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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
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~Entergy March 14, 2018 Mr. David C. Lew Acting Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Brian R. Sullivan Site Vice President
SUBJECT:
Notification of Changes to Comprehensive Recovery Plan and Area Action Plan Action Completion Dates Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35
REFERENCES:
- 1. Entergy letter to NRC, "Pilgrim Nuclear Power Station Recovery Plan," dated July 28, 2017 (Letter Number 2.17.056) (ML 17212A571) 2. NRC letter to Entergy, "Confirmatory Action Letter -Pilgrim Nuclear Power Station," dated August 2, 2017 (ML 17214A088) LETTER NUMBER: 2.18.012
Dear Mr. Lew:
On July 28, 2017, Entergy Nuclear Operations, Inc. (Entergy) transmitted the Pilgrim Nuclear Power Station (PNPS) Comprehensive Recovery Plan (CRP) (Reference 1) to the U.S. Nuclear Regulatory Commission (NRC). The CRP contains the actions that Entergy is taking to address the decline in performance at PNPS, including actions to address the issues that led to PNPS being placed in the Multiple/Repetitive Degraded Cornerstone Column (Column IV) of the NRC Action Matrix. In response, the NRC transmitted the PNPS Confirmatory Action Letter (CAL), dated August 2, 2017, confirming the commitments made by Entergy (Reference 2). Subsequent to the issuance of the CAL, refinement of the schedule for Area Action Plan (AAP) inspections has been discussed with the NRC Staff. The purpose of these discussions was to ensure alignment between the PNPS schedule for completion of Enclosure 2 action items supporting closure of AAPs, and the availability of NRC inspection resources. Based on coordination with the NRC Staff, the schedule of inspections was revised. Accordingly, correspondence is required pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232 to notify the NRC in advance, if for any reason, an action listed in the CAL cannot be completed within the specified schedule. Since some of the dates will be shifted, NRC notification is required in advance of the changes.
Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station Letter No. 2.18.012 Page 2 of 2 In addition, during preparation activities for the upcoming CAL inspections, Entergy identified a number of AAP actions in Enclosure 1 of Reference 2 (the CRP) that need to be clarified or modified to ensure common *understanding of the required actions. The changes are provided in Attachment 1 of this letter. Notification of the modified PNPS schedule is provided in Attachment 2. If you have any questions or require additional information, please contact Mr. Peter J. Miner at (508) 830-7127. Sincerely, Brian R. Sullivan Site Vice President BRS/pm
Attachment:
- 1. Notification of Changes to Actions in Comprehensive Recovery Plan 2. Notification of Changes to Area Action Plan Action Completion Dates to Support Revised Inspection Schedule cc: U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 *** Mr. John Lamb, Senior Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8C2A Washington, DC 20555-0001 NRG Senior Resident Inspector Pilgrim Nuclear Power Station Letter Number 2.18.012 Notification of Changes to Actions in Comprehensive Recovery Plan Notification of Changes to Actions in Comprehensive Recovery Plan 1. ODFA-5.6 should state, "The actions specified in ODFA-5.1 and 5.2 also address deficiencies identified during the 95003 inspection." 2. The following Operations Standards and Site Leadership actions are listed under the Risk Recognition and Decision-Making Action Plan (RRDM) and are more appropriately addressed under the Operations Standards and Site Leadership Action Plan (OPS). To address this the following revisions are requested: a. Add new section OPS-5: Additional Actions (Enclosure 1 and 2) b. RRDM-4.1 to become OPS-5.1 (Enclosure 1) c. RRDM-4.2 to become OPS-5.2 (Enclosure 1) d. RRDM-4.3 to become OPS-5.3 (Enclosure 1 and 2) e. RRDM-4.5 to become OPS-5.4 (Enclosure 1) f. RRDM-4.6 to become OPS-5.5 (Enclosure 1) 3. OPS-5.2 (formerly RRDM-4.2) should be reworded to read "Schedule 3 operations manager mentor visits to Pilgrim following RF0-21." 4. OPS-5.3 (formerly RRDM-4.3) should be reworded to read "Issue additional actions based on the results and insights from the mentor visits conducted per OPS-5.1 and OPS-5.2." 5. Revise RRDM-4.8 to read: "RRDM-4.8 addresses the NRC 95003 observation that based on interviews and a review of current open corrective action program items generated by the subject matter experts, the NRC team noted resistance to the improvement recommendations of the subject matter experts by some station managers. For example, in reference to CR-PNP-2016-07486, subject matter experts identified that numerous outage preventive maintenance activities were extended without sufficient technical justification and without conducting a risk review in accordance with procedure 1.3.142, PNPS Risk Review and Disposition. 6. Revise RRDM-4.9 to read: "RRDM-4.9 addresses the NRC 95003 observation that some station leaders (managers and first-line supervisors) from across multiple departments appeared to be lagging in their demonstration of the new decision-making principles and implementation of procedure 1.3.142, PNPS Risk Review and Disposition, and the NRC 95003 observation that the current action plans allow the station 'the flexibility to remove the SMEs and mentors following a successful effectiveness review of the related area.' Implementation of the SMEs and mentors should continue until a positive change in safety culture is sustained and verified by NRC inspection." Page 1 of 1 Letter Number 2.18.012 Notification of Changes to Area Action Plan Action Completion Dates to Support Revised Inspection Schedule Notification of Changes to Area Action Plan Action Completion Dates to Support Revised Inspection Schedule Human Performance Corrective Action Program SRV White Finding Nuclear Safety Culture Operational Standards and Leadership Engineering Programs and Equipment Performance Procedure Use and Adherence Operability Determinations and Functionality Assessments Corrective Action Program SRV White Finding Nuclear Safety Culture Operational Standards and Leadership Risk Recognition and Decision Making Engineering Programs Equipment Reliability Work Management 02/28/18 05/18/18 02/28/18 No Change 03/30/18 05/18/18 03/30/18 No Change 05/31/18 11/23/18 05/31/18 08/24/18 05/31/18 08/24/18 06/28/18 08/24/18 06/28/18 08/24/18 06/28/18 08/24/18 J Page 1 of 1