Letter Sequence RAI |
---|
EPID:L-2020-LLA-0070, Attachments 1 - 3: Summary of Evaluation of Proposed Changes, Proposed Change to PNPS Renewed Facility License Condition 3.G (Mark-up) and (Clean Copy) (Open) |
|
|
|
---|
Category:Letter
MONTHYEARL-24-002, Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G2024-02-0202 February 2024 Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G ML23342A1182024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 ML23334A1822023-11-30030 November 2023 Biennial Report for the Defueled Safety Analysis Report Update, Technical Specification Bases Changes, 10 CFR 50.59 Evaluation Summary, and Regulatory Commitment Change Summary November 2021 Through October 2023 L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23306A0992023-11-0202 November 2023 and Indian Point Energy Center, Notification of Changes in Schedule in Accordance with 10 CFR 50.82(a)(7) L-23-011, 10 CFR 72.48 Biennial Change Summary Report2023-10-27027 October 2023 10 CFR 72.48 Biennial Change Summary Report IR 05000293/20234012023-08-31031 August 2023 NRC Inspection Report No. 05000293/2023401 & 2023001 (Cover Letter Only) IR 05000293/20230022023-08-0404 August 2023 NRC Inspection Report No. 05000293/2023002 L-23-008, Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI)2023-05-23023 May 2023 Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI) ML23136A7792023-05-15015 May 2023 Annual Radiological Environmental Operating Report, January 1 Through December 31, 2022 ML23135A2152023-05-15015 May 2023 Annual Radioactive Effluent Release Report, January 1 Through December 31, 2022 L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023 HDI Annual Occupational Radiation Exposure Data Reports - 2022 L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-31031 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations ML23088A0382023-03-29029 March 2023 Stations 1, 2, & 3, Palisades Nuclear Plant, and Big Rock Point - Nuclear Onsite Property Damage Insurance ML23069A2782023-03-13013 March 2023 Request for Scoping Comments Concerning the Environmental Review of Monticello Nuclear Generating Plant, Unit 1 Subsequent License Renewal Application ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities IR 05000293/20220042023-02-15015 February 2023 NRC Inspection Report No. 05000293/2022004 ML22356A0712023-01-31031 January 2023 Issuance of Exemption for Pilgrim Nuclear Power Station ISFSI Regarding Annual Radioactive Effluent Release Report - Cover Letter ML22347A2782022-12-21021 December 2022 Independent Spent Fuel Storage Installation Security Inspection Plan Dated December 21, 2022 L-22-042, Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.152022-12-14014 December 2022 Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.15 L-22-041, Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension2022-12-0909 December 2022 Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension IR 05000293/20220032022-11-18018 November 2022 NRC Inspection Report No. 05000293/2022003 L-22-036, Decommissioning Trust Fund Agreement2022-11-0808 November 2022 Decommissioning Trust Fund Agreement ML22276A1762022-10-24024 October 2022 Decommissioning International Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22266A1922022-09-23023 September 2022 and Pilgrim Nuclear Power Station - Request to Withdraw Prior Submissions from NRC Consideration ML22272A0352022-09-22022 September 2022 S. Lynch-Benttinen Letter Regarding U.S. Citizen Intent to Sue U.S. Fish and Wildlife and NOAA Fisheries Representing the Endangered Species (Na Right Whale) Which Will Be Adversely Affected by Holtec International Potential Actions ML22269A4202022-09-22022 September 2022 Citizen Lawsuit ML22241A1122022-08-29029 August 2022 Request for Exemption from 10 CFR 72.212(a)(2), (b)(2), (b)(3), (b)(4), (B)(5)(i), (b)(11), and 72.214 for Pilgrim ISFSI Annual Radioactive Effluent Release Report IR 05000293/20220022022-08-12012 August 2022 NRC Inspection Report No. 05000293/2022002 ML22215A1772022-08-0303 August 2022 Decommissioning International (HDI) Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22206A1512022-08-0101 August 2022 NRC Office of Investigations Case Nos. 1-2022-002 & 1-2022-006 ML22221A2592022-08-0101 August 2022 LTR-22-0217-1-NMSS - Town of Duxbury Letter Opposing the Irradiated Water Release from Pilgrim (Docket No. 05000293) ML22193A1662022-07-28028 July 2022 LTR-22-0154-1 - Heather Govern, VP, Clean Air and Water Program, Et Al., Letter Regarding Radioactive Wastewater Disposal from the Pilgrim Nuclear Power Station (Docket No. 05000293) ML22175A1732022-07-28028 July 2022 LTR-22-0153-1 - Response Letter to D. Turco, Cape Downwinders, from A. Roberts, NRC, Regarding Holtec-Pilgrim Plans to Dump One Million Gallons of Radioactive Waste Into Cape Cod Bay ML22154A4882022-06-0101 June 2022 Letter from Conservation Law Foundation Regarding Irradiated Water Release from Pilgrim ML22154A1622022-05-26026 May 2022 Letter and Email from Save Our Bay/Diane Turco Regarding Irradiated Water Release from Pilgrim ML22136A2602022-05-16016 May 2022 Submittal of Annual Radiological Environmental Operating Report for January 1 Through December 31, 2021 ML22136A2572022-05-16016 May 2022 Submittal of Annual Radioactive Effluent Release Report for January 1 Through December 31, 2021 ML22102A0932022-05-12012 May 2022 LTR-22-0067 Response to Matthew P. Levesque, President, Barnstable Town Council Regarding Irradiated Water Release from Pilgrim IR 05000293/20220012022-05-11011 May 2022 NRC Inspection Report No. 05000293/2022001 ML22104A0542022-04-30030 April 2022 LTR-22-0093 Response to Sheila Lynch-Benttinen, Regarding Irradiated Water Release from Pilgrim L-22-026, Occupational Radiation Exposure Data Report - 20212022-04-29029 April 2022 Occupational Radiation Exposure Data Report - 2021 ML22152A2592022-04-25025 April 2022 Zaccagnini Letter Dated 04/25/22 ML22152A2642022-04-19019 April 2022 Flynn Letter Dated 04/19/22 ML22091A1062022-04-0101 April 2022 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) L-22-022, and Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec.2022-03-25025 March 2022 and Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec. ML22130A6762022-03-14014 March 2022 Decola Ltr Dtd 03/14/22 Re Potential Discharge of Radioactive Water from Pilgrim Nuclear Power Station ML22041B0762022-03-0707 March 2022 03-07-22 - Letter to the Honorable William R. Keating, Responds to Letter Regarding Proposed Release of Irradiated Water at Pilgrim Nuclear Power Station Into Cape Cod Bay ML22054A2962022-02-23023 February 2022 Annual ISFSI Radioactive Effluent Release Report for 2021 2024-02-02
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML21223A2422021-08-16016 August 2021 Enclosure - Pilgrim Nuclear Power Station - Request for Additional Information Regarding Pilgrim - License Amendment Request Independent Spent Fuel Storage Installation Only Emergency Plan ML21161A1072021-07-0909 July 2021 Request for Additional Information Regarding Pilgrim License Amendment Request ISFSI Only Emergency Plan ML21013A5232021-01-15015 January 2021 Request for Additional Information Regarding the Request to Change the Physical Security Plan - Alternative Measures ML20297A2382020-10-22022 October 2020 Fleet DQAP RAIs - Enclosure ML20297A2372020-10-22022 October 2020 Request for Additional Information - HDI Fleet Decommissioning Quality Assurance Program ML20142A2422020-05-26026 May 2020 Acceptance of Requested Licensing Action Physical Security Plan Revision and License Amendment Request to Incorporate Additional Independent Spent Fuel Storage Installation with Requests for Additional Information ML20280A1912020-04-17017 April 2020 Request for Additional Information- Clarifying Information for Pilgrim ISFSI Physical Security Amendment Application ML19207B3662019-07-26026 July 2019 NRR E-mail Capture - Pilgrim - RAI Direct and Indirect Transfer of Lic.; Conforming Lic. Amend.; Req. for Exemption 10 CFR 50.82(A)(8)(I)(A) for Holtec Decom. International, Llc ML19154A5242019-06-0303 June 2019 NRR E-mail Capture - RAI - Pilgrim Post-Decommissioning Technical Specifications (PDTS) License Amendment Request (LAR) ML19086A3492019-03-21021 March 2019 NRR E-mail Capture - Pilgrim Power Station - Request for Additional Information Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment (EPID: L-2018-LL0-0003) ML19036A6512019-02-0404 February 2019 NRR E-mail Capture - RAI - Pilgrim EP Exemption ML18320A1292018-11-16016 November 2018 NRR E-mail Capture - Request for Additional Information (RAI) - Pilgrim Post-Decommissioning Technical Specifications (PDTS) License Amendment Request (LAR) ML18323A1192018-11-15015 November 2018 CAL 5 Document Request #2 ML18317A2202018-11-11011 November 2018 NRR E-mail Capture - (External_Sender) Questions and Comments Regarding Pilgrim EP Exemption RAI, October 16, 2018 ML18317A2192018-11-0808 November 2018 NRR E-mail Capture - (External_Sender) RAI EP 11.06.18-Question ML18310A0212018-11-0606 November 2018 NRR E-mail Capture - RAI - Pilgrim EP Exemption ML18289A4072018-10-16016 October 2018 NRR E-mail Capture - RAIs - Pilgrim EP Exemption ML18285A8182018-10-12012 October 2018 NRR E-mail Capture - for Your Action: RAIs - Pilgrim - LAR - EP and EAL Scheme to Address Permanently Defueled Condition ML18124A1392018-05-0404 May 2018 NRR E-mail Capture - RAI - Pilgrim ERO Staffing License Amendment Request ML18094B0922018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to B. S. Ford RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for ISFSI Docket Nos.: 72-43, 72-51, 72-1044, 72-07, 72-12, and 72-59) ML18005A5422018-01-0505 January 2018 NRR E-mail Capture - Second Round of RAI for DAEC Fifth Inservice Inspection Interval Program Plan, Relief Request RR-03 - EPID: L-2017-LLR-0110 ML16347A0042016-12-0909 December 2016 NRR E-mail Capture - Pilgrim: Request for Additional Information for Relief Requests on Volumetric Exam Requirements, PNPS-ISI-001, 002 and 003 ML16013A0642016-01-13013 January 2016 NRR E-mail Capture - Request for Additional Information Entergy CNRO-2015-00023 - Revision to Entergy Quality Assurance Program Manual (Fleet Submittal CAC Nos. MF7086-MF7097) ML15341A1662015-12-0707 December 2015 NRR E-mail Capture - Entergy Fleet RR-EN-15-1, Request for Additional Information (CACs MF6341-MF6349) ML15211A6612015-07-30030 July 2015 Licensed Operator Positive Fitness-For-Duty-Test ML15051A0322015-02-25025 February 2015 Request for Additional Information Regarding the Safety Limit Minimum Critical Power Ratio License Amendment Request ML14342A0942014-12-17017 December 2014 Request for Additional Information Regarding Relief Request PRR-24, Nozzle-to-Vessel Welds and Nozzle Inner Radii Examinations ML14042A0432014-02-18018 February 2014 Request for Additional Information Regarding Safety Limits to Resolve Pressure Regulator Fail-Open Transient License Amendment Request ML13333A9102013-12-0505 December 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool ins ML13323B4702013-11-25025 November 2013 Request for Additional Information Regarding Relief Request PRR-22 ML13304B4182013-11-0101 November 2013 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns ML13179A4622013-07-0505 July 2013 Entergy Nuclear Operations, Inc., Decommissioning Funding Status Report Request for Additional Information Regarding the Decommissioning Funding Status Report ML13182A4252013-07-0101 July 2013 Request for Additional Information E-mail from R.Guzman to W.Lobo PR-03 and PR-05 Fifth Ten-Year Inservice Testing (IST) Program ML13165A2762013-06-20020 June 2013 Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (NRC Order EA-12-051) ML12278A3862012-10-0404 October 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2, and 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford, Request for Additional Information, Round 2, Amendment Request to Revise QA Program Manual and Staff Qualification TSs ML1209604492012-04-0505 April 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Request for Additional Information, Revise Quality Assurance Program Manual and Staff Qualification Technical Specificat ML1208601472012-03-26026 March 2012 Request for Additional Information - Pilgrim Nuclear Power Station Revision to Condensate Storage Tank Low Level Trip Setpoint ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic ML12056A0472012-03-12012 March 2012 Enclosure 1 - Recommendation 2.1: Seismic ML1132502282011-11-22022 November 2011 Request for Additional Information, Relief Request No. PRR-21 ML1132202342011-11-21021 November 2011 Request for Additional Information 60-Day Response to Bulletin 2011-01, Mitigating Strategies, ML1114402342011-05-25025 May 2011 Request for Additional Information to Support the Review of 2011 Decommissioning Funding Status Report ML1108202082011-04-11011 April 2011 Summary of Telephone Conference Call Held on March 23, 2011, Between the USNRC and Entergy Nuclear Operations, Inc., Concerning the Pilgrim Nuclear Power Station License Renewal Application ML1106101872011-03-0303 March 2011 Request for Additional Information to Support the Review of Pilgrim Nuclear Power Station Cyber Security Plan (Id: 2.10.034) ML1105403302011-02-15015 February 2011 Response to Request for Additional Information (Rai), Dated January 5, 2011 on the Cyber Security Plan ML1100900272011-01-10010 January 2011 Request for Additional Information Revision to TS for Setpoint and Setpoint Tolerance Increase for Safety Relief Valves and Spring Safety Valves, and Related Changes (ME3543) ML1034105062011-01-0707 January 2011 December 1, 2010, Summary of Telephone Conference Call Held Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc., Concerning the Pilgrim Nuclear Power Station License Renewal Application 2021-08-16
[Table view] |
Text
May 26, 2020 Ms. Pamela B. Cowan Senior Vice President and Chief Operating Officer Holtec Decommissioning International, LLC Krishna P. Singh Technology Campus 1 Holtec Blvd.
Camden NJ 08104
SUBJECT:
PILGRIM NUCLEAR POWER STATION - ACCEPTANCE OF REQUESTED LICENSING ACTION RE: PHYSICAL SECURITY PLAN REVISION AND LICENSE AMENDMENT REQUEST TO INCORPORATE ADDITIONAL INDEPENDENT SPENT FUEL STORAGE INSTALLATION WITH REQUESTS FOR ADDITIONAL INFORMATION (EPID: L-2020-LLA-0070)
Dear Ms. Cowan:
By letter dated April 2, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20141L057 Pkg.), as supplemented by letter dated April 22, 2020, (ADAMS Accession No. ML20122A055), Holtec Decommissioning International, LLC (HDI) submitted a license amendment request for the Pilgrim Nuclear Power Station (Pilgrim) pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.4, 10 CFR 50.54(p), 10 CFR 73.55(r), and 10 CFR 50.90. HDI requests approval of the Pilgrim Physical Security Plan (PSP) revision and requests an amendment to License Condition 3.G, Physical Protection. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this amendment application.
As part of its amendment application, HDI submitted a proposed revised PSP that integrates the existing PSPs Appendix D. HDI indicated that this appendix provides the security requirements for the new Independent Spent Fuel Storage Installation (ISFSI II) that is currently being built in the Owner Controlled Area outside of the existing Pilgrim Protected Area. HDI anticipates that the ISFSI II pad will be completed in the fourth quarter of 2020. According to HDI, the Security Training and Qualification Plan and the Safeguards Contingency Plan are included in the proposed revised PSP but remain unchanged from the existing PSP.
In its amendment application cover letter, HDI indicated that it understands that NRC approval of the proposed revised PSP and the associated revision to Pilgrim License Condition 3.G is required prior to making the new ISFSI II pad operational and moving loaded casks to the new ISFSI II. Also, HDI explained it plans to conduct a campaign to transfer additional irradiated fuel located in the spent fuel pool (SFP) to dry cask storage on the existing Pilgrim ISFSI pad under the current license during the second through fourth quarter of calendar year 2020. In addition, HDI informed the NRC that it is planning for the subsequent fuel loading campaigns that would result in the use of the ISFSI II currently scheduled to commence in the second quarter of calendar year 2021, provided that the NRC approves the amendment application. Additionally,
P. Cowan HDI stated that movement of the fuel from the SFP to dry cask storage on the new ISFSI II pad will result in a significant reduction in site risk and therefore requested (provided the application is accepted for a detailed technical review) that the NRC complete its review by February 2, 2021. HDI indicated that completion of the NRCs review by this date would align with HDI plans for movement of the first cask from the existing ISFSI to the new ISFSI II during the second dry fuel storage campaign and requested that the NRC make the amendment immediately effective (provided that the amendment application is approved).
The NRC staff has completed its acceptance review of this license amendment request. The acceptance review was performed to determine if there is enough technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of 10 CFR, an amendment request to the license must fully describe the changes requested, and following as far as applicable, the form prescribed for original application. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRC staff has reviewed your application and concluded that it does provide technical information in enough detail to enable the NRC staff to initiate a detailed technical review and make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment. The staff has started its detailed technical review and have identified areas where additional information related to the following documents are necessary to complete its detailed technical review: 1) HDIs Post Shutdown Decommissioning Activities Report, 2) HDIs environmental evaluation, and 3) HDIs Physical Security Plan. In support of an effective and efficient review, the NRC has enclosed three requests for additional information (RAIs).
Satisfactory responses are needed to complete our technical review. Please respond to the RAIs within 30 days. If you are unable to meet this date, please provide a proposed response date, within 10 business days of receipt of this letter.
Given the lesser scope and depth of the acceptance reviews, as compared to the detailed technical reviews, there may be instances in which issues that impact the NRC staffs ability to complete the detailed technical review are identified despite completion of an adequate acceptance review. If additional information is needed, besides the enclosed RAIs, HDI will be advised by separate correspondence.
Based on the information provided in your submittal, and supplement, and discussions during the pre-licensing meeting on January 31, 2020 (ADAMS Accession No. ML20045D106), the NRC staff has estimated that this licensing request will take approximately 450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> to complete. This estimate assumes, HDI will respond to the attached RAIs with the needed information, as well as any other RAIs that might be issued in the future, in a timely manner.
The NRC staff expects to complete this review in approximately eight months and will attempt to complete its review no later than February 2, 2021. If there are emergent complexities or challenges in our review that would cause changes to the initial forecasted completion date or significant changes in the forecasted hours, the reasons for the changes, along with the new estimates, will be communicated during the routine interactions with the assigned project manager.
P. Cowan These estimates are based on the NRC staffs initial review of the application and they could change, due to several factors including RAIs, unanticipated addition of scope to the review, or hearing-related activities.
If you have any questions, please contact me, at (301) 415-6822 or via e-mail at Amy.Snyder@nrc.gov.
Sincerely, Amy M. Digitally signed by Amy M.
Snyder Snyder Date: 2020.05.26 06:23:00
-04'00' Amy M. Snyder, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-293
Enclosure:
Requests for Additional Information cc: Listserv
ML20142A242 *via e-mail OFFICE DUWP DUWP NSIR/DPCP EMRB/Acting DUWP NAME A. Snyder* B. Watson* A. Rivera* D. Diaz. Toro* A. Snyder DATE 5-19-20 5-19-20 5-22-20 5-21-20 5-26-20 Holtec Decommissioning International, LLC, Pilgrim Independent Spent Fuel Storage Installation Physical Security Plan Amendment Application, Requests for Additional Information
- 1. On page 3 of 5 of the April 2, 2020, submittal cover letter (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20136A038), Holtec Decommissioning International, LLC (HDI) stated the following:
As discussed in the HDI Revised PSDAR (Post Shutdown Decommissioning Activities Report); existing ISFSI (Independent Spent Fuel Storage Installation) pad space and dry cask loading limitations require the construction of additional ISFSl capacity. The construction of the Pilgrim (Pilgrim Nuclear Power Station) ISFSI II will provide this additional capacity to support storage of the remaining spent fuel stored in the SFP (spent fuel pool) and must be completed in order to support the schedule provided in the HDI Revised PSDAR.
According to the March 31, 2020, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations submittal (ADAMS Accession No. ML20091M858), it appears that HDI modified its Pilgrim decommissioning schedule and some of its major milestones from the HDI Revised PSDAR, dated November 18, 2018 (ADAMS Accession No. ML18320A040). However, HDI refers to the schedule in HDIs Revised PSDAR in HDIs April 2, 2020, amendment application cover letter instead of the updated decommissioning schedule presented in its March 31, 2020, submittal. Please clarify how the , Figure 1, Holtec Decommissioning International Pilgrim Nuclear Power Station Decommissioning Schedule Timeline, of the March 31, 2020, submittal applies to the April 2, 2020, submittal and HDIs Revised PSDAR for the Pilgrim.
- 2. On page 3 of 5 of the April 2, 2020, submittal cover letter, HDI stated the following; Furthermore, HDI has evaluated this proposed license amendment against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR (Title 10 of the Code of Federal Regulations) 51.21 and has concluded, pursuant to 10 CFR 51.22(b), that no environmental impact statement or environment assessment need be prepared in connection with the proposed amendment.
Additionally, in Section 4, Environmental Considerations, of Attachment 1 to the HDIs cover letter, HDI specified that HDI has determined that it [the proposed license amendment] meets the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(12). HDI has explained that modifications associated with this proposed amendment include lighting, intruder detection systems, protected area boundary fencing, access control systems, telecommunications equipment, a vehicle barrier system, and a central alarm station and that activities associated with the proposed amendment do not involve any significant construction impacts. HDI, however, has not provided in its application the bases and supporting information for concluding that 10 CFR 51.22(c)(12) is applicable. Please provide HDIs assessment with rationale as to why a categorical exclusion applies to this proposed licensing proceeding and supporting information.
The information the NRC staff uses to conduct and inform its environmental reviews must be ENCLOSURE
publicly available, as appropriate. Therefore, please ensure that the information included in response to this request for additional information can be made publicly available. This information is needed to allow NRC staff compliance with the National Environmental Policy Act of 1969 and 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions.
- 3. On page 1 of 5 of the April 2, 2020, submittal cover letter, HDI stated that it requests approval of the enclosed Pilgrim Nuclear Power Station (PNPS) Physical Security Plan (PSP) revision HDI submitted, as enclosure 1, the description of PNPS Physical Security Plan Changes - (Security Related Information) and as enclosure 2, the proposed changes to the PNPS Security Plan including Appendix D (Safeguards, Information) as opposed to the proposed PSP revision. Per the NRC License No. DPR-35, Provision 3. 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 of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: Pilgrim Nuclear Power Station Physical Security, Training and Qualification, and Safeguards Contingency Plan, Revision 0 submitted by letter dated October 13, 2004, as supplemented by letter dated May 15, 2006.
The NRC staff will review the submittal with the proposed changes but also must review the entire PSP in total to ensure that certain other areas of the PSP are compatible with the proposed changes. This is needed due to the complexity of your submittal and your proposed PSP strategy of phasing in the new ISFSI II. Because changes to the Pilgrim PSP were made under 10 CFR 50.54(p)(2) since 2006 that did not require NRC approval, those changes were not submitted to the NRC. In order for staff to complete its technical review of this amendment application, the NRC staff requests that HDI submit a copy of the entire PSP. Further, if any changes to the PSP are made in the future under 10 CFR 50.54(p)(2), between now and the completion of the technical review for this amendment application review, the NRC staff request that the changes be submitted for the same reason as stated above for the purpose of this amendment application review. Such submittals, if there are any, may impact the proposed review schedule.