ML20335A009

NRC Inspection Report No. 05000293/2020002 & 2020003, Holtec Decommissioning International, LLC, Pilgrim Nuclear Power Station, Plymouth, Massachusetts

ML20335A009
Person / Time
Site:	Pilgrim
Issue date:	11/30/2020
From:	Anthony Dimitriadis Decommissioning Branch I
To:	Cowan P Holtec Decommissioning International
References
IR 2020002, IR 2020003
Download: ML20335A009 (16)

See also: IR 05000293/2020002

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BOULEVARD, SUITE 100

KING OF PRUSSIA, PA 19406-2713

November 30 , 2020

Pamela B. Cowan

Sr. Vice President and COO

Holtec Decommissioning International, LLC

Krishna P. Singh Campus

1 Holtec Blvd.

Camden, NJ 08104

SUBJECT: NRC INSPECTION REPORT NO. 05000293/2020002 & 2020003, HOLTEC

DECOMMISSIONING INTERNATIONAL, LLC, PILGRIM NUCLEAR POWER

STATION, PLYMOUTH, MASSACHUSETTS

Dear Ms. Cowan:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a period of

onsite and remote inspections under Inspection Manual Chapter 2561, Decommissioning

Power Reactor Inspection Program," at the permanently shutdown Pilgrim Nuclear Power

Station (PNPS). Onsite inspections were performed on July 13 - 16 and August 17 - 20, 2020.

Additional inspection activities (in office reviews via remote means) were conducted throughout

the period as a consequence of the COVID-19 public health emergency (PHE). The inspectors

examined activities conducted under your license as they relate to safety and compliance with

the Commission's rules and regulations and the conditions of your license. The inspection

consisted of observations by the inspectors, interviews with site personnel, and a review of

procedures and records. The results of the inspection were discussed with Mr. John Moylan,

Site Vice President and other members of the PNPS staff on November 9, 2020, and are

described in the enclosed report. No findings of safety significance were identified.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its

enclosure, and your response, if any, will be made available electronically for public inspection

in the NRC Public Document Room or from the NRC document system (ADAMS), accessible

from the NRC Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible,

your response should not include any personal privacy, proprietary, or safeguards information

so that it can be made available to the Public without redaction.

Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov;

select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations,

Guidance and Communications. The current Enforcement Policy is included on the NRC's

Website at www.nrc.gov; select About NRC, Organizations & Functions; Office of

Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related

Information'). You may also obtain these documents by contacting the Government Printing

Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST,

Monday through Friday (except Federal holidays).

P. Cowan 2

No reply to this letter is required. Please contact Harold (Harry) Anagnostopoulos at 610-337-

5322 if you have any questions regarding this matter.

Sincerely,

/RA/

Anthony Dimitriadis, Chief

Decommissioning, ISFSI, and Reactor Health

Physics Branch

Division of Nuclear Materials Safety

Docket No. 05000293

License No. DPR-35

Enclosure: Inspection Report 05000293/2020002 & 2020003

w/Attachment

cc w/encl: Distribution via ListServ

P. Cowan 3

NRC INSPECTION REPORT NO. 05000293/2020002 & 2020003, HOLTEC

DECOMMISSIONING INTERNATIONAL, LLC, PILGRIM NUCLEAR POWER STATION,

PLYMOUTH, MASSACHUSETTS DATED NOVEMBER 30, 2020

DOCUMENT NAME: G:\DNMS\WordDocs\Current\Insp Letter\Pilgrim 2020002 22 Nov 2020

rev3.docx

SUNSI Review Complete: HAnagnostopoulos

After declaring this document AAn Official Agency Record it will be released to the Public.

To receive a copy of this document, indicate in the box: C = Copy w/o attach/encl = Copy w/

attach/encl N = No copy ML20335A009

OFFICE DNMS/RI DNMS/RI

NAME HAnagnostopoulos/HA ADimitriadis/ad

DATE 11/23/2020 11/30/2020

OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

INSPECTION REPORT

Inspection No. 05000293/2020002 & 2020003

Docket No. 05000293

License No. DPR-35

Licensee: Holtec Decommissioning International, LLC (HDI)

Facility: Pilgrim Nuclear Power Station (PNPS)

Location: Plymouth, MA 02360

Inspection Dates: April 21, 2020 - September 30, 2020

Inspectors: Harold Anagnostopoulos, Senior Health Physicist

Decommissioning, ISFSI, and Reactor Health Physics Branch

Division of Nuclear Materials Safety, Region I

Orysia Masnyk Bailey, Health Physicist

Decommissioning, ISFSI and Reactor Health Physics Branch

Division of Nuclear Materials Safety, Region I

Earl Love, Storage and Transportation Inspector

Inspection and Oversight Branch

Office of Nuclear Material Safety, NRC Headquarters

Eugene DiPaolo, Senior Reactor Inspector

Engineering Branch 2

Division of Reactor Safety, Region I

Approved By: Anthony Dimitriadis, Chief

Decommissioning, ISFSI, and Reactor Health Physics Branch

Division of Nuclear Materials Safety, Region I

EXECUTIVE SUMMARY

Holtec Decommissioning International, LLC (HDI)

Pilgrim Nuclear Power Station (PNPS)

NRC Inspection Report No. 05000293/2020002 & 2020003

A period of announced decommissioning inspections was completed on September 30, 2020.

Onsite inspections were performed on July 13 - 16 and August 17 - 20, 2020. Remote

inspection activities were conducted throughout the period as a consequence of the COVID-19

public health emergency (PHE). The inspections included a review of the fire protection

program, inspection of dry fuel storage efforts, organization and management, safety reviews &

design changes, self-assessments, audits, corrective actions, spent fuel pool safety,

decommissioning performance and status, maintenance and surveillance, and occupational

radiation exposure. The inspections consisted of observations by the inspectors, interviews with

PNPS personnel, a review of procedures and records, and plant walkdowns. The NRC's

program for overseeing the safe operation of a shutdown nuclear power reactor is described in

Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program."

Based on the results of this inspection, no findings of safety significance were identified.

ii

REPORT DETAILS

1.0 Background

June 10, 2019, Entergy Nuclear Operations, Inc. (ENOI) certified cessation of power

operations and the permanent removal of fuel from the PNPS reactor vessel (ADAMS

Accession Number: ML19161A033). This met the requirements of 10 Code of Federal

Regulations (CFR) 50.82(a)(1)(i) and 50.82(a)(1)(ii). On June 11, 2019, the NRC

notified PNPS that the Operating Reactor Assessment Program would terminate and

that implementation of the Decommissioning Power Reactor Inspection Program would

begin (ADAMS Accession No. ML19162A033). On August 27, 2019 an amended

license was issued transferring the license from ENOI to Holtec International, LLC HDI

(ADAMS Accession No. ML19235A050). PNPS is in active decommissioning with fuel in

the spent fuel pool as described in IMC 2561.

2.0 Decommissioning Fire Protection Program

a. Inspection Scope [Inspection Procedure 64704]

The inspectors performed an inspection of Holtec Decommissioning Internationals

(Holtec) Fire Protection Program (FPP) to determine if the program was sufficiently

implemented and maintained to satisfy the nuclear safety and radioactive release goals,

objectives, and performance criteria. The last performance of Inspection Procedure

71111.05T, Fire Protection (Triennial), at Pilgrim was completed on November 1, 2018.

The results of that inspection were documented in NRC Inspection Report 05000293/2018015 (ADAMS Accession No. ML 18339A084). Except for changes to the

onsite fire brigade and reliance on offsite fire emergency response organization(s) to

respond to an onsite fire, no major changes had been implemented to the Pilgrim Fire

Protection Program since that inspection. Therefore, the inspection was limited to

reviewing the adequacy of the Fire Protection Program with respect to these changes.

Per Regulatory Guide 1.191, Fire Protection Program for Nuclear Power Plants during

Decommissioning and Permanent Shutdown, the licensee of a permanently shut down

nuclear power plant is required by 10 CFR 50.48(f) to maintain a Fire Protection

Program to address the potential for fires that could result in the release or spread of

radioactive materials. The primary focus is protection of the integrity of the spent fuel

and preventing or minimizing the release of radioactive materials resulting from fires

involving contaminated plant systems or radioactive waste. To accomplish the

inspection objectives, the inspectors utilized the guidance provided in Inspection

Procedure 64704 and Regulatory Guide 1.191 and assessed the adequacy of the onsite

incipient fire brigade and reliance on offsite fire emergency response organization(s) to

respond to an onsite fire.

Inspection of the adequacy of the overall Fire Protection Program will be coordinated

when additional substantive changes have been made to support the decommissioning

effort.

b. Observations and Findings

Based on the inspection results, the inspectors concluded that Holtec appropriately

maintained the FPP related to the fire brigade within the NRC requirements of 10 CFR

1

50.48(f) for plants undergoing decommissioning. Holtec maintained the leadership,

staffing, and training of the onsite fire brigade. Agreements were appropriately

established with the Town of Plymouth Fire Department, a fully staffed and professional

fire department, to be the primary responder for onsite fires. Procedures for response

and measures for coordination with offsite responders were appropriately established.

The inspectors verified that Holtec conducted training with offsite responders on facility

layout, fire hazards, fire plans, firefighting equipment, radiological hazards, and health

physics relevant to firefighting operations. The inspectors confirmed that Holtec

maintained applicable onsite firefighting equipment (e.g., fire pumps) and assured

compatibility of the plants fire system connections with fire apparatus and equipment of

the offsite responders.

c. Conclusions

No findings of significance were identified.

3.0 Independent Spent Fuel Storage Installation

3.1 Pre-operational Testing of an ISFSI (IP 60854)

a. Inspection Scope

On May 11-24, 2020, the inspectors performed a remote inspection (via teleconference

and video-feed) of pre-operational dry-run activities that were performed in order to

demonstrate proficiency in the implementation of a licensee procedure associated with

drying multi-purpose canisters (MPC). This is a new procedure that incorporates the

licensees transition from vacuum drying to the use of a Forced Helium Dehydration

System (FHD) for the MPC. This procedure implements Engineering Change Order No.

5014-295 and outlines performance of a reverse flow operation to reduce time required

to meet the requirements of Certificate of Compliance (CoC) 72-1014, Amendment 12.

In this change, the gas stream enters through the MPC drain access port and exits

through the MPC vent access port.

During the dry-run activities, the inspectors observed cask processing activities (via use

of a mock MPC) to determine whether the Pilgrim staff and contractors had appropriately

developed, implemented, and evaluated preoperational testing activities to safely

process an MPC. This included observations of MPC blowdown, FHD, and helium

backfilling.

The inspectors also observed Pilgrim pre-job briefings to assess their ability to identify

critical steps of the evolution, potential failure scenarios, and the use of human

performance tools to prevent errors.

The remote inspection was augmented through in-office review of the licensees 10 CFR

72.212 report, records, and procedures provided for this portion of the inspection.

2

b. Observations and Findings

The inspectors noted that altering the direction of flow while drying the MPC contents did

not affect ability of FHD to reach the CoC required drying or backfill limits.

The inspectors noted the fuel basket of the MPC-68M (versus the previous MPC-68) is

fabricated entirely from sectional Metamic (neutron absorbing material). This, combined

with the use of fuel spacers, ensures that the active fuel region of fuel assemblies

remains within the neutron-poison region of the MPC basket with water in the MPC.

The MPC-68M fuel spacers have square flow holes that are one inch from the bottom of

the basket. The previously-used MPC-68 fuel baskets had arced flow holes cut out of

the bottom of the panels.

During the dry-run with the new MPC-68M, a fuel assembly seating verification fit-up test

was performed by inserting a test (i.e., non-fuel) bundle into five of the MPC fuel

channels. In one of the channels, Pilgrim encountered an interference at the bottom of

fuel channel F-5. Pilgrim temporarily ceased operation and entered the condition into

their corrective action program as PIL-01627. To understand the scope of the issue, all

channels were challenged with a test fuel bundle, and it was found that 30 spacers in the

fuel basket had failed to seat properly. The cause was determined to be a result of the

less ridged neutron-absorbing panels and different flow holes of the MPC-68M.

To complete the dry-run, all MPC-68M fuel channels were re-tested and all fuel spacer

fit-up issues were corrected. Pilgrim fabricated a testing-rod that is now used to verify

that the proper channel length is present prior to loading a fuel bundle into that channel.

c. Conclusions

No findings of significance were identified.

3.2 Operation of an ISFSI at Operating Plants (IP 60855)

a. Inspection Scope

On May 18-15, 2020, the inspectors performed a remote inspection (via teleconference

and video-feed) due to Covid-19 restrictions, to evaluate Pilgrims loading of their first of

eleven MPCs of the 2020 dry fuel storage loading campaign. On July 13-16, 2020, the

inspectors performed an onsite inspection to evaluate the loading of the ninth MPC.

The inspections encompassed fuel transfer operations from the spent fuel pool to dry

storage, using the HI-STORM 100 dry cask storage system.

The inspections included:

• Cask No. 18 (MPC serial number 1021-685), HI-STORM Serial No. 1284, and

• Cask No. 26 (MPC serial number 1021-678), HI-STORM Serial No. 1276

3

The inspectors reviewed several major updates to the dry fuel storage efforts, examined

the HI-STORM 100 certificate of compliance No. 72-1014 (Amendment 12), and final

safety analysis report (FSAR) Revision 17.

The inspectors reviewed Pilgrims program associated with fuel characterization and

selection for dry storage. The inspectors reviewed the first cask fuel selection package

to verify that the licensee was loading fuel in accordance with the CoC, TS, and

procedures. Inspectors reviewed a recording made of the fuel assemblies loaded into

the first MPC to ensure the loading was in accordance with Pilgrims loading plan. The

inspectors observed fuel assemblies being loaded into the MPC.

The inspectors observed transport and submerging of the HI-TRAC/MPC into the spent

fuel pool and onto the cask leveling platform. As part of this review the inspectors

observed radiation protection technicians as they performed surveys, decontamination

work and provided job coverage for the cask loading workers. This assessment included

review of survey data maps and radiological records from the first MPC loading.

The inspectors observed MPC processing activities, including helium backfill, hydrostatic

testing, and helium leak testing of the vent and drain port covers. The inspectors

observed the set-up of remote equipment (i.e., the robotic weld-head), hydrogen gas

purge and monitoring, and MPC lid fit-up and welding. The inspectors observed weld

surface pre-cleaning and drying, dye penetrant application, penetrant removal,

developer application, and final weld assessment.

The inspectors performed a walk-down of the heavy haul path and toured the ISFSI pad

to assess the material condition of the pad and the HI-STORM modules. As part of the

movement of the MPC and HITRAC, the inspectors observed HI-TRAC stack-up,

download of MPC into the overpack, and transport of overpack with the loaded MPC to

ISFSI Pad.

The inspectors also reviewed the licensees planned activities associated with long-term

operation and monitoring of the ISFSI.

The inspectors reviewed corrective action reports and the associated follow-up actions

that were generated during and after Pilgrims dry-run demonstrations to ensure that

issues were entered into the corrective action program, prioritized, and evaluated in a

manner that is commensurate with their safety significance.

b. Observations and Findings

Dry fuel storage campaign activities were determined to be in compliance with the MPC-

68M CoC, TS, regulatory requirements, and station procedures.

The inspectors noted that welding procedure specifications were qualified in accordance

with Holtec welding requirements, and that welders and personnel performing visual

examination/NDE of welds were trained and certified under PCI Energy Services (an

approved Holtec vendor).

The inspectors noted that ISFSI staff maintained doses associated with dry cask

activities as low as reasonably achievable (ALARA). The ionizing radiation exposure for

the first MPC evolution was 1,465 mRem, and this was reduced to 803 mRem for the

4

eighth cask. This reduction was attributed to improvements in operations and

appropriate adjustments as the campaign progressed.

The inspectors also verified that transient combustibles were not being stored on the

ISFSI pad or the vicinity of the HI-STORMS. The inspectors also confirmed that

transient combustible materials entry onto the ISFSI pad was controlled in accordance

with procedures.

c. Conclusions

No findings of significance were identified.

3.3 Review of 10 CFR 72.212(b) Evaluations (IP 60856)

a. Inspection Scope

The inspectors reviewed a Pilgrim 10 CFR 72.212(b) evaluation (Revision 5). This

evaluation allowed the application of changes that were authorized by CoC 1014,

Amendment 12 to a storage module that was previously loaded under the initial CoC

1014, Amendment 7.

The inspectors reviewed Holtecs evaluation of Engineering Change (EC) No. 82162,

Dry Fuel Storage Licensing & Operations that addressed Phase 1 dry fuel storage

(DFS) operations.

b. Observations and Findings

The inspectors verified that Pilgrim was in compliance with CoC 1014, Appendix A,

Technical Specifications, and Appendix B, Approved Contents and Design Features"

are applicable to the PNPS ISFSI. The inspectors also determined that the storage

modules deployed at the PNPS ISFSI complied with all applicable terms, conditions, and

specifications in Amendment 7 and/or 12 of HI-STORM CoC.

The inspectors determined that an appropriate regulatory basis was used for loading and

transporting eleven HI-STORM 100S Version B storage modules, containing MPC-68M

canisters with spent fuel, to the lower ISFSI pad.

Specifically, EC No. 82162 included adequate justification for a number of departures

from prior DFS operations including; use of a new tracked vertical cask transporter,

placement of HI-TRAC with empty MPC directly on rails, and installation/removal of the

HI-STORM lid using a mobile crane. The EC also adequately addressed licensing

requirements.

c. Conclusions

No findings of significance were identified.

5

4.0 Decommissioning Performance and Status Review

a. Inspection Scope [Inspection Procedures 36801, 37801, 40801, 60801, 62801, 71801,

83750]

The inspectors reviewed a sample of licensee commitments and requirements.

The inspectors evaluated the contribution of the onsite safety review committee and the

10 CFR 50.59 safety review process. The inspectors reviewed plant modifications and

plans for any major decommissioning activities.

The inspectors assessed Holtecs ability to identify, resolve, and prevent problems and

deficiencies.

The inspectors also reviewed spent fuel pool instrumentation, alarms, and leakage

detection, and verified that Pilgrims wet spent fuel storage and handling controls were

consistent with regulatory requirements and the applicable safety requirements.

The inspectors evaluated the maintenance and surveillance programs to determine if

they supported the safe storage of spent fuel and the reliable operation of radiation

monitoring and effluent control equipment. The inspectors examined maintenance work

priorities and backlog. The inspectors also conducted conference calls to discuss a

historical issue with neutron absorbing materials in the spent fuel pool and how the

facility is controlling heavy loads onsite.

The inspectors attended a sampling of licensee meetings and verified that licensee

activities were in accordance with licensed requirements. The inspectors performed a

walkdown of the main control room and examined the controls and indicators that were

currently available to the operating staff. The inspectors performed plant tours and

observed the conduct of facility maintenance, repair, and operations. In addition, the

inspectors reviewed the organization, experience, and staffing levels of the radiation

protection (RP) organization.

The inspectors examined the planning and authorization of radiation work and observed

the conduct of radiological work and radiation protection technician work coverage. The

inspectors also attended a pre-job briefing for removal of control rod drive mechanisms

and observed the work inside the drywell. The inspectors observed the movement of an

intermodal container that was posted and controlled as a locked high radiation area and

also observed the cutting of local power range monitors on the refueling floor.

The inspectors reviewed the Pilgrim programs for external radiation exposure monitoring

and control, internal radiation exposure monitoring and control, radioactive

contamination monitoring and control, and radioactive material control. The inspectors

also reviewed Pilgrims programs for ionizing radiation exposure optimization.

b. Observations and Findings

The inspectors determined that the quality assurance organization conducted a program

of audits and surveillances that were critical and intrusive, and that the organization was

6

active in the follow-up of previous audit observations and findings (in an effort to ensure

effective resolution).

The inspectors noted an active involvement by the Pilgrim site industrial safety

representative in oversight of the site characterization efforts.

The inspectors noted that the site safety review process did not explicitly call for the

reviewer to screen any proposed program change for an impact on UFSAR accidents

and accident analysis. The inspectors did further note that the current procedure did

accomplish this by implication and that the process could be enhanced (and facilitate

review and audit) by calling this out explicitly. This was discussed with the licensee

during the inspection period.

The inspectors determined that the pre-planning for removal of the control rod drive

mechanisms, which can exhibit elevated radiation exposure levels, was extensive and

effective in controlling the work in a safe and efficient manner.

c. Conclusions

Based on the results of this inspection, no findings of safety significance were identified.

5.0 Exit Meeting Summary

On November 9, 2020, the lead inspector presented the inspection results to

Mr. John Moylan, Site Vice President, and other members of the HDI staff. No

proprietary information was retained by the inspectors or documented in this report.

7

PARTIAL LIST OF PERSONS CONTACTED

J. Moylan, Site Vice President

A. Sterdis, Regulatory Assurance Vice President

J. McDonough, Operations Manager

D. Noyes, Senior Compliance Manager

L. Berlinski, Nuclear Consultants International - Lead Oversight Manager

M. Dagnello, Maintenance Manager

J. Frattasio, Fire Marshall, Assistant Operations Manager

D. Fucito, Consulting Engineer

B. Gailes, Human Resources Manager

M. Gatslick, EP Specialist

C. Hayes, Holtec Project Manager

P. Kristian, Refuel Floor Project Manager

M. Lawson, Radiation Protection Manager

M. LeFrancois, Demolition Manager

F. McGinnis, Regulatory Assurance Specialist

P. OBrien, Communications

J. ODonnel, Certified Fuel Handler

E. Sanchez, RP Supervisor, Refuel Floor Manager

A. Steward, RP Supervisor

P. Sullivan, Site Oversight

P. Tetreault, Security Superintendent

ITEMS OPEN, CLOSED, AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED

8.B.14, Fire Protection Technical Requirements, Revision 61

Agreement between Plymouth Fire Department and Holtec Pilgrim, LLC, dated 12/19/2019

2020-2022 Emergency Management Comprehensive Grant Agreement between Holtec

Decommissioning International, LLC and the Town of Plymouth, dated 09/19/2019

ALARA Plan 2020-135-AP1

Audit AP-QA-2/6/14/15-2019-PNP-1, dated 3/23/2020

Audit AP-QA-10/12/18/19/-2019-PNP-01, dated 1/24/2020

Defueled Daily Surveillance Log, 2.1.15.1, Revision 2

EC-PNP-2020-018, Incipient Fire Brigade, dated 03/19/2020

EN-PE-210-Rev. 4, BWR Reactor Core and MPC Fuel Verification

Engineering Change PNP-2019-005, Revision 0

Engineering Change PNP-2019-006

Engineering Change PNP-2020-015, Revision 0

Engineering Change PNP-2020-017, Revision 0

Engineering Change PNP-2020-021, Revision 0

Engineering Change PNP-79602, Revision 0

8

LIST OF DOCUMENTS REVIEWED (Contd)

Engineering Change 40944, Revision 0

Engineering Change 46918, Revision 0

Engineering Change 80693, Revision 0

Engineering Change 80915, Revision 2

Engineering Change 82162, Revision 2

Fuel Handling, 4.3, Revision 146

FQC-ADM-5059, 10 CFR 50.59 Review Program Qualification Card, Revision 4

FQC-ADM-7248, 10 CFR 72.48 Review Program Qualification Card, Revision 2

FQC-ADM-PAD06, Process Applicability Determination Qualification Card, Revision 4

GQP - 9.2 High Temperature Liquid Penetrant Examination and Acceptance Standards for

Weld, Base Materials and Cladding (50° - 350°F)

GQP - 9.6, Rev. 19, Visual Examination of Welds HPP-2877-300

HPP-2877-0100, Rev.0, MPC Preparation for Loading at Pilgrim

HPP-2877-0200, Rev. 0, MPC Loading at Pilgrim

HPP-2877-0300, Rev. 0-3, MPC Sealing, Drying, and Backfilling at Pilgrim

HPP-2877-0400, Rev. 0, MPC Stackup and Transfer at Pilgrim

HPP-2877-0500, Rev. 0, MPC Transport at Pilgrim

HPP-2877-0700, Rev. 0, Response to Abnormal Conditions at Pilgrim

Human Performance Evaluation, PIL-01166

Independent Safety Review, EC PNP-2020-018, dated 10/2/2019

Independent Safety Review, LBDCR 2020-12, dated 5/1/2020

Independent Safety Review, PNPS Permanently Defueled Emergency Plan, dated 3/31/2020

Issue Report PIL-00005

Issue Report PIL-00040

Issue Report PIL-00995

Issue Report PIL-01078

Issue Report PIL-01132

Issue Report PIL-01166

Issue Report PIL-01168

Issue Report PIL-01171

Issue Report PIL-01371

Issue Report PIL-01409

Issue Report PIL-01460

Issue Report PIL-01517

Issue Report PIL-01524

Issue Report PIL-01535

Issue Report PIL-01627

Issue Report PIL-01630

Issue Report PIL-01637

Issue Report PIL-01638

Issue Report PIL-01643

Issue Report PIL-01645

Issue Report PIL-01671

Issue Report PIL-01677

Issue Report PIL-01851

KGO-ENO-HK1-19-058, Pilgrim Rev 0 Response to Boraflex CSA RAI, dated 7/1/2019

List, PNPS Maintenance Rule Basis Documents Listing, dated 8/6/2020

List, Pilgrim Station Engineering Changes (since 01/01/2020)

List, Pilgrim Station Engineering Changes Active (6/15/2019 to 8/7/2020)

List, Qualified Safety Evaluation Screeners and Reviewers

9

LIST OF DOCUMENTS REVIEWED (Contd)

List, Work Order Backlog, as of 8/12/2020

Logs, RP Supervisor for CRD Removal Project

NEIL Services Letter, Pilgrim Nuclear Power Station Plan for Emergency Response-Transition

from an on-site Fire Brigade to utilization of an off-site Fire Brigade, dated 01/20/2020

O-CH-01-01-01, PNPS Incipient Fire Response Training and PNPS Fire Response Training,

Revision 0

Operator Control Room and Inside Readings datasheet

Operator Inside Tour datasheet

P-EN-DC-115, Engineering Change Process, Revision 28

P-EN-DC-330, Fire Protection Program, Revision 7

P-EN-DC-330, Fire Protection Program, Revision 7

P-EN-NF-200, Special Nuclear Material Control, Revision 15

P-EN-LI-100, Process Applicability Determination, Revision 29

P-EN-LI-101, 10 CFR 50.59 Evaluations, Revision 19

P-EN-LI-102, Performance Improvement Program, Revision 37

P-EN-LI-112, 10 CFR 72.48 Evaluations, Revision 13

P-EN-OM-119, Independent Safety Review, Revision 21

PI-CNSTR-OP-HLTC-H-01, Revision 4, Closure Welding of Holtec Multi-Purpose Canisters -HI-

STORM 100, Hl-STAR 100, HI-STORM FW & UMAX Systems

PIL-1018-02, Self-Assessment - P-EN-LI-100 Process Applicability Reviews, dated 3/12/2020

Pilgrim Defueled Safety Analysis Report, section 7.2.23

Pilgrim Nuclear Power Station Defueled Safety Analysis Report, Section 3.3.9, Fire Protection

System, Revision 0

Pilgrim Nuclear Power Station - Issuance of Amendment No. 250 RE: Permanently Defueled

Technical Specifications, dated 10/28/2019

Pilgrim Nuclear Power Station Procedure 4.3, Rev.146, Fuel Handling Procedure

Pilgrim Nuclear Power Station Procedure 6.1-225, Rev 7, RP Controls for Dry Fuel Storage

Pilgrim Nuclear Power Station Report No. HI-2135753, Fuel Compatibility Report for Entergy

Pilgrim Nuclear Plant

Pilgrim Nuclear Power Station Report No. HI-2188761, Loading Plan Report for Pilgrim

Presentation, Pilgrim Project ALARA Meeting, dated August 6, 2020

Procedure No. 2.01, Station Access Control, Revision 52

Procedure No. 5.3.36, Extensive Damage Mitigation Guidelines (EDMG) Support Procedures

and Strategies, Revision 20

Procedure No. 5.5.1, General Fire Procedure, Revision 28

Procedure No. 5.5.2, Special Fire Procedure, Revision 60

Procedure No. 8.B.1, Fire Pump Test, completed 01/29/2020

Procedure No. 8.B.1, Fire Pump Test, completed 02/24/2020

Procedure No. 8.B.1, Fire Pump Test, completed 03/25/2020

Process Applicability Determination for EC 79602, Revision 0

Process Applicability Determination review for EC 82162 R2, Holtec report HI-2200348 Revision

2

Processing Liquid Radioactive Discharges, 2.5.2.17, Revision 23

Radiological air sample 2020-99

Radiological air sample 2020-101

Radiological air sample 2020-103

Radiological survey, Map #11, dated 03/02/2020

Radiological survey, Map #17, dated 7/13/2020

Radiological survey, Map #18, dated 7/13/2020

Radiological survey, Map #30, dated 8/14/2020

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LIST OF DOCUMENTS REVIEWED (Contd)

Radiological survey, Map #37, dated 8/17/2020

Radiological survey, Map #84, dated 04/05/2020

Radiological survey, Map #166, dated 8/14/2020

Radiological survey, Map #168, dated 05/27/2020

Radiological survey, Map #300, dated 8/18/2020

Radiological survey plan, Free-Release Survey Plan for the Contractor Office, Warehouse &

Ships Buildings, dated 3/25/2020

Radiological survey plan, Free-Release Survey Plan for the Kelly Building, dated 3/2/2020

Radiological survey sheets, CRD removal project

Radiological Work Permit 2020115

Radiological Work Permit 2020135, Revision 01

Report No. 89XM-1-ER-Q-19, Pilgrim Nuclear Power Station Updated Fire Hazards Analysis,

Revision 19

Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel

Storage Installations, dated March 31, 2020.

SEP-FPP-PNP-001, Fire Protection Plan, Revision 6

Spent Fuel Pool Storage Rack Coupon Retrieval, 4.8, Revision 10

Station Daily Status Reports

Training slides, EN-LI-100 Initial Training

Training slides, Process Applicability Determination Refresher Training

Work Order WO-00036441-03-01-000

Work Order WO-52892134-01

Work Order WO-52755646-01

Work Order WO-52756084-01

LIST OF ACRONYMS USED

ADAMS Agencywide Document and Access Management System

CFR Code of Federal Regulations

CoC Certificate of Compliance

DFS Dry fuel storage

EC Engineering Change

ENOI Entergy Nuclear Operations, Inc

FHD Forced helium dehydration

FPP Fire Protection Program

FSAR Final Safety Analysis Report

GPO Government Printing Office

HDI Holtec Decommissioning International, LLC

IMC Inspection Manual Chapter

IP Inspection Procedure

ISFSI Independent Spent Fuel Storage Installation

MPC Multi-purpose canister

NRC U.S. Nuclear Regulatory Commission

PHE Public Health Emergency

PNPS Pilgrim Nuclear Power Station

RP Radiation Protection

SFP Spent Fuel Pool

TS Technical Specifications

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