ML20283A292

Physical Security Plan Revision and License Amendment Request to Incorporate Alternate Measures

ML20283A292
Person / Time
Site:	Pilgrim
Issue date:	10/05/2020
From:	Sterdis A Holtec Decommissioning International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML20283A292 (17)

Text

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SAFEGUARDS INFORM ATION

HOLT EC

• Krishna P. Singh Technqlogy Campus, 1 Holtec Blvd., Camden, NJ 08104 DECOMMISSiO NING Telephone (856) 797-:0900.

INTERNATIO NAi.. Fax (856) 797-0909 10 CFR 50.90 10 CFR 50.54(p)

October 05, 2020 ATTN: Document Control Desk

. U.S. Nuclear Regulatory Commission Two White Flint North

_1_ 154_5J~ockville Pike Rockville, MD 20852-2738 Pilgrim Nuclear Power Station Renewed Facility License. No. DPR-35 NRC Docket Nos. 50-293 and 72-1044

Subject:

Physical Security Plan Revision and License Amendment Request to Incorporate Alternate Measures *

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," November 16, 2018 (ML18320A040)

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

[3] NRC Interim Staff Guidance, NSIR/DSP-ISG-03, "Review of Security Exemptions/L icense Amendment Requests for Decommissioning Nuclear Power Plants," September 28, 2015 (ML15106A737)

[4] Letter from Holtec Decommissioning International, LLC to U.S. Nuclear Regulatory Commission - Pilgrim Physical Security, Training &

Qualification, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation II Plan, Revision 19A to Support NRC Review of the Physical Security Plan Revision and License Amendment Request Incorporating Additional Independent Spent Fuel Storage Installation dated July 22, 2020.

Pursuant to the provisions of 10 Code of Federal Regulations (CFR) 50.90, 10 CFR 50.54(p),

10 CFR 73.55(r), and 10 CFR 50.4, Holtec Decommissioning International, LLC (HDI) hereby NOTE: THE ENCLOSURES TO TIDS LETTER CONTAIN "SAFEGUARD S INFORMATION', AND "SECURITY RELATED INFORMATION '. THE ENCLOSURES AND ATTACHMENTS MUST BE PROTECTED ACCORDINGL Y. UPON REMOVAL OF THE ENCLOSURES, THIS LETTER IS DECONTROLL ED."

HDI-PIL-20-076 Page 1 of4 Sob/

SAFEGUARDS INFORM ATION NHss z~

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SAFEGUARDS INFORMATION HO LTE C Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 oecoM Missio NING Telephone (856) 797-0900 I NT ERNA TIO NA L Fax (856) 797-0909 1---- ---t-c :qtJe S men pe ammg to the Pilgrim Nuclear Power Station (PNPS) .

Physical Security, Training & Qualification and Safeguards Contingency Plan (PSP) and a proposed revision to License Condition 3.G, Physical Protection.

The proposed changes reflected in the enclosed Pilgrim Physical Securit y Plan (PSP) introdu ce an alternative measure with regards to the physical protection of Spent Nuclear Fuel (SNF), from radiologici:1I sabotage and/or theft. Specifically, the propos al is a change in the defens iv~ ~tr-_at~gy.3he changes would implement a Nuclear Regula tory-commission (NRCf approv ed alternative measure as allowed by 10 CFR 73.55 (r} "Altern ative Measures".

Specifically, the proposal is a change in the defensive strategy. The change would implem ent a Nuclear Regulatory Commission (NRC) approved alterna tive measure as allowed by 10 CFR 73.55 (r} "Alternative Measures". This License Amend ment Request (LAR) will show that the process and measures utilized for the protection against radiological sabota ge and/or theft of SNF with regards to the Pilgrim Nuclear Power Station (PNPS)

• Protected Area (P/A), meet the same performance objectives and require ments as specified in 10 CFR 73.55. .

a The proposed changes are appropriate for facility that is performing the "DEGON" method of decommissioning and is within the descriptions provided by the Post-S hutdown Decommissioning Activities Report submitted to the NRC on November 16, 2018 (Reference

1) and is aligned with the revised schedule provided in the HDI Annual Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storag e Installations submitted to the NRC on March 31, 2020 (Reference 2).

The proposed PSP is consistent with the guidance provided by NRC Staff in NSIR/DSPISG-03, "Revie w of Security Exemptions/License Amendment Requests for Decommissioning Nuclea r Power Plants" (Reference 3).

Pursua nt to 10 CFR 50.91(a)(1), HDI has performed an evaluation and determined that the proposed amendment presents no significant hazards consideration under the standards set*

forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazard s consideration" is justified. Furthermore, HDI has evaluated this proposed license amend ment against the criteria for identification of licensing and regulatory actions requiring environ mental assess ment in accordance with 10 CFR 51.21 and has concluded, pursua nt to 10 CFR 51.22(b), that no environmental impact statement or environment assess ment need be prepared in connection with the proposed amendment.

Attach ment 1 to this letter provides a summary and an evaluation of the proposed PSP which is based on Revision 19A (currently in the NRC approval process). Attachm ent 1 includes NOTE: THE ENCLOSURES TO TIIIS LETTER CONTAIN "SAFEGUARDS INFORM ATION' , AND "SECUR ITY RELATED INFORMATION'. THE ENCLOSURES AND ATTAC HMENTS MUST BE PROTE CTED ACCORDINGLY. UPON REMOV AL OF THE ENCLOSURES, TIDS LETTER IS DECON TROLL ED."

HDI-PIL-20-076 Page2 of4 SAFEGUARDS INFO RMA TIO N

SAFEGUARDS INFO RMA TION HOL TEC Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 DECOMM ISSIONI NG Telephone (856) 797-0900 INTERN ATION AL Fax(856 )797-090 9 1-------- =e---fle --->>'ign 1f1Cafr t-hazar ds-cons 1 era I0n etermination and environm ental review conclusion.

Attachment 2 to this letter provides a markup of the current PNPS Rene~e d Facility License to reflect changes to License Condition 3.G, -Physical Protection. Attachment 3 to this letter provides the retyped (clean} page of the proposed license condition change.

- Enclosure 1 to this submittal contains attachments that are "Safeguards Informat ion" and "Security Related Information" and must be protected accordingly. Disclosure of Safeguards Inf<>rmatio_n i~ prohibited by Section-147 of the AtomicE nergyA ction of 1954 as amended.

Security Related Information is to be withheld from public disclosure pursuant to 10 CFR 2.390. Enclosure 1 provides a description and evaluation of the proposed PSP revision, including a description of programmatic assumptions applied to the development of the proposed PSP based on 10 CFR 72.212(b}(9}. Enclosure 1 also includes a summar y of the alternative measure requested pursuant to 10 CFR 73.55(r}, descriptions of key design features of the proposed PSP, and a list of Orders applicable to the PSP with cross references to relevant PSP sections.*

Enclosure 2 contains "Safeguards Information" and must be protected accordingly.

This enclosure provides the Pilgrim Physical Security, Training & Qualification, Safegua rds Contingency Plan, and Independent Spent Fuel Storage Installation II Plan," Revision 20.

This is a revised version of the PSP that was submitted via Reference 4.

Enclosure 3 is a compact disk (CD} that provides an electronic copy of the above referenced documents. As such, the CD contains "Safeguards Information" and must be protecte d

accordingly.

HDI requests approval of the proposed license amendm entby March 31, 2021. Once approved, the amendment will be implemented within 30 days.

Pursuant to 10 CFR 50.91, "Notice for public comment; State consultation," paragra ph (b}, a non-safeguards copy of this submittal is being provided to the Commonwealth of Massachusetts, Emergency Management 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.

NOTE: THE ENCLOS URES TO TIIIS LETTER CONTAI N "SAFEGU ARDS INFORM ATION', AND "SECUR ITY RELATE D INFORM ATION'. THE ENCLOSURES AND ATTACH MENTS MUST BE PROTEC TED ACCORD INGLY. UPON REMOVA L OF THE ENCLOS URES, TIIIS LETTER IS DECONT ROLLED ."

HDI-PIL-20-076 Page3 of4

_SAFEGUARDS INFO RMA TION

SAFEGUARDS INFOR MATIO N HOLT EC Krishna P. Singh Technology Campus, 1 Holtec Blvd.; Camden, NJ 08104 DECOMMIS SIONING Telephone (856) 797-0900 INTERNA TIONAL Fax (856) 797-0909 1-----'----- --t---eeela r-e--ttnder the pe11alty-uf perJury that the forgoing is true and correct.

Executed on October 05, 2020.

Sincerely,

~ olgned A nd rea L * . ~~~=.:t':.';;Sterdls,c=US, by Andrea L stenf,s

• Decomrnlsslonlng titemallonal, SterdIS =~~~~I~~;

Andrea L. Sterdis HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC Attachments 1 . Summary and Evaluation of Proposed Changes (uncontrolled)

2. Proposed Change to PNPS Renewed Facility License Condition 3.G (mark-up) -

(uricontrolled) _

3. Revised PNPS Renewed Facility Operating License Condition 3.G (clean copy)-

(uncontrolled)

Enclosures

1. Description of PNPS Physical Security Plan Changes - (Safeguards Information)

2.

• Pilgrim Physical Security, Training & Qualification, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation II Physical Security Plan, Revision 20 (Safeguards Information)

3. Compact Disk, Containing Enclosures 1,2, and 3 (Safeguards Information) cc: (without Enclosures 1, 2, and 3)

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

Director, Massachusetts Emergency Management Agency NOTE: THE ENCLOSUR ES TO TIIlS LETTER CONTAIN "SAFEGUAR PS INFORMAT ION', AND "SECURITY RELATED INFORMAT ION'. THE ENCLOSURES AND ATTACHME NTS MUST BE PROTECTE D ACCORDINGLY. UPON REMOVAL OF THE ENCLOSURES, TIIlS LETTER IS DECONTRO LLED."

HDI-PIL-20-076 Page4 of4 SAFEGUARDS INFOR MATIO N

HOLTE C Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 DECOMMISSIO NING iNTERNATIO NAl- Fax (856)797-0909 Attachment 1 to HDI Letter HDI-PIL-20-076 Summary and Evaluation of Proposed Changes (8 pages including ~over page)

Attachment 1 to IIDI-PIL~20-076 Page 1 of7

HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Summary and Evaluation of Pro osed Chan Telephone (856) 797-0900 Fax (856) 797-0909 e!S___ _ _~ - - - - - - - - - - - - - - - - - - - c -

1.0 Summary of Proposed Changes This proposed change to the Pilgrim Nuclear Station (PNPS) Physical Security Plan (PSP) reflects the introduction of an alternative measure with regards to the physical protection of Spent Nuclear Fuel (SNF), from radiological sabotage and/or theft. Specifically, the proposal is a change in the defensive strategy. The change would implement a Nuclear Reguiatory Commission (NRC) approved alternative m~~~ure as allowed by 10 CFR 7'3.55(r)-"Alternative-

-Measures": Thislicense Amendment Request (LAR) will show that the process and measures utilized for the protection against radiological sabotage and/or theft of SNF with regards to the PNPS Protected Area (P/A), meet the same performance objectives and requirements as specified in 10 CFR 73.55.

The proposed PSP was developed to meet regulatory requirements for protection of the spent fuel against the design basis threat of radiological sabotage. The* proposed PSP is designed to meet the physical protection requirements for protection of spent fuel stored in the Spent Fuel

• Pool (SFP), and the existing Independent Spent Fuel Storage Installation (ISFSI) storage pad, as well as in the new ISFSI II storage pad .

. This proposed PSP requires prior NRC approval PSP LAR (Reference 1) submitted on April 2, 2020 which added the security protection requirements applicable to the new PNPS ISFSI II

. storage area._

The proposed PSP is consistent with NRC guidance provided in Nuclear Security Incident Response/Division of Security Policy - Interim Staff Guidance (NSIR/DSP.:.ISG)-03, "Review of Security Exemptions/License Amendment Requests for Decommissioning Nuclear Power

.Plants," (Reference 2).

The proposed PSP addresses Orders previously issued by the NRC which are applicable to the current Pilgrim PSP.

2.0 Applicable Regulatory Requirements Pursuant to 10 Code of Federal Regulations (CFR) 50.54(p) and 10 CFR 50.90, Holtec Decommissioning International, LLC (HDI) is requesting approval of proposed Pilgrim 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 PSP is required to protect spent fuel against the design basis threat of radiological sabotage in accordance with the same provisions setforth in the physical security requirements of 10 CFR 73.55 with certain conditions and exceptions as specified in the regulation. This submittal includes requests for alternative measures pursuant to 10 CFR 73.55(r), 10 CFR 50.90 and 10 CFR 50.54 that support the proposed PSP revision.

3.0 No Significant Hazards Consideration Determination The proposed PSP revision addresses the physical protection of material on site that is licensed under the PNPS Renewed Facility License, as well as the general license for the PNPS ISFSI.

Attachment 1 to HDI-PIL-20-076 Page2 of7

HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 PNPS has submitted the certifications~or 1o GER 50 82(a)(1 ), (RefereRre-3t-ther-efor-e-t-he 10 1-------.CF R Part 50 license for PNPS no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, pu~uant to 10 CFR 50.82(a)(2).

The proposed amendment incorporates an alternative measure per 10 CFR 73.55(r),

"Alternative Measures" as the regulatory basis for the proposed change. The* modifications associated with this proposed amendment include removal of three buildings on site fo allow for better line of site and interdiction of adversaries, minor modifications to the interior of buildings to-strengthen fighting positions; and enhancing existirrg security' intruder deforrenffeatures .

around the site. HDI has evaluated the proposed amendment to determine if a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Response: No PNPS has submitted notifications pursuant to 10 CFR 50.82(a)(1) for permanent cessation of power reactor operations and permanent removal of fuel from the reactor vessel. Upon docketing of the 10 CFR 50.82(a)(1) certifications, under 10 CFR 50.82(a)(2) the PNPS Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. The irradiated fuel at PNPS is currently stored in the SFP and within the ISFSI on a single pad.

In this condition, the number of credible accidents or transients is significantly smaller than for a plant authorized to operate the reactor or emplace or retain fuel in the reactor vessel.

Construction of the second ISFSI pad is in progress and scheduled for completion in the fourth quarter 2020 to allow for complete off-load of the SFP to dry storage in casks within the new ISFSI II storage pad.

The proposed amendment would have no significant effect on facility SSCs and no significant effect on the capability of facility SSCs to perform their design functions .for any accident previously evaluated, it does not significantly increase the likelihood of the malfunction of facility SSCs and does not increase the probability or consequenc~s of an accident previously evaluated.

The casks are maintained in ~ccorqance with the provisions of the general license for the PNPS ISFSI, utilizing 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 with.in a sealed metallic canister, or Multi-Purpose Canister (MPC).}"heHI-ST ORM 100 receives and contains the sealed MPC for long term storage, and provides gamma and neutron shielding, ventilation passages, missile protection, and protection against natural phenomena and accidents for the MPG. Cask FSAR Chapter 11, "Accident Analysis",

Attachment 1 to HDI-PIL-20-076 Page 3 of7

HOLT EC DECOMMISS IONING INTERNAT IONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Section 11.2 provides the evaluation oiaccident s for::t~~ 8-Gask -Systei 11 w Ic satisfies the following minim1.,1m acceptance criteria: *

• The MPG confinement boundary maintains radioactive material confinement,

• The MPG fuel basket structure maintains the fuel contents subcritical,

• The stored SNF can be retrieved by normal means, and

• The system provides adequate shielding. _ _

The Hl~STORM 100 Cask Sy;te~ p~ovid~; the spent nu~lear fuel and radioactive material in storage with confinement, radiation shielding, criticality and passive heat removal, independe nt of other facility SSCs.

• The modifications associated with this proposed amendmen t include removal of three buildings on site to allow for better line of sight and interdiction of adversaries, minor modifications to the interior of buildings to strengthen fighting positions, and enhancing existing security intruder deterrent features around the site. The proposed security modifications do not significantly affect the ability of the Cask System and MPG 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 acciden(pr eviously evaluated

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated Response: No The proposed amendmen t does not involve any physical alteration of any facility SSCs or Cask System componen ts required to mitigate or prevent any accident previously evaluated, and does not have a significant effect on the capability of any facility SSC or Cask System componen t to perform its design functions.

Thus, the proposed amendmen t 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

• malfunction or personnel errors that could result in a new or different kind of accident.

Since the proposed amendmen t does not significantly affect any Cask System components; the credible events for the ISFSI are not changed.

Therefore, the proposed amendmen t does not create the possibility of a new or different kind of accident from any previously evaluated.

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 retention of fuel into the reactor vessel, therefore the occurrence of any postulated accidents associated with an operating nuclear reactor is no longer credible. *

• Attachment 1 to HDI-PIL-20-076 Page4of7

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ oa1*04

HOLTEC Telephone (856) 797-0900 PECOMMl551C>NiNG Fax(856)797-0909 INTERNATIONAi-After all fuel is removed from the ool and saiely stored in dry casks-u:a-eittler:-tSJ;Sr-1'.p};:aH'ld1------

ocatIon, a postulated fuel handling accident is no longer credible in this configuration~

The proposed amendment does not involve a significant change in any facility SSC or Cask System component's design, configuration, or operation. Therefore, the modifications associated with this proposed amendment do not significantly affect the capability or manner in which facility SSCs or Cask System components perform their s*afety functions, or the safety margins associated with their design and function.

Therefore, the proposed amendment does noJ_involve a_significant reduction in a margin-of

- *safety: *- - * - - -- --- ----- -- ~ --- *. _ -

• 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 the criteria for categorical exclusion set forth in 10 CFR ,

51.22(c)(12). The proposed amendment is being submitt~d under the provisions of 10 CFR Part 50 for approval of a safeguards plan and changes to the PNPS Renewed Facility License, and in accordance with 10 CFR Part 72.

Activities associated with the proposed amendment do not involve any significant construction impacts, and are consistent with the plan for future reduction in the security area that focuses primarily on the storage for spent fuel,- described in NUREG-0586, "Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," as a general activity expected to occur during decommissioning. The proposed amendment is confined to (i) organizational and procedural matters; (ii) modifications to systems used for security; and (iii) administrative changes. The proposed amendment also addresses security organizational changes and describes procedural and other administrative changes.

• 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 None 6.0 Conclusion 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 proposed changes, (2) activities consistent with the approved changes will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 References

1. Letter from Holtec Decommissioning International, LLC to U.S. Nuclear Regulatory Commission - "Physical Security Plan Revision and License Amendment Request to Incorporate Additional Independent Spent Fuel Storage Installation," dated April 2, 2020.

(ML20136A038)

Attachment 1 to HDI-PIL-20-076 Page 5 of7

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104

HOLTEC Telephone (856) 797-0900 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL

2. NRC Interim Staff Guidance NS ;empt...,*, n < : , , r - - - - - - - - - - - - i Icense Amendment Requests for Decommissioning Nuclear Power Plants," September 28, 2015 (ML15106A737)

3. . Letter, Entergy Nuclear. Operations,.lnc. to USNRC, "Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel,"

dated June 10, 2019, (Accession No. ML 1961A033).

4. NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning ci _

~Nuclear i=acilities,"~Volumes--1 & 2-of-Supplement-1,-Novembet 200Z{M[023470327ancf - -

ML023500310)

5. NRC Regulatory Guide 5.69, "Guidance for. the Application of the Radiological Sabotage Design-Basis Threat in the Design, Development, and Implementation of a Physical Security Program that Meets 10 CFR 73.55 Requirements" .

8.0 Tables Table -1 PNPS Physical Security Plan (PSP), Revision 20, 10 CRF 73.55(r) Change Matrix Attachment 1 to HDI-PIL-20-076 Page 6 of7

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104

HOLTEC Telephone (856) 797-0900 DECOMMISSIONING Fax(856)797-0909 iNTERNATIONAl-Table 1 PNPS Physical Security Plan (PSP), Revision 20, 10 CRF 73.SS(r) Change Matrix PSP Section Section Title Details Section Protection Against a Vehicle Updated verbiage to be in line with the 11.2.2 Bomb of . . . current shutdown and defueled condition.

__ Section __ _ _Waterbome-ThreatMeasures- - - lJpdated verbiage to-be in line with the 11.2.3 current shutdown and defueled condition.

Chapter 18 Response Requirements Modified the committed number of Armed Responders and Armed Officers.

Figure 25.1 Facility Layout Updated to reflect removal of structures and addition of security barriers.

Appendix A Glossary of Terms and NO CHANGES Acronyms Appendix B Training and Qualification Plan NO CHANGES Appendix C PNPS Safeguards Contingency N/A Chapter 7 Plan Protective Strategy Section 7.1 Defense in Depth Strategy Updated verbiage to be in line with the current shutdown and defueled condition with regards to Target Sets.

Section 7.2 Outer Defense - Vehicle Barrier Updated verbiage to be in line with the System (VBS) and OCA Land- current shutdown and defueled condition based Assault with regards to additional access/egress point through barrier system Appendix D PNPS Independent Spent Fuel NO CHANGES*

Storage Installation II (ISFSI II)

Attachment 1 to HDI-PIL-20-076 Page7 of7

HOLTEC Krishna P. Sing'1 Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 DECOMMISSIONING INTERNATIONAi..

Fax(856)797-0909

.Attachment 2 to .

HDI-PIL-20"'."076 Proposed Change to PNPS Renewed Facility License Condition 3.G (mark-up)

(2 pages including cover page)

Attachment 2 to HDI-PIL-20-076 Page 1 of2

HOLT EC DECOMMISSIO NING INTERNATIO NAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Existing License Condition 3.G (first paragraph) (mark-up)

G. Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions ofthe Miscellaneous Amendments and * *

• Search Requirements revisions-to-10-CFR 73;55 (51 FR 27817 and27822), ana the aufhority-of-10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Pilgrim Nuclear Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision O," submitted by letter dated October 18, 2004, as supplemented by letter dated May 16, 20 October 05, 2020 Attachment 2 to HDI-PIL-20-076 Page2 of2

_____K_ris_h_n_a_P_._S_in_g_h_T_ec_h_n_ol_og_y_C_a_m_p_u_s_,_1_H_o_lre_c_B_lv_d_.,_C_a_m_d_e_n,_N_J_0_8_1_0_4 HOLTE C Telephone (856) 797-0900 DECOMMISSION ING INTERNATIO N,H Fax (856) 797-09()9 Attachmen t 3 to HDI-PIL..20-076-Revised PNPS Renewed Facility Operating License Condition 3.G (clean copy)

(2 pages including cover page) to HDI-PIL-20-076 Page 1 of2

---

K_ris_h_n_a_P_._S_in_gh_T_ec_h_n_ol_o_gy_C_am_pu_s_,_1_H_o_lte_c_B_lv_d_.,_C_a_m_d_e_n_,N_J_08_1_0_4 HOLTE C Telephone (856) 797-0900 P~COMMl!iSIONiNG INHRNATIONAL Fax (856) 797-0909 Revised License Condition 3.G (first paragraph) (Clean Copy)

G. Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments mad_e P!JrS_Uant to__10_CFR]2.21 2(b){9)and to-the-authority of 10CFR -50.90-ana 10 Ci=-R 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 7321, is entitled: "Pilgrim Nuclear Power Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Pilgrim ISFSI II Physical Security Plan, Revision 20;" supplemented by letter dated October 05, 2020. to HDI-PIL-20-076 Page2 of2

• SAFEGUARDS INFORMATION Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 HOLT E C - - - - - - ---------------

o~coMM,ss1 0NiN(;

INT~RNhTI ONAL Telephone (856) 797-0900 Fax (856) 797-0909 Enclosure 1 to HDI Letter J

HDI-PIL-20-0 76 Description of PNPS Physical Security Plan Changes (33 pages including Cover Sheet)

NOTE: ATTACHMENTS 1,2,3 and 7 TO THI~ ENCLOSURE CON)"AIN "SAFEGUARDS INFORMATION' AND MUST BE MUST BE PROTECTED ACCORDINGLY. ATTACHMENTS 4, 5, and 6 CONTAIN SECURITY RELATED INFORMATION AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THESE ATTACHMENTS THIS ENCLOSURE BECOMES DECONTROLLED.

Enclosure 1 to HDI~PIL-20-076 P~ge 1 of33

• sAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 HOLTE C - - - - - - - - - - - - ' - - - - --C...----------

oecoMM1ss10N1Nc; Telephone (856) 797-0900 INT~RNATIONA~

• *** **** *-

• Fax (856) 797-0909 Description Page No.

Purpose of Requested License Amendment.. .................................... .......................... 3 Executive Summary ................................................................................................................. 5 Description and Evaluation of Proposed Changes .............................................. :....... ~ ........... 8 1.0 Summary Description

-- 2;0-Detailed*DescriptiO"n and-Basis for fhe-Cha-nges 2.1 Proposed Changes to the Pilgrim Physical Security Plan 2.2 Programmatic Assumptions Used for Alternative Measure

1. Defense in Depth

a. Design Basis Threat

b. Target Set(s)

c. Defensive Strategy

2. Evaluation Date

3. Training

4. Equipment

5. Modifications Design and Implementation 2.3 Alternative Measures Proposed for the Pilgrim Physical Security Plan 2.4 Summary Evaluation of Proposed Alternative Measures 2.5 Applicable Orders for Pilgrim Nuclear power Station 2.6 Actions To Be Completed Prior to Implementation of Revision 20 3.0 References Attachments to Enclosure 1 .................................... .................................... ........ 33 Attachment 1: Target Set(s) (SGI}

Attachment 2: Blast Calculations (SGI}

Attachment 3: Pilgrim 360 - Defensive Strategy Evaluation and Data (SGI}

Attachment 4: Lesson Plan and Training Needs Analysis (SRI)

Attachment 5: 10 CFR 73.55 - Compliance Matrix (SRI}

Attachment 6: 10 CFR 73 Appendix C - Compliance Matrix (SRI)

Attachment 7: NRC Order EA-13-132, Compliance Matrix (SGI)

NOTE: ATTACHMENTS 1,2,3 and 7 TO THIS ENCLOSURE CONTAIN "SAFEGUARDS INFORMATION' AND MUST BE MUST BE PROTECTED ACCORDINGLY. ATTACHMENTS 4, 5, and 6 CONTAIN SECURITY RELATED INFORMATION AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THESE ATTACHMENTS THIS ENCLOSURE BECOMES UNCONTROLLED.

Enclosure 1 to HDI-PIL-20-076 Page2 of33 SAFEGUARDS INFORMATION