ML17166A289
| ML17166A289 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Indian Point, Pilgrim, Vermont Yankee  |
| Issue date: | 06/20/2017 |
| From: | Couture P Entergy Nuclear Operations |
| To: | Office of Nuclear Reactor Regulation |
| Lamb, John, 415-3100 | |
| References | |
| Download: ML17166A289 (20) | |
Text
Licensing Action Submittal Plan - Decommissioning June 20, 2017
Agenda
- Background
- Major Milestones and Decommissioning Transition Actions (PAL/PNP/IPEC)
- Integrated Submittal Schedule (PAL/PNP/IPEC)
- Vermont Yankee Submittals
- Summary 1
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Background===
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Background
Vermont Yankee
- Permanently ceased operations on December 29, 2014 and permanently defueled on January 12, 2015
- Fuel transfer to dry storage expected to be completed by end of 2018
- Pursuing transfer of Part 50 license in order to facilitate accelerated decommissioning and license termination Palisades
- Intend to permanently cease operations on October 1, 2018 Pilgrim
- Intend to permanently cease operations no later than June 1, 2019 Indian Point
- Intend to permanently cease operations of Unit 2 by April 30, 2020 and Unit 3 by April 30, 2021
- Unit 1 is in SAFSTOR 1
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Background
- An integrated submittal plan for all 4 sites is provided to support NRC resource planning
- Overall goal is to provide for a safe and efficient transition from an operating site to a permanently defueled facility
- Two key milestone dates
- Permanently shutdown and defueled
- End of the zircfire period (assumed to be 18 months, for planning purposes)
- Need dates are 60 days in advance of key milestone dates
- Enables efficient implementation while preserving the decommissioning trust fund
- Provides certainty for employee transitions
- Requested approval dates may be more than 60 days in advance of milestone for licensing action requests submitted with more than 12 months lead time 1
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Background===
- Licensing submittals are based on
- Review of the regulations and guidance documents
- Review of industry guidance (NEI Guidance)
- Benchmarking and lessons learned from industry peers and within Entergy (e.g., Vermont Yankee and FitzPatrick),
including review of RAIs
- Licensing submittals will follow recent precedent
- Plan to use a staggered approach to submit the needed licensing actions, whenever practical 1
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Background===
- Goal is to submit licensing actions with 1224 months lead time, whenever practical
- Requesting the staff to complete its review by the need date in order to implement the licensing action at the site in a predictable and timely manner
- Some initial licensing actions are critical in ensuring a smooth transition from an operating staff model to one that is appropriate for a decommissioning facility, based on the reduced risk profile
- Scope and schedule are subject to change 1
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Major Milestones and Decommissioning Transition Actions (PAL/PNP/IPEC) 7
Major Milestones and Decommissioning Transition Actions PALISADES PILGRIM IP2 IP3 Planned Shutdown Date On 10/1/18 By 6/1/19 By April 30, 2020 By April 30, 2021 Licensing Action Need Date for Permanent Defueling 8/1/18 4/1/19 January 2020 January 2021 Licensing Action Need Date for Post ZircFire February 2020 October 2020 August 2021 August 2022 SUBMITTAL TARGET SUBMITTAL DATE Palisades Pilgrim IP2 IP3 Certified Fuel Handler Training and Retraining Program 3/28/17 Approved 4Q18 4Q19 License Amendment Request Supporting Staffing and Training 7/15/17 2/14/17 4Q18 4Q19 Requirements Changes in Administrative Technical Specifications License Amendment Request for Post Shutdown Emergency Plan 7/31/17 8/31/17 4Q18 4Q19 Exemption Request to Permit Suspension of Certain Security 7/15/17 2/7/17 4Q18 4Q19 Measures During Severe Weather Conditions (10 CFR 73.55(p)(1)(i) and (ii))
Bold indicates submittal has been made 8
Integrated Submittal Schedule (PAL/PNP/IPEC) 9
Integrated Submittal Schedule 24 Month Look Ahead 2Q17 3Q17 4Q17 1Q18 Palisades
- CFH Program
- Admin TS LAR
- LAR to modify
- EP Exemption
- 73.55 handling TS
- Records Exemption
- Permanently Defueled TS LAR 1
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Integrated Submittal Schedule 24 Month Look Ahead 2Q18 3Q18 4Q18 1Q19 Palisades
- Sitespecific QAPM
- Certification of
- EA03009 Order
- PSDAR/DCE Permanent Rescission (PWR
- EA02026 Partial Removal of Fuel RPV Head Rescission
- Decommissioning Inspection)
- Fukushima Orders QAPM
- Onsite/Offsite Rescission Insurance/Liability Exemptions
- Eliminate Cyber Security License Condition LAR Pilgrim
- EA06137 Order
- Commingled Fund Rescission
- EP Exemption Exemption
- EA02026 Partial
- Records
- PSDAR/DCE Rescission Exemption
- Sitespecific QAPM IP2
- CFH Program
- Admin TS LAR
- 73.55 Exemption 1
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Integrated Submittal Schedule Item Submittal Target Submittal Date Associated Palisades Pilgrim IP2 IP3 Decommissioning Milestone 1 Certification of Permanent Cessation of Power Operations 1/4/17 TBD TBD TBD Permanent Shutdown 2 Certified Fuel Handler Training and Retraining Program 3/28/17 Approved 4Q18 4Q19 Permanent Removal of Fuel 3 License Amendment Request Supporting Staffing and Training 7/15/17 2/14/17 4Q18 4Q19 Permanent Requirements Changes in Administrative Technical Specifications Removal of Fuel 4 License Amendment Request for Post Shutdown Emergency Plan 7/31/17 8/31/17 4Q18 4Q19 Permanent (ERO onshift and augmented staff changes) Removal of Fuel 5 Exemption Request to Permit Suspension of Certain Security 7/15/17 Approved 4Q18 4Q19 Permanent Measures During Severe Weather Conditions (10 CFR 73.55(p)(1)(i) Removal of Fuel and (ii))
6 License Amendment Request for Permanently Defueled Technical 6/1/18 3/31/18 1Q19 1Q20 Permanent Specifications/Bases and Revised License Conditions Removal of Fuel 7 License Amendment Request to Remove Irradiated Fuel Handling 10/31/17 N/A N/A N/A Permanent related Tech Specs Removal of Fuel 8 Exemption Request for Use of the Decommissioning Trust Fund for N/A 3/1/19 January January Permanent Spent Fuel Management Expenses 2020 2021 Removal of Fuel 9 Submittal of PostShutdown Decommissioning Activities Report 5/1/18 3/1/19 January January Permanent (PSDAR)/Site Specific Decommissioning Cost Estimate 2020 2021 Removal of Fuel Bold indicates submittal has been made 1
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Integrated Submittal Schedule Item Submittal Target Submittal Date Associated Palisades Pilgrim IP2 IP3 Decommissioning Milestone 10 Irradiated Fuel Management Plan (10 CFR 50.54(bb)) 10/1/20 3/1/19 January January Permanent 2020 2021 Removal of Fuel 11 Certification of Permanent Removal of Fuel 10/31/18 6/30/19 May May Permanent 2020 2021 Removal of Fuel 12 Modifications to parent company financial support N/A 3/1/19 January N/A Permanent arrangements 2020 Removal of Fuel 13 Exemption Request to Certain 10 CFR 50.47 and 10 CFR 50, 2/1/18 12/1/18 4Q19 4Q20 End of Zircfire Appendix E Emergency Preparedness Requirements Period 14 License Amendment Request for Permanently Defueled 2/1/18 12/1/18 4Q19 4Q20 End of Zircfire Emergency Plan Period 15 Exemption request for onsite property damage insurance (10 2/1/19 12/1/19 1Q20 1Q21 End of Zircfire CFR 50.54(w)(1)) Period 16 Exemption request for offsite liability insurance 2/1/19 12/1/19 1Q20 1Q21 End of Zircfire requirements (10 CFR 140.11(a)(4)) Period 17 Exemption Request Regarding Maintenance of Records 1/31/18 10/31/18 3Q19 3Q20 Permanent Removal of Fuel 18 License Amendment Request to Delete Cyber Security 2/1/19 8/31/19 3Q20 3Q21 End of Zircfire License Condition Period 19 License Amendment Request to Delete NFPA805 License 10/15/17 N/A N/A N/A Permanent Condition Removal of Fuel 1
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Integrated Submittal Schedule Item Submittal Target Submittal Date Associated Palisades Pilgrim IP2 IP3 Decommissioning Milestone 19 QA Program Change Sitespecific QAPM 7/1/18 3/1/19 March March N/A 2020 2021 20 QA Program Change - Decommissioning QAPM 10/31/18 6/30/19 May May Permanent 2020 2021 Removal of Fuel 21 EA06137 Order Rescission* (BWR Radiological Mitigation N/A 6/1/18 N/A N/A Permanent Strategies) Removal of Fuel 22 EA02026 Partial Order Rescission* (Mitigation Strategies) 4/1/18 6/1/18 4Q19 4Q20 Permanent Removal of Fuel 23 Fukushima Orders (EA12049, EA12051, EA13109 4/1/18 12/1/18 4Q19 4Q20 Permanent (Pilgrim))* Removal of Fuel 24 EA03009 Order Rescission (PWR RPV Head Inspection) 3/31/19 N/A 4Q19 4Q20 Permanent Removal of Fuel 1
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Vermont Yankee Submittals 15
Vermont Yankee SUBMITTAL SUBMITTAL REQUEST DATE APPROVAL BY License Transfer Application 2/9/17 12/31/17 License Amendment Request for ISFSI Physical Security Plan 3/29/17 6/30/18 License Amendment Request for ISFSI Emergency Plan and EALs 5/15/17 6/30/18 License Amendment Request for Tech Specs Permanent Removal of 6/30/17 5/31/18 Fuel from SFP and Operating License Changes QA Program Changes Involving Reduction in Commitments to Support 6/30/17 5/31/18 ISFSI Operations Exemption Request from certain requirements of 10 CFR 72.212 and 5/17/17 10/31/17 10 CFR 72.214 (Holtec CoC Cooling time 2 years and higher DHR) 10 CFR 20.2002 Request for Alternate Disposal at U.S. Ecology - Idaho 1/14/16 4/15/16 (Contaminated water disposal)
License Amendment Request for Cyber Security Milestone 8 Extension 5/1/17 12/15/17 Bold indicates submittal has been made 1
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Summary 17
Summary
- Entergy announced closure of Palisades on October 1, 2018, Pilgrim no later than June 1, 2019, Indian Point Units 2 and 3 by April 30, 2020 and Unit 3 by April 30, 2021, respectively
- Priority is to have licensing actions needed to support efficient and timely staffing transition from operations to decommissioning approved at least 60 days prior to the planned closures of Palisades and Pilgrim
- Priority for Vermont Yankee is a timely review and approval of the licensing actions needed to support the accelerated fuel loading campaign and transfer of the Part 50 license
- A list of decommissioning licensing actions is being provided to the NRC for advance notice
- Dates and scope are best estimates and subject to change 1
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