ML20188A061

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Response to NRC Request for Information on Physical Security Plan Revision and License Amendment Request to Incorporate Additional Independent Spent Fuel Storage Installation
ML20188A061
Person / Time
Site: Pilgrim
Issue date: 06/25/2020
From: Sterdis A
Holtec Decommissioning International
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML20188A061 (13)
v • d • e


Text

SAFEGUA!RDS '

INFORMATION

H Q LT E C _____ Krishna P. Singh Technology Campus, 1 HOltec Blvd., Camden, NJ 0810'J

___.: ;______:; , ;_ __:.____Te-,e-p-ho-ne_(_85_6_)7-97---09-00 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL 10 CFR50,90 10 CPR 50.54(p) 10 CFR 73.55(r)

June 25, 2020

  • U.S. Nuclear Regulatory Commission Attn: Document Control Desk I

Washington, DC 20555-0001 I I

Pilgrim Nuclear Power Station Renewed Facility License No; DPR-35 NRC Docket Nos. 50-293 and 72-1044 i

Subject:

Response to NRC Request fo~ Information on Physical Security Plan Revision and License Amendment Request to Incorporate Additional Independent Spent Fuel Storage Installation

References:

[1] Letter from Holtec D~commissioning International, LLC to U.S. Nuclear Regulatory

.Commission - Physical Security Plan Revision and License Amendment Request to I

  • Incorporate Additional Independent Spent Fuel Storage Installation," dated April 2, 2020. (ML20136A038)

[2] US Nuclear Regulato~ Commission to Holtec Decommissioning Intemtional, LLC

-Pilgrim Nuclear Power Station -Acceptance of Requested License Action RE Physical Security Plan Revision and License Amendment Request to Incorporate Additional Independent Spent Fuel Storage Installation With Requests for Additional Information (EPD: L-2020-LLA-0070) dated May 26, 2020 (ML20142A242)

I

[3] Letter from Holtec Debommissioning International, LLC to U.S. Nuclear Regulatory Commission - Notification of Revised Post-Shutdown Decommissioning Activities

  • Report and Revised Site-Specific Decommissioning Cost Estimate for Pilgrim
  • Nuclear Power station/' dated November 16,2018 (ML18320A040)

[4] Letter from Holtec Dedommissioning International, LLC to I

u'.s. Nuclear Regulatory Commission - "Report on Status of Decommissioning Funding for Reactors and Independent Spent FueJ Storage Installations," dated March 31, 2020 (ML20091M858) ,

Dear Sir or* Madam:

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

  • Spent Fuel Storage Installation at the Pilgrim Nuclear Power Station (PNPS) site (Reference 1). On May 26, 2020, the U.S. Nuclear Regulatory Commission:(NRC) Office of Nuclear Material Safety and Safeguards (NMSS) identified that the NRC Staff has compteted its acceptance review of the license amendment request NOTE: ENCLOSURE 2 TO THIS LETIER CONTAINS "SAFEGUARDS INFORMATION' AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ENCLOSURE 2 THIS LEITER IS DECON1ROLLED."

HDI-PIL-20-047 Page 1 of3 SAFEGUARpS INFORMATION SoDJ

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Nl'-1 S..S

SAFEGUA'.RDS INFORMATION

H Q LT EC _____ Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104.

. . ; ;.___. .; ;.;. ___..;___T_e_lep-ho_n_e_(B-56-)7-97--0-9-00 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL I *

(LAR) to determine if enough technical info~atiQn in scope and depth was provided to allow the NRC staff to complete its detailed technical review (Reference 2).

I Reference 2 identified the NRC has determined that the proposed LAR provides 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 in terms of regulatory requirements and the protection of public health and safety and the environment. Reference 2 also identified that the NRC has initiated technical reviews and has determined; that additional information related to the following dacuments is necessary to complete its detailed technical reviews: 1) HDI's Post Shutdown Decommissioning Activities Report; 2) HDI's environmental evaluation, and 3) HDI's Physical Security Plan. In support of an effective review, the NRC identified three request~ for ~dditional information (RAis).

I The specific RAls and the associated HDI resppnses to the RAis are summarized in the Attachment to this letter.

  • RAI #1 requested clarification of HDI schedulJ information submitted after the Site Post Shutdown Decommissioning Activities Report (PSDAR) which was submitted in November 2018 (References 3 and 4).

RAI #2 requested an HDI assessment as to why a categorical exclusionfrom 10 CFR 51.22{c)(l2) is applicable to the proposed licensing proceeding. RAI #3 requested an entire copy of the PSP mark-up, including Appendix D, which was submitted to:address the new ISFSI II cask storage pad security requirements. *

  • Enclosure 2 to this letter provides the proposed PSP markup that was requested in RAI #3. This enclosure
  • contains "Safeguards Information as defined by 10 CFR 73.22 and its disclos:ure to unauthorized individuals
  • is prohibited by Section 147 of the Atomic en~rgy Act of 1954, as amended, and must be protected accordingly.

. I Pursuant to 10 CFR 50.91, "Notice for comment; State consultation," paragraph (b), a copy of this RAI response, with the attachment but without Enclosme 2, is being provided to the Commonwealth of Massachusetts, Emergency Management Agency.

. I This letter contains no new regulatory commitm~nts.

If you have any questions or need further inform~tion, please contact me at (856) 797-0900, ext.. 3813.

NOTE: ENCLOSURE 2 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION' AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL 0~ ENCLOSURE 2 THIS LETTER IS DECONTROLLED."

HDI-PIL-20-047 Page 2 of3 SAFEGUARDS INFORMATION

SAFEGUMIDS INFORMATION*

H Q LT EC ________ Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104

_ _ , ; . , c . _ _ . . ; _ __ _ _T_ele-p-ho_n_e(-85_6_)7-97--0-9-00 r

OECOMMISSIONINC frax (856) 797-0909 I N T ERN AT 1. 0 N A L I declare under the penalty of perjury that the ;forgoing is true ~d correct.

  • i Executed on June 25, 2020.

Sincerely, Df-GlgnedbyAndteaLStenj\s Andrea L. ON: en=Andrea L Sferdis, c=US, o=HDI, ou=Ho!tec Ster S Andrea L.~terdis "*- *°"

Oecomrrissloning lnhlmatfonal, emall:r.a,draa,i*;terdls@holtec.com 2020 25 14 4 30

. " ' 00*

HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC 1 Attachment Summary ofNRC RAis and HDI Responses (Uncontrolled)

I Enclosure

1. Environmental Review of EC 81419 and EC 81420 (Uncontrolled)
2. PNPS Pilgrim Physical Security, Training & Qualification and Safeguards Contingency Plan, Revision 18A (Safeguards In(ormation) cc: (without Enclosure 2)

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

Director, Massachusetts Emergency Management Agency NOTE: ENCLOSURE 2 TO THIS LETTER CONTAINS tSAFEGUARDS INFORMATION' AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ENCLOSURE 2 THIS LETTER IS DECONTROLLED."

HDI-PIL-20-047 Page3 of3 SAFEGUARDS INFORMATION

Attachment to HDI-PIL-20-047 I

Summary of NRC RAis and HDI Responses (Uncontrolled)

Attachment to HDI-PIL-20-047 Page I of5

Krishna P. Sing!l Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 HQ LT EC --------------T-el-ep-ho_n_e-(8-56-)7-9-7--09-00 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL Summary of NRC RAls and HDI Response I

A Nuclear Regulatory Commission (NRC) request for additional information (RAI) regarding a license amendment request to revise the Pilgrim Nuclear Power Station (PNPS) License Condition 3.0 for Physical Protection and a Physical Security Plan revisi9n was received by Holtec Decommissioning International, LLC (HDI) via NRC letter dated May 26, 2020. HDI response to the RAis are provided below.

NRC Request #1 On page 3 of S of the April 2, 2020, submittal cover letter (Agenoywide 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 ISFSI capacity. The construction of the Pilgrim (Pilgrim Nuclear Power Station) ISFSI ll 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" sut;,mittal (ADAMS Accession No. ML20091M8S8), 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 HDI's Revised PSDAR in HDI's April 2, 2020, amendment application cover letter instead of the updated decommissioning schedule presented in its March 31, 2020, submittal,.Please clarify how the Enclosure 2, Figure 1, "Holtec Decommissioning International Pilgrim Nuclear Power Station Decommissioning Schedule Timeline," of the March 31, 2020, submittal appli.es to the April 2, 2020, submittal and HDl's Revised PSDAR for the Pilgrim.

  • HDI Response to RAJ #1; On March 31, 2020, pursuant to NRC regulations, :HDI submitted the HDI Fleet Annual Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations (ADAMS Accession No. ML20091M858). Enclosure 2 of this report includes the annual status of decommissioning

~ding, status of funding for managing irradiated fuel, ~d the financial assurance report for Pilgrim Nuclear Power Station (Pilgrim). In addition, Enclosure 2 of this submittal provided an updated schedule that reflects the current decommissioning plan for Pilgrim. Figure 1 to Enclosure 2 provided a schedule revised from the schedule provided in the November 16, 2018 Revised Post-Shutdown Decommissioning Activities Report (PSDAR) (ADAMS Accession No. ML18320A040). As indicated in Enclosure 2, the schedule revisions were evaluated and are not significant as defined in 10 CFR 50.82 (a)(7).

Attachment to HDI-PIL-20-047 Page2 of5

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H Q LT E( ---------::...,...,----=-=----~---T-el-ep_;,.ho_n_e_(8-56-'-)7-9-7--09-00 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL The schedule (and high-level milestones) included in Figure 1 of Enclosure 2 to the HDI annual report, represent HDI's current schedule at Pilgrim including the current completion schedule for construction and operation of the ISFSI II cask storage pad and for the start of the Phase 2 spent fuel cask loading c~paign.

These project milestones are coordinated and ci:)nsistent with the requested February 2, 2021 approval date identified in the HDI Physical Security Plan (PSP) license amendment request and PSP revision request submitted on April 2, 2020 (ADAMS Accession No. ML20136A038).

NRC Request #2 On page 3 of 5 of the April 2, 2020, submittal cover letter, HDI stated the following:

Furthermore, HDI has evaluated this prQposed license amendment against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CPR (Title 10 of the Code of Federal Regulations) 51.21 and has concluded, pursuant to 10 CFR 5 l .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 HDI's cover letter, HDI

. specified that HDI has "determined that it [the proposed license amendment] meets the criteria for categorical exclusion set forth in 10 CPR 51.22(c)(l2)/' HD~ bas explained that modifications associated with this proposed amendment include lighting, intruder detection systems, protected area boundary fencing, access a

control systems, telecommunications equipment, vehicle barrier system, and a central alann station" and _

that "activities associated with the proposed amendment do not involve any significant construction impacts."

HDI, however, bas not provided in its application'the bases and supporting information for concluding that 10 CFR 51.22(c)(l2) is applicable. Please provide HDI's assessment with rationale as to why a categorical exclusion applies to this proposed licensing proceedmg and supporting information.

  • The information the NRC staff uses to conduct and inform its environmental reviews must be 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

BDI Response to RA #2; 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review", Sub part (c)(12) identifies the following categorical exclusion criteria:

  • Issuance of an amendment to a license under parts 50, 52, 60, 61, 63, 70, 72, or 75 of this chapter relating solely to safeguards matters (i.e., protection against sabotage or loss or diversion of special nuclear material) or issuance of an approval of a safeguards plan submitted under parts 50, 52, 70, 72, and 73 of this chapter, provided that the amendment or approval does not involve any significant construction impacts. These amendments and approvals are c,onfined to:

Attachment to HDI-PIL-20-047 Page 3 of5

          • Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 H Q LT E( -------"-----...;;;_;;__-;.....___T_e_lep_h_on_e_(8-56-)-79-7--09-00 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL (ii) modifications to systems used'for security and/or materials accountability.

HDI has assessed the proposed license amendment I and security plan change against the criteria identified in 10 CFR 51.22(c)(12). The proposed license amendment will be.issued under 10 CFR 50 and is related solely to issuance and approval of a safeguards plan submitted under part 73 of this chapter. The proposed license amendment and security plan changes do not involve any significant construction impac;ts and are confined to modifications to systems used for security and/o'r materials accountability. As such, the license amendment and security plan change result in minimal gr01.1~d disturbance and meet the criteria for exclusion from 10 CFR 5l.22(c)(12).

The proposed security plan requires the establishment of a protected area (PA) around the ISFSI II cask storage pad and modification of the existing site pA in the location where the existing site PA connects to the ISFSI II haul path. Site modifications BC 81419 and EC 81420 were implemented to establish the security provisions needed to support the operation of the' new and revised protected areas.. Environmental review of these security modifications was performed using the site procedure that evaluates environmental impact.

The environmental review performed is provided in Enclosure 1 to this letter.

The environmental review identified the referenced ECs add additional capability necessary to support operation .of protected area controls as well as mo,dification of security fencing and vehicle barriers on previously disturbed land areas (i.e., no excavatiop in previously undisturbed areas). EC 81420 added a 53 kva back-up diesel generator and fuel tank to support operation of the new ISFSI II cask storage pad protected area. The environmental impact of adding a backup diesel generated was assessed and determined not to have a significant effect on the environment based on the small size of the generator, low running hours expected, low sulfur diesel fuel used, and the secondary containment provided to capture potential fuel tank leakage.

NRC Request #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 St;ation (PNPS) Physical Security Plan (PSP) revision ... " HDI submitted, as enclosure 1, the description ofPNPS 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, Provis~on 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 Safegµards Information protected under 10 CFR 73.21, is entitled: Pilgrim Nuclear Power ~tation 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 Attachment to HDI-PIL-20-047 Page4of5

H Q LT E( _________ Krishna P. Singfl Technology Campus, 1 Holtec Blvd., Camden, NJ 08104

_...,;___T_e-lep_h_on-e-(8-56-)7-9-7--09-00 DECOMMISSIONING Fax (856) 797-0909 I NTE°R NATION AL 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 copiplexity 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 S0.S4(p)(2) since 2006 that did not require NRC approval, those changes were not submitted to the NRC. In order for staff to qomplete its technical review of this amendment

  • application, the NRC staff requests that HDI submit a copy of the entire PSP. Further, if any ehanges 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 ame~dment 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. '

HDI Response to RAJ #3:

HDI has reviewed the RAI request and is submittlng a full copy ofthe proposed PSP. Enclosure 2 to this letter provides a "Safegijards Information" copy ~fthe proposed PSP, including Appendix D, which addresses the security requirements applicable to operation:and use of the new ISFSI II cask storage pad.

Attachment to HDI-PIL-20-047 Page 5 of5

          • Krishna P. Singp Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 HQ L.T EC -----------------------,---T-e-le-ph-on_e_(B-56-)-79-7--09-00 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL Enclosure l to HDI-PIL-20-047 I
  • Environmental Review of E(:; 81419 and EC 81420 (Uncontrolled)

Enclosure 1 to HDI-PIL-20-047 Pagel of4

HOLTEC DECOMMISSION INC INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 NUCLEAR MANAGEMENT NON,Q\IAUlY Rlll.AlH EN*EV-1115 I R&V,7 MANUAL INFORMA'!IONAL USII envlNlnmental Reviews and Evalu11t1ona ATTACHMENT 9.1 SITE ACTIVITY REYIEW FORM (T'/l'ICAI.)

S,tEET 1 of 1 EC 81419- PA Modification for Haul Path; EC 81420-ISPSI II Protected Area (PA)

C:hecll Appropriate Box(es) for Ac1Mty Being Perfonned:

(Attachment 9.4 provides a brl1f ducrlpUcn of tll9 Hl'll;nlng n,gul1tor, balk for tho ai:tlvltles listed bolow,)

1. 0 Lllnd dlslllrl:lllnce equal IO or greater tlllln one ecro (I.e** gll!ding activiliea, construction or buildings, excavations, rerore!JlaUon, cniallon or removol of ponds). *
2. El Any land dlslllrbance or undistuilied sutfm::o or 11ubllulface land are1u1 (Le., gradlnt nctMllas, construction. eicc:avlltloll$, 1d1reatallon, Cffl&llng, or removing ponds), Nott,: ACIMty win take plaae on previously dislurbed tend areas (l.o. Soconda,y Accossll&S Parking Lot amt ex/stfng /oach field).

Ona exception Is a smtl/1 port/0/I (llPf'FOlllmately 900 sq. ft.) of vehicle barrier system. Havl/8118r. this consists oJ the p/llcem8nt or e concrel8 bel'fifJr on grado (I.a. no wteavallon tor .!lubsul'faoo foundation n:,quJmd) and lhus screemi out par regulatc,y basis oullined In Altachmenl 9.4.

3. C For Vermont Yankee only, land dlsturb!lnce lnvcMng prevlousty dltllUrtled llllld lhll ls 1!11111 lllan one acre*

4,, .a Dl'lldgfng ectlllllfe11 In a lake, !Iver, pand, ditches or etream.

Changing Ille amount of thennal heat bein9 discharged to the river or lake (le., aasodaied wllll once

6. C through and dosed cyole QQOling wimewaterdisellllrgea).

[J Chanplno Iha c:oncentra\kln er qu1111tlty of chom11:111a. bolng dleeharged to the liver, lake, er elr (I.e.,

all!loclaled with wastewatar and air emisalon dlschBrg$$).

7. b Using *now ar dilfe111nt chemlcehl, which could patentialfy be diacharged and that ere rrently not authorized fOr use by the I1ate regulalo!y agency (Let .. osoclated wilh ~tewater discharge,).
8. C Cllanglng the de11lgn or operal!On
  • of the lnlllkt'I or dliii:liarge stmclUnlS (I.e., Increase water
  • wllhdrawal llow at intuk11 struclure or dlsdlarge Row at dlSCllarg& alructure).
8. C Mod¥n11 Iha dllalgn or opemilan at Ille cooling tower that will change water er alt ftow ehanM:teristlc:G. '
10. 0 Modlfrlng the d(lslgn or operellon or Iha plant lhlll Will change tM pall! or an existing water dl!dmrge or that w,11 result in a new -let discharge (i.e.. a!19oclated witll wastewaler discllarges),
11. 0 Modifying el(lstltlg s!a11anery fuel bum1119 equipment that oould potentll!liy result in an lncntase of air emissions (I.e., diesel fuel ol~ butane, gasoline, propam,, end kerosene).

12, ll!I lnstalllng or !llmovlng stationary tu.el burning equipment or using portable fuel burning equipment (I.e., dleael fuel oil, butane, gasoline, propam,, end lmrosem,). /Addilkm of backup ct/ese/ glHIIH&/or}

13. (l!) lnstelllng or using equipment that Will rosutt in an air emlstlon ~arge (Le.. ozone, voe, pattlculates. l!IUlfur dloldde, Cll!bon monoxide, nitrogen oxide). [Actctf/lon of bscl<up diesel generator}
14. li!I lnstalBng or modifying a staltoriary or mobile tank (I.e., fuel on. gasoline, kerosene, propane, butane, sulfuric acid). [l)fese/ fuel tank associated with backllp diesel genarator}.
15. lhllng or storing alls or c:llt!!mleals In ccntalnem ~5. gallons that could be dil8Clly released into !he environment.
16. C Burying or ptaclno anv solid Wllllfflll ' In Iha site enm !hat may affeel runoff, surtam water, ar

'°(

groUntlWaler. *

17. C Generates a new hazardous W11Sle stream or lncmas&a en existing hazardous waste etream.

P~panxl By: oomJnJtjk Fucjto, Dato: 06!05/2020 Mark ~... ,:-.=~

ApprovedBy:Mark Lawson I awson W"'~-Dato: 6/25/207.0 NOTE: Completed fOffll must bO reviewed end AppRM!d by Chemisby M!lnagor or deslgooe prior toetmtlng Ille aetlvlly.

' EN-EV-115 REV?

Enclosure 1 to HDI-PIL-20-047 Page2 of4

H O LT EC

    • ___ Kr_is_h_na_P_.S_i_ng;c_h_T_e_c_hn_o_lo...;.g-"-y_C_a_m-"-p_us_,_1_H_o_lte_c_B_l_vd_.,_c_a_m_d_e_n,_N_J_O_B_1_04_

Telephone (856) 797-0900 DECOMMISSIONING Fax (856) 797-0909 INTERNATIONAL NUCLEAR MANAGEMENT NON-QI/Al.ITV Rl!U.1EO EN*EV-115 I REV,7 MANUAL INPOltWl'IIOHM. use Environmental Reviews and Evaluatlons ATTACIKM!!NT 1.2 ENVIRONMll~AL RIM&W FORM (TYPICAl.)

SHEET1 of1

1. Faonlty: eNf'S /Sf§l 11
2. Document Number: EC 81419 {PA Mgiflrteatl!W (Jlr Haul Path/EC 81420 ISFS/ ff Pmtected Ama
3. ER Number: fi.tJiru iHti, i1~i0
4. Activity Reviewed:* Atlachmenl S.1 Items 12. 13. 14 I
s. Complete Soreenlng Below (es applicable \o eaoh site):

eference Within Scopo secllon 2.0(1) References 181 Yes No NIA Section 2.0(2] References !li!l 1Ye11 No NIA section 2,0[4] References (ANO) C yes No Q!Jl',4/A Section 2.otSJ Referenc:es (GGNS) IJ Yes a No l!IJN/A section 2.0(8J Rererences ( P2) a Yes . 0 No l!!JNIA Yes Section 2.0(7) References (IP3) c ves. t'l No Ill NIA a Yes Section 2.0(8] Referencea (JAF) YGI IJ No

  • Iii NIA Vea O*No Section 2.0(13) References (PLP) Yea No IBI NIA Yea 0 No Section 2.0[9] Rererenoea (PNPS) ll!I Yes 0 No 0 NIA o Yes llD No Section 2.0[10) Rcfcrcncca (RBS) Yes No 181 NII\ Yao 0 No Section 2.0(11] References (VYNPS) a Yes No llD NIA Yes No Section 2.0[12) Refefences (W3) a v,s a No IBI NIA Yes 0 No
8. If within scope. attach cited reference(s) and appropriate sectlon(s) along with a brll!lf discussion: See NRC, EPA websites and HDIDOC for ci/ed*rererences; see Allachment 9.3 for brief dl~uss/On.
7. If a modlllcaUon, revision or approwil Is needed, attach a brief discussion: See Att.9.3 for discussion.
8. Prepared By: .,,D.,,ocum:wln.,.1c.,,kuf.,.uc.,,..tto..__ _'1A

__,,(__,**_______ Date: 06/0§12020

  • NOTE: For land dl01ull>anca oolivitloc lnvolvlng excavallon ondlor baakfflllng or grading or undlehnbed uurfaco or subsurface land areas, unless othelWise directed by the Chemistry Mllnager or deslgnee. the cons!ntclloll aupervl$0r must be lnfom,ed to Immediately l\top work setMiles 11h0uld lltdlaeolagh:al. historical or otller oulluml
  • msollttle!I be uncovered dullng excavallon, ancno notlfr the Chemistry Mana{l8f or deslgnee, In the event that an unonlldpated dlsoovery Is made, the Chemistry Manager or deslgnee Is to noti1y the Slate Historic PmseM11tion Off11:9r and consult wilh the agency in conducting an assossment of lhe discovery to dclennlne If addlllonal wed< IS needed.

EN-EV-115 REV 7 Enclosure 1 to HDI-PIL-20-047 Page3 of4

  • Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 06104 HOLTEC Telephone (656) 797-0900 Fax (656) 797-0909

'DECOMMISSIONING INTERNATIONAL NUCLEAR MANAGEMENT NON,Ql/,W'IY ftaAffl)

EN,EV,1111 I REV,7 MANUAL IN,CIWA1IORAI. 111!1!

Envlronmontal RUVIIIW1!1 and Evablallllffll ATTACIIMl!Nt 0.3 EIMRONMEN1'AL EVALUATION FOIINI ('NPICAL)

SHEET 1 of 1 EC 81419- PA Modlflcntlon fOr Haul Plllh : EC 11420 -tSFSI II Prr:ltee.ted,Are (PAJ

1. Document El/lltuated: EC 8'1419: PA MC>dlflea11on for Haul Pall'lf EC 81420: ISFSI II Pmlecled Area 2, Ooscrlp!lon of proposed change (a1tactu1ddlllonal alleets If needed):

~ : Modfflcotton of Ol(Tst/ng PA and SOCA (onces to allow ptllJ/f. of now ISFSI II ht!UI palhroed.

~ : fnstollal/an of /SFSI II Proteolod Arna (PA) Seour/fy (oaturos (Cenlml Amrm Station Bulldlnr,, fonf:l!ts, mlc,owaves, aamoras, vtJhicle b11trler system)

3. Analy~l11 of environmental lmpac;t (attacm:addlllonet aheeta tr needed):

PNPS Rotorenr:os 2.0191 are 1101 /mpocrod by this actlv/lY. lt&ms 12, 13, 14 &m cl!IJCll&d to fil"fJot lnstaffatfon of a 63 lwa backup diesel genoralar to BUpply emetgOnoy p<;wor to Iha ISFSI II fm:f!lly In tho avant lhal tho normal power supply Is lntenup/ed*

. Notation IIOS bf1(ill lnc/uded Ir, EC 81420 to u/11/w ASTM 0976 or EN 690 Ullra Low Sulfur Dlosel (VLSO) with nulfuraontont <16 mg/kg (15.ppmJ to mfnlmlzo envltonmen111/ lmpacls, and to ar,suro that tha now dlotrol (lflnarator Is added to I/HJ sfto air emission permlls ~ to tumo\18r.

,4; If oppOcoblo, attematlvell for roduclng envlronmontnl lmpaet (o!Uleb adcQUor,111 shoete If needed):

Operation of1110 baakup dleaol fjonerolar will only be mqutmd upon tho loss of the normal powBr

..*.: supply, typically no mort1 than 1*2 flVllll'8 Pf calendar Jll)sr wllh-!yplcal duration of 24. hours per

  • event. As noted above, use of ULSD fuel wlll be omployr,d to mlnlm1zt; en11/tonmentel Impacts. In add11ion, lb& dmset fuel tank lm:luctas secondary containment to cmpturo dlaool fuel lnl110 ellllnl of a

/oak In the primary tonk. *

6. eummlll)'* of baalll tor eoncl111lgn11 (altaeh a~lllllcmal 11ha11!a Ir nH<111d):

ThO add/rlon of a diesel gSMrotor to tho 8/to will have no s/fln/Dcant etroct on 1119 envllDllmenL Th/8 cono/uslon Is bDsod on Iha telatlvoly .small ti/re of tho generator. antit;lpated low n,nn/ng h0111S per aa/endar~a,; uso of VI.SD fuel and fuel tonk wllh ser:onda,y coatafnment.

8, Slgnlllcant Ad11erae Environmental Impact Eldsls: C Vas IBJ No

7.

References:

(attach addlllonal aheeta If need~d): None TOT, P~R!R DATE REVIEWER DATE PGS

...... ~._.l..,.._

....=~*

~

~- G.ft-/'IA Mark Lawson OitCl!<IIJM~.~

0 . - ~ ~ .. n.1.o~

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