View source for L-21-057, Supplemental Information to Update - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan

{{Adams
| number = ML21140A045
| issue date = 05/20/2021
| title = Supplemental Information to Update - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency 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-21-057
| document type = Letter type:L, Response to Request for Additional Information (RAI)
| page count = 23
| project = 
| stage = Supplement
}}

=Text=
{{#Wiki_filter: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 50.54(q)(4)
May 20, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket Nos. 50-293 and 72-1044

==Subject:==
Supplemental Information to Update - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan

==References:==
: 1. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan, February 18, 2021 (ML21049A192)
: 2. US NRC Electronic Mail Request to Andrea Sterdis (HDI) Request for Additional Information Related to Request for Approval of Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan, April 8, 2021 (ML21099A038, ML21099A044)
: 3. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, License Amendment Request to Approve the Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan, February 23, 2021 (ML21054A321)
By {{letter dated|date=February 18, 2021|text=letter dated February 18, 2021}} (Reference 1) Holtec Decommissioning International, LLC, (HDI) submitted a License Amendment Request (LAR) for Pilgrim Nuclear Power Station (PNPS). The proposed amendment would revise the site emergency plan for the Independent Site Fuel Storage Installation (ISFSI) Only condition.
In an electronic mail request dated April 8, 2021 (Reference 2), the NRC issued a Request for Additional Information (RAI) to Oyster Creek Nuclear Generating Station (OCNGS) indicating that it had reviewed the information submitted in Reference 3 and additional information was needed to support its continued review.
A review of the PNPS submittal indicates that the NRC RAIs sent to OCNGS are applicable to the PNPS License Amendment Request (Reference 1) since both Reference 1 and Reference 3 submittals utilized a common template.
HDI-PIL-21-057 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 supplements Reference 1 by providing HDIs responses to the RAIs sent to OCNGS as applicable to the PNPS LAR provided in Reference 1. Attachment 2 provides updated clean pages of the PNPS ISFSI Only Emergency Plan and ISFSI Only Emergency Action Levels reflecting the response information provided in Attachment 1.
HDI has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Reference 1. The additional information provided in this submittal does not affect the previously stated bases in Reference 1 for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4).
There are no regulatory commitments contained in this submittal.
If you have any questions or require additional 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 May 20, 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: 2021.05.20 06:37:59 -04'00' Andrea L. Sterdis HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC HDI-PIL-21-057 Page 2 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Attachments:
: 1. PNPS Response to NRC Request for Additional Information 2 Updated (clean) pages of the PNPS Independent Fuel Storage Installation Only Emergency Plan (IOEP) and PNPS ISFSI Only Emergency Actions Levels and Technical Bases (IOEAL) cc:
USNRC Regional Administrator, Region I USNRC Project Manager, NMSS - Pilgrim Nuclear Power Station USNRC Region I, Lead Inspector - Pilgrim Nuclear Power Station Director, Massachusetts Emergency Management Agency HDI-PIL-21-057 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-21-057 Attachment 1 PNPS Response to NRC Request for Additional Information (11 pages follow)

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

==SUMMARY==

By {{letter dated|date=February 18, 2021|text=letter dated February 18, 2021}} (Reference 1), Holtec Decommissioning International, LLC (HDI) submitted a license amendment request for review and approval of the Pilgrim Nuclear Power Station (PNPS) Independent Spent Fuel Storage Installation Facility (ISFSI) Only Emergency Plan and its associated Emergency Action Level scheme. The proposed changes were submitted to the U.S. Nuclear Regulatory Commission (NRC) for approval prior to implementation, as required under Paragraph 50.54(q)(4) of Title 10 of the Code of Federal Regulations (10 CFR).
In an electronic mail request dated April 8, 2021 (Reference 2), the NRC issued a Request for Additional Information (RAI) to Oyster Creek Nuclear Generating Station (OCNGS) indicating that it had reviewed the information submitted in Reference 3 and additional information was needed to support its continued review.
A review of the PNPS submittal indicated that the OCNGS RAIs were applicable to the PNPS License Amendment Request (Reference 1) since both Reference 1 and Reference 3 submittals utilized a common template.
Accordingly, this attachment provides HDI- Pilgrims response to the NRC RAI issued to OCNGS contained in the Reference 2 electronic mail request. Each specific question is followed by HDI-Pilgrims response.
Changes made to the previously submitted PNPS ISFSI Only Emergency Plan and EALs are shown as markups at the end of the RAI response as necessary. Attachment 2 to this submittal supplement contains clean corrected EPlan and EAL pages for replacement.
RAIs and HDI-Pilgrim Responses NRC RAI - 1 to OCNGS Requirement:
* 10 CFR 50.47(b)(12), requires that arrangements are made for medical services for contaminated injured individuals.
* 10 CFR Part 50, Appendix E.IV.E.6 requires arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary.
* Associated guidance in NUREG-0654, Section II.B, Evaluation Criterion L.4 states that each licensee shall arrange for transporting victims of radiological accidents to medical facilities.
Issue: Section 5.2.2, Ambulance Service, of Enclosure 1 Attachment 1, Oyster Creek ISFSI Only Emergency Plan, states, Arrangements are made for prompt ambulance transport of persons with injuries involving radioactivity to designated hospitals. Such service is available on a 24-hour per day basis and is confirmed by letter of agreement.
HDI-PIL-21-057 Page 1 of 11

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 However, previously Section 7.2.3.1, Local Services, of Attachment 3, Clean Copy - Permanently Defueled Emergency Plan (PDEP), in {{letter dated|date=February 13, 2018|text=letter dated February 13, 2018}} (ADAMS Accession No. ML18044A214), states,
: 1. Transportation of injured personnel using an ambulance service (Lacey Township, Lanoka Harbor, and Waretown First Aid Squads)
In {{letter dated|date=October 17, 2018|text=letter dated October 17, 2018}} (ADAMS Accession No. ML18221A400), the NRC issued the amendment approving the proposed permanently defueled emergency plan The SER stated, Therefore, the NRC staff concludes that the licensee's proposed Oyster Creek PDEP, as provided in Attachment 3 to the licensees {{letter dated|date=February 13, 2018|text=letter dated February 13, 2018}}, is acceptable.
The current text in IOEP Section 5.2.2 does not identify what ambulance services are available.
Request: Clarify what ambulance service(s) are confirmed by letter(s) of agreement with the OCNGS ISFSI.
HDI-Pilgrim Response to RAI - 1 Not applicable to the PNPS submittal. The IOEP specifies that ambulance services are provided by American Medical Response (AMR), Inc. and coordinated by the Plymouth Fire Department.
The submitted IOEP states:
2.1, Overview of ISFSI Emergency Plan 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 American Medical Response (AMR), Inc.; and medical services are provided by Beth Israel Deaconess Medical Center.
NRC RAI - 2 to OCNGS Requirements:
* 10 CFR 50.47(b)(1), as exempted, requires that each principal response organization has staff to respond and augment its initial response on a continues basis.
* 10 CFR 50.47(b)(2), as exempted, requires on-shift facility licensee responsibilities for emergency response are unambiguously de"ned, adequate staf"ng to provide initial facility accident response in key functional areas is maintained at all times.
* 10 CFR Part 50, Appendix E.IV.A.1, as exempted, requires a description of the normal plant organization. Additionally, Appendix E.IV.A.2, as exempted, requires a description of the onsite emergency response organization (ERO).
HDI-PIL-21-057 Page 2 of 11

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909
* Associated guidance in NUREG-0654, Section II, Evaluation Criterion A.4, states each licensee shall be capable of continuous (24 hour) operation. Evaluation Criteria B.1, states that each licensee shall specify the on-site emergency organization of the plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement. Evaluation Criteria 35 states each licensee shall specify the position or title and major tasks to be performed by persons to be assigned to the functional areas of emergency activities.
Issue: Section 6.1 On-site Positions" of the IOEP only identi"es the ISFSI Shift Manager/Security Operations Supervisor (ISS) position. Table 61 only identifies the Emergency Director as the on-shift staff to "ll all functional areas.
Request: Identify other on-shift positions and types of staff that are available to "ll emergency response functions at OCNGS ISFSI. Identify who would assume Emergency Director duties at OCNGS ISFSI if the ISS is incapacitated or somehow unavailable during a shift.
HDI-Pilgrim Response to NRC RAI - 2 The submitted IOEP states:
3.1.10 Emergency Director This position is the highest level of authority for the PNPS Emergency Response Organization (ERO) and on-site emergency activities. This position is held by the ISFSI Shift Supervisor (ISS) or designated alternate. The ISS in the IOEP is equivalent to the Lead Security Shift Supervisor (LSSS) as defined in the ISFSI Only Security Plan.
On-shift positions are listed on in table 6-1 in the IOEP. As listed, the PSP dictates the number of security personnel on shift. The IO PSP requires a minimum of: Security Supervisor (ISS) and a Security Officer. The Security Officer would succeed the ISS if incapacitated until on call replacements are achieved. The Security Officer is trained to perform call outs and off-site notifications. This succession is covered in EPIPs/Security procedures.
NRC RAI - 3 to OCNGS Requirement:
* 10 CFR 50.47(b)(7), as exempted, requires the principal points of contact with news media for dissemination of information during and emergency are established in advance, and procedures for coordinated dissemination of information to the public are established.
* Associated guidance in NUREG-0654, Section ll.G, Evaluation Criterion 3.a, states each principal organization shall designate the points of contact and physical location for use by news media during an emergence. Also, Evaluation Criteria 4.a states each licensee shall designate a spokesperson who should have access to all necessary information.
HDI-PIL-21-057 Page 3 of 11

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Evaluation Criteria 4.b states each licensee shall establish arrangements for timely exchange of information among designated spokespersons. Evaluation Criteria 4.c states each licensee shall establish coordinated arrangements for dealing with rumors.
Issue: In IOEP Section 6.2.1, the Resource Manager is identi"ed as serving as the public information interface. In Section 11.0 Public information," corporate public affairs personnel are identified to represent the facility as the company spokesperson, and to disseminate information to the public.
Request: Clarify the apparent duplication of responsibilities between the Resource Manager and corporate public affairs personnel for the OCNGS ISFSI.
HDI-Pilgrim Response to NRC RAI - 3 The Resource Manager provides information to the Corporate Public Affairs and coordinates with Corporate Public Affairs who becomes the lead on dissemination of information to the public.
Section 6.2.1 Resource Manager functions have been updated to show that the Corporate Public Affairs becomes the lead for this function. DPP-PIL-EP-001 (IOEP) section 6.2.1 Resource Manager on page 19 following sentence change as follows:
The Resource Manager will augment the Emergency Director by assisting in the assessment of the emergency condition and coordinating any required resources, including serving as the public information interface (until turnover to Corporate Public Affairs occurs).
NRC RAI - 4 to OCNGS Requirement:
* 10 CFR 50.47(b)(5), as exempted, requires procedures have been established for noti"cation, by the licensee, of State and local response organizations...
* 10 CFR Part 50, Appendix E.IV.D.3, as exempted, requires a licensee to have the capability to notify responsible State and local governmental agencies after declaring an emergency.
* Associated guidance in NUREG-0654, Section E. Evaluation Criterion E.1. states that each licensee shall establish procedures which describe mutually agreeable bases for notification of response organizations consistent with the emergency classi"cation and action level scheme.
Issue: Section 9.0, Notification Methods and Procedures, of Enclosure 1 Attachment 1, states, in part:
Procedures are established for the prompt noti"cation to NJ OEM [New Jersey-Of"ce of Emergency Management] and local organizations. . ..
However, previously the response to request for additional information (RAI) OC-03 in Attachment 1, Response to Request for Additional Information, in {{letter dated|date=February 13, 2018|text=letter dated February 13, 2018}} states, HDI-PIL-21-057 Page 4 of 11

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Local organization EOCs [Emergency Operations Centers]: Ocean County, Lacey Township, and Ocean Township are noti"ed by the State of New Jersey, as necessary, when an Unusual Event, Alert, or other State EOC noti"cation has been made by the OC Shift Manager. The local county and townships have established this process for the current operating plant and will continue to support this method during this decommissioning period.
The Local Warning Points/EOC block on Figure 6.1 [Exelon Noti"cation Scheme] has been revised to indicate the three local EOCs that will be contacted by the State EOC in the attached revised PDEP.
The current text in IOEP Section 9.3.1 does not detail how the local governmental organizations will be notified.
Request: Clarify how the local governmental organizations will be noti"ed of an emergency at the OCNGS ISFSI.
HDI-Pilgrim Response to NRC RAI - 4 Not applicable to the PNPS submittal. The submitted IEOP states:
9.2     Emergency Messages The Emergency Director is responsible for the notification of an emergency declaration to MEMA, the Plymouth Fire Department, and the NRC within 60 minutes of the event classification or change in classification.
The Emergency Director directly notifies both state and local governmental response agencies.
NRC RAI - 5 to OCNGS Requirement:
* 10 CFR 50.47(b)(8), as exempted, requires that adequate emergency facilities and equipment to support the emergency response are provided and maintained.
* 10 CFR Part 50, Appendix E.IV.E., as exempted, requires each licensee to describe emergency facilities.
* Associated guidance in NUREG-0654, Section II.H, Evaluation Criterion H.2, states each licensee shall establish an emergency facility from which evaluation and coordination of all licensee activities related to an emergency is to be carried out, and from which the licensee shall provide information to federal, State, and local authorities responding to emergencies.
Also, in Evaluation Criteria H.6, each licensee shall make provisions to acquire data from or for emergency access to offsite monitoring and analysis equipment including geophysical phenomena monitors, (e.g., meteorological, and seismic).
Issue: IOEP Section 12.1, Emergency Response Facilities, identifies the Emergency Response Facility (ERF) as the facility from which command and control functions are managed. However, the HDI-PIL-21-057 Page 5 of 11

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 IOEP does not identify the location of the ERF. The IOEP does not include information on the availability of, or access to geophysical phenomena monitors.
Request: Provide the location of the ERF for the OCNGS ISFSI. Provide information on the availability of or access to geophysical phenomena monitors for the OCNGS ISFSI.
HDI-Pilgrim Response to NRC RAI - 5 The onsite ERF is the office area within the Indoctrination & Support (I&S) Building within close proximity to the ISFSI facility and is where the ISFSI Security Supervisors Office is located. The ISFSI Security Supervisors Office has been added to the DPP-PIL-EP-001 (IOEP) page 10, ERF definition 3.1.12 is changed as follows:
The ISFSI Security Supervisors Office is the facility containing the communications equipment necessary for emergency conditions.
Geophysical information is available to the ISFSI Security Supervisor as described in EPIPs by the following means:
The National Weather Service (NWS) Norton Massachusetts office provides meteorological information (e.g., wind speed, temperature, and wind direction) from several locations in the vicinity of PNPS. This information is available by telephone or the internet.
Seismic information can be obtained from the U.S. Geological Surveys (USGS) National Earthquake Center by telephone or internet or the Weston Observatory (New England Seismic Network) via the internet.
NRC RAI - 6 to OCNGS Requirement:
* 10 CFR 50.47(b)(10), as exempted, requires that a range of protective actions has been developed for emergency workers.
* Associated guidance in NUREG-0654, Section II.J, Evaluation Criterion J.2, states each licensee shall make provisions for evacuation routes and transportation for onsite individuals. Also, Evaluation Criteria J.3 states each licensee shall provide for radiological monitoring of people evacuated from the site. Further, Evaluation Criteria J.6 states licensees shall make provisions for the use of individual respiratory protection.
Issue: The IOEP does not address evacuation routes or transportation for onsite individuals, radiological monitoring of site evacuees, or the provision of respiratory protective equipment.
Request: Provide information on evacuation routes, monitoring of people evacuated from the site, and provision of respiratory protective equipment for the OCNGS ISFSI.
HDI-PIL-21-057 Page 6 of 11

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-Pilgrim Response to RAI - 6 Details of Evacuation routes and Radiation monitoring are covered in Emergency Plan Implementing Procedures (EPIPS) and Site radiation control procedures. Primary evacuation is to off site. Medical evacuation is to one of the two listed hospitals in the IOEP.
The protective equipment for PNPS ISFSI is listed in Appendix A page 42 of DPP-PIL-EP-001 (IOEP) has the following change:
* Protective clothing, including respiratory protection.
NRC RAI - 7 to OCNGS Requirement:
* 10 CFR 50.47(b)(15), requires radiological emergency response training is provided to those who may be called on to assist in an emergency.
* 10 CFR Part 50, Appendix E.IV.F.1 requires description of specialized initial training and periodic retraining of categories of emergency personnel, including first aid and rescue teams.
* Associated guidance in NUREG-0654, Section II.B, Evaluation Criterion O.3, as modified by Attachment 1 to NSIR/DPR-ISG-02, "Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants" (ADAMS Accession No. ML14106A057), states that each licensee shall arrange for transporting victims of radiological accidents to medical facilities.
Issue: Section 19.1.2, First Aid Personnel, of Enclosure 1 Attachment 1, states, First Aid training is provided to personnel assigned on-shift in accordance with site training and qualification plan.
However, previously Section 11.2.2, Emergency Response Organization Training, of Attachment 3, in {{letter dated|date=February 13, 2018|text=letter dated February 13, 2018}} (ADAMS Accession No. ML18044A214), states, Personnel assigned the responsibility of first aid response will be trained with courses equivalent to Red Cross First Aid, CPR, or AED for Lay Responders or equivalent.
The current text of Section 19.1.2 First Aid Personnel does not provide information on the level of training provided.
Request: Clarify what level/type of training first aid personnel receive at the OCNGS ISFSI.
HDI-Pilgrim Response to RAI - 7 The following sentence has been added to Section 19.1.2 on page 37 of DPP-PIL-EP-001 (IOEP):
HDI-PIL-21-057 Page 7 of 11

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Personnel assigned the responsibility of first aid response will be qualified by an accredited nationally recognized organization (e.g. American Red Cross, American Heart Association, etc.) in First Aid, CPR, or AED for Lay Responders or equivalent.
NRC RAI - 8 to OCNGS Requirement:
* 10 CFR 50.47(b)(16), as exempted, requires that responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.
* Associated guidance in NUREG-0654, Section II.P, Evaluation Criterion P.7, states each plan shall contain a listing, by title, procedures required to implement the plan. The listing shall include the section(s) of the plan to be implemented by each procedure.
Issue: The IOEP includes an Appendix B, which has a column to identify appropriate procedures. However, the column only indicates TBD for all procedures.
Request: Provide an appropriate listing, by title, of the procedures required to implement the IOEP for the OCNGS ISFSI.
HDI-Pilgrim Response to RAI - 8 EPIPs will follow similar level of detail as provided for the PDEP for emergency preparedness actions that are required by the IOEP. The EPIP titles will be updated prior to implementation of the IOEP.
NRC RAI - 9 to OCNGS Requirement:
* 10 CFR 50.47(b)(4), as exempted, requires a standard emergency classification and action level scheme.
* 10 CFR Part 50, Appendix E.IV.B.1, as exempted, requires a description of the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification.
* Associated guidance in NUREG-0654, Section II.D, Evaluation Criterion D.1, states that an emergency classification and emergency action level scheme must be established by the licensee.
Issue: PD-HA1, Hostile Action is occurring or has occurred, of Enclosure 1, Attachment 2, EAL Bases, states, This IC [Initiating Condition] addresses the notification of an aircraft attack threat or an occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA.
HDI-PIL-21-057 Page 8 of 11

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 However, the EAL itself does not state the location in the Emergency Action Level.
Request: Revise the Emergency Action Level to include the location discussed in Enclosure 1, , EAL Bases.
HDI-Pilgrim Response to RAI - 9 within the OWNER CONTROLLED AREA has been added to the EAL PD-HA1 and repeated in the bases document. See Attachments 1 and 2, DPP-PIL-EP-002 (IO EAL) pages 14 and 18.
: 1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor.
NRC RAI - 10 to OCNGS Requirement:
* 10 CFR 50.47(b)(4), as exempted, requires a standard emergency classification and action level scheme.
* 10 CFR Part 50, Appendix E.IV.B.1, as exempted, requires a description of the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification.
* Associated guidance in NUREG-0654, Section II.B, Evaluation Criterion D.1, states that an emergency classification and emergency action level scheme must be established by the licensee.
Issue: Definitions section, of Enclosure 1 Attachment 2, EAL Bases, does not have a definition for the following terms:
* Emergency Action Level (EAL)
* Emergency Classification Level (ECL)
* Initiating Condition (IC)
Request: Revise the definition section to include the definitions for Emergency Action Level (EAL),
Emergency Classification Level (ECL), and Initiating Condition (IC).
HDI-Pilgrim Response to RAI - 10 Not applicable to the PNPS submittal. The submitted IEOP states:
Emergency Action Level (EAL): Refer to Section 3.3.
Emergency Classification Level (ECL): Refer to Section 3.1.
Initiating Condition (IC): Refer to Section 3.2 HDI-PIL-21-057 Page 9 of 11

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 NRC RAI - 11 to OCNGS Requirement:
* 10 CFR 50.47(b)(4), as exempted, requires a standard emergency classification and action level scheme.
* 10 CFR Part 50, Appendix E.IV.B.1, as exempted, requires a description of the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification.
* Associated guidance in NUREG-0654, Section II.B, Evaluation Criterion D.1, states that an emergency classification and emergency action level scheme must be established by the licensee.
Issue: The Definitions section of Enclosure 1 Attachment 2, EAL Bases, has the following terms that are not used in the EAL Bases:
* Normal Level
* Unplanned Request: Revise the Definitions section to exclude the definitions for Normal Level and Unplanned.
HDI-Pilgrim Response to RAI - 11 Definitions have been removed from DPP-PIL-EP-002 (IO EAL) page 11.
NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.
HDI-PIL-21-057 Page 10 of 11

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

==References:==
: 1. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan, February 18, 2021 (ML21049A192)
: 2. US NRC Electronic Mail Request to Andrea Sterdis (HDI) Request for Additional Information Related to Request for Approval of Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan, April 8, 2021 (ML21099A038, ML21099A044)
: 3. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, License Amendment Request to Approve the Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan, February 23, 2021 (ML21054A321)
HDI-PIL-21-057 Page 11 of 11

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-057 Attachment 2 Updated (clean) pages of the PNPS Independent Fuel Storage Installation Only Emergency Plan (IOEP) and PNPS ISFSI Only Emergency Actions Levels and Technical Bases (IOEAL)
(7 pages follow)

Procedure Number: Revision:
DPP-PIL-EP-001          0 ISFSI Only Emergency Plan                 Use Category:
Reference Use    Page 10 of 45 3.1.11 Emergency Plan Implementing Procedure (EPIP)
Specific procedures describing actions taken by plant staff to activate and implement the IOEP.
3.1.12 Emergency Response Facility (ERF)
The ISFSI Security Supervisors Office is the facility containing the communications equipment necessary for emergency conditions. It is operated under the direction of the Emergency Director and serves as the primary location for classification of the emergency, notification of the emergency to offsite agencies, assessment actions, and emergency action direction.
3.1.13 Emergency Response Organization (ERO)
Organization comprised of assigned individuals who would respond and assist during a classified emergency.
3.1.14 Fire Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.
3.1.15 Frequency That unit of time specified (monthly, quarterly, etc.) plus or minus 25 percent, unless otherwise specifically stated. This definition does not apply to "Annual" when it is related to the conduct of the Biennial Exercise. Biennial Exercises are performed within the calendar year.
3.1.16 Hostile Action An act toward the ISFSI or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the ISFSl. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the Owner Controlled Area).
3.1.17 Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

Procedure Number: Revision:
DPP-PIL-EP-001          0 ISFSI Only Emergency Plan                Use Category:
Reference Use    Page 19 of 45
* Suspending security measures 6.1.2 Security Security is maintained in accordance with the ISFSI Physical Security Plan.
Security performs accountability as directed by the ISS or Emergency Director.
6.2   Augmented ERO Positions PNPS maintains the necessary personnel and resources to support the PNPS ISFSI Emergency Director in responding to an emergency.
In addition to the resources listed below, additional personnel resources may be directed to report to the PNPS ISFSI by the Emergency Director to provide additional support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from PNPS staff and can be requested from various contractors.
6.2.1 Resource Manager The Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration. The Resource Manager will augment the Emergency Director by assisting in the assessment of the emergency condition and coordinating any required resources, including serving as the public information interface (until turnover to Corporate Public Affairs occurs). The Resource Manager does not need to physically report to PNPS to perform the assigned responsibilities.
6.2.2 Augmented Responder For a declared emergency involving radiological consequences, a minimum of one person trained in radiological monitoring and assessment will report to the PNPS ISFSI within four (4) hours of the emergency declaration.
6.2.3 Offsite Response Organizations Additional support is available from OROs, as described in Section 5.2 of this Plan.
6.3   Functional Responsibilities Table 6-1 lists the functional responsibilities that fulfill emergency staffing capabilities.
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DPP-PIL-EP-001          0 ISFSI Only Emergency Plan                Use Category:
Reference Use    Page 42 of 45 APPENDIX A EMERGENCY EQUIPMENT, SUPPLIES AND REFERENCE MATERIALS EMERGENCY RESPONSE FACILITY Procedures / Reference Materials
* ISFSI Only Emergency Plan
* ISFSI Only EAL Technical Bases Document
* Emergency Telephone Directory
* EPIPs Equipment
* Portable radiation monitoring instrument
* Portable emergency lighting
* Medical emergency response kit ONSITE LOCATIONS Equipment / Supplies
* Portable radiation and contamination monitoring instruments
* Contamination control supplies
* Decontamination control supplies
* Protective clothing, including respiratory protection
* Dosimeters
* Radiological postings and barricades Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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DPP-PIL-EP-001          0 ISFSI Only Emergency Plan                Use Category:
Reference Use     Page 37 of 45 receive duty-specific training. Additional emergency preparedness training is provided as part of annual access training.
19.1.2 First Aid Personnel First Aid training is provided to personnel assigned on-shift in accordance with site training and qualification plan. Personnel assigned the responsibility of first aid response will be qualified by an accredited nationally recognized organization (e.g.
American Red Cross, American Heart Association, etc.) in First Aid, CPR, or AED for Lay Responders or equivalent.
19.1.3 Radiation Monitoring Personnel Radiation monitoring personnel shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.
* Use of Radiation Protection procedures
* Use of emergency survey equipment
* Communications
* Field Surveys
* Role of dose assessment in an emergency
* Monitoring of radioactive releases
* Protective actions for onsite personnel
* Review of applicable drill and exercise-identified deficiencies 19.1.4 Personnel Badged for Unescorted Access Personnel who are badged for unescorted access receive access training annually. Information pertaining to their safety and the safety of visitors under escort during a classified emergency is included in this training.
Access training shall include the following emergency preparedness topics:
* Basic Emergency Plan and implementing preparedness topics
* Emergency classification levels
* Call out of personnel during an emergency
* Personnel accountability procedures Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

Procedure Number:          Revision:
ISFSI Only Emergency Action                 DPP-PIL-EP-002                   0 Levels (EALs) and Technical               Use Category:
Bases                             Reference Use             Page 14 of 23 ATTACHMENT 1 Table PD-1: Recognition Category "PD" and E Initiating Condition Matrix ALERT                                                     UNUSUAL EVENT Hazards and Other Conditions Affecting Facility Safety PD-HA1     HOSTILE ACTION is occurring or has                PD-HU1     Confirmed SECURITY CONDITION or threat.
occurred.
Hostile Action Emergency Action Level (EAL):                                Emergency Action Level (EAL):
: 1. A HOSTILE ACTION is occurring or has                      1. Notification of a credible security threat directed occurred within the OWNER CONTROLLED                         at the site AREA as reported by the Security Shift OR Supervisor.
: 2. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.
PD-HA3     Other conditions exist which in the judgment      PD-HU3      Other conditions exist which in the judgment of the Emergency Director warrant                             of the Emergency Director warrant declaration of an ALERT.                                      declaration of an UNUSUAL EVENT.
Emergency Director Judgment Emergency Action Level (EAL):                                Emergency Action Level (EAL):
Other conditions exist which, in the judgment of the         Other conditions exist which in the judgment of the Emergency Director, indicate that events are in              Emergency Director indicate that events are in progress progress or have occurred which involve an actual or         or have occurred which indicate a potential degradation potential substantial degradation of the level of safety     of the level of safety of the facility or indicate a security of the facility or a security event that involves probable   threat to facility protection has been initiated. No life-threatening risk to site personnel or damage to site    releases of radioactive material requiring offsite equipment because of HOSTILE ACTION. Any                     response or monitoring are expected unless further releases are expected to be limited to small fractions of    degradation of equipment required for spent fuel cooling the EPA Protective Action Guideline exposure levels.         occurs.
Emergency Director Judgment Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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ISFSI Only Emergency Action                DPP-PIL-EP-002          0 Levels (EALs) and Technical              Use Category:
Bases                          Reference Use    Page 18 of 23 ATTACHMENT 2 - EAL BASIS PD-HA1 Initiating Condition:
HOSTILE ACTION is occurring or has occurred.
Emergency Action Level (EAL):
: 1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor.
Basis:
This IC addresses the notification of an aircraft attack threat or an occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the facility and staff for a potential aircraft impact.
Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
As time and conditions allow, these events require a heightened state of readiness by the facility staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The ALERT declaration will also heighten the awareness of Offsite Response Organizations (ORO), allowing them to be better prepared should it be necessary to consider further actions.
This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR &sect; 73.71 or 10 CFR &sect; 50.72.
EAL #1 Basis This EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the facility PROTECTED AREA.
Basis Reference(s):
: 1.       NEI 99-01 Rev 6, PD-HA1
: 2.       Station Security Plan Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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ISFSI Only Emergency Action               DPP-PIL-EP-002          0 Levels (EALs) and Technical             Use Category:
Bases                          Reference Use    Page 11 of 23 Emergency Classification Level (ECL): Refer to Section 3.1.
Initiating Condition (IC): Refer to Section 3.2.
HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) or its personnel that includes the use of violent force to destroy equipment, take Hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force.
Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).
HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
Imminent: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.
OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business.
PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.
SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.
VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.
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