ML21223A242

Enclosure - Pilgrim Nuclear Power Station - Request for Additional Information Regarding Pilgrim - License Amendment Request Independent Spent Fuel Storage Installation Only Emergency Plan

ML21223A242
Person / Time
Site:	Pilgrim
Issue date:	08/16/2021
From:	Amy Snyder Reactor Decommissioning Branch
To:	Sterdis A Holtec Decommissioning International
Amy Snyder, 301-415-6822
Shared Package
ML21223A239	List: ML21223A241 ML21223A242
References
EPID L-2021-LLA-0021
Download: ML21223A242 (3)

Text

LICENSE AMENDMENT REQUEST RELATED TO PROPOSED EMERGENCY PLAN CHANGES FOR THE HOLTEC DECOMMISSIONING INTERNATIONAL, LLC PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 AND 72-1044 By application dated February 18, 2021 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML21049A192), as supplemented by the letters dated May 20, 2021 and July 29, 2021 (ADAMS Accession Nos. ML21140A045 and ML21140A045, respectively), Holtec Decommissioning International, LLC (HDI) requested approval by the U.S. Nuclear Regulatory Commission (NRC) of the proposed Pilgrim Nuclear Power Station (PNPS) Independent Spent Fuel Storage Installation Facility (ISFSI) Only Emergency Plan (IOEP) to support the planned off-load of the PNPS spent fuel pool and transfer of the spent fuel to the ISFSI.

The following are clarifications to the responses provided for the requests for additional information (RAIs). Timely and accurate response to these draft clarifications is requested.

RAI-1

Previous RAI Request: Please clarify that American Medical Response provides transportation for contaminated injured personnel.

HDI (PNPS) response:

Brewster Ambulance Service is currently under contract with the town of Plymouth to provide medical transportation service to the Plymouth area. PNPS has confirmed that Brewster Ambulance Service is capable of transporting contaminated injured personnel.

American Medical Response no longer provides this service to the Plymouth area.

DPP-PIL-EP-001 (IOEP), Section 2.1 Overview of ISFSI Emergency Plan on page 6 has been changed as follows:

Emergency services are provided by local, public, and private entities.

Fire support services are provided by the Plymouth Fire Department; law enforcement support services are provided by local, Commonwealth, and Federal law enforcement authorities, as appropriate; ambulance services are provided by Brewster Ambulance Service; and medical services are provided by Beth Israel Deaconess Medical Center and Morton Hospital.

Issue:

However, it is not clear to the NRC staff that there is a letter of agreement with the Brewster Ambulance Service.

Request:

Please clarify if there is a letter of agreement with the Brewster Ambulance Service and if it specifically states that they would provide transportation of injured personnel for PNPS, including contaminated injured personnel. If this agreement is provided through a contract with the town of Plymouth, please provide documentation that specifically states the Brewster Ambulance Service would provide transportation of injured personnel for PNPS, including contaminated injured personnel.

RAI-2

Previous RAI Request: Please clarify how the Plymouth Township will be notified for an emergency at the PNPS ISFSI.

HDI (PNPS) response:

Procedures have been established for the prompt notification to MEMA [Massachusetts Emergency Management Agency] and the Town of Plymouth in the event of an emergency declaration. PNPS Procedure EP-IP-100, Emergency Assessment and Response, Attachment 9.2 Event Notification Checklist provides the contact number for the Town of Plymouth that would be used by the Emergency Director to notify the town of an event at the Station.

Issue:

However, the sections of the proposed IOEP identified previously in the RAI have not been revised in response to the RAI.

Request:

Please revise the proposed IOEP as appropriate.

RAI-5

Previous RAI Request: Please clarify how onsite announcements are made.

HDI (PNPS) response:

Procedures have been established for the prompt notification of ISFSI personnel in the event of an emergency declaration. Announcements, are made via security radios utilizing PNPS Procedure EP-IP-100, Emergency Assessment and Response, Attachment 9.2 Event Notification Checklist.

Issue:

However, it is not clear to the NRC staff how personnel (public, as well as workers) in the ISFSI Controlled Area as well as the decommissioning reactor site located within the Owner Controlled Area (or within the site boundary) would be notified of an emergency declaration or any potential protective actions.

Request:

Please clarify how onsite announcements are made to personnel without security radios in the ISFSI Controlled Area, as well as the decommissioning reactor site located within the Owner Controlled Area of an emergency declaration or any potential protective actions.

RAI-6

Previous RAI Request: Please clarify if weekly testing of the commercial telephone system is required.

HDI (PNPS) response:

At the ISFSI, testing of both the portable radios and commercial telephone system is done by Security on a more frequent basis in accordance with Security procedures, therefore weekly testing of the commercial telephone system is not required.

Issue:

However, Section 10.0, Table 10-1 Communication Systems, of Enclosure 1, Attachment 1, has not been revised and provides the testing frequency for the commercial telephone system as weekly.

Request:

Please revise the proposed IOEP as appropriate.

New Clarification RAI discussed in the August 11, 2021 call.

Issue:

Table 1, Emergency Plan Initiating Conditions Being Deleted, of Section 3.1, Elimination of SFP Initiating Conditions and EALs, of the February 18, 2021 application provides, PD-HU1 Confirmed SECURITY CONDITION or threat (1 or 2 or 3) at the Independent Spent Fuel Storage Installation (ISFSI)

However, Table PD-1: Recognition Category PD and E Initiating Condition Matrix, in the, ISFSI Only Emergency Action Levels (EALs) and Technical Bases, of the February 18, 2021 application, as well as the May 20, 2021 supplement provides, PD-HU1 Confirmed SECURITY CONDITION or threat.

Request:

Please indicate what version of PD-HU1 is accurate and is to be reflected in the approval.