ML18262A135

NRC License Transfer Application 9/25/2018 Pre-Submittal Meeting Presentation Slides

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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HOLTEC INTERNATIONAL Pilgrim Nuclear Power Station NRC License Transfer Application Pre-Submittal Meeting 25 September 2018 Pamela Cowan, Sr. VP and COO, Holtec Decommissioning International Steven Scheurich, VP Nuclear Decommissioning, Entergy

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HOLTEC I NTERNAT IO NA L Update on Pilgrim Status

• Current staffing level: "'585 utility and security employees

• 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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HOLTEC I NTERNAT I ONA L Transaction Overview

• 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 I NTE R NATIONA L Holtec Nuclear StewardshiQ Nuclear Manufacturing Commitment to Facility Owner SNC Lavalin Nuclear Partnerships Core Strategy Strong Financial Position Fuel Casks - Product line leader

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• Operating Site Fuel Transfer NRC Experience I *****~ = -

-~ ~- I-SMR New < *-:.~ -.. O&D Site Turnkey Fuel Build HOLTEC Transfer projects I N TERNATI O NA L Consolidated

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Interim Fuel Storage

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Decommissioning Investing in Nuclear is an integral part of Ho/tee's long-term strategy

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11,U l>Owta Of P(OHl HOLTEC I NTERNATIONA L Holtec Decommissioning Fleet Strategy Establish, Implement & Advance the Industry Decommissioning Baseline Qualified and "Fleet-Based" Procedures &

Experienced Approach Processes Personnel Based on nuclear industry Existing Holtec nuclear- Adopt NRC-approved site operating fleet model experienced personnel programs, processes and procedures Additional nuclear plant Drive lessons learned experienced personnel Maintain compliance with site across sites license & NRC regulations Partner with SNC-Lavalin Maximize Maintain, protect & control standardization Integrate site organization at spent nuclear fuel license transfer Drive technology Ensure environmental &

innovation Qualified industry vendors personnel protection

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HOLTEC IN TERNAT I ONA L Holtec Team

• Spent fuel management and nuclear services

• ETR Fleet spent fuel cask/storage vendor 1111111111 Holtec International Provide resources and oversight to support the HOLTEC INTERNATIONAL safe, compliant operation of the acquired sites Holtec Power, Inc.

• Pilgrim licensed operator

• Wholly-owned Holtec subsidiary 1111111111 HOLTEC DECOMMISSIONING INTERNATIONAL licensed operator for all decommissioning sites Holtec Pilgrim, Holtec Deconvnissioning in the Ho/tee fleet, including Pilgrim LLC International, LLC (Licensed Owne,j (Licensed Operator}

Comprehensive

• Pilgrim Decommissioning General Contractor (DGC) Decommissionino International, LLC

• Jointly owned by Holtec/SNC-Lavalin (DGC)

• Extensive decommissioning project experience C;)I Comprehensive Decommissioning International A Holtec and SNC* Lavalin Company DGC for the Ho/tee fleet

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lN r ,ow11 o, ,,o,Lr HOL TEC I NTrRNATIONAI Holtec's Decommissioning Timeline SAFSTOR Timeline 2019 2024 2062 End Dry Storage 2075 2!3j 2084 Ho/tee's Planned Accelerated*DECON Timeline 2019 2021 2027

! t 2062 I 2064 Holtec Decommissioning Complete/NRC License Ownership Amended to ISFSI Only 2063 Accelerates Decommissioning from 2083 to 2027 License Termination Complete - 2063 vs. 2083 *

• Assumes DOE Fuel Pick-Up Complete in 2062 Note: Dates subject to change 7

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1Hf .. OWtl Of .. lOl'lf HOLTEC I NTERNATIONA L 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

• 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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HOLTEC INTERNATIONAi Technical Qualifications

• 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 HOLTEC INTERNATIONA L 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, 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 HDI Holtec Executive Committee 1-----;

President &

CNO L- HDI

- - - - - - - - - - - 1 VP Quality Assurance and Nuclear Oversight HDI Senior Vice President &

Chief Operating Officer COi President HDI HDI HDI VP Licensing VP Treasurer & NOT VP Technical Management Support HDI - Pilgrim COi Site VP VP for Corporate Operations COi - Pilgrim Decommissioning General Manager Decommission ing Deputy General Manager Regulatory Spent Fuel Radiation PNPS Incumbent Waste Decommissioning Project Affairs Management Protection Organization at the Management Projects Controls

...J time of License 1 Transfer

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HOLTEC INTERNATIONAL 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

- 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 HOLTEC INTERNATIONAi Next Steps: Regulatory Plan License Transfer Application {joint submittal with Entergy) October 2018 DECON PSDAR including site-specific DCE October 2018 Revised Spent Fuel Management Plan October 2018 Exemption request to use NDT funds for SFM and Site October 2018 Restoration Request License Transfer Application approval April 2019