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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) |
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Category:Letter type:L
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 L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 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 L-23-011, 10 CFR 72.48 Biennial Change Summary Report2023-10-27027 October 2023 10 CFR 72.48 Biennial Change Summary Report 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) 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 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 L-22-036, Decommissioning Trust Fund Agreement2022-11-0808 November 2022 Decommissioning Trust Fund Agreement L-22-026, Occupational Radiation Exposure Data Report - 20212022-04-29029 April 2022 Occupational Radiation Exposure Data Report - 2021 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. L-21-134, and Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Independent Spent Fuel Storage Installations2021-12-17017 December 2021 and Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Independent Spent Fuel Storage Installations L-21-130, Registration of Casks to Store Spent Fuel and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2021-12-14014 December 2021 Registration of Casks to Store Spent Fuel and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool L-21-125, Registration of Casks to Store Spent Fuel2021-12-0101 December 2021 Registration of Casks to Store Spent Fuel L-21-118, Changes to Signature Authority & Addressee for Holtec Decommissioning International, LLC Correspondence Re to Oyster Creek Nuclear Generating Station, Pilgrim Nuclear Power Station, Indian Point Nuclear Generating Units 1, 2, 3, & Palisades2021-11-0909 November 2021 Changes to Signature Authority & Addressee for Holtec Decommissioning International, LLC Correspondence Re to Oyster Creek Nuclear Generating Station, Pilgrim Nuclear Power Station, Indian Point Nuclear Generating Units 1, 2, 3, & Palisades L-21-114, Registration of Casks to Store Spent Fuel2021-11-0404 November 2021 Registration of Casks to Store Spent Fuel L-21-107, Registration of Casks to Store Spent Fuel2021-10-0404 October 2021 Registration of Casks to Store Spent Fuel L-21-098, Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan2021-09-0707 September 2021 Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan L-21-055, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E2021-08-30030 August 2021 Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E L-21-088, Registration of Casks to Store Spent Fuel2021-08-0404 August 2021 Registration of Casks to Store Spent Fuel L-21-073, Decommissioning International - Fuel Storage Cask Certificate Number: 1014 - Registration of Changes to Previously Loaded Casks2021-08-0404 August 2021 Decommissioning International - Fuel Storage Cask Certificate Number: 1014 - Registration of Changes to Previously Loaded Casks L-21-090, Response to Request for Additional Information (Rai), License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan2021-07-29029 July 2021 Response to Request for Additional Information (Rai), License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan L-21-086, Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G2021-07-22022 July 2021 Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G L-21-078, Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G2021-07-0606 July 2021 Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G L-21-072, Supplemental Information to Support Proposed Independent Spent Fuel Storage Installation- Only Security, Training, and Qualification, Safeguards Contingency Plan2021-06-22022 June 2021 Supplemental Information to Support Proposed Independent Spent Fuel Storage Installation- Only Security, Training, and Qualification, Safeguards Contingency Plan L-21-057, Supplemental Information to Update - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan2021-05-20020 May 2021 Supplemental Information to Update - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan L-21-048, Annual Report of Individual Monitoring of Radiation Exposure for CY20202021-04-27027 April 2021 Annual Report of Individual Monitoring of Radiation Exposure for CY2020 L-21-038, Onsite Property Damage Insurance (10 CFR 50.54(w)(3))2021-04-0101 April 2021 Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) L-21-037, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2021-03-31031 March 2021 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations L-21-036, Proposed Independent Spent Fuel Storage Installation-Only Security, Training and Qualification, Safeguards Contingency Plan2021-03-17017 March 2021 Proposed Independent Spent Fuel Storage Installation-Only Security, Training and Qualification, Safeguards Contingency Plan L-21-008, License Amendment Request to Approve Pilgrim Nuclear Power Station Independent Spent Fuel Storage Installation Only Emergency Plan2021-02-18018 February 2021 License Amendment Request to Approve Pilgrim Nuclear Power Station Independent Spent Fuel Storage Installation Only Emergency Plan L-20-098, and Oyster Creek Nuclear Generating Station, 10 CFR 140.15 Proof of Financial Protection2020-12-30030 December 2020 and Oyster Creek Nuclear Generating Station, 10 CFR 140.15 Proof of Financial Protection L-20-080, Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to Covid 19 Pandemic2020-11-20020 November 2020 Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to Covid 19 Pandemic L-20-019, Request for Approval of HDI Fleet Decommissioning Quality Assurance Program, Revision 02020-08-27027 August 2020 Request for Approval of HDI Fleet Decommissioning Quality Assurance Program, Revision 0 L-20-057, Registration of Use of Cask to Store Spent Fuel2020-08-17017 August 2020 Registration of Use of Cask to Store Spent Fuel L-20-048, Physical Security, Training & Qualification and Safeguards Contingency Plan, Revision 192020-07-21021 July 2020 Physical Security, Training & Qualification and Safeguards Contingency Plan, Revision 19 L-20-029, Response to NRC Request for Clarifying Information2020-04-22022 April 2020 Response to NRC Request for Clarifying Information L-20-022, Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3))2020-04-0101 April 2020 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) L-20-023, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2020-03-31031 March 2020 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations L-20-017, Annual Report of Individual Monitoring of Radiation Exposure for 20192020-02-27027 February 2020 Annual Report of Individual Monitoring of Radiation Exposure for 2019 L-19-021, Holtec Decommissioning International (Hdi) Response to Confirmatory Order EA-17-132/EA-17-1532019-12-31031 December 2019 Holtec Decommissioning International (Hdi) Response to Confirmatory Order EA-17-132/EA-17-153 L-19-020, Oyster Creek Nuclear Generating Station - 10 CFR 140.15 Proof of Financial Protection2019-12-27027 December 2019 Oyster Creek Nuclear Generating Station - 10 CFR 140.15 Proof of Financial Protection L-19-003, (PNPS) - Transmittal of Revision to 10 CFR 50.54(q) Review for EP-PP-01, PNPS Emergency Plan Revision 512019-10-16016 October 2019 (PNPS) - Transmittal of Revision to 10 CFR 50.54(q) Review for EP-PP-01, PNPS Emergency Plan Revision 51 L-2018-064, Submittal of Joint Composite Adversary Force2018-03-0808 March 2018 Submittal of Joint Composite Adversary Force L-06-002, Correction to Response to Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power2008-07-24024 July 2008 Correction to Response to Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power 2024-02-02
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARL-21-098, Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan2021-09-0707 September 2021 Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan L-21-090, Response to Request for Additional Information (Rai), License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan2021-07-29029 July 2021 Response to Request for Additional Information (Rai), License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan L-21-057, Supplemental Information to Update - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan2021-05-20020 May 2021 Supplemental Information to Update - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan ML20188A0612020-06-25025 June 2020 Response to NRC Request for Information on Physical Security Plan Revision and License Amendment Request to Incorporate Additional Independent Spent Fuel Storage Installation L-20-029, Response to NRC Request for Clarifying Information2020-04-22022 April 2020 Response to NRC Request for Clarifying Information CNRO-2019-00030, Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2019 Summary2019-12-30030 December 2019 Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2019 Summary ML19210E4702019-07-29029 July 2019 Transmittal of Response to NRC Request for Additional Information Regarding Request for Direct and Indirect License Transfers, RAI-PFPB-1 and - 2 ML19197A1142019-07-16016 July 2019 Response to Request for Additional Information - License Amendment Request to Revise the Technical Specifications - Permanently Defueled Technical Specifications ML19170A3912019-06-19019 June 2019 Final Response Regarding Request for Information Pursuant to Title 10 CFR 50.54(f) Recommendations 2.1, 2.3 and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident ML19109A1772019-04-17017 April 2019 Response to NRC Request for Additional Information ML19056A1912019-02-18018 February 2019 Attachment 1: Response to Request for Additional Information - Exemption from the Requirements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50, Entergy Nuclear Operations, Inc ML19050A1912019-02-14014 February 2019 Response to Request for Additional Information - Exemption from the Requirements of 10CFR50.47 and Appendix E to 10CFR50 ML19016A1352019-01-10010 January 2019 Response to Request for Additional Information - License Amendment Request to Revise the Technical Specifications - Permanently Defueled Technical Specifications ML18341A2192018-12-0404 December 2018 Response to Request for Additional Information - Exemption from the Requirements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50 ML18338A2052018-11-30030 November 2018 Response to Request for Additional Information - Exemption from the Requirements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50 ML18317A0582018-11-0808 November 2018 Response to Request for Additional Information - License Amendment Request to Emergency Plan and Emergency Action Level Scheme to Address the Permanently Defueled Condition ML18317A0592018-11-0808 November 2018 Response to Request for Additional Information - License Amendment Request to Revise the Emergency Plan and Emergency Action Level Scheme to Address the Permanently Defueled Condition ML18268A1342018-09-21021 September 2018 Response to Request for Information Relating to Notification of Changes to Comprehensive Recovery Plan ML18135A1042018-05-29029 May 2018 Responses to Request for Information - Senator Edward Markey Letter Dated April 23, 2018 (Enclosure) ML18152A8722018-05-23023 May 2018 Attachments 1 & 2: Response to Request for Additional Information - License Amendment Request to Revise the Emergency Plan to Address the Permanently Defueled Condition. Letters of Agreement Enclosed ML18066A0822018-03-19019 March 2018 Enclosure - Letter to Senator Elizabeth Warren, Et Al., from Chairman Svinicki Regarding Winter Storms and an Inspector for Pilgrim Nuclear Power Station ML16333A0052016-11-18018 November 2016 Transmittal of Response to Request for Additional Information - Relief Request on Volumetric Exam Requirements, PNPS-ISI-004 & 005 ML16224B0142016-08-0202 August 2016 Response to Request for Additional Information - Relief Request Number PRR-52, Proposed Alternative to Pressure Testing of Mechanical Joints as a Result of Repair/Replacement Activity and the Use of Code Case N-795. ML16071A4412016-03-0707 March 2016 Entergy Fleet Relief Request No. RR-EN-15-1-Proposed Alternative to Use ASME Code Case N-789-1 - E-mail from G.Davant to R.Guzman - Response to Second RAI (MF6340 - MF6349) CNRO-2016-00005, Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM)2016-02-25025 February 2016 Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM) CNRO-2016-00002, Entergy - Relief Request Number RR EN-15-1, Rev. 1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Water Service, Secti2016-01-29029 January 2016 Entergy - Relief Request Number RR EN-15-1, Rev. 1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Water Service, Section Xl, CNRO-2015-00002, Entergy Operations, Inc. - Response to RAI Questions and Submittal of RR EN-15-2, Rev. 12015-12-0404 December 2015 Entergy Operations, Inc. - Response to RAI Questions and Submittal of RR EN-15-2, Rev. 1 ML15301A2562015-10-21021 October 2015 Calculation M1396, Evaluation of Probability of Failure for Recirculation Inlet (N2) in the Nozzle-to-Shell Welds and Nozzle Blend Radii Regions, 1400071.301, Revision 0, February 2014 ML15301A2552015-10-21021 October 2015 Response to Request for Additional Information Regarding Relief Request PRR-50, Implementation of Code Case N-702 ML15209A6062015-07-17017 July 2015 Station'S Notification of Full Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation 2021-09-07
[Table view] |
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
,0rc1L (VMss
. 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) *
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:
- Dry Fuel Storage Project Plan
- 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
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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