

4.3.4 Heaw Loads

a. Loads in excess of 2000 lb. shall be prohibited from travel over fuel assemblies in the spent fuel storage pool with the exception that heavy load handling over irradiated fuel In the Multi-Purpose Canister is permitted using a single-failure-proof handling system.

b. No fuel which has decayed for less than 200 days shall be stored in racks within an arc described by the height of the cask around the periphery of the leveling platform during cask handling operations in the spent fuel pool or when a cask is in the spent fuel pool.

Amendment No. 250 4.0-1 . I

Note: TS 5.1.1 Responsibility 5.1 relocate to DSAR 5.0 ADMINISTRATIVE CONTRQLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect nuclear safety.

5.1.2 The control room supervisor (CRS) shall be responsible for the shift command function. '

Note: Delete TS 5.1.2 Amendment No. 177,223,246 XXX 5.0-1

Organization 5.2 Note: TS 5.2.1.a thru d relocate to DSAR 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for facility staff and corporate management, respectively. The onsite and offsite organizations shall

_include the positions for activities affecting safety of the nuclear fuel.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be document~ anq updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements, including the plant-specific titles of those personnel fulfilling the responsibilities of the J?ositions delineated in these Technical Specifications, shall be documented in the Pilgrim Station Final Safety Analysis Report (FSAR);

b. The plant manager shall be responsible for overall safe operation of the facility and shall have control over those onsite activities necessary for safe storage and maintenance of the nuclear fuel;

c. The specified corporate officer for Pilgrim shall have corporate responsibility for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure safe management of nuclear fuel; and

d. The individuals who train the CERTIFIED FUEL HANDLERS, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

5.2.2 Facility Staff The facility staff organization shall include the following:

a. Each duty shift shall be composed of af least one control room Note: Delete TS 5.2.2 supervisor and one NON-CERTIFIED OPERATOR. The NON-CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER.

(continued)

Amendment No. 4+1-, 48+, 223, 246 5.0-2

5.0 ADMINISTRATIVE CONTROLS 5.2 Organization (continued) 5.2.2 Facility Staff (continued)

b. At least one person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the Control Room when nuclear fuel is stored in the spent fuel pool.

c. Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER.

d. Shift crew composition may be less than the minimum requirement of 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements and all of the following conditions are met:

1) No fuel movements are in progress;

2) No movement of loads over fuel are In progress; and

3) No unmanned shift positions during shift turnover shall be permitted while the shift crew Is less than the minimum.

e. . Not Used

f. An individual qualified in radiation protection procedures shall be on site during fuel handling operations and during movement of heavy loads over the fuel storage racks. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

g. Not Used

h. The control room supervisor shall be a CERTIFIED FUEL HANDLER.

i. Not Used Amendment No. 250 5.0-3

NOTE: TS 5.3.1 relocate to DSAR Facility Staff Qualifications I 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Quality Assurance Program Manual (QAPM).

5.3.2 An NRC approved training and retraining program for CERTIFIED FUEL HANDLERs shall be maintained.

PNPS 5.0-4 Amendment No. 47+, ~ . 246

Note: TS 5.4.1 relocate to DSAR 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. The procedures applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978;

b. Not Used

c. Quality assurance for effluent and environmental monitoring;

d. Fire Protection Program Implementation; and

e. All programs specified in Specification 5.5.

Amendment No. 250 5.0-5

Note: TS 5.5.1 relocate to DSAR

s.o ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented and maintained.

5.5.1 Offsite Dose Calculation Manual (ODCM)

a. The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and

b. The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities and descriptions of the Information that should be included In the Annual Radiological Environmental Operating, and Radioactive Effluent Release, repo~s required by Specification 5.6.2 and Specification 5.6.3.

c. Licensee initiated changes to the ODCM:

1. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:

a. sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and

b. a determination that the change(s) maintain the levels of radioactive effluent control required by 10CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;

2. Shall become effective after the approval of the plant manager; and

3. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings In the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

(continued)

Amendment No. 250 5.0-6

Note: TS 5.5.4 relocate to DSAR 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals (continued) 5.5.2 Not Used 5.5.3 Not Used 5.5.4 Radioactive Effluent Controls Program This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall Include the following elements:

a. Limitations on the functional capability of radioactive liquid and gaseous monitoring Instrumentation Including surveillance tests and setpolnt determination In accordance with the methodology in the ODCM:

b. Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas, conforming to ten times the concentration values In Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402;

c. Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents In accordance with 10 CFR 20.1302 and with the methodology and parameters In the ODCM;

d. Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released to unrestricted areas, conforming to 10 CFR 50, Appendix I;

e. Determination of cumulative contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters In the ODCM at least every 31 days.

Determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM at least every 31 days;

f. Limitations on the functional capability and use of the liquid and gaseous effluent treatment systems to ensure that appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses In a period of 31 days would exceed 2% of the guidelines for the annual dose or dose commitment, conforming to 10 CFR 50, Appendix I; (continued)

Amendment No. 250 5.0-7

Note: TS 5.5.4 moved to DSAR 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals (continued) 5.5.4 Radioactive Effluent Controls Program* {continued}

g. Limitations on the dose rate resulting from radioactive material released in gc!seous effluents from the site boundary to areas at or beyond the site boundary conforming to the following:

1. For noble gases: Less than or equal to 500 mrem/yr to the whole body and less than or equal to 3000 mrem/yr to the skin, and

2. For lodine-131, lodine-133, Tritium, and all radionuclides in particulate form with half-lives greater than B days: Less than or equal to 1500 mrem/yr to any organ.

h. Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I;

i. Limitations on the annual and quarterly doses to a member of the public from lodine-131, lodlne-133, Tritium, and all radionuclldes in particulate form with half lives > B days in gaseous effluents released to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; and

j. Limitations on the annual dose or dose commitment to any member of the public, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources. conforming to 40 CFR 190.

5.5.5 Not Used 5.5.6 Technical Specifications {TS) Bases Control Program This program provides a means for processing changes to the Bases of these Delete TS 5.5.6 Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. a change in the TS incorporated in the license; or

2. a change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

(continued)

Amendment No. 250 5.0-8

5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals (continued) 5.5.6 Technical Specifications (TS) Bases Program (continued}

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

d. Proposed changes that*meet the criteria of Specification 5.5.6b above shall be reviewed and approved by the NRC prior to implementation.

Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

. Amendment No. 250 5.0-9

5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Not Used 5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the facility during the previous calendar year shall be submitted by Note : Relocate TS 5.6.2 May 15 of each year. The report shall Include summaries, interpretations, and and 5.6.3 to DSAR analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include a summary of the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified In the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the fonnat of the table In the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the faclllty shall be submitted in accordance with 10 CFR50.36a by May 15th of each year.

The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the facility. The material provided shall be consistent with the objectives outli_ned in the ODCM and process control procedures and In conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

Amendment No. 250 5.0-10

5.0 ADMINISTRATIVE CONTROLS

5. 7 High Radiation Area 5.7.1 Pursuant to 10 CFR 20, paragraph 20.1601(c), In lieu of ttie requirements of 10 CFR 20.1601, each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation Is > 100 mrem/hr but< 1000 mrem/hr, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by_ requiring issuance of a Radiation Work Permit

{RWP). Individuals qualified in radiation protection procedures (e.g., radiation protection personnel) or personnel continuously escorted by such individuals may"be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates

~ 1000 mrem/hr, provided they are otherwise following facility radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device that continuously indicates the radiation dose rate in the area.

b. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset Integrated dose is received. Entry into such areas with this !110nitoring device may be made after the dose rate levels in the area have been established and personnel are aware of them.

c. An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the radiation protection manager In the RWP.

5.7.2 In addition to the requirements of Specification 5.7.1, areas with radiation levels

.: ,; 1000 mrem/hr shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the control room supervisor on duty or radiation protection supervision. Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels In the immediate work areas and the maximum allowable stay times for individuals in those areas. In lieu of the stay time specification of the RWP, direct or remote {such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.

(continued) 5.7 High Radiation Area (continued} Move to next page Amendment No. 250 XXX 5.0-11

5.0 ADMINISTRATIVE CONTROLS 5.7.3 For individual high radiation areas with radiation levels of> 1000 mrem/hr, accessible to personnel, that are located within large areas such as reactor containment, where no enclosure exists for purposes of locking, or that cannot be continuously guarded, and where no enclosure can be reasonably constructed around the individual area, that Individual area shall be barricaded and conspicuously posted, and a flashing light shall be activated as a warning device.

Amendment No. 250 XXX 5.0-12

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-017 Enclosure 1 Attachment 2 Retyped Facility License and Technical Specification Pages

HOLTEC PILGRIM, LLC And HOLTEC DECOMMISSIONING INTERNATIONAL, LLC (PILGRIM NUCLEAR POWER STATION)

DOCKET NO. 50-293 RENEWED FACILITY LICENSE Renewed License No. DPR-35 The Nuclear Regulatory Commission (the Commission) has found that:

a. DELETED

b. The facility will be maintained in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; and

c. There is reasonable assurance (i) that the activities authorized by the renewed license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the rules and regulations of the Commission; and

d. Holtec Pilgrim, LLC (Holtec Pilgrim) is financially qualified and Holtec Decommissioning International, LLC (HDI) is technically and financially qualified to engage in the activities authorized by this renewed license, in accordance with the rules and regulations of the Commission; and

e. Holtec Pilgrim and HDI have satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements" of the Commission's regulations; and

f. The issuance of this renewed license will not be inimical to the common defense and security or to the health and safety of the public; and

g. After weighing the environmental, economic, technical, and other benefits of the facility against environmental costs and considering available alternatives, the issuance of this renewed license (subject to the condition for protection of the environment set forth herein) is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements of said regulations have been satisfied.

h. DELETED Amendment No. 250 Renewed License No. DPR-35

Facility Operating License No. DPR-35, dated June 8, 1972, issued to the Boston Edison Company (Boston Edison) is hereby amended in its entirety, pursuant to an Initial Decision dated September 13, 1972, by the Atomic Safety and Licensing Board, to read as follows:

1. This renewed license applies to the Pilgrim Nuclear Power Station, a single cycle, forced circulation, boiling water nuclear reactor and associated electric generating equipment (the facility), owned by Holtec Pilgrim and maintained and operated for decommissioning by HDI. The facility is located on the western shore of Cape Cod Bay in the town of Plymouth on the Holtec Pilgrim site in Plymouth County, Massachusetts, and is described in the "Final Safety Analysis Report," as supplemented and amended.

2. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses:

A. Pursuant to the Section 104b of the Atomic Energy Act of 1954, as amended (the Act) and 10 CFR Part 50, Licensing of Production and Utilization Facilities, a)

Holtec Pilgrim to possess and b) HDI to possess, maintain, and decommission the facility at the designated location on the Pilgrim site; B. HDI, pursuant to the Act and 10 CFR 70, to possess at any time special nuclear material that was used as reactor fuel, in accordance with the limitations for storage, as described in the Final Safety Analysis Report, as supplemented and amended; C. HDI, 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 material 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; D. HDI, 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 material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and E. HDI, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations; 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50 and Section 70.32 of 10 CFR Part 70; and is subject to all applicable Amendment No. 250 Renewed License No. DPR-35

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 below:

A. DELETED B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. XXX are hereby incorporated into the license. The licensee shall maintain the facility in accordance with the ISFSI Only Technical Specifications.

C. DELETED D. DELETED E. DELETED F. DELETED G. Physical Protection The licensee 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 FR27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: Pilgrim Independent Spent Fuel Storage Installation-Only Security, Training and Qualification, and Safeguards Contingency Plan, Rev 0 supplemented by letter dated March 17, 2021 (ML to be provided by NRC).

H. DELETED I. DELETED J. Conditions Related to the Sale and Transfer (1) Deleted (2) Deleted (3) Deleted (4) Deleted (5) The Decommissioning Trust agreement(s) shall be in a form which is acceptable to the NRC and shall provide, in addition to any other clauses, that:

a) Investments in the securities or other obligations of Holtec Amendment No. XXX Renewed License No. DPR-35

Pilgrim, Holtec International, their affiliates, subsidiaries or associates, or their successors or assigns shall be prohibited. In addition, except for investments tied to market indexes or other non-nuclear sector mutual funds, investments in any entity owning one or more nuclear power plants is prohibited.

b) The Director, Office of Nuclear Reactor Regulation, shall be given 30 days prior written notice of any material amendment to the trust agreement(s).

K. DELETED L. DELETED M. DELETED

4. DELETED

5. DELETED

6. DELETED

7. DELETED

8. DELETED

9. DELETED

10. This license is effective as of the date of issuance and until the Commission notifies the licensee in writing that the license is terminated.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signature on File Eric J. Leeds, Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A - ISFSI Only Technical Specifications (Radiological)

Date of Issuance: May 29, 2012 Amendment No. XXX Renewed License No. DPR-35

APPENDIX A TO RENEWED FACILITY LICENSE DPR-35 ISFSI ONLY TECHNICAL SPECIFICATIONS FOR PILGRIM NUCLEAR POWER STATION PLYMOUTH, MASSACHUSETTS Holtec Pilgrim, LLC and Holtec Decommissioning International, LLC Amendment No. ###

TABLE OF CONTENTS 4.0 DESIGN FEATURES 4.0-1 4.1 Site Location 4.0-1 4.2 Not Used 4.0-1 4.3 Spent Fuel Storage 4.0-1 5.0 ADMINISTRATIVE CONTROLS 5.0-1 5.7 High Radiation Area 5.0-1 Amendment No. ### i

4.0 DESIGN FEATURES 4.1 Site Location Pilgrim Nuclear Power Station is located on the western shore of Cape Cod Bay in the Town of Plymouth, Plymouth County, Massachusetts and contains approximately 517 acres owned by Holtec Pilgrim as shown on FSAR Figures 2.2-1 and 2.2-2. The site boundary is posted and a perimeter security fence provides a distinct security boundary for the protected area of the station.

4.2 Not Used 4.3 Spent Fuel Storage Spent Fuel shall not be stored in the Spent Fuel Pool Amendment No. ### 4.0-1

5.0 Administrative Controls 5.7 High Radiation Area 5.7.1 Pursuant to 10 CFR 20, paragraph 20.1601(c), in lieu of the requirements of 10 CFR 20.1601, each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is > 100 mrem/hr but < 1000 mrem/hr, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures (e.g., radiation protection personnel) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates 1000 mrem/hr, provided they are otherwise following facility radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device that continuously indicates the radiation dose rate in the area.

b. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel are aware of them.

c. An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the radiation protection manager in the RWP.

5.7.2 In addition to the requirements of Specification 5.7.1, areas with radiation levels 1000 mrem/hr shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the control room supervisor on duty or radiation protection supervision. Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels in the immediate work areas and the maximum allowable stay times for individuals in those areas. In lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.

(continued)

Amendment No. ### 5.0-1

5.0 Administrative Controls 5.7 High Radiation Area (continued) 5.7.3 For individual high radiation areas with radiation levels of > 1000 mrem/hr, accessible to personnel, that are located within large areas such as reactor containment, where no enclosure exists for purposes of locking, or that cannot be continuously guarded, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded and conspicuously posted, and a flashing light shall be activated as a warning device.

Amendment No. ### 5.0-2

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-017 Enclosure 1 Attachment 3 Technical Specification Administrative Controls Relocated to the DSAR HDI-PIL-21-017 Attachment 3 Page 1 of 6

DSAR APPENDIX B ADMINISTRATIVE CONTROLS RELOCATED FROM PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS This attachment provides the administrative controls proposed to be relocated from the Pilgrim Nuclear Power Station (PNPS) Technical Specifications (TS), Section 5.0, "Administrative Controls," to Appendix B to the Defueled Safety Analysis (DSAR), as described and evaluated HDIs submittal to the NRC requesting a License Amendment and Technical Specification changes to address permanent removal of fuel from the spent fuel pool and final storage in the site Independent Spent Fuel Storage Facility Installation (ISFSI).

On implementation of the approved amendment, the administrative controls and other requirements shown below will be incorporated into new Appendix B to the DSAR. This is consistent with a past site practice, which previously captured relocated site Technical Specifications in Appendix B to the Final Safety Analysis Report (FSAR).

Capturing these specifications in the DSAR, ensures the specifications are identified in a licensee-controlled document. In addition, by relocating the following requirements in the DSAR, future changes will be evaluated to under the 10 CFR 50.59 change review process to ensure that adequate controls remain in-place to safely protect spent fuel located in dry casks located on site controlled ISFSI cask storage pads.

Text formatted in red strikethrough is shown for information purposes to clarify the location of deletions from the TS administrative control specification that is being relocated. Text formatted in red with an underline has been added to the TS administrative control specification. These changes are administrative changes that are needed to address ongoing organizational changes, and to reflect that the facility has removed all fuel from the spent fuel pool, and that the proposed TS no longer allow spent fuel to be stored in the spent fuel pool.

HDI-PIL-21-017 Attachment 3 Page 2 of 6

B-5.1. Responsibility B-5.1.1 The plant manager responsible for overall operational activities shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager responsible for overall operational activities or his designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect nuclear safety B- 5..2 Organization B-5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for facility staff and corporate management, respectively.

The onsite and offsite organizations shall _include the positions for activities affecting safety of the nuclear fuel.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements, including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications requirements, shall be documented in the Pilgrim Station Final Defueled Safety Analysis Report (FDSAR);

b. The plant manager responsible for overall operational activities shall be responsible for overall safe operation of the facility and shall have control over those onsite activities necessary for safe storage and maintenance of the nuclear fuel.

c. The specified corporate officer for Pilgrim shall have corporate responsibility for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure safe management of nuclear fuel; and

d. The individuals who train the CERTIFIED FUEL HANDLERs, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions B. 5.3 Facility Staff Qualifications B-5.3.1 Facility Staff Qualifications Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Quality Assurance Program Manual (QAPM).

B.5.4 Procedures B-5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

c. Quality assurance for effluent and environmental monitoring

d. Fire Protection Program implementation; and

e. All programs specified in Specification B-5.5.

HDI-PIL-21-017 Attachment 3 Page 3 of 6

Section 5.5 Programs and Manuals B-5.5.1 Offsite Dose Calculation Manual (ODCM)

a. The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseousairborne and liquid effluents, in the calculation of gaseousairborne and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and

b. The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities and descriptions of the information that should be included in the Annual Radiological Environmental Operating, and Radioactive Effluent Release, reports required by Specification B-5.6.2 and Specification B-5.6.3.

c. Licensee initiated changes to the ODCM:

1. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:

a. sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and

b. a determination that the change(s) maintain the levels of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;

2. Shall become effective after the approval of the plant manager responsible for overall operational activities; and

3. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

B-5.5.4 Radioactive Effluent Controls Programs B-5.5.4 Radioactive Effluent Controls Program This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

a. Limitations on the functional capability of radioactive liquid and gaseousairborne monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM;

b. Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas, conforming to ten times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402; HDI-PIL-21-017 Attachment 3 Page 4 of 6

c. Monitoring, sampling, and analysis of radioactive liquid and gaseousairborne effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM;

d. Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released to unrestricted areas, conforming to 10 CFR 50, Appendix I;

e. Determination of cumulative contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days. Determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM at least every 31 days;

f. Limitations on the functional capability and use of the liquid and gaseousairborne effluent treatment systems to ensure that appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a period of 31 days would exceed 2% of the guidelines for the annual dose or dose commitment, conforming to 10 CFR 50, Appendix I;

g. Limitations on the dose rate resulting from radioactive material released in gaseousairborne effluents from the site boundary to areas at or beyond the site boundary conforming to the following:

1. For noble gases: Less than or equal to 500 mrem/yr to the whole body and less than or equal to 3000 mrem/yr to the skin, and Not Used

2. For Iodine-131, Iodine-133, Tritium, and all radionuclides in particulate form with half lives greater than 8 days: Less than or equal to 1500 mrem/yr to any organ.

h Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; Not Used i Limitations on the annual and quarterly doses to a member of the public from Iodine-131, Iodine-133, Tritium, and all radionuclides in particulate form with half lives > 8 days in gaseousairborne effluents released to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; and j Limitations on the annual dose or dose commitment to any member of the public, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.

B- 5.6 Reporting Requirements B-5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the facility during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include a summary of the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements HDI-PIL-21-017 Attachment 3 Page 5 of 6

in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results.

The missing data shall be submitted in a supplementary report as soon as possible.

B-5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the facility shall be submitted in accordance with 10 CFR 50.36a by May 15th of each year. The report shall include a summary of the quantities of radioactive liquid and gaseousairborne effluents and solid waste released from the facility. The material provided shall be consistent with the objectives outlined in the ODCM and process control procedures and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

HDI-PIL-21-017 Attachment 3 Page 6 of 6

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-017 Enclosure 1 Attachment 4 List of Regulatory Commitment HDI-PIL-21-017 Attachment 4 Page 1 of 2

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Regulatory Commitment This table identifies actions discussed in this letter for which HDI commits to perform. Any other actions discussed in this submittal are described for the NRC's information and are not commitments.

TYPE Scheduled Completion Commitment (Check One)

Date One-Time Continuing (If Required)

Action Compliance The administrative controls relocated X On Implementation of the from TS will be incorporated into approved amendment Appendix B to the PNPS DSAR as shown and described in Attachment 3 to this amendment request.

HDI-PIL-21-017 Attachment 4 Page 2 of 2

v t e Letter Sequence Request
EPID:L-2021-LLA-0049, Physical Security, Training & Qualification and Safeguards Contingency Plan, Revision 19 (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request, Request Acceptance Supplement Administration Questions Answers 25 June 2020 Results Approval Other: ML21203A048
MONTHYEAR2021-03-17 [Table View]

ML21076A404

Text

Subject:

References:

SUMMARY

2.0 PROPOSED CHANGE

3.0 TECHNICAL EVALUATION

4.3 Precedents

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Attachment:

Attachment:

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