ML18275A395

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9/25/2018 Summary of Pre-submittal Meeting with Entergy Nuclear and Holtec International to Discuss Potential License Transfer Application for Pilgrim Nuclear Power Plant
ML18275A395
Person / Time
Site: Pilgrim
Issue date: 10/12/2018
From: John Lamb
Special Projects and Process Branch
To:
Entergy Nuclear Operations
Lamb J, NRR/DORL/LSPB, 301-415-3100
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ML18275A403 List:
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Download: ML18275A395 (9)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 12, 2018 LICENSEE: Entergy Nuclear Operations, Inc.

FACILITY: Pilgrim Nuclear Power Station

SUBJECT:

PUBLIC MEETING WITH THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC. REGARDING PRE-SUBMITTAL OF A LICENSE TRANSFER APPLICATION TO HOLTEC INTERNATIONAL FOR PILGRIM NUCLEAR POWER STATION On September 25, 2018, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of the Entergy Nuclear Operations, Inc. (Entergy), at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was for NRC and Entergy to discuss the pre-submittal of a license transfer application for the sale of Pilgrim Nuclear Power Station (Pilgrim) to Holtec International (Holtec).

On September 6, 2018, a meeting notice and agenda was issued (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18249A324).

The meeting began at 1:30 p.m. with opening remarks by the NRC staff followed by a roll call of attendees (see Enclosure).

By letter dated November 10, 2015 (ADAMS Accession No. ML15328A053), Entergy submitted its certification to permanently cease power operations at Pilgrim no later than June 1, 2019, pursuant to Section 50.82(a)(1 )(i) of Title 10 of the Code of Federal Regulations (10 CFR).

On August 1, 2018, Holtec announced an agreement between Holtec and Entergy for Holtec to purchase Pilgrim. Under the terms of the agreement, which is subject to regulatory approvals, Holtec will assume ownership of the site, real property and used nuclear fuel. The full announcement can be found at https://holtecinternational.com/2018/08/01 /holtec-international-to-acq uire-pilgrim-and-palisades-sites-from-entergy-after-their-reactors-shutdown-proto-prom pt-decommissioning-planned-for-bot h-sites/#more-157 44.

The Entergy/Holtec staff provided a presentation (ADAMS Accession No. ML18262A135).

Entergy stated that approximately 585 people are currently employed at Pilgrim. Entergy plans to permanently defuel within approximately 30 days of permanent shutdown on June 1, 2019.

Entergy said it plans to select approximately 300 decommissioning organization employees.

The company expects to submit the Pilgrim Post-Shutdown Decommissioning Activities Report (PSDAR) by the end of October 2018. Entergy plans to select SAFSTOR as a decommissioning strategy for Pilgrim. In accordance with 10 CFR 50.82(a)(3),

decommissioning will be completed within 60 years of permanent cessation of operations. If the

license transfer of Pilgrim from Entergy to Holtec is not approved, Entergy will go forth with the SAFSTOR decommissioning strategy for Pilgrim.

The proposed Entergy decommissioning plan has the following timeframes:

  • 2019 - 2024: Fuel transfer,
  • 2024 - 2075: SAFSTOR and independent spent fuel storage installation (ISFSI) operations,
  • 2062: End dry storage,
  • 2075 - 2083: Decontamination and decommissioning (D&D) and license termination, and
  • 2083 - 2084: Site restoration.

Holtec Decommissioning International (HDI) presented information regarding the company and its partners, parent companies, subsidiaries, and joint ventures.

HDI explained its financial strength. HDI discussed the company, SNC-Lavalin, as well as the company, Atkins. HDI talked about the Holtec team, including the joint venture by Holtec and SNC-Lavalin known as Comprehensive Decommissioning International (COi). COi is a decommissioning general contractor. The company that would own Pilgrim if the license transfer is approved is known as Holtec Pilgrim, LLC, and HDI would be the licensed operator.

HDI would select DEGON as a decommissioning strategy for Pilgrim if the license transfer is approved. Under DEGON (immediate dismantling), soon after the nuclear facility closes, equipment, structures, and portions of the facility containing radioactive contaminants are removed or decontaminated to a level that permits release of the property and termination of the NRC license.

The HDI plan has the following timeframes:

  • 2019 - 2021: Fuel transfer,
  • 2021 - 2027: D&D and site restoration,
  • 2027 - 2062: ISFSI operations,
  • 2062 - 2063: License termination, and
  • 2064: Site restoration.

HDI described (1) the decommissioning organization structure, (2) its financial and technical qualifications, (3) spent fuel management plan, (4) foreign ownership, control, or domination, and (5) nuclear insurance.

HDI plans to submit the following:

  • License transfer with Entergy in October 2018,
  • The DEGON PSDAR including site-specific decommissioning cost estimate in October 2018,
  • The revised spent fuel management plan in October 2018,
  • Exemption request to use decommissioning trust funds for spent fuel management and site restoration in October 2018, and
  • License transfer approval in April 2019.

The NRC staff asked questions regarding the Entergy and Holtec interactions with the Commonwealth of Massachusetts Nuclear Decommissioning Citizens Advisory Panel (NDCAP);

finances; decommissioning trust fund (DTF); company structure; the Holtec Pilgrim, LLC, the potential licensed owner; HDI, the potential licensed owner; SNC-Lavalin; contingency plans if assumptions change; and regulatory approvals needed.

Christopher Burk, Legislative Fellow from the Office of Congressman William R. Keating (D-MA, 9th District), asked about the size of the current Pilgrim work force and the proposed size of the Pilgrim work force after the license transfer. Entergy stated that Pilgrim currently has approximately 585 employees and plans to have approximately 300 employees for decommissioning.

Lindsey Baxter Griffith, Legislative ~ssistant from the Office of Senator Edward J. Markey (D-MA), asked if the site cleanup will be to a 1O millirem standard and not the NRC 25 millirem standard and does Entergy have an agreement with the Commonwealth of Massachusetts.

Entergy stated that it does not have an agreement with the Commonwealth of Massachusetts, but Entergy will be meeting with the Commonwealth of Massachusetts. Entergy also stated that some Entergy agreements will be passed onto Holtec with the license transfer and other Entergy agreements will be re-negotiated or terminated.

Michael Jackman, District Director from the Office of Congressman William R. Keating, asked about work force level and agreements with the labor unions. COi responded that Holtec is talking with the unions and plans to take over the Collective Bargaining Agreements that

  • Entergy has with the unions:

Jim Cantwell, State Director from the Office of Senator Edward J. Markey, asked about the decommissioning trust fund (DTF) and a finding of public interest for the license transfer. The NRC staff stated that d.ecommissioned licensees are required to report to the NRC annually on the status of the DTF, and the NRC staff reviews the DTF report to determine whether there is reasonable assurance that there is enough money in the DTF to complete decommissioning.

Shawn Mullin, Co-Chair of NDCAP, asked about the process for public involvement and comments. The NRC staff stated that the license transfer application will be noticed in the Federal Register that will allow 30 days for comments and 20 days to request a hearing.

Donna Gilmore of San Onofre Safety made comments related to the fuel loading incident on August 3, 2018, at San Onofre Nuclear Generating Station. The NRC sent a team to evaluate an incident in which a loaded fuel storage canister became stuck while being lowered into an underground storage vault. The Special Inspection began on September 10, 2018. An inspection report documenting the Special Inspection team's findings will be publicly available within 45 days of the end of the inspection.

Mary Lampert of Pilgrim Watch asked about the Holtec corporate structure, the limited liability corporations, lawsuits with the Department of Energy, dry cask repairs, and dry cask warranties.

At this meeting, the NRC staff made no regulatory decisions regarding the merits of the proposed license transfer for Pilgrim.

The meeting was adjourned at 3:32 p.m.

/JcYJ mb, Senior Project Manager rojects and Process Branch Divisi of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

List of Attendees cc: Listserv

LIST OF ATTENDEES PUBLIC MEETING BETWEEN ENTERGY NUCLEAR OPERATIONS, INC. (ENTERGY) AND THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) STAFF TUESDAY, SEPTEMBER 25, 2018 1:30 p.m. - 3:30 p.m.

ONE WHITE FLINT NORTH, ROOM 0-1084 NAME ORGANIZATION Lindsey Baxter Griffith Office of Senator Markey (Massachusetts, MA)

Christopher Burk Office of Congressman Keating (MA-91h District)

Jim Cantwell* Office of Senator Markey (MA)

Hannah Vogel* Office of Senator Markey (MA)

Rory Clark* Office of Senator Markey (MA)

Edward Rupia* Office of Senator Warren (MA)

Michael Jackman* Office of Congressman Keating (MA-9th District)

Joseph Derfler* Office of the Attorney General of the Commonwealth of MA Doug Broaddus NRC Lisa Clark NRC Tony Bowers NRC Michael Dusaniwskyj NRC Joe Anderson NRC John Lamb NRC Amy Snyder NRC John Hughey NRC Will Smith NRC Emil Tabakov NRC Jenny Weil NRC Steven Scheurich Entergy Mandy Halter Entergy Phil Couture Entergy Susan Raimo Entergy John Gordon Entergy David Lewis Pillsbury Law Pam Cowan Holtec Decommissioning International Erin McCarthy Holtec International Andrea Sterdis Comprehensive Decommissioning International (CDI)

Jason Day CDI Chris Massey CDI Jeremy Parriott CDI Enclosure

NAME ORGANIZATION Michael McMahon Energy Strategies, LLC Doug Tifft* NRC Kara McCullough* NRC Neil Sheehan* NRC Dave McIntyre* NRC Julie Boettcher* NRC Pete Miner* Entergy Charlie Minot* Entergy Paul Gallant* Entergy Ed Duda* Entergy Gene Lafond* Entergy Charlie McDonald* Entergy Judith Shumate* Entergy John Bonner* Entergy Dominick Fucito* Entergy Russ Mellor* Entergy John Ohrenberger* Entergy Michael Twomey* Entergy Brendan Paradis* Entergy Andy Cardine* Entergy John Giarusso* Commonwealth of MA, MA Emergency Management Agency Commonwealth of MA, Nuclear Decommissioning Citizens Advisory Kevin O'Reilly*

Panel (NDCAP)

Steve Colman* FEMA Dan McElhinney* FEMA Anthony DeFelice* FEMA Bill Eberst* FEMA Tim Harris* FEMA Rod McCullom* Nuclear Energy Institute Sean Mullin* Bi 2 Technologies Nicholas Mattia* Boston Edison Shaun Sexstone* AECOM Don Dracon* AECOM Bob Fraser* AECOM Mary Lampert* Pilgrim Watch Diane Turco* Cape Downwinders Richard Orthen* NextEra Bill Maher* NextEra Steve Franzone* NextEra

NAME ORGANIZATION Tom Szymansky* Dominion Melissa Moultan* GZA Jaeger Wells* Westinghouse Donald Lewis* Westinghouse Peter Leombruni* Westinghouse Billy Mack* Accelerant Solutions Catherine Carlock* Boston Business Journal Sarah.Tan* WCAI NPR Brian Morris* WCAI NPR John Stang* RadWaste Monitor Budd Haemer* American Electric Power Doug Jacobs* NAC International Nick Theodore* Balch & Bingham, LLP Erika Cook* Consultant Daniel Wolf* NDCAP Pine DuBois* NDCAP Robert Jones* NDCAP David Johnston* NDCAP Jack Priest* NDCAP Alan Lovett* Public Allison Grades* Public Donna Gilmore* Public Adam Levin* Public Anthony Defolis* Public Janet Azarovitz* Public Brian Merchant* Public Bruce Gellerman* Public Ed Posivak* Public Ellie French* Public Fred Gerloff* Public Gabrielle Gould* Public Guntram Mueller* Public Jeff Hays* Public Jeffrey Griffiths* Public Jeffrey Martin* Public Jim Ostroff* Public John Paquin* Public John Tabe* Public Lisa Jansen* Public

NAME ORGANIZATION Lori Clark* Public Mark Kirshe* Public Matt Fallon* Public Michael Wilt* Public Mike Duman* Public Patrick O'Brien* Public Paul Gallant* Public Peter LeJeune* Public Philip Warburg* Public Renn Fowler* Public Ricardo Manrique* Public Richard Orthis* Public Solange Disantis* Public Sterling Ginterich* Public Tim Mgau* Public Tyler Sweeney* Public

  • via phone

SUBJECT:

PUBLIC MEETING WITH THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC. REGARDING PRE-SUBMITTAL OF A LICENSE TRANSFER APPLICATION TO HOLTEC INTERNATIONAL FOR PILGRIM NUCLEAR POWER STATION DATED OCTOBER 12, 2018 DISTRIBUTION:

PUBLIC PM File Copy RidsACRS_MailCTR Resource RidsNmssDuwpRDB Resource RidsNrrDorlLspb Resource RidsNrrLAJBurkhardt Resource RidsNrrPMPilgrim Resource RidsNsirDpr Resource RidsOpaMail Resource RidsRgn1 MailCenter Resource JWeil, OCA DScrenci, R-1 NSheehan, R-1 MYoung, R-1 JKulp, R-1 EAndrews, R-1 ZCruz, NMSS/DUWP/RDB BWatson, NMSS/DUWP/RDB JAnderson, NSIR/DPR/RLB MNorris, NSIR/DPR/RLB/ORLT ADAMS Accession Nos.:

Package: ML18275A403 Letter: ML18275A395; Slides: ML18262A135; M eefmg Nofice: ML18249A324 OFFICE NRR/DORL/LSPB/PM NRR/DORL/LSPB/LA NRR/DORL/LSPB/BC NRR/DORULSPB/PM DBroaddus NAME Jlamb JBurkhardt Jlamb (EBrown for)

DATE 10/10/18 10/10/18 10/12/18 10/12/18 OFFICIAL AGENCY RECORD