ML25051A261

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EA-24-105 Notice of Violation - Holtec Decommissioning International, LLC, Pilgrim Nuclear Power Station - NRC Independent Spent Fuel Storage Security Inspection Report 07201044/2025401 - Public
ML25051A261
Person / Time
Site: Pilgrim
Issue date: 02/27/2025
From: Ray Lorson
Region 1 Administrator
To: Trice K
Holtec Decommissioning International
References
EA-24-105 IR 2025401
Download: ML25051A261 (1)


Text

OFFICIAL USli ONLY SliCURITY RlilATliD INFORMATION EA-24-105 Kelly Trice President - HDI UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475ALLENDALE ROAD, SUITE 102 KING OF PRUSSIA, PA 19406-1415 February 27, 2025 Holtec Decommissioning International, LLC 1 Holtec Blvd., Krishna P. Singh Technology Campus Camden, NJ 08104

SUBJECT:

Dear Kelly Trice:

NOTICE OF VIOLATION - HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, PILGRIM NUCLEAR POWER STATION - NRC INDEPENDENT SPENT FUEL STORAGE SECURITY INSPECTION REPORT NO. 07201044/2025401 This letter refers to the Independent Spent Fuel Storage Installation (ISFSI) security inspection conducted on November 4 - 5, 2024, at the Pilgrim Nuclear Power Station. The inspection examined activities related to the licensee's physical security plan, revision 1, and NRC Order EA-13-132 dated July 23, 2013, "Additional Security Measures." The inspection was conducted using NRC Inspection Procedure 81311, "Physical Security Requirements for Independent Spent Fuel Storage Installations." Inspection report 07201044/2024402 (ML24331A0421) dated November 26, 2024, documented the inspection results. We note that Holtec Decommissioning International (HDI) took immediate corrective actions to address the security-related apparent violation(s) (AV/AVs) documented in this report. However, the nature of security-related AV/AVs, and the corrective actions taken to address such issues, are considered sensitive information and are not included in this letter but are included in the non-public enclosure.

Enclosure transmitted herewith contains SUNSI. When separated from enclosure, this transmittal document is decontrolled.

1 Designation in parentheses refers to an Agency-wide Documents Access and Management System (ADAMS) accession number. Unless otherwise noted, documents referenced in this letter are publicly-available using the accession number in ADAMS.

OFFICIAL USli ONLY SliCURITY RliLATliD INFORMATION

K. Trice OFFICIAL USE ONLY SECURITY REbAT6D INFORMATION 2

In the letter transmitting the inspection report, we informed you that the AV/AVs was/were being considered for escalated enforcement action and provided you with an opportunity to address the AV/AVs by either attending a pre-decisional enforcement conference or by providing a written response before we made our final enforcement decision. In a letter dated December 17, 2024 (ML24353A014), you provided a written response. In your written response you did not contest the AV/AVs and you described the actions taken and planned by Holtec to address the AV/AVs.

Based on the information identified during the inspection and the information that you provided in your December 17, 2024, letter, the NRC has determined violation(s) of NRC requirements occurred, as cited in the enclosed Notice of Violation (Notice) provided as Enclosure 1 (non-public). The circumstances surrounding the violation(s) were described in detail in the subject inspection report 07201044/2024402. In accordance with the NRC's Enforcement Policy, the Notice is considered an escalated enforcement action.

The NRC has concluded that information regarding: (1) the reason for the violation(s); (2) the corrective actions that have been taken and the results achieved; and (3) the date when full compliance was achieved is already adequately addressed on the docket in NRC Inspection Report No. 07201044/2024402 and in your letter dated December 17, 2024. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of this cover letter will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

However, the material enclosed herewith contains Security-Related Information in accordance with 10 CFR 2.390(d)(1) and its disclosure to unauthorized individuals could present a security vulnerability. Therefore, the material in the enclosure will not be made available electronically for public inspection in the NRC Public Document Room or in the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. If Security-Related Information is necessary to provide an acceptable response, please mark your entire response Security-Related Information in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.

OFFICIAL USE ONLY SECURITY RELAT6D INFORMATION

K. Trice OFFICIAL USE ONLY SECURITY Rl!LATED INFORMATION 3

If you have any questions concerning this matter, please contact Brice Bickett of my staff at 610-337-5312 or Brice.Bickett@nrc.gov.

Docket No.

07201044 License No. DPR-35

Enclosure:

Notice of Violation cc w encl: (w OUO-SRI) via BOX Brian McWilliams, Manager Site Security Dan Gagnon, Fleet Security Director James Piquette, Security Superintendent Jean Flemin*g, Vice President of Licensing and Regulatory Affairs David Bryant, Assistant Director for Planning and Preparedness, Massachusetts Emergency Management Agency Raymond K. Lorson Regional Administrator OFFICIAL USl:i ONLY SECURITY RELATED INFORMATION

ML25051A261 (Cover letter w/o enclosure) (Publicly Available)

ADAMS ACCESSION NUMBER: ML25051A265 (Cover letter w/SRI enclosure} (Non-Publicly Available)

Cover Letter Only

[g!Non-Sensitive

[g!Publicly Available X SUNSI Review D Sensitive D Non-Publicly Availaple Cover Letter w/OUO-SRI Publicly Available Enclosure Non-Sensitive X SUNSI Review

[gl Sensitive

[gl Non-Publicly Available MD 3.4 A.7 OFFICE RI/DRSS RI/DRSS RI/DRSS RI/ORA OE NSIR/DSO RI/DRSS NAME LCasey/LC BBickett EEve BKlukan DFurst BYip PKrohn DATE 2/7/2025 2/12/2025 2/12/2025 2/12/2025 2/18/20254 2/14/2025 2/19/2025 OFFICE RI/RA NAME Rlorson DATE 2/27/2025