Letter Sequence Draft Other |
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Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance
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MONTHYEARML14216A5562014-08-0404 August 2014 Acceptance of Requested Licensing Action Request for Order Approving Indirect Transfer of Control and Conforming License Amendments Project stage: Acceptance Review ML14216A2622014-08-28028 August 2014 Request for Withholding Information from Public Disclosure for Susquehanna Steam Electric Station, Units 1 and 2 Project stage: Withholding Request Acceptance ML14311A6722014-10-24024 October 2014 Response to Request for Additional Information Application for Approval of Indirect Transfer of Control PLA-7245 Project stage: Request ML14308A6842014-10-24024 October 2014 Request for NRC Hearing on the Proposed Transfer from PPL to the Future Talen Energy Corporation Project stage: Request NRC-2014-0211, Comment of Eric Joseph Epstein on Behalf of Three Mile Island Alert, Inc. Regarding Susquehanna Steam Electric Station, Units 1 and 2 and ISFSI; Application for License Transfer2014-11-0505 November 2014 Comment of Eric Joseph Epstein on Behalf of Three Mile Island Alert, Inc. Regarding Susquehanna Steam Electric Station, Units 1 and 2 and ISFSI; Application for License Transfer Project stage: Request PLA-7256, Supplemental Information to the Application for Approval of Indirect Transfer of Control2014-11-0606 November 2014 Supplemental Information to the Application for Approval of Indirect Transfer of Control Project stage: Request PLA-7261, Clarification of RAI Response PLA-72612014-11-25025 November 2014 Clarification of RAI Response PLA-7261 Project stage: Request ML14342A8132014-12-0808 December 2014 SSES Units 1 and 2 Draft RAIs Application for Approval of Indirect Transfer of Control of Licenses Project stage: Draft RAI ML14342A8082014-12-0808 December 2014 E-mail from J. Whited to R. Sgarro (PPL) SSES Units 1 and 2 Draft RAIs Application for Approval of Indirect Transfer of Control of Licenses Project stage: Draft RAI PLA-7267, Update to July 11 Request for Order Approving Indirect Transfer of Control2014-12-10010 December 2014 Update to July 11 Request for Order Approving Indirect Transfer of Control Project stage: Request ML14346A1002014-12-12012 December 2014 E-mail from J. Whited to R. Sgarro Susquehanna Steam Electric Station Draft License Transfer Revised 2nd RAIs Project stage: Draft Other ML14346A1022014-12-12012 December 2014 Draft License Transfer Revised 2nd RAIs Project stage: Draft Other ML14345A2412014-12-16016 December 2014 Request for Additional Information Request for Order Approving Indirect Transfer of Control and Conforming License Amendments Project stage: RAI PLA-7274, Response to Second Request for Additional Information Regarding Application for Approval of Indirect Transfer of Control PLA-72742015-01-0505 January 2015 Response to Second Request for Additional Information Regarding Application for Approval of Indirect Transfer of Control PLA-7274 Project stage: Request ML15006A3992015-01-13013 January 2015 Request for Withholding Information from Public Disclosure for Susquehanna Steam Electric Station, Units 1 and 2, Project stage: Withholding Request Acceptance PLA-7278, Updated Information Application for Approval of Indirect Transfer of Control PlA-72782015-01-13013 January 2015 Updated Information Application for Approval of Indirect Transfer of Control PlA-7278 Project stage: Request PLA-7301, Updated Information Application for Approval of Indirect Transfer of Control2015-03-0909 March 2015 Updated Information Application for Approval of Indirect Transfer of Control Project stage: Request PLA-7305, Updated Information Application for Approval of Indirect Transfer of Control2015-03-13013 March 2015 Updated Information Application for Approval of Indirect Transfer of Control Project stage: Request ML15043A1622015-03-18018 March 2015 Request for Withholding Information from Public Disclosure for Susquehanna Steam Electric Station, Units 1 and 2 Project stage: Withholding Request Acceptance PLA-7309, Updated Talen Energy Corp. Director Information Application for Approval of Indirect Transfer of Control2015-03-18018 March 2015 Updated Talen Energy Corp. Director Information Application for Approval of Indirect Transfer of Control Project stage: Request PLA-7293, NRC Decommissioning Funding Status Report2015-03-20020 March 2015 NRC Decommissioning Funding Status Report Project stage: Request PLA-7316, Updated Talen Energy Corporation Officer Information Application for Approval of Indirect Transfer of Control2015-03-31031 March 2015 Updated Talen Energy Corporation Officer Information Application for Approval of Indirect Transfer of Control Project stage: Request ML15091A7712015-04-0101 April 2015 E-mail from R. Sgarro to J. Whited License Transfer Conditions of the Order Clarification of Wording Project stage: Other ML15054A0582015-04-10010 April 2015 Letter Forwarding Order Approving Transfer of Licenses and Conforming Amendments Related to Susquehanna Steam Electric Station, Units 1 and 2 (TAC MF4426 and MF4427) Project stage: Acceptance Review ML15058A0732015-04-10010 April 2015 Order Approving Transfer of Licenses and Conforming Amendments Related to Susquehanna Steam Electric Station, Units 1 and 2 (TAC MF4426 and MF4427) Project stage: Other ML15054A0662015-06-0101 June 2015 Issuance of Conforming Amendment Indirect Transfer of Renewed Facility Operating Licenses to Susquehanna Nuclear, LLC (TAC Nos. MF4426 and MF4427) Project stage: Approval 2014-08-04
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Category:Request for Additional Information (RAI)
MONTHYEARML24150A3362024-05-29029 May 2024 Request for Confirmation of Information Relief Request 1RR06 (Proposed Alternative) Susquehanna Nuclear, LLC Susquehanna Steam Electric Station (Susquehanna), Unit 1 Docket No. 50-387 IR 05000387/20244042024-05-0707 May 2024 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection 05000387/2024404 and 05000388/2024404 ML24102A1252024-04-10010 April 2024 Request for Additional Information for Susquehanna, Unit 1 Alternative Request 4RR-11 ML23334A1502023-11-30030 November 2023 NRC Request for Additional Information Re. Susquehanna Relief Request RR-02 ML23277A0412023-10-0505 October 2023 Notification of Commercial Grade Dedication Inspection (05000387/2024011 and 05000388/2024011) and Request for Information ML23013A2082023-01-13013 January 2023 Request for Additional Information ML22146A1022022-05-26026 May 2022 Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000387/2022404 and 05000388/2022404 ML22146A0742022-05-25025 May 2022 NRR E-mail Capture - NRC Request for Additional Information - Susquehanna License Amendment Request ML22111A3132022-04-21021 April 2022 NRR E-mail Capture - NRC Request for Additional Information - Susquehanna License Amendment Request ML22041A1562022-02-10010 February 2022 Information Request for a Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000387/2022013 and 05000388/2022013 ML21316A1242021-11-18018 November 2021 Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding Emergency Core Cooling Technical Specifications ML20056E4392020-02-21021 February 2020 Ti 2515/194 Inspection Documentation Request ML20010D2012020-01-0909 January 2020 Request for Additional Information Related to Request to Allow Application of Framatome Analysis Methodologies Necessary to Support a Planned Transition to Atrium 11 Fuel Under Maximum ML19319A0092019-11-14014 November 2019 NRR E-mail Capture - Draft RAI for SSES Units 1 and 2 LAR to Replace ESW Piping ML19319B1922019-11-14014 November 2019 NRR E-mail Capture - RAI for Susquehanna, 1 and 2 License Amendment Request - Replace the Emergency Service Water System and Residual Heat Removal Service Water System ML19128A0232019-05-0707 May 2019 Request for Additional Information: Susquehanna Steam Electric Station, Units 1 and 2 License Amendment Request for ESW Piping Replacement ML18352B1832018-12-13013 December 2018 Enclosurequest for Additional Information (Letter to K. Cimorelli Request for Additional Information Regarding Susquehanna Nuclear, Llc'S Decommissioning Funding Plan Update for Susquehanna Steam Electric Station Independent Spent Fuel Stor ML17180A2002017-07-0707 July 2017 Request for Additional Information Regarding License Amendment Request to Revise Diesel Generator Surveillance Requirements with New Steady State Voltage and Frequency Limits ML17059D2142017-03-0606 March 2017 Susquehanna Steam Electric Station - Supplemental Information Needed for Acceptance of Requested Licensing Action Re: License Amendment Request to Revise Diesel Generator Surveillance Requirements with New Steady State Voltage Frequency Limits ML16251A0652016-09-0909 September 2016 Susquehanna Steam Electric Station, Unit 2 - RAI Regarding Temporary Change of Unit 2, Technical Specifications 3.7.1 & 3.8.7 to Allow Replacement of Unit 1, 480 Volt Engineered Safeguard System Load Center Transformers(CAC No. MF7298) ML16245A2052016-09-0101 September 2016 Draft Request for Additional Information Replacement of Load Center Transformers ML16243A0952016-08-30030 August 2016 Draft Request for Additional Information Application for Approval of Indirect Transfer of Control of Licenses ML16060A2302016-03-24024 March 2016 Acceptance of Requested Licensing Action License Amendment Request for Temporary Change of Unit 2 Technical Specifications 3.71 and 3.87 to Allow Replacement of Unit 1 480V Ess Load Center Transformers ML15316A5632015-11-13013 November 2015 Request for Additional Information Regarding Proposed Relief Requests for the Third 10-Year Inservice Inspection Interval(Cac Nos. MF6302 Through MF6307) ML15292A1782015-10-15015 October 2015 TSTF-425 LAR Draft 3rd RAIs ML15230A0802015-08-26026 August 2015 Request for Additional Information Regarding License Amendment Request to Adopt NEI 99-01, Revision 6, EAL Scheme Change ML15209A9742015-08-24024 August 2015 Request for Additional Information License Amendment Request to Adopt Technical Specifications Task Force Traveler (TSTF)-425 ML15230A0462015-08-17017 August 2015 Draft RAIs SSES EAL Scheme Change LAR in Accordance with NEI 99-01 Rev 6 ML15229A2092015-08-17017 August 2015 SSES Draft Request for Additional Information Licensee Request to Adopt TSTF-425 ML15229A2002015-08-17017 August 2015 E-mail from J. Whited to J. Jennings SSES Draft TSTF-425 RAIs ML15183A3502015-07-0202 July 2015 SSES Relief Requests 3RR-19, 3RR-20, and 3RR-21 Draft Identified Information Insufficiencies (TAC Nos. MF6302 Through MF6307) ML15103A3962015-05-22022 May 2015 Request for Additional Information License Amendment Request to Adopt Technical Specifications Task Force Traveler (TSTF)-425 (TAC Nos. MF5151 and MF5152) ML15128A5092015-05-0808 May 2015 E-mail from J. Whited to D. Filchner SSES Draft Request for Additional Information LAR for Implementation of TSTF-425 ML15128A5162015-05-0808 May 2015 SSES Draft Request for Additional Information LAR for Implementation of TSTF-425 ML15008A4702015-01-30030 January 2015 Request for Additional Information Request to Revise Technical Specification 3.4.10, RCS Pressure and Temperature (P/T) Limits. ML15016A2742015-01-16016 January 2015 Draft RAIs License Amendment Request for Change to TS 3.4.10 P/T Limits (TAC Nos. MF4597 and MF45980) ML15016A2722015-01-16016 January 2015 E-mail from J. Whited to D. Filchner Draft RAIs License Amendment Request for Change to TS 3.4.10 P/T Limits (TAC Nos. MF4597 and MF45980) ML14343A9842015-01-0808 January 2015 Request for Additional Information Relief Request 4RR-01 ML14345A2412014-12-16016 December 2014 Request for Additional Information Request for Order Approving Indirect Transfer of Control and Conforming License Amendments ML14346A4022014-12-12012 December 2014 Draft RAIs Relief Request 4RR-01 ML14346A4012014-12-12012 December 2014 E-mail from J. Whited to D. Filchner Susquehanna Steam Electric Station Draft RAIs Relief Request 4RR-01 ML14346A1022014-12-12012 December 2014 Draft License Transfer Revised 2nd RAIs ML14346A1002014-12-12012 December 2014 E-mail from J. Whited to R. Sgarro Susquehanna Steam Electric Station Draft License Transfer Revised 2nd RAIs ML14342A8132014-12-0808 December 2014 SSES Units 1 and 2 Draft RAIs Application for Approval of Indirect Transfer of Control of Licenses ML14342A8082014-12-0808 December 2014 E-mail from J. Whited to R. Sgarro (PPL) SSES Units 1 and 2 Draft RAIs Application for Approval of Indirect Transfer of Control of Licenses ML14233A2772014-08-27027 August 2014 Request for Additional Information License Amendment Request to Change the Low Pressure Safety Limit ML14233A3392014-08-21021 August 2014 Draft RAIs for Susquehanna Steam Electric Station Units 1 and 2 License Amendment Request for Changes to the Low Pressure Safety Limits ML13298A7582014-03-0707 March 2014 Request for Additional Information Regarding Request for Changes to Technical Specification Surveillance Requirements to Increase Diesel Generator Minimum Steady State Voltage (TAC ME9607 and ME960) ML13298A7812014-03-0707 March 2014 Request for Additional Information Regarding Request for Changes to Technical Specification Surveillance Requirement 3.8.1.19 to Increase Diesel Generator Minimum Steady State Frequency (TACs ME9609. ML14013A1502014-01-31031 January 2014 Request for Additional Information Regarding Relief Requests for the Fourth 10-Year Inservice Testing Interval 2024-05-07
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DRAFT REQUEST FOR ADDITIONAL INFORMATION OFFICE OF NUCLEAR REACTOR REGULATION APPLICATION FOR APPROVAL OF INDIRECT TRANSFER OF CONTROL PPL SUSQUEHANNA, LLC SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2 DOCKET NOS. 50-387 AND 50-388 By letter dated July 11, 2014,1 as supplemented by letters dated October 24, 2014,2 and November 6, 2014,3 PPL Susquehanna, LLC (PPL Susquehanna), submitted an application for approval of Indirect Transfer of Control of the licenses for the Susquehanna Steam Electric Station, Units 1 and 2 (SSES), pursuant to Section 184 of the Atomic Energy Act of 1954, as amended (the Act), Title 10 of the Code of Federal Regulations (10 CFR) Section 50.80, "Transfer of licenses" and 10 CFR 72.50, "Transfer of license." The indirect transfers of control results from a series of transactions in which PPL Corporation will spin off PPL Energy Supply, LLC which will result in a new intermediate parent company, Talen Energy Holdings, Inc. To complete its review, the Nuclear Regulatory Commission (NRC) staff requests the following additional information regarding financial qualifications and decommissioning financial assurance.
Financial Qualifications - Regulatory Requirements In accordance with 10 CFR 50.33(f)(2), the Applicants provided a projected five year income statement for SSES and stated that PPL Susquehannas anticipated sources of revenue from sales of energy would provide reasonable assurance of an adequate source of funds to meet PPL Susquehannas share of expenses for the plan.
Under 10 CFR 50.33(l) a non-utility applicant must provide information sufficient to demonstrate its financial qualifications to carry out the activities for which the license is being sought. In addition, per NUREG 1577, Rev. 1, the reviewer "will also consider relevant-financial information (i.e., information on cash or cash equivalents that would be sufficient to pay fixed operating costs during an outage of at least 6 months... and any other relevant factors)."
Finally, 10 CFR 50.33 f(5) states, in part:
The Commission may request an established entity or newly-formed entity to submit additional or more detailed information respecting its financial arrangements.... [T]his may include information regarding a licensee's ability to continue the conduct of the activities authorized by the license...
1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML14195A110.
2 ADAMS Accession No. ML14311A681.
3 ADAMS Accession No. ML14311A292.
DRAFT
The finding of reasonable assurance that funds will be available to cover estimated operating costs for the period of the license relies on the applicant providing sufficient information regarding availability of credit or support agreements, bank lines of credit or other specifically identified sources of funds, sufficient to fund the estimated fixed operating and maintenance costs the period of the license.
RAI 6
Talen Energy Corp.s S-1 filing with the Securities and Exchange Commission on November 5, 2015, page 40 stated:
We face intense competition in the competitive power generation market, which may adversely affect our ability to operate profitablyWe believe that the commencement of commercial operation of new electricity generating facilities in the regional markets where we own or control generation capacity and the evolution of demand side management resources will continue to increase competition in the wholesale electricity market in those regions, which could have an adverse effect on electricity and capacity prices.
The ability of the licensee, PPL Susquehanna, and new parent company, Talen Energy Corp.,
to generate and access necessary funds may be impaired if the revenue and cash flow is significantly less than in the past.
a) Please address this concern generally.
b) The application indicated that sources of funds other than the revenue generated by SSES, specifically a parent support agreement and credit facility would be available to pay fixed operating costs during an outage of at least six months for SSES. Provide supporting financial information for the staff to evaluate the reasonableness of these sources of funds.
RAI 7
Talen Energy proposed two divestiture options in a filing with the Federal Energy Regulatory Commission July 15, 2014 (EC14-112). One involves divesting a total of seven plants in New Jersey and Pennsylvania for a total of 1,315 MW. The second involves divesting six Riverstone plants, plus a 399-MW coal-fired plant in Maryland and two PPL hydro plants in Pennsylvania for a total of 1,346 MW. Indicate how the divestiture plans will impact sources of funds available from Talen Energy Corp. or otherwise impact the financial qualifications of SSES.
RAI 8
Following the announcement that PPL Corp. (PPL) intended to spin-off the power generation subsidiary, PPL Energy (to become Talen Energy Corp.), Standard & Poor's Ratings Services and Fitch Ratings downgraded PPL Energy/Talen. Fitch cut PPL Energy to double-B from triple-B-minus and placed the company's ratings on rating watch negative. S&P lowered its rating on PPL Energy to double-B from double-B-plus, and placed it on CreditWatch negative.
DRAFT
Both ratings agencies cited the debt level of Talen following the transaction as a factor in their analysis. Provide the ratings agencies reports describing the credit downgrades.
RAI 9
As stated in their November 5, 2014, Security Exchange Commission S-1 filing, Talen Energy Corp., indicated that their debt level would be a financial risk factor:
Our indebtedness, which would have been approximately $3,693 million on a pro forma basis as of June 30, 2014, could adversely affect our financial condition and impair our ability to operate our business.
As of June 30, 2014, after giving effect to the Transactions, we would have had approximately $3,693 million in total indebtedness. See Capitalization. Our indebtedness could have important consequences to our future financial condition, operating results and business, including the following:
requiring that a substantial portion of our cash flows from operations be dedicated to payments on our indebtedness instead of other purposes, including operations, capital expenditures and future business opportunities; limiting our ability to obtain additional debt or equity financing for working capital, capital expenditures, debt service requirements, acquisitions and general corporate or other purposes; increasing our cost of borrowing; and limiting our ability to adjust to changing market and economic conditions and limiting our ability to carry out capital spending that is important to our growth.
The NRC has previously expressed concern about the financial impacts on NRC licensees resulting from holding company and LLC corporate structures.4 Absent specific corporate policies, Talen Energy Corp. may impact the financial viability of SSES by using the nuclear units earnings to fund other Talen Energy operations, leaving insufficient funds available for PPL Susquehanna for nuclear operations.
Provide further information regarding whether operating revenues from SSES will be transferred to Talen Energy Corp. Explain how sufficient equity and liquidity will be retained in PPL Susquehanna to maintain safe operations. Indicate if loans may be made from PPL Susquehanna to Talen Energy Corp. or any affiliated companies, providing supporting documentation as to the type and magnitude of any such loans.
RAI 10
In it July 31, 2014 SEC 10 Q filing, PPL Corp. stated:
Following the announcement of the transaction to form Talen Energy, efforts have been initiated to identify the appropriate staffing for Talen Energy and for PPL and its subsidiaries following completion of the spinoff. At present, there is considerable uncertainty as to the range of costs that will be incurred and when those costs will be recognized, as the amount of each category of costs will depend on the number of employees leaving the company, current position and compensation level, years of service and expected separation date. Additionally, 4
See SECY-93-025 and SECY-94-280.
DRAFT
certain of these costs are expected to be reimbursed to PPL by Talen Energy upon closing of the transaction. As a result, a range of the separation costs associated with the spinoff transaction and the timing of when those costs will be recognized cannot be reasonably estimated at this time but could be material.
Explain the impacts of reduced staffing on SSES operations. Provide an estimate of the costs that are expected to be reimbursed to PPL Susquehanna by Talen Energy.
DRAFT