ML18226A002
| ML18226A002 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/14/2018 |
| From: | Gallagher M Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation |
| Lamb J, NRR/DORL/LSPB, 415-3100 | |
| References | |
| Download: ML18226A002 (20) | |
Text
Oyster Creek Nuclear Generating Station Decommissioning Michael Gallagher Vice President License Renewal & Decommissioning, Exelon Generation NRC Pre-Submittal Meeting for License Transfer Application August 15, 2018
Agenda
Introductions
Current Status of Oyster Creek Overview of Holtec International and Partners License Transfer Application Submittal Schedule 1
Current Status of Oyster Creek
- Current staffing level ~450 PSDAR Timeframes
- Planned for permanent shut-down in September 2018
- March 2020 - Dec. 2073:
- Post Shutdown Decommissioning Dormancy Activities Report submitted on May 21, 2018
- March 2024: all fuel moved to
- June 2076: large component
- Planning for SAFSTOR has been removal complete performed while ensuring an efficient
- Dec. 2077: plant systems removal shift to DECON can be made at any and building decontamination time complete
- In all strategies, moving fuel to dry storage as soon as possible reduces
- Sept 2078: license termination risk and is the most efficient option
- April 2080: site restoration
- Should the transaction not close or the license not transfer, Exelon Generation will maintain Oyster Creek in SAFSTOR in accordance with the PSDAR 2
Oyster Creek Nuclear Generating Station Decommissioning License Transfer Application NRC Pre-Submittal Meeting 15 August 2018 www.holtec.com
About Holtec & Its Partner Parent Companies Holtec Decommissioning Subsidiaries International CDI is jointly owned by Holtec and SNC-Lavalin with Holtec as the majority owner 2
Holtec Nuclear Stewardship Nuclear Manufacturing Facility Owner Site ownership is an integral part of Holtec's long-term strategy 3
Holtec Financial Strength
- US company, headquartered in Camden, NJ
- Profitable in every year of operation since Holtec began 30 years ago
- Large and diversified customer base in US and 16 foreign countries
- No long term debt 4
Founded in 1911, SNC-Lavalin is a publicly traded company providing professional services and project management solutions Core Business
- OEM component supplier
- Decommissioning planning, project management and engineering
- Decommissioning cost estimating
- Waste management Financials
- Sustained growth with over
$15 billion (CAD) in backlog
- Strong credit ratings, Standard & Poors Rating BBB/stable Decommissioning
- DOE O&M Projects experience
- Management Team experience on Zion, Magnox, research reactor and other decommissioning projects Team members led planning and execution on these projects 5
SNC-Lavalin Group SNC-Lavalin
- Global engineering and construction group
- Developer and OEM of the CANDU reactor technology
- Acquired Atkins in 2017 ATKINS
- Wholly-owned subsidiary of SNC-Lavalin
- Extensive experience in nuclear cleanup and decommissioning activities
- Key acquisition of EnergySolutions Projects, Products, and Technology Division in 2017 6
Holtec Team Holtec International
- Private entity
- Spent fuel management and nuclear services Holtec International
- HI-STORE CIS Facility (New Mexico) Application
- SMR Program (partnership with SNC-Lavalin)
- ETR Fleet spent fuel cask/storage vendor Holtec Power, Inc.
Holtec Decommissioning International
- Wholly-owned Holtec subsidiary Holtec
- Formed to maintain Holtec owned decommissioning Nuclear Asset Decommissioning Management plants Company, LLC International, LLC (Licensed Operator)
- Resourced to manage licensed and decommissioning activities at permanently shutdown and defueled sites.
Oyster Creek Comprehensive
- Will become licensed operator for Oyster Creek Environmental Decommissioning Protection, LLC CDI (Comprehensive Decommissioning International) (Licensed Owner)
International, LLC
- Jointly owned by Holtec/SNC-Lavalin
- Decommissioning General Contractor (DGC) 7
Exelon Oyster Creek SAFSTOR Timeline Shutdown/ Move fuel to SAFSTOR Fuel License Site permanent ISFSI pad and ISFSI removed SAFSTOR only D&D Termination Restoration defuel complete operations from site 2018 2024 2033 2034 2034-2075 2075-2077 2078 2080 Holtecs Planned Accelerated DECON Timeline Shutdown/ Move fuel to Fuel ISFSI License permanent ISFSI pad D&D removed operations Termination defuel complete from site 2018 2019 2021 2027 2033 2034 2035 Holtec Partial Site Ownership Release/Site Restoration* *Excludes ISFSI
- Assumes Spent Fuel Removal Complete in 2034 Accelerates Decommissioning from 2077 to 2027 License Termination Complete in 2035 vs. 2078**
Decommissioning Organization Holtec Holtec Executive Decommissioning Committee International President & CNO HDI VP Quality Assurance and Nuclear Oversight HDI Senior Vice President &
Chief Operating Officer HDI HDI HDI - Oyster Creek HDI VP Treasurer & NDT VP Licensing Site VP VP Technical Support Management Comprehensive Decommissioning International President CDI - OC Decommissioning General Manager Spent Fuel Radiation Protection Plant Operations Decommissioning Regulatory Affairs Waste Management Project Controls Management Manager Oyster Creek Phase II Projects Organization 9
Regulatory Plan Submittal Date Purchase and Sale Agreement July 31, 2018 (completed)
License Transfer Application (joint August 17, 2018 submittal with Exelon)
Revised PSDAR to reflect DECON Early September 2018 including DCE update Revised Spent Fuel Management Plan Early September 2018 Exemption request to use NDT funds Early September 2018 for SFM and Site Restoration License Transfer approval Request NLT May 2019 10
Compliance with NRC Regulations License Transfer Application NRC Regulation Review Areas Application contents and NRC reviews 10 CFR 50.80 Financial Qualifications and Financial 10 CFR 50.33 Assurance 10 CFR 50.75 10 CFR 50.40(b),
10 CFR 50.34 Technical Qualifications NUREG-0800, 13.1.1-13.1.3 Regulatory Guide 1.8; ANSI 3.1 Foreign Ownership, Control or 10 CFR 50.38 Domination 11
Compliance with NRC Regulations License Transfer Application NRC Regulation Review Areas 10 CFR 50.54(w)(1)
Insurance and Indemnity 10 CFR 140.11(a)(4)
Quality Assurance 10 CFR 50 Appendix B No Significant Hazards Considerations 10 CFR 2.1315(a) and Conforming Amendment 10 CFR 51.22(b)
Environmental Consideration 10 CFR 51.22(c)(21) 12
Technical Approach Holtec team will accomplish the following:
- Maintain the plant in compliance with the site license and NRC requirements
- Oversee the completion of the ISFSI expansion
- Perform radiological decommissioning
- Relocate spent fuel from the wet to dry storage
- Store, control and protect the nuclear spent fuel
- Decommission the ISFSI
- Restore the site 13
Why this strategy?
- Accelerate moving the nuclear spent fuel from the pool to the pad
- Uses a qualified and integrated team
- Focused on site compliance with license and regulations
- Accelerate the decommissioning and waste removal
- Reduced risk of radiological release
- Earlier release of the site for beneficial use 14
Transition Plan
- Readiness assessment prior to license transfer
- Establish a seamless integrated organization on site
- Adopt existing Programs, Procedures and Processes
- Employ remaining Oyster Creek site personnel
- Oyster Creek incumbent manager targeted for HDI Site VP position Seamless transition at License Transfer Compliance Maintained 15
Conclusion License Transfer for Accelerated Decommissioning Oyster Creek License Transfer Application will satisfy NRC requirements and guidance
- 1. Technical Qualifications
- 2. Financial Qualifications and Decommissioning Funding
- 3. Foreign Ownership, Control, or Domination
- 4. Nuclear Insurance and Indemnity
- 5. Commitment and Focus on Nuclear Safety Accelerated decommissioning is in the public good
- 1. Achieves prompt decommissioning of Oyster Creek
- 2. Accelerates potential re-purpose of the site
- 3. Sets stage for irradiated fuel transfer to ISFSI 16
Next Steps Milestones Target Date Joint Exelon and Holtec LTA Submittal August 2018 Holtec submits Revised PSDAR/DCE, Spent Fuel Plan September and Exemption to use NDT funds (Spent Fuel 2018 Management and Site Restoration)
Oyster Creek NRC approvals May 2019 Exelon shutdown and defueling
- NRC certifications of permanent cessation of October 2018 operations and permanent defuel Oyster Creek Transaction Close July 2019 CONFIDENTIAL 17