View source for L-21-036, Proposed Independent Spent Fuel Storage Installation-Only Security, Training and Qualification, Safeguards Contingency Plan

{{Adams
| number = ML21085A596
| issue date = 03/17/2021
| title = Proposed Independent Spent Fuel Storage Installation-Only Security, Training and Qualification, Safeguards Contingency Plan
| author name = Sterdis A
| author affiliation = Holtec Decommissioning International, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS, NRC/NRR
| docket = 05000293, 07201044
| license number = DPR-035
| contact person = 
| case reference number = HDI-PIL-21-036
| package number = ML21085A595
| document type = Letter type:L, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 21
}}

=Text=
{{#Wiki_filter:SAFEGUARDS INFORMATION Krishna P. Singh Technology Campus, 1 Ho/tee Blvd., Camden, NJ 08~04 H    *o LT E C -------- --------            --T-ele -pho-n e-{8_5 6_)_7_ 97_-0_ 90_0 DiCOMMl5SJ ONING
   ,N  n R NAT, o NAL Fax (856) 797-0909 10 CFR 50.90 10 CFR 50.54(p) 10 CFR 73.55(r)
March 17, 2021 U.S. Nuclear Regulatory Commiss ion One \l\nllte Flint A TIN: Documen t Control Desk 11555 Rockville Pike Rockville MD 20852-27 38 Pilgrim Nuclear Power station
(
Renewed Facility License No. DPR-35 NRC Docket Nos. 50-293 and 72-1044 Subject           Pilgrim *Station Proposed Independent Spent Fuel Storage Installation-Only Security, Training and Qualification, Safeguards Contingency Plan

==References:==

[1] Letter, Holtec Decommissioning International, LLC to US NRC, "Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-
                      , Specific Decommissioning Cost Estimate for Pilgrim Nuclear Power Station,"
                       . Novembe r 16, 2018 (ML18320A040)
[2] Letter, Holtec Decommissioning International, LLC to US NRC, aReport on Status
* of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations,* March 31, 2020 (ML20091M858)
[3] NRC Interim Staff Guidance, NSIR/DSP-ISG-03, "Review of Security Exemptions/
License Amendme nt Requests for Decommissioning Nuclear Power Plants,*
September 28, 2015 (ML15106A737)
* Pursuant to the provisions of 1O Code of Federal Regulations (CFR) 50.4, 10 Ci=R 50.54(p), 10 CFR 73.55(r), and 10 CFR 50.90, Holtec Decommissioning International, LLC (HDI) Is submitting a
request for amendment to the Renewed Facility License (FL) for Pilgrim Nuclear Power Station (Pilgrim). Specifically, this proposed license a~ndme nt requests Nuclear Regulatory Commissi on (NRC) approval of the Pilgrim Independent Spent Fuel Storage Installation-Only Security, Training and Qualification, and Safeguards Contingency Plan, Rev O (ISFSl-0 PSP). The proposed pl_an will supersede the currently approved Physical Security, Training & Qualification and Safeguards NOTE: ENCLOSU RE 1 AND ITS ATTACHMENTS TO TillS LETI'ER CONTAIN ''SAFEGUARDS INFORMATION" AND "SECURITY-RELATED INFORMA TION" AND MUST BE PROTECTED ACCORDINGLY.
UPON SEPARATI ON OF THE ENCLOSURE, TIIlS LETTER AND ATTACHMENTS 1,2,AND.3 ARE DECONTR OLLED.
IIDI-PIL-21--036                              -                            ,
Page 1 of3
                                                                                                     ~ol SAFEGUARDS INFORMATION A)t-{SS 2/p f.}~L f.-J~ '5 s

                                                                 \
SAFEGUARDS INFORMATION
         *****----~-*s_h_~_P._S_i~_h_T~_,_ncl_~                __c_~_P_~_.1_~_~  __81_w_.,_Cam
__d_~_._~_oa_1_~_
HO l TE C                                                               Telephone   (856) 797-0900 O!COMM15510NINC
          , NTC11N,n10N,.,                                                               Fax (856) 797-0909
_Contingency Plan-(Revision 19A) and addresses the protection of material on site that Is licensed by the Pilgrim License that includes the Independent Spent Fuel Installations (ISFSI) .as well as
* other special nuclear material on site, with the exception of material subject to the requirements of 10 CFR Part 37,**Physical Protection of Category 1 and Category 2 Quantities of Radiation Matertal.
* The Mure site configuration that is reflected In the plan assumes that all remaining spent fuel in the spent fuel pool has been removed to the ISFSI (ISFSI Only status). Spent fuel movement .
        ,t~ the ISFSl-:ls_currently schec:lu~ to.be completed~ Qcto~r 2021.
The proposed ISFSl-9 PSP change and License Ame~ment Request are appropriate for a facility
* that Is perfomllng the *oECON* method of decommissioning and Is within' the descriptions provided by the HDI Revised Post Shutdown Decommissioning Actlvities Report submitted to the NRC on November 16, 2018 (Reference 1) as amended by the HDI Annual Report- on status of Decommissioning.Funding fpr,Reactors and Independent Spent Fuel Storage lnstallatlons
\_
submitted to the NRC on March 31,. 2020 (Reference 2).                      _                *
                                                                                                         /
The existing approved Site Security Plan (PSP Rev 19A) Appendix D addresses the security requirements for the ISFSI II cask storage Protected Area (PA). This submittal is consistent with the requirements of the existing PSP Appendix D.                  '
The proposed ISFSl-0 PSP is consistent with the guidance provided by NRC Staff in NSIR/DSP-ISG- 03, *Review of Security Exemptions/License Amendment Requests for Decommissioning Nuclear P ~ Plants* (Reference 3).                           ,.,
(                 '                                  .
Pursuant to 10 CFR 50.91 (a)(1 ), HDI has perfonned an evaluation and determined that the proposed amendment presents        no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), end, accordingly, a finding at *no significant hazards consideration* Is Justified.
Furthermore, HDI has evaluated this prop<;)Sed ll~nse amendment against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21.and has concluded, pursuantto.10 CFR 51.22(b), that no environmental impact statement or enviroriment assessment need be prepared in_connection)with the proposed amendment.                        *                                 ,
Attachments 1, 2 and 3 to this letter contain non-controlled descriptions   of the Evaluatlon of the Proposed Changes, and the License Condition Change. ,              '                    -
                \
I Enclosure 1 to this letter and its Attachments provide *Security-Related Information* and                '
      \                                                  '
        *Safeguards Information: The *Securtty-Related lnformetion* 1s required to be withheld from public disclosure pursuant to 10 CFR 2.390. The *Safeguards Information* as defined by 10CFR 73.22 and its disclosure to unauthorized Individuals is prohibited by Section 147 of the Atomlc_Energy'Act of 1954, as amended, and must be protected accordingly.                                        *
                           /           .            '
NOTE: ENCLOSURE 1 AND ITS ATTACHMENTS TO THIS LEITER CONI'AIN "SAFEGUARDS INFORMATION''
AND "SECURITY-RELATED INFORMATION" AND MUST BE PROTECI'ED ACCORDINGLY. UPON
   - SEPARATION OF TIIE ENCLOSURE, THIS LETIER AND ATTACHMENTS 1,2,AND 3 ARE DECONTROLLED.
HDI-PJL,.21-036 Page2 of3 SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION
       ----~-s_h_na_P_._s_I~_h_T~_~_o_~_Cam_p_~_.1_H_o_~_c_B_~_-,_~_m_dM_,_~_0_8_1_M_
H O LT EC                                                                  Telephone (856) 797-0900 DECOMMISSIO NING rNnRN ... noNAL
                                                                                     , Fax (856) 797-0909 In order to support the site transition to *IsFSI only" status, HDI Is requesting the NRC approval .Jof this proposed license amendmen t by September 30, 2021. HDI requests an ir:nplementation period of 30 days following HDrs submittal of written notification to the NRC that the remaining spent fuel
                             ,                          \                                  '
assemblies have been transferred from the spent fuel pool to the ISFSI.
1
                                                                                                    \
Pursuant to 10 CFR 50.91, *Notice for public comment; state consultation,* paragraph (b), a copy of
_ this appDcatlon for li~!lse amendme flt_~ letter Attachment s 1, 2 !!nd 3 are being___Q!:Qvid~ to the Common~e alth of Massachusetts, Emergency Manageme nt Agency.
This letter contains no new regulatory commitments.
If you have any questions or need further information, please contact me at (856) 797-0900, ext.
3813.
I declare under the penalty of perjury that the forgoing is true and correct.
Executed on March 17, 2021.
Sincerely, Andrea Sterdis Andrea L. Sterdis HDI Vice President, Regulatory and Environmental Affairs Holtec Decommiss ioning International, LLC Letter Attachment s
: 1. Summary and Evaluation of Proposed Changes (uncontrolled)
: 2. Proposed Change to PNPS Renewed Facility License Condition 3.G (mark-up)- '
(uncontrolle d)               ,
: 3. Revised PNPS Renewed Facility License Condition 3.G (clean copy) - (uncontrolled)
Enclosure
: 1. Description of PNPS Physical Security Plan Changes - (Safeguard s and Security--:
Related Information)
* cc:     (without Enclosure)
NRC Regional Administrat or - Region I NRC NMSS Project Manager (Pilgrim Nuclear Power Station).
Director, Massachus etts Emergency Manageme nt Agency NOTE: ENCLOSURE I AND ITS ATTACHMENTS TO TIIlS LETTER CONTAIN "SAFEGUAR DS INFORMATION" AND "SECURITY-RELATED INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON
* SEPARATION OF Tiffi ENCLOSURE, THIS LETTER AND ATTACHMENTS 1,2,AND 3 ARE DECONfROL LED.
HDI-PIL-21-036 Pago 3 of3 SAFEGUARDS INFORMATION

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o~coMM1ss10N1N c INT~RN.-.TION.-. L Krf_s_hna_P_._Sl-'ng;;_h_T_ec_h_nol____;og::..:...y_Cam_"-Pus_,1_H_o_lt_ec_B_lvd_.,_C_am_d_e_n_,N_J_08_104_
Telephone (856) 797-0900 Fax(856)797-0909
                                  -        HDI-PIL-21-036--
                                                                             ,i Attachment 1 Summary and Evaluation of Proposed Changes (8 pages includlng cover page)
HDI-PIL-21-036 Page 1 of8

 ;~-~~'----~-s_ hn_a_P_._Sl _ng_h_T_~_ oo_l_~~Cam              __  P~_,1_H_o_~_B_lw_.,_~_m_d_~_,N_J_0_8_1M_
0EcoMM1ss10N1NG INTeRNATIONAL Telephone (856) 797-0900 Fax(856)797-0909 Summary and Evaluation of Proposed Changes 1.0        Sum~ary of Proposed Changes                                                                     I In accordance With the provisions of 1o CFR 50.4 and 50.90, Holtec Decommissioning 1s*
requesting-an amendrnent-tG--the-~llgrim Nuclear-Power-Station Renewed-Facility License /'- - -
(FL) Condition 3.G. The proposed license amendment would document the approval of the proposed *Pilgrim Independent Spent Fuel Storage Installation-Only Security, Training and Qualification, and Safeguards Contingency Plan, Revision o* (ISFSl-0 PSP) provided in
          *Enclosure 1. Upon ~RC approval and HDI implementation of the proposed ISFSl-O PSP,
         -the'lndependent Spent Fuel Storage Installation (ISFSI), currently known as ISFSI II, will be identified as the ISFSl-0 and will be the only spent fuel storage area at Pilgrim Station. The ISFSl-0 will also be the only Protected Area (PA) identified by the site ISFSl-O PSP.
Consistent with the overall HDI decommissioning plan, all spent fuel will be offloaded from the spent fuel pool, the *onstte* ISFSI will be off-loaded of all dry fuel storage casks, the
                                                                                                              )
existing PNPS site PA will be eliminated, and the site will return to an Industrial facility.
Security protection requirements for the site areas outside of the ISFSl-0 PA, will be protected as necessary in accordance with 10 CFR Part 37, Physical Protection of Category*
1 and Category 2 Quantities, of Radiation Material.
The proposed ISFSl-0 PSP was developed to meet regulatory requirements for protection of tlie spent fuel against the design basis threat of radiological sabotage. The proposed ISFSl-0 PSP Is designed to meet the physical protection requirements for protection of spent fuel stored in an ISFSI cask storage area.
i The proposed ISFSl-0 PSP Is consistent with NRG guidance provided in Nuclear Security Incident Response/DMslon of Securtty Polley- Interim Staff Guidance (NSIR/DSP-ISG)-
03, *Review of Security Exemptions/License Amendment Requests for Decommissioning Nuclear Power Plants, (Reference 1). In addition, the PSP was Informed by ~curfty plans 8
recently reviewed/approved by NRG ;for similar facilities with all spent fuel in dry cask storage within an ISFSI (Re~rence 2).
        , The proposed ISFSl-O PSP evaluated Security Orders previously issued by the NRG that are applicable to the current Pilgrim PSP. The currently approved Physical Security Plan required update to reflect changes-proposed in the ISFSl-0 PSP.
Pendjng ucenstna Actions under NBC Review There are three pending licensing actions currently under NRC Review that relate to this LAR.
                                           *  .J On October 5, 2020, (Reference 6) HDI requested NRC- approval of a proposed revision to the License and PNPS Physical Security Plan to address Alternate Measures as related to security protection of the existing protected area established for Pilgrim Statlor;i.
HDI-PIL-21-036 Page 2 of8

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DKOMMl5SIONING INT6RNATIONAL j
Kri_*s_hna_P_._Sl--'-'19;....h_T_ech_n_ol_;og;_;._y_Cam_;....PU_s_,1_H_olte_c_B_lvd_.,_cam_d_en_,NJ_O_B1_04_
Telephone (856) 797-0900.
Fax:(856)797-0909 On February 18, 2021 (Reference 7) 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).
HDI also Intends to request NRC approval of a proposed revision to the License and TS
           , .to accommodate transition to ISFSI Only Technical Specifications (IOTS) In March 2021.
2.0       Appllcable Regulatory..Re.qulrements Pursuant to 10 Code of Federal Regulations (CFR) 50.54(p) and 10 CFR 50.90, Holtec Decommission 1
ing International, LLC (HDI) is requesting approval of proposed Pilgrim ISFS I-O PSP and an amendment for a conforming change to PNPS Renewed Facility License Condition 3.G. In accordance 'with 10 CFR 72.212(b)(9), the proposed ISFSl-0 PSP is required to protect spent fuel against the design basis threat of radiological sabotage in accordance with the same provisions set forth In the physical security requirements of 10 CFR 73.55 with certain conditions and excep~ns as specified in the regulation, and NRC Order EA 13-132 *1sauance of Order for lmplementatlon of Additional Security M888Ul'98 and Fingerprinting for Unescorted Access for PNPS ISFSr. This submittal Includes requests for alternative measures pursuant to 10CFR 73.55(r), 10 CFR 50.90 and 10 CFR 50.54 that support the proposed PSP revision.
3.0       No Significant H~rds Consideration Detennlnatlon The proposed Independent Spent Fuel Storage Installation ISFSI Only Physical Security                                                ,
Plan (ISFSI-OPSP) addresses the physical protection of,material on site that is licensed
           , under the PIigrim Nuclear Power Statlon,(PNPS) Renewed Facility License. as wen as the general license for the PNPS ISFSl-0 cask storage pad.                                                       (
Pilgrim has submitted the certifications for 10 CFR 50.82(a)(1), therefore 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, pursuant to 10 CFR 50.82{a)(2). A pending license amendment for ISFSl-Only Technical Specifications (IOTS) will be sul)Jnltted which requests a revised license condition that will permanently preclude storage of fuel in the Spent Fuel Pool (SFP) after all spent fuel has been removed and transferred to dry casks. The proposed amendment for the ISFSl-0 PSP reflects the configuration of the facility after spent nuclear fuel has been removed from the SFP and stored In approved dry casks in the                                                '----
ISFSI-0 protected area (PA).                          '
HDI has evaluated the proposed amendinent to detemUne if a significant.hazards consideration is Involved by focusing on the three standards set forth In 10CFR 50.92, Issuance of Amendment, as discussed below:
J, HDI-PIL-21-036 Attachment 1 Page 3 of8
_J

H O LT                         Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 EC-----              -~--____,;;_;'-----'----------
o~coMM1ss10N1N c INTSRNATION,._ l Telephone (856) 797-0900 Fax (856) 797-0909
: 1. The proposed change does not Involve a significant Increase In the probablllty or consequences of an ~ccldent previ~usly evaluated.
Response: No I                   Pilgrim has submitted notification pursuant to 10 CFR 50.82(a)(1) for pennanent cess~ion o f ~ reactor ~~ons and permanent removal _of_fuel'from the reactor vessel. Upon docketing of the 10 CFR50.82(a)(1) certifications, under 10,
                 -CFR 50.82(a)(2)ihe PNPS Part 50 license noionger authortzes-operation of the reactor qr emplacement or retention of fuel Into the reacto~ vessel. The irradiated fuel at PNPS is currently stored in the SFP and within the 'on-site" ISFSI In dry caaka. In this condition, the number of credible accidents or transients is slgnificantly smaller than for a plant authorized to operate the reactor or emplace or retain fuel in the reactor vessel.
* The proposed ISFSl-0 storage pad Is completed and was verlflecl functional. The existing approved Site Security Plan (PSP) contains Appendix D (PSP Rev 19A),
which addresses the required sequrlty requirements for the ISFSl-0 cask storage PA. PSP Rev 19A was approved by the NRC in December 2020, and security procedures to Implement the approved security plan were implemented on March 1, 2021. The ISFSl-0 storage pad was designed to allow for complete off-load of all spent fuel from the SFP to dry fuel storage casks, with additional capacity to store the existing ~ry C8lks currently located In the "on-site" ISFSI storage pad, plus additional allowance for storage of reactor-related Greater than Class C (GTCC) waste storage casks.
* The ISFSl-0 PSP reflects the f&#xb5;ture site configuration with all spetJt fuel removed from the spent fuel pool, and stored within the ISFSl-0 PA. 'Mth all spent fuel removed from the spent fuel pool, the Fuel Handling Accident (FHA) currently described In PNPS Defueled Safety Analysis Report (DSAR) Chapter 6 Is no longer credible. Since the FHA is no longer applicable, the proposed amen~ment would not involve a significant Increase In the probabillty or consequences of accidents previously evaluated.
The casks are maintained In accordance with the provisions of the Holtec International HI-STORM 100 Cask System, Certificate of Compliance (CoC) No. 72-1014, and in accordance with the associated Cask Final Safety Analysis Report (FSAR). The HI-STORM 100 Cask System consists of spent nuclear fuel (SNF) residing within a fuel basket structure contained within a sealed metallic canister, or Multi-Purpose canister (MPC). The HI-STORM 100 receives and contains the sealed MPC for long term storage, and provides gamma and neutron shleldlng, ventilation passages, mlsslle protection, and protection against natural pheno~na and accidents for the MPC. Cask FSAR Chapter 11, "Accident Analysla", Section 11.2
                 . provides the evaluation of accidents for th~ HI-STORM 100 Cask System which satisfies the following minimum acceptance criteria:
HDI-PIL-21-036 Attachment 1 Page 4 of8

Krishna P. Singh HOLTE            C - - - - - - -Technology                    Campus, 1 Holtec Blvd.,
                                                    - - - - - - ~ - -Camden,            -----
NJ 08104 oeco1,11,11ss,0N1Nc .
INTERNATIONA t Telephone (856) 797-0900 Fax(856)797--0909
* The MPC confinement boundary maintains radioactive material confinement,
                         *
* The MPC fuel basket structure malntains the,fuel contents subcritlcal,
* The"rstored SNF can be retrieved by normal means, and
* The system provides adequate shielding.
                -    The HI-STORITT0O"Cask System provides7he spent nuclear fuel and radioactive material In storage with confinement, radiation shielding, crijicality and passive h~ removal, Independent of other facility structures, systems and components '(SSCs).
Security modifications associated with the ISFSl-0 storage pad and the associated Appendix D to the current PSP (Revision 19A) were previously reviewed and approved by the NRC, and included new security systems for lighting, intruder detection systems, protected area boundary fencing, access control systems, telecommunications equipment a vehicle barrier system, and a central alarm station.
These security modifications do not significantly affect the abllity of the cask System -
and MPC to perform their functions as described in the Cask FSAR. Hence the proposed amendment has no effect on the ability of the Cask System to perform its
                  . design function nor would It Increase the likelihood of an accident previously e~ated.
Therefore, the prpposed amendment does not Involve a significant increase         in the probability or consequences of a prevlousty*evaluated aecident or a reduction in the margin of safety.
: 2. The proposed change d&deg;'-8 not create the possibility of a new or different kind of
             -accident from any accident previously evaluated Response: No The proposed amendment does not Involve any physical alteration of any facility structures, systems, and co'mponents (SSCs) or Cask System components required to mltlg_ate or prevent any accident previously evaluated and does not have a significant effect on the capability of any facility SSC or Cask System component to perform Its design functions. Thus, the proposed amendment does not create any initiators or precursors of a new or different kind of accident than previously evaluated. Likewise, the proposed amendment does not create the possibility of a new failure mode associated with any SSC malfunctjon or personnel errors that could result In a new or different kind of accident. Since the proposed amendment does not significantly affect any Cask System compon~nts, the credible events for the ISFSI are not changed.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.
HDI-PIL-21-036 Page 5 of8

Krishna P. Singh Technology Ca;pus,
"  HOLTE C - - - - - - - - - - -                                       Holtec Blvd., Gamden, NJ 08104 011coMM1ss10N1Nc INT&RNATIONJ\l Telephone (856) 797-0900 Fax(856)797-0909
: 3. The proposed change does* not Involve a significant reduction In a margin of safety Response: No                                                                              /
Pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for PNPS no longer authorizes operation of the reactor or emplacement or rete_ntlon of fuel Into the reactor'vessel, therefore *the occurrence of any postulated accidents associated with an-operatll'lg-ffl.Jclear ~ o r is no-longer-eredible. The pmposed-ehanges would--
become effective When all spent fuel has been transferred to the new ISFSl-0 storage pad with no intent to return spent fuel to* the spent fuel pool. 'Nith all spent fuel stored In approved dry casks and located in the ISFl-0 storage area, the fuel handling accident described In PNPS DSAR Chapter 6 Is no longer credible.
The proposed amendment does not Involve a significant change in any faolllty SSC or Cask Syatem component's design, configuration, or operation. Therefore, the modifications associated with this proposed amendment do not significantly affect the capability or manner in which the Cask System ar:id the ISFSl-O storage pad
* perform their safety functions, or the safety margins associated with their design and design- fun~lon.
Therefore, the proposed, amendment does not *involve a significant reduction in a margin of safety.
Based on the above, HDI concludes that he proposed amendment presents no significant hazards ~nslderatlon under the standards set forth in 10 CFR 50.92(~)..
and accordingly, a flndJng of "no algnlfloant hazarda conalderatlon" II Juatlfled.
4.0 . Environmental Considerations HDI has evaluated this proposed amendment against the criteria for identification of licensing and regulatory actions *requiring environmental assessment in accordance with 10 CFR 51.21, and determined that it meets t h e ~ for categorical exclusion set forth in 1Q, CFR 51.22(c)(12). The proposed amendment is being submitted _under the provisions of 10 CFR Part 50 for approval of a safeguards plan and changes to the PNPS R~newed Faclllty License, and in accordance with 10 CFR Part 72.                      -
Activities associated with the proposed amendment do not Involve any significant construction impacts and ere consistent with the plan for Mure reduction in the security area that focuses primarily on the storage for spent fuel, described In NUREG-0586, "Generic Environmental Impact Statement on DecommJssionlng of Nuclear Facilities," as a general activity expected to occur during decommissioning. The proposed amendment is confined to (I) organizational and procedural matters; and (Iii) administrative changes.
The proposed amendment-did not implement any new security modifications in order to facilitate ISFSl-0 PSP operation. The currently approved Site Security Plan and Its Appendix D (Revision 19A) was previously implemented along with the site modifications HDI-PIL-21-036 Attachment I Page 6 of8

H *o LT I; C _ _ _ _                 _ _P._
Krishna     ....;::.__
Singh          _. . . . : :. : _Campus, Technology            __;__ 1_ __
Holtec   __
Blvd.,    _ _NJ_
Camden,      __
08104 oecoMM1ss10N1N c INT6RNATIONAL Telephone (856) 797-0900 Fax(856)797-0 909 necessary to ensure ISFSI operational status. The site security mods Implemented for the PSP Rev 19 were previously evaluated and it was determined that they qualified for a categorical exclusion from an environmental review based on the criterion of 1Q_ CFR 51.22(c)(12). .
        . Therefore, pursuant to 10 CFR 51.22(b); an environmental assessment or impact statement is not required to be prepared in connection with the proposed amendment.
5.0      Precedent ,
Many decommissioning nuclear power plant sit~ have transition to ISFSl-only Security Plans and have updated_ their security license Condition. PIigrim Is requesting a security plan change that Is similar to previous approved ISFSI-Only Security Plans. The changes Included in the ISFSl-0 Security Plan proposed In this amendment request are informed .r by the ISFSI PSP provided to the NRC by the Vennont Yankee Nuclear Power Station (Reference 2)                     *-                                     -                     1 6.0       Concluslon
                  -                                    ~
Based on the considerations discussed above, (1) there Is reasonable assurance that the health and safety of the public will not be endangered by the proAosed changes, (2) activities consistent with the approved changes wlll be conducted in compliance with the Commllllon'a regulatlona, and (3) the !nuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
7.0      References 1:         NRC Interim Staff G1,Jldance, NSIR/DSP-I S~, ~ of Security Exemptlon8I License Amendment Requests for Decommissioning Nuclear Power Plants," September-28, 2015 (ML15106A737) 1   2.         Letter, -Entergy Nuclear Operations, In~ to USNRC, "Vermont Yankee Independent Spent Fuel Storage Installation Physical Security Plan, Revision 0, Proposed Change No.
315,* dated Merch.29, 2017 (ML 17117M21)
: 3.         Letter, Entergy Nuclear Operations, Inc. to USNRC,-"Certtflcatlona of Pennanent Cessation of Power Operations and Permanent Removal of Fuel from .the Reactor Vessel,"
dated June 10, 2019, ML19161A033).
: 4.         NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facflftfea,
* Volumes 1 & 2 of Supplement 1, November 2002 (ML023470327 and ML023500310)                                                                                       r
: 5.         NRC Regulatory Gulde 5.69, *Guidance for the Appllcatlon of the Radlologlcal Sabotage Design-Basis Threat In the Design, Development, and Implementation of a Physical Security Program that.Meets 10 CFR 73.55 Requirements.*
HDI-PIL-21-036 Page 7 of8

(
-H   O LT E C _ _ _ _          Krishna
__  P. Singh
____;;_Technology
_ _~_____;Gampus,
__   1 Holtec
__      _ Camden, Blvd.,  ___       NJ_ 08104 oecaMM1ss,oN1Na INTtRNJ\TIONJ\ l Telephone    (856) 797-0900 Fax(856)797-0 909
(
: 6.       Letter, Holtec Decommissioning International, Inc to USNRC, *physical Security    '     Plan Revision and License Amendment Request to Incorporate Alternate Measures,* dated October 5, 2020, (ML20283A292).
l                                                  *
: 7.       Letter,-Holtec Decommissioning International, Inc. to USNRC, *ucense Amendment Request to Approve the Pilgrim Nuclear Power station Independent Spent Fuel Storage
        -installation Only Emergency Plan,* dated February 18, 2021 (Mt21049A192).
      --8.       Letter, US Nuclear Regulatory Commission to Holtec Decommissioning lntemation~
Inc. (HDI), "Pilgrim Nuclear Power Station - Issuance of Amendment to Revise the Physical Security Plan to Incorporate an Additional Inda-pendent Spent Fuel Storage Installation (EPID: L-2020-LLA-0?OOt, dated December 1, 2020 (ML2032~7 )                           1 HDI-PIL-21--036 Page 8 of8

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H O LT E C --------= -------=-        ='------' ----'----' -------'-- ---
orcoMM1bs10N1NG                                               Telephone (856) 797-0900 1N1 ERN...r10N11L                                                     Fax (856) 79 7-0909 HBI-PIL--41-036 Attachment 2 Proposed Change to PNPS Renewed Facility License C9ndition 3.G (mark-up)
(2 pages including cover page)
HDI-PIL-21-036 Page 1 of2

 -Ill H   *o LT EC _ _ _ _              Krishna
_ _P._   Singh            Technology
                                                 . . : :. . . ._  _____;c_:_ Campus,
__:__ 1
_ Holtec
__    Blvd.,
_ Camden,
___       NJ_08104 orcoMM1,s10N1NG                                                                            Telephone (856) 797-0900 1NHl!NAT1ol'i.-.L                                                                                  Fax (85B) 797-0909 provisions of the Act and to the rules, regulations, and orders of the ColT)mlsslon now or hereafter in effect; and is subject to the additional conditions specified below:
A. DELETED
* Add revised Amendment No.
B.TechnicalSpecif ications  \
* ns contained in Appendix A, as revised through Amendment No. ~ .              hereby Incorporated in the renewed license. The_
licensee shall maintain the facility in accordance with the Permanently Defueled Technical Specifications.                -
C. Records HDI *shall keep facility records in accordance with the requirements of the Technical Specifications.
D.DELETED E.DELETED F.DELETED G. Physical Protection The licel"!see 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, i~ titled: *pnflrilfl N1:1slear PO't*ter Station Ses1:1rity ~an, TFSinl~g and Q1:1alifisatlon Plan, Safeg1:1ards Contlngensy Plan, and Pilgrim ISFSI II Physlsal SOGl:lrity Plan, Re11islonJQ.Aq" 6l:IJ:)f)lemented'by {{letter dated|date=April 2, 2020|text=letter dated April 2, 2020}}, (Accession No. ML20122A055) as s1:1pplemented by letters dated, J1:1ne 26, 2020 (ML2018&A.001 ), J1:1ly 21, 2020 (ML20213C03.1, nonp1:1blis), J1:1ly 22, 2020 (ML20213B743, nonp1:1bllo), and J1:1ly 301 2020 (ML20220A361 and ML20220.i\352, nonp1:1blis).                .          l
* Pilgrim Independent Spent Fuel Storage Add submittal date and                      _  Installation-Only Security, Training and ML#
Qualification,  and Safeguards Contingency Plan, Revision 0 HDI-PIL-21-036 Page2 of2

H   O LT EC _ _ _ _     Krishna
_ _P._  Singh Technology
_;;__           Campus,_
__;:.:....__;.__ 1 Hallee
_ _Blvd.,
_ _Camden,
___     NJ_08104 ofcoMM1ss10N1Nc                           ~,                        Telephone (856) 797-0900 INTEl{N.-.TION.-.L Fax(856)797~909 Attachment 3 to HDI-PIL-21-036 Revised PNPS Renewed Facility License Condition 3.G (clean copy)
(2 pages Including cover page)
IIDI-PIL-21--036 Page 1 of2 r

H   O LT EC _ _ _ _          Krishna
__    P._
Singh          Technology
                                             ....:::...,__          Campus, 1 Holtec Blvd., Camden,
____;:;;,,:'-----'----                    NJ 08104 0fcoMMlss,oN1NG                                                                  Telephone (856) 797-0900 INHR N'IT10NAL                                                                            Fax c856) 797-090 9 Revised License-Condition 3.d (first paragraph) (Clean Copy)
G.       Physical Protection
-The licensee shall- fully-implement and-maintain-in effect all pmvisiORs- of the Commissien-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 lnfonnation protected under 10 CFR 7321, Is titled: *Pilgrim Station Independent Spent Fuel storage Installation-Only (ISFSl-
: 0) Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan Revision 0,"
submitted by {{letter dated|date=March 17, 2021|text=letter dated March 17, 2021}} (ML# to be assigned by NRC);--
j I_
HDI-PIL-21-036 Attachmkrt 3 Page2 of2

SAFEGUARDS INFORMATION Krishna P. Singh Technology Campus, Holtec Blvd., Csmden, NJ 08104 HOLTE C - - - ' - - - - - - - - - - - - -1 '                   ----------
oecoMM1ss10N1NG                                                     Telephone (856) 797-0900 1NTERNAr10N>.1                                                              Fax (856) 797-0909
                                     -HBI-PIL 03&--
Enclosure 1                                           J
               ,, Description of PNPS Physi~I ~ecurity Plan Changes (24 pages Including cover page}
J I
NOTE: THIS ENCLOSURE 1 AND ITS ATTACHMENTS CONTAIN "SAFEGUARDS INFORMATION"' AND *sECURITY-RELATED INFORMATION" ~D MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ENCLOSURE 1 AND ITS ATTACHMENTS, THIS COVER PAGE BECOMES DECONTROLLED.
HDI-PIL-21-036 EnclOSID'e 1 Page 1 of24 SAFEGUARDS INFORMATION
                           )

                     )
                                                        -              C SAFEGUARDS INFORMATION HOLTE C - - - - - -Krishna              P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ,D8104
                                 -~--.....::C.C                 ....--'-----------'--
0RcoMM1s110N1N o                                                            Telephone {856) 797-0900 INTIRNA"!'.ION, \L I '                 Fax(856)797-0 909 HDI-PIL-21-036 Attachmen t 3 to-Enclosure 1
                                                                         /
I Pilgrim ISFSl-0 PhYrslcal Security Plan (Revision 0)
                                                  \
(116 pages lncludl~g cover pa9e)
* r
(
NOTE: ATTACHMENT 3 TO ENCLOSURE 1 CONTAINS ..SAFEGUARDS NFORMATIONN AND Ml:JST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THIS ATTACHMENT, THIS COVER PAGE BECOMES DECONTROLLED.
HDI-PIL-21-036 Attachment 3 to Enclosure 1 Cover Page
                                .SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION
  ,~~~'---- ~-s_h~~ P_._S_i~ _h_T_~_ ~_o~~~- m~p-~_. _1_Holte    __c B_~_-,_~_m_d~_.~_0_6_1~_
0KOMM1ss, 0N1Nc INTERNAT IONAL                                                    Telephone (656) 797-0900 FB?C(656)797-0909 r
                                 -     ---MDI-PIL-21--036 -- - --   ) '
Attachment 2 to Enclosure 1 Pilgrim Nuclear Power Station
                                 , Physical Security Plan Revision 19A Mark-up (229 pages Including cover page}
NOTE: ATTACHMENT 2 TO ENCLOSURE 1 CONTAINS .,SAFEGU,ARDS INFORMATION* AND M~ST BE PROTECTE D
ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 2, THIS COVER PAGE BECOMES DECONTROLLED.
HDI-PIL-21-036             '                                                  ../
Attachment 2 to Enclosure 1 Pago 1 of229 SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H O LT E C --------='---- ..::..:.......--'-                               -----'---~---
0RcoMi,ui,,_0N,N~                   )                                    Telephone (856) 797-0900 I NTIR N.-.TION.-. L                                                              Fax (856) 797-0909
                                         -    HDI-Pl L-21-036
                                                                                      --r     --       , -;
Attachment 7 to Enclosure 1 Order EA 13-132 Review- Compliance Matrix (59 pages includln'g cover page)
(
NOTE: ATTACHMENT 7 TO ENCLOSURE 1 CONTAINS "SAFEGUARDS,INFORMATION" AND MUST BE PROTECTED ACCORDINGL'(. UPON REMOVAL OF THIS ATTACHMENT, THIS COVER PAGE BECOMES D~CONTROLLED.
HDI-PIL-21-036 Attachment 7 to Enclosure 1 Page 1 of59 SAFEGUARDS INFORMATION

                  /
SAFEGUARDS INFORMATION
      .                      Krishna P. Singh Techn.ology Campus, 1 Holtec Blvd., Camden, NJ 08104 HOLTE C - - - - - - - - - - ~ ~                              -----------~
DfiCOMMIS510NING                                                      . Telephone (856) 797-0900 1NTERNAr10~.-.L                                                                  Fax (8S6) 797-0909 I
HDl~Pl~-21-036 * - ** ,. -
Attachment 8 to Enclosure    J 1
JSFSl-0 Blast Calculatlons (41 pages including C':)V&r page) _
j J
J
/   NOTE: ATTACHMENT 8 TO ENCLOSURE 1 CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVALOF_THISATTAOIMENT, THIS.COVER PAGE BECOMES [)ECONTROLLED.
HDI-PIL-21--036                        '
Attachment 8 to Enclosure 1                                                                         J Page 1 of 41 SAFEGUARDS INFORMATION

  ,.~~T"' ____
oicoMMrss,oN,N c INl E"flNATIONAL SAFEGUARDS INFORMATION Krlsh_---:-n_a_P_.S_lng~h_Tech_n_o_logy-=-ca_m....:..,p_us-,_1_Holtec
__B_lvd_.,_Cam_d_en_,'-N_J_08_1_04_
                                                                                                  )
Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-036
                                    ,          -                                       (
Attachmen t 9 to Enclosure 1 Pllgrlm Station Local Law Enforcement Memorandum of Understanding (2 pages Including cover- page) f                                    - '
I NOTE: ATTACHMENT 9 TO ENCLOSURE 1 CONTAINS *SAFEGUARDS INFORMATION* AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THIS ATTACHMENT, THIS COVER PAGE BECOMES DECONTROLLED.
HDI-PII.,;-21-036 Attachment 9 to Enclosure 1 Page 1 of2 SAFEGUARDS INFORMATION f
                                                                                                                                  '}}