ML19176A276

Notification of Expected Date of Transfer of Ownership of Nuclear Unit to Oyster Creek Environmental Protection, LLC; Notification of Satisfactory Documentary Evidence of Insurance; and Notification of Receipt of All Required Regulatory App

ML19176A276
Person / Time
Site:	Oyster Creek
Issue date:	06/25/2019
From:	Sterdis A Holtec Decommissioning International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
2905004, EA-19-070, EPID L-2018-LLM-0002
Download: ML19176A276 (10)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 June 25, 2019 10 CFR 50.80 10 CFR 50.90 10 CFR 72.50 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15

Subject:

Notification of Expected Date of Transfer of Ownership of Nuclear Unit to Oyster Creek Environmental Protection, LLC; Notification of Satisfactory Documentary Evidence of Insurance; and Notification of Receipt of all Required Regulatory Approvals

References:

1. Letter from Amy Snyder (USNRC) to Bryan C. Hanson (Exelon Generation Company, LLC) dated June 20, 2019, Order Approving Transfer of the License for the Oyster Creek Nuclear Generating Station and Conforming License Amendment (EPID# L-2018-LLM-0002) (ML19095A454)

2. Letter from Jim Palaia (ANI) to Document Control Desk (USNRC) dated June 21, 2019, regarding Nuclear Liability Insurance for Oyster Creek Nuclear Generating Station

3. Letter from Michael Kolodner (NEIL) to Eric Olvera (USNRC) dated June 21, 2019, regarding Nuclear Property Insurance for Oyster Creek Nuclear Generating Station

4. Letter from Amy Snyder (USNRC) to Bryan C. Hanson (Exelon Generation Company, LLC) dated June 12, 2019, Oyster Creek Generating Station -

Exemption from the Requirements of 10 CFR 140.11(a)(4) Concerning Document ID: 2905004

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Offsite Primary and Secondary Liability Insurance (EPID L-2019-LLE-0007)

(ML19129A363)

5. Letter from Amy Snyder (USNRC) to Bryan C. Hanson (Exelon Generation Company, LLC) dated June 12, 2019, Oyster Creek Nuclear Generating Station - Exemption from The Requirements Of 10 CFR 50.54(w)(1),

Concerning Onsite Property Damage Insurance (EPID L-2019-LLE0007)

(ML19129A319)

6. Letter from J. Bradley Fewell, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission -Application for Order Approving Direct Transfer of Renewed Facility Operating License and General License and Proposed Conforming License Amendment Oyster Creek Nuclear Generating Station, August 31, 2018 (ML18243A489)

In accordance with Section III of the Order issued in Reference 1, we are informing the Director of the Office of Nuclear Reactor Regulation and the Director of Nuclear Material Safety and Safeguards of the upcoming transfer of the Oyster Creek Nuclear Generating Station (OCNGS)

Renewed Facility Operating License No. DPR-16 and the transfer of the generally licensed Oyster Creek Independent Spent Fuel Storage Installation from Exelon Generation Company, LLC, as owner and operator, to Oyster Creek Environmental Protection, LLC to own and Holtec Decommissioning International, LLC to operate the Oyster Creek Nuclear Generating Station.

The closing of the transfer is expected to occur on July 1, 2019.

Additionally, as discussed in Reference 2, Oyster Creek Environmental Protection, LLC (OCEP) and Holtec Decommissioning International, LLC (HDI) have obtained nuclear liability insurance for Oyster Creek Nuclear Generating Station from American Nuclear Insurers (ANI). A copy of Reference 2 is provided as Enclosure 1. As discussed in Reference 3, OCEP and HDI have also obtained nuclear property insurance for Oyster Creek Nuclear Generating Station from Nuclear Electric Insurance Limited (NEIL). A copy of Reference 3 is provided as Enclosure 2. These documents provide evidence that the appropriate amount of insurance required of a licensee under 10 CFR 140.11(a)(4) and 10 CFR 50.54(w) of the Commissions regulations, consistent with the exemptions issued to Oyster Creek on June 12, 2019 (References 4 and 5) have been obtained.

Furthermore, OCEP and HDI have entered into a decommissioning operator services agreement that provides for HDI to act as the agent for OCEP and for OCEP to pay HDIs costs of post shutdown operations, including decommissioning and spent fuel management costs. This satisfies the associated regulatory commitment included in Reference 6.

Document ID: 2905004

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 All required regulatory approvals for the transfer of these licenses have been obtained.

There are no regulatory commitments contained in this correspondence.

We will keep the U.S. Nuclear Regulatory Commission informed of any developments that have an impact on the schedule of closing the transfer of these licenses.

If you have any questions, please contact me at (856)797-0900, x3813 or David P. Helker (Exelon Generation Company) at 610-765-5525.

Respectfully, Andrea L. Sterdis Vice President Regulatory and Environmental Affairs Holtec Decommissioning International, LLC Document ID: 2905004

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

Enclosures:

1. Letter from Jim Palaia (ANI) to USNRC Document Control Desk dated June 21, 2019, regarding Nuclear Liability Insurance for Oyster Creek Nuclear Generating Station

2. Letter from Michael Kolodner (NEIL) to Eric Olvera (USNRC) dated June 21. 2019, regarding Nuclear Property Insurance for Oyster Creek Nuclear Generating Station cc: (w/Enclosures)

Director - Nuclear Reactor Regulation, USNRC Director - Nuclear Material Safety and Safeguards, USNRC Regional Administrator - USNRC Region I USNRC Decommissioning Inspector - Oyster Creek USNRC Project Manager, NMSS - Oyster Creek Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, New Jersey Document ID: 2905004

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 bcc: (w/Enclosures)

Sr. Vice President Regulatory Affairs and General Counsel Sr. Vice President, MidAtlantic Operations Vice President, Licensing and Regulatory Affairs Vice President, Decommissioning Decommissioning Director, Oyster Creek Director, Licensing Regulatory Assurance lead, Oyster Creek Commitment Coordinator, KSA Records Management, KSA President and CEO Holtec Decommissioning International, LLC Sr. Vice President and COO Holtec Decommissioning International, LLC President Comprehensive Decommissioning International, LLC D. Helker (Exelon)

L. Holden (Exelon)

A. Sterdis (Holtec)

T. Domeyer (Exelon)

A. Ryan (Holtec)

E. Connolly (Holtec)

Document ID: 2905004

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 ENCLOSURE 1 LETTER FROM JIM PALAIA (ANI) TO USNRC DOCUMENT CONTROL DESK DATED JUNE 21, 2019 REGARDING NUCLEAR LIABILITY INSURANCE FOR OYSTER CREEK NUCLEAR GENERATING STATION Document ID: 2905004

UNDERWRITING DEPARTMENT Jim Palaia, Vice President June 21, 2019 ATTN: Document Control Desk Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Exelon Generation Company, LLC. - License Transfer to Oyster Creek Environmental Protection, LLC and Ho/tee Decommissioning International, LLC To Whom It May Concern:

This letter confirms that American Nuclear Insurers will write nuclear liability insurance for the Oyster Creek Nuclear Generating Station, located in Lacey Township, Ocean County, NJ, upon transfer of the operating facility license from Exelon Generation Company, LLC to Oyster Creek Environmental Protection, LLC and Holtec Decommissioning International, LLC.

As of the transaction close date, expected to be on July 1, 2019, ANI will amend the policy and certificate for the Oyster Creek Nuclear Generating Station as follows:

Facility Form Policy No. NF-0164: ANI will amend the named insured to "Oyster Creek Environmental Protection, LLC and Holtec Decommissioning International, LLC" in lieu of "Exelon Generation Company, LLC." The operator of the facility will be amended to read "Holtec Decommissioning International, LLC" in lieu of "Exelon Generation Company, LLC."

Master Worker Certificate No. NW-0558: ANI will amend the named insured to "Oyster Creek Environmental Protection, LLC and Holtec Decommissioning International, LLC" in lieu of "Exelon Generation Company, LLC." The operator of the facility will be amended to read "Holtec Decommissioning International, LLC" in lieu of "Exelon Generation Company, LLC."

The commitment to write insurance for the Oyster Creek Nuclear Generating Station remains valid thru January 1, 2020. In the event the closing of the transaction occurs after this date, ANI will review the existing circumstances prior to reinstating our commitment to provide insurance.

American Nuclear Insurers 9513ast.onbury Blvd .. Suit.e 3CD

• 13astonbury, CT 03Cl334453 jpalaia@iuclea"insurance.c.om

• Voice: (860) 682-1345

• Fax: [860) 659QT.e

Please do not hesitate to contact me should you have any questions.

Regards,

<;J-fdL_

Jim Palaia Vice President, Underwriting C: Mr. Frank Proctor, Conner, Strong & Buckelew Ms. Pamela Cowan, Holtec Decommissioning International, LLC

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 ENCLOSURE 2 LETTER FROM MICHAEL KOLODNER (NEIL) TO ERIC OLVERA (USNRC) DATED JUNE 21, 2019 REGARDING NUCLEAR LIABILITY INSURANCE FOR OYSTER CREEK NUCLEAR GENERATING STATION Document ID: 2905004

NEIL C©J .........

Nuclear Electric Insurance Limited 1201 N Market St Suite 1100 Wilmington, DE 19801 USA office + 302 888 3000 fax + 302 888 3007 June 21, 2019 Mr. Eric Olvera U.S. Nuclear Regulatory Commission OWFN - 07C2A Washington, DC 20555-001 Re.: Exelon Generation Company, LLC - License Transfer to Oyster Creek Environmental Protection, LLC

Dear Mr. Olve~a :

This letter confirms that Nuclear Electric Insurance Limited will write nuclear property insurance for Oyster Creek Environmental Protection, LLC as the owner of 100% of the Oyster Creek Nuclear Generating Station. A Primary Property and Decontamination Liability Policy will be effective upon close of the transfer of the facility license to own the plant from Exelon Generation Company, LLC.

The combined limits on the above referenced policy will satisfy the NRC required minimum property insurance limit of

$50 million for this site.

This commitment to write nuclear property insurance for Oyster Creek Environmental Protection, LLC for a twelve-month policy period remains valid through July 31 , 2019. If the asset transfer takes place after that date, we will review the circumstances before re-stating our commitment.

Sincerely, Michael W. Kolodner, CPCU, ARM, Are Vice President - Underwriting MWK/jdo cc: Frank Proctor (Conner Strong)

John Oehler (NEIL)

Ken Manne (NEIL)

Peter Cavanaugh (NEIL)