L-20-029, Response to NRC Request for Clarifying Information

Response to NRC Request for Clarifying Information

ML20122A055
Person / Time
Site:	Pilgrim
Issue date:	04/22/2020
From:	Sterdis A Holtec Decommissioning International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
HDI-PIL-20-029
Download: ML20122A055 (10)

Text

Sf1FEGUARDS INFORMATION

• ** *

• Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H Q LT E C --------------T-el e-p-ho-ne_(_85 _6_)7-9-7--09_0_0 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL 10 CFRS0.90 10 CPR 50.54(p) 10 CPR 73.55(r)

April 22, 2020 U.S. Nuclear Regulatory Commission One White Flint ATTN: Document Control Desk 11555 Rockville Pike Rockville MD 20852-2738 Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRCDocketNos. 50-293 and 72-1044

Subject:

Response to_ NRC Request for Clarifying Information

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. -

[2] Email from U.S. Nuclear Regulatory Commission to Holtec Decommissioning International, LLC- Request for clarifying information to support the NRC's Acceptance Review of the Pilgrim ISFSI Physical Security Plan License Amendment Application, dated April 17, 2020

Dear Sir or Madam:

On April 2, 2020, Holtec Decommissioning International, LLC (HDI) submitted a Proposed Revision to the Physical Security Plan and License Amendment Request (LAR) to incorporate an additional Independent

. Spent Fuel Storage Installation at the Pilgrim Nuclear Power Station (PNPS) site (Reference 1). On April 17, 2020, the U.S. Nuclear Regulatory Commission (NRC) Nuclear Material Safety and Safeguards (NMSS)

Project Manager requested clarifying information to support the NRC's acceptance review of the requested LAR (Reference 2). This letter provides the requested information. The enclosedJ~formation clarifies the information contained in the referenced submittal and is provided to facilitate the NRC's acceptance review.

The specific information requests and station responses are summarized in Attachment 1 to this letter. The enclosures to this letter provide the requested information.

NOTE: ENCLOSURE 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION' AND ENCLOSURE 2 TO THIS LETTER CONTAINS "SENSITIVE SECURITY INFORMATION. THESE ENCLOSURES MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ENCLOSURES 1 AND 2 THIS LETTER IS DECONTROLLED" HDI-PIL-20-029 Page 1 of3 ~oDI I\) /vi 5 5 -z._{p

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. S}. . FECU1\RDS INFORMP. . TION

• • • • • Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H Q LT E( --------=------=:.:.----=-----T-ele-p-ho_n_e(-,---85_6_)7-9-7--09 **********---------------*--

D ECOM MISS 10 NIN

......................................................... G Fax (856) 797-0909 INTERNATIONAL Enclosure 1 contains "Safeguards Information" as defined by 10 CFR 73 .22 and its disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy Act of 1954, as amended, and must be

• protected accordingly. Enclosure 1 provides figures that are being resubmitted, as well as the Local Law Enforcement Agency (LLEA) Memorandum of Understanding (MOU) and the associated integrated response plan.

• Enclosure 2 contains Security-Related Information to be withheld from public disclosure pursuant to 10 CFR 2.390. Enclosure 2 provides a revision to the regulatory compliance matrix that was contained in the initial submittal. The revision addresses compliance with the applicable security orders for the ISFSI II cask storage pad.

Pursuant to 10 CFR 50.91, Notice for public comment; State consultation," paragraph (b), a copy of this clarific~tion response, with the attachment 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.

I declare under the penalty of perjury that the forgoing is true and correct.

Executed on April 22, 2020.

Sincerely, Digitally signed by Andrea L sterdis A nd rea L. ~~~g'/:°.f.:':t~::!; C sterdis, c=US,

• • Ceconimissionlng International,

, Sterd1s , ~~t~!!o12~~'.;;13~~:~':°:

Andrea L. Sterdis HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC ALS/fm NOTE: ENCLOSURE 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION'AND ENCLOSURE 2 TO THIS LETTER CONTAINS "SENSITIVE SECURITY INFORMATION. THESE ENCLOSURES MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ENCLOSURES 1 AND 2 THIS LETTER IS DECONTROLLED" HDI-PIL-20-029 Page 2 of3

S}_._FEGUARDS INFORMATION

• • • • • Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H O LT E( -------"-------=.:.----=------Te-le-p-ho-ne_(_85_6_)7-9-7--09 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL Attachment

1. Summary of Clarification Requests and HDI Responses (uncontrolled)

Enclosures

1. PNPS Physical Security Plan Requested Clarification Information (Pilgrim ISFSI II PSP)

(Safeguards Information)

2. Revised Security Order Compliance Matrix (Security Related Information) cc: (without Enclosure 1)

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

Director, Massachusetts Emergency Management Agency NOTE: ENCLOSURE 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION' AND ENCLOSURE 2 TO THIS LETTER CONTAINS "SENSITIVE SECURITY INFORMATION. THESE ENCLOSURES MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ENCLOSURES 1 AND 2 THIS LETTER IS DECONTROLLED" HDI-PIL-20-029 Page 3 of3

Attachment 1 to *HDI Letter HDI-PIL-20-029 Summary of Clarification Requests and HDI Responses (5 pages including cover page)

Attachment I to HDI-PIL-20-029 Page I of5

• • • • • Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H Q LT EC _____ ___;;______::_:._ __;_____T_ele-p-ho_n_e(~85_6_)7-9-7--09 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL Summary of Clarification Requests and HDI Responses 1.0 Clarification Request:

Provide Figure 1.2 ofproposed PNPS Physical Security Plan.

Response

Figure 1.2, ISFSI Overview, to the proposed PNPS Physical Security Plan is provided in Enclosure 1 (Safeguards Infonnation).

2.0 Clarification Request:

Provide Figure C2 ofC6 (Vehicle Barrier System (VBS) Blast Analysis Calculation (Safeguards Infonnation).

Response

Figure C2 of C6 in the VBS blast Analysis Calculation is provided in Enclosure 1 (Safeguards Infonnation).

3.0 CJarification Request:

The PNPS site response and recovery plan which includes the Local Law Enforcement Agency (LLEA) Memorandum of Understanding (MOU).

Response

The PNPS site response and recovery plan which includes the LLEAMOU is included along with the integrated response plan which provides additional details, See Enclosure 1 (Safeguards Information).

4.0 Clarification Request:

Provide a compliance matrix regarding each line item of the ISFSI Additional Security Measures (ASM) Order that references each order requirement and the section of the Pilgrim II ISFSI PSP where the order requirement is located. The ASM Order contains Safeguards lnfonnation.

(Safeguards Infonnation) *

• Response:

The summary of applicable Security Orders aitd the associated compliance matrix tables are provided in Enclosure 2 (Security-Related Infonnation)

Attachment! to HDI-PIL-20-029 Page 2 ofS

• • • • • Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H Q LT EC -----------"-'-----'-----T-ele-p-ho_n_ e(~85_6_)7_9_7--09_0_0 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL 5.0 Clarification Request:

• Provide the*Pilgrim site procedure for cask transfer from the current PA to the future ISFSI Protected Area (PA).

Response

The HDI Pilgrim Security Procedure for Haul Path Operations will be used to transfer spent fuel casks from the existing Pilgrim Protected Area (PA) to the future ISFSI TI PA. This procedure is still being developed. Terms, duties, and responsibilities may be revised as needed based on ongoing reviews. As such, transmittal of the completed procedures is not currently possible.*

The current schedule is to complete the development of the procedure by July 31, 2020. The procedure will be provided to the NRC when complete.*

The Pilgrim Security Procedure for Haul Path Operations will provide specific instructions for the security force performing the duties required when spent fuel is transported from the existing station PA, Security Owner Controlled Area (SOCA), and Vehicle Barrier System (VBS) to the Pilgrim Independent Spent Fuel Storage Installation II (ISFSI II) PA and VBS. This procedure is being developed to specifically compliment the stations Physical Security Plan (PSP) covering the following attributes:

RESPONSIBILITIES

1. Protect the Spent Fuel from sabotage or theft.

2. Establish Controlled Access Areas (CAA).

3. Establish a Vehicle Exclusion Area (VEA).

4. Perform access control functions.

5. Escorting spent fuel movement from Pilgrim PA, SOCA, and VBS to ISFSI II PA and VBS.

6. Maintaining liaison with the Central Alarm Station (CAS), *secondary Alarm Station (SAS),

Independent Central Alarm Station (ICAS), Lead Security Shift Supervisor (LSSS);

Transport Escort Commander, Local Law Enforcement Agency (LLEA), and Dry Fuel Storage Supervisor (DFS).

GENERAL

1. Communications: Security Operations CAS/SAS/ICAS, Transport Escort (Commander/Responders), Contingency, LLEA.

2. Transport Escorts will be armed with contingency weapons, equipment, and communications.

3. Transport Escort Vehicles will be bullet resisting.

4. Coordinate evolution with Radiation Protection.

5. Any vehicle used within 30 feet of a loaded cask shall be constantly attended by its operator AND have a known fuel quantity; when totaled with other fuel sources, is less than 50.

gallons.

Attachment 1 to HDI-PIL-20-029 Page 3 of5

• • • • • Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H Q LT E( --------------T-ele -p-ho-ne-(-,--85 _6_)7-9-7--09 DECOMMISSIONING

... .................... . ............. --~*******--**** .*....*.

Fax (856) 797-0909 INTERNAT_IONAL

6. All vehicles hauling compressed gas cylinders or pressurized liquid containers, will be restricted from the ISFSI II and the Haul Path, or activities.involving such potential explosive sources will be halted along the Haul Path and the ISFSI U.

7. All vehicles except those assigned/authorized by security (inchiding LLEA) will not be permitted in the VEA.

8. All tanker trucks hauling flammable, combustible liquids and gases will be restricted from the ISFSI II and the Haul Path during transport operations to prevented them from approaching within 500 feet of the VCT/Goldhofer (HI-STORM transport) travel route.

9. Complete patrol of Haul Path to verify standoff distances and to establish the VEA prior to initiation of evolution.

SECURITY OPERATIONS

1. Maintain control of the CAA and the CAA authorization list. The authorization list will be approved by the DFS and Security Superintendent.

2. All personnel requiring entry into the CAA will be hand searched for PA contraband/prohibited items once the spent fuel has exited the protected area unless they have been under security's constant control or observation after leaving the CAA.

3. No personnel will be allowed into the CAA unless on the authorization list.

4. The spent fuel is to be escorted by the Transport Escorts from the time it exits the PA_until it reenters the ISFSI II PA.

5. All personnel, material or vehicles reentering the PA will be searched unless, full security access control of personnel, material and vehicles were maintained.

6. Establish Vehicle Exclusion Area VEA.

7. Patrol/Observe for any unauthorized vehicles or personnel in the VEA.

8. Challenge all vehicles attempting entry into the VEA. *

9. Search all required vehicles prior to allowing authorized entry into the VEA before transfer operations have begun. Vehicles not directly related to the security of or transport of the cask will be restricted from the area. *

10. ff any vehicle is allowed entry into the VEA (security or LLEA), the security positions that are responsible for assisting in the monitoring of the VEA will be notified.

11. If any suspicious activity is noted, the CAS/SAS/ICAS, and the Transport Escort Commander will be alerted.

12. ff any unauthorized vehicles are observed to be entering the VEA, CAS/SAS/ICAS, and the Transport Escort Commander win be notified.

CONTINGENCIES

1. Transporter malfunction

2. Unforeseen Transporter/Cask Issues

3. Armored Vehicle escort malfunction

4. Loss of Communications

5. Unlawful assembly

6. Severe weather

7. Unauthorized vehicle Attachment I to HDI-PIL-20-029 Page 4of5

• • • • • Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H Q LT E ( ---------'--------'------Te-le-p-ho-ne-(~85_6_)7-97--0-9-00 DECOMMISSIONING Fax,(856) 797-0909 INTERNATIONAL

8. Unauthorized personnel

9. Missing Security Force Member

10. Missing LLEA member

11. Bomb Threat

12. Attack Threat

13. Sniper

14. Vehicle borne device: Large/Small

15. Armed Attack

16. Waterborne Device

17. Contingency experienced by Site Security Forces

REFERENCES:

• Physical Security Plan

• Dry Fuel Storage Project Plan

• 10 CFR 73.55

• 10 CFR 73 Appx B

• 10 CFR 7.3 Appx C

• 10 CFR 73.1

• 10 CFR 73.25

• 10 CFR 73.26

• 10 CFR 73.27

• 10 CFR 73.37

• 10 CFR 73.51

• 10 CFR Part 37

• NUREG-0561-Physical Protection of Shipment oflmidiated Fuel: Final Report (Rev. 2)

• Pilgriin StationJntegrated Response Plan

• Pilgrim Station Memorandums of Understandin~

• Haul Path Blast Calculations

• Security Procedure 3.27 (SGI) Safeguard Contingency Responsibility Matrix Attachment 1 to HDI-PIL-20-029 Page 5 ofS

SAFEGU..A..RDS INFORMATION

• • • • • Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H O LT E C --------------------Te-le-ph-o-ne-(8-5-6)-7-97--0-90-0 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL Enclosure 1 to HDI Letter HDI-PIL-20-029 PNPS Physical Security Plan Requested Clarification Information (Pilgrim ISFSI II PSP)

1. Physical Security Plan Figure 1.2

2. Figure C2 of C6 Vehicle Barrier System Blast Analysis Calculation

3. Local Law Agency (LLEA) Memorandum of Understanding (MOU) and Integrated Response Plan Details (54 Total pages including Cover Sheet)

Note: This enclosure contains "SAFEGUARDS INFORMATION and must be protected accordingly. Upon separation of the enclosure contents, this enclosure cover page is Decontrolled

• to HDI:PIL-20-029 Page 1 of 1

SECURITY-RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390

• • • • • ---~-*_sh_n_a_P_._Si_ng~h_T_~_n_o_lo_gy_Ca_m~p_u_s,_1_H_o_lt_~_B_lv_d_.,_C_am_de_n_,_NJ_08_1_04_

H Q LT E( Telephone (856) 797-0900 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL Enclosure 2 to HDI Letter HDI-PIL-20-029 Revised Security Order Compliance Matrix (7 pages including Cover Sheet)

Note: This enclosure contains "SECURITY-RELATED INFORMATION and must be protected accordingly. Upon separation of the enclosure contents, this enclosure cover page is Decontrolled Enclosure 2 to HDI-PIL-20-029 Page 1.of7