ML18262A135
| ML18262A135 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/25/2018 |
| From: | Cowan P, Scheurich S Entergy Nuclear Operations, Holtec |
| To: | Office of Nuclear Reactor Regulation |
| Lamb J, NRR/DORL/LSPB, 301-415-3100 | |
| References | |
| Download: ML18262A135 (15) | |
Text
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Pilgrim Nuclear Power Station NRC License Transfer Application Pre-Submittal Meeting 25 September 2018 HOLTEC INTERNATIONAL Pamela Cowan, Sr. VP and COO, Holtec Decommissioning International Steven Scheurich, VP Nuclear Decommissioning, Entergy
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Update on Pilgrim Status
- Current staffing level: "'585 utility and security employees HOLTEC I NTERNAT IO NA L
- Pilgrim to permanently cease operations no later than June 1, 2019
- Anticipate permanently defueling reactor within "'30 days post-shutdown
- Entergy will select "'300 Decommissioning Organization employees from incumbent staff and transition prior to transaction closing
- Target filing Entergy's PSDAR/DCE and related submittals by end of October 2018
- Ongoing commitment to open and transparent communications with:
Local stakeholders (e.g., Citizens Advisory Panel)
Employees
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Transaction Overview HOLTEC I NTERNAT IONA L On July 31, 2018, executed an Equity Purchase and Sale Agreement for sale of Entergy Nuclear Generation Company (ENGC) to Holtec subsidiary Nuclear Asset Management Company, LLC Post-sale, ENGC will remain the owner licensee (and will be renamed Holtec Pilgrim, LLC)
Holtec Decommissioning International (HDI) will become licensed operator HDI will contract with Comprehensive Decommissioning International (CDI) to serve as the Decommissioning General Contractor Holtec Pilgrim will remain the owner of:
Pilgrim site, including associated assets; primarily the Pilgrim Nuclear Decommissioning Trust (NDT) and liabilities; primarily the decommissioning obligation Title to spent nuclear fuel and DOE Standard Contract All Pilgrim Decommissioning Organization employees at the time of transaction closing will be offered positions with CDI Transaction closing dependent upon several conditions, including NRC license transfer approval
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Holtec Nuclear StewardshiQ Commitment to Nuclear Strong Financial Position Fuel Casks - Product line leader SMR New Build I
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Consolidated Interim Fuel Storage Nuclear Manufacturing Facility Owner Core Strategy Operating Site Fuel Transfer
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HOLTEC SNC Lavalin Partnerships NRC Experience O&D Site Turnkey Fuel Transfer projects I N TERNATI O NA L I-
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_,....--3all Decommissioning HOLTEC I NTE RNATIONA L Investing in Nuclear is an integral part of Ho/tee's long-term strategy
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HOLTEC 11,U l>Owta Of P(OHl I NTERNATIONA L Holtec Decommissioning Fleet Strategy Establish, Implement & Advance the Industry Decommissioning Baseline "Fleet-Based" Approach Based on nuclear industry operating fleet model Drive lessons learned across sites Maximize standardization Drive technology innovation Qualified and Experienced Personnel Existing Holtec nuclear-experienced personnel Additional nuclear plant experienced personnel Partner with SNC-Lavalin Integrate site organization at license transfer Qualified industry vendors Procedures &
Processes Adopt NRC-approved site programs, processes and procedures Maintain compliance with site license & NRC regulations Maintain, protect & control spent nuclear fuel Ensure environmental &
personnel protection
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Holtec Team
- Spent fuel management and nuclear services
- ETR Fleet spent fuel cask/storage vendor Provide resources and oversight to support the safe, compliant operation of the acquired sites
- Pilgrim licensed operator
- Wholly-owned Holtec subsidiary licensed operator for all decommissioning sites in the Ho/tee fleet, including Pilgrim 1111111111 HOLTEC INTERNATIONAL 1111111111 HOLTEC DECOMMISSIONING INTERNATIONAL
- Pilgrim Decommissioning General Contractor (DGC)
- Jointly owned by Holtec/SNC-Lavalin C;)I Comprehensive
- Extensive decommissioning project experience Decommissioning International A Holtec and SNC*Lavalin Company DGC for the Ho/tee fleet HOLTEC IN TERNAT I ONA L Holtec International Holtec Power, Inc.
Holtec Pilgrim, LLC (Licensed Owne,j Holtec Deconvnissioning International, LLC (Licensed Operator}
Comprehensive Decommissionino International, LLC (DGC)
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lN r,ow11 o,,,o,Lr Holtec's Decommissioning Timeline SAFSTOR Timeline 2019 2024 Ho/tee's Planned Accelerated*DECON Timeline 2019 Holtec Ownership 2021 2027 Decommissioning Complete/NRC License Amended to ISFSI Only 2062 2075 End Dry Storage
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2062 I 2064 2063 Accelerates Decommissioning from 2083 to 2027 License Termination Complete - 2063 vs. 2083
- HOL TEC I NTrRNATIONAI 2!3j 2084
- Assumes DOE Fuel Pick-Up Complete in 2062 Note: Dates subject to change 7
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1Hf.. OWtl Of.. lOl'lf Financial Qualifications Pilgrim NDT satisfies 10 CFR 50.7S(e)(l)(i) as a prepayment method of providing decommissioning financial assurance NDT will be retained by Holtec Pilgrim, LLC NDT balance was approximately $1.086 billion as of August 31, 2018 HOLTEC I NTERNATIONA L NDT value at transaction closing will be sufficient to fund the costs of radiological decommissioning, spent fuel management, and site restoration under the Holtec plan LTA that provides schedule and financial data supporting the adequacy of the NDT fund including the following:
Decommissioning, spent fuel management and site restoration costs by category Annualized decommissioning cost estimate with reasonable contingency assumptions Cash flow analysis NDT value at closing is sufficient to meet the 10 CFR 50.75(e}(l)(i)
- ment method of orovidina financial assurance
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Technical Qualifications HOLTEC INTERNATIONAi
- HDI will integrate existing Pilgrim knowledge and incumbent staff to support HDI site organization HDI will adopt existing NRC-approved programs, processes and procedures for Pilgrim Existing Pilgrim site organization at the time of license transfer will be integrated into the COi site organization including:
- Plant Operations Emergency Planning Security HDI will have full control and oversight over CDI, including the site organization
- HDI/CDI team will jointly conduct transition readiness assessments with Entergy prior to license transfer HD/ is technically qualified to ensure compliance with the NRC licenses and regulations
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tHf,ow,11 o, PlOHf Technical Qualifications HDI/CDI team possesses extensive experience in nuclear operating, decommissioning, and spent fuel management Ability to draw from Holtec's technical resources (R&D, engineering, HOLTEC INTERNATIONA L manufacturing facilities) and experienced personnel to support decommissioning HDI managed by senior Holtec personnel Mature nuclear safety culture Draw from existing corporate nuclear programs (e.g.,: QA, project management)
Ability to draw from COi's and SNC-Lavalin's technical resources and experience in decommissioning SNC-Lavalin corporate family includes Atkins and former EnergySolutions' Projects, Products and Technology division Extensive experience in decommissioning planning, project management and engineering, decommissioning cost estimating, waste management Management team experience on Zion, Magnox, research reactor and other decommissioning projects
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HOLTEC IN T ERNA T IONA L HDI Decommissioning Organization Holtec Executive Committee 1-----;
HDI President &
CNO HDI HDI VP Licensing VP Treasurer & NOT Management Regulatory Affairs
...J Decommission ing Deputy General Manager Spent Fuel Management Radiation Protection L-HDI
1 VP Quality Assurance HDI Senior Vice President &
Chief Operating Officer HDI - Pilgrim Site VP COi - Pilgrim Decommissioning General Manager PNPS Incumbent Organization at the time of License Transfer and Nuclear Oversight HDI VP Technical Support Waste Management 1 COi President COi VP for Corporate Operations Decommissioning Projects Project Controls
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Other License Transfer Reguirements
- Spent Fuel Management Holtec Pilgrim, under Holtec ownership, will retain SNF rights and obligations pursuant to DOE standard contract Holtec will be responsible for ISFSI decommissioning HOLTEC INTERNATIONAL Spent fuel management activities funded by NDT, contingent on NRC approval of exemption request to be submitted by Holtec Foreign ownership, control, and domination (FOCD)
No FOCD issues Holtec Board of Directors are all U.S. Citizens Holtec and the licensee entities are not owned, controlled or dominated by any foreign person
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- Nuclear Insurance Holtec will obtain onsite property damage insurance coverage and offsite nuclear liability coverage as required Proof of the coverage will be provided to the N RC prior to license transfer
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1w 1,ow 1a or,,.o,Lt HOLTEC INTERNATIONAL License Transfer Accelerates Decommissioni~g LTA satisfies NRC requirements/guidance:
Technical qualifications Financial qualifications for decommissioning funding Foreign ownership and insurance requirements License transfer is in the public interest:
Prompt decommissioning of Pilgrim (,v8 years post sale)
Utilizes incumbent Pilgrim employees Potential repurpose of site by the owner Holtec commitment to local community and to be a fair partner
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nu.. ow(a or Pf;O,l r Next Steps: Regulatory Plan License Transfer Application {joint submittal with Entergy)
DECON PSDAR including site-specific DCE Revised Spent Fuel Management Plan Exemption request to use NDT funds for SFM and Site Restoration Request License Transfer Application approval HOLTEC INTERNATIONAi October 2018 October 2018 October 2018 October 2018 April 2019