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EPID:L-2019-LSO-0029, Stations - Status of Funding for Managing Irradiated Fuel for Year Ending December 31, 2018 - 10 CFR 50.82(a)(8)(vii) - Entergy Nuclear Operations, Inc (Open) |
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Category:Request for Additional Information (RAI)
MONTHYEARML19224A4722019-08-26026 August 2019 VY Report on Status of Decommissioning Funding for Shutdown Reactors Enclosure ML18094B0922018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to B. S. Ford RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for ISFSI Docket Nos.: 72-43, 72-51, 72-1044, 72-07, 72-12, and 72-59) ML18045A8172018-04-0505 April 2018 Request for Additional Information on Vermont Yankee License Transfer Request (License DPR-28, Docket No. 50-271) ML17341A3842017-12-14014 December 2017 Request for Additional Information Regarding License Amendment Request to Change Physical Security Plan to Reflect an ISFSI-Only Configuration ML17313A4312017-11-0303 November 2017 NRC Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar ML17279B1452017-10-24024 October 2017 Request for Additional Information Regarding the License Amendment Request to Change the Emergency Plan and Emergency Action Level Scheme to Reflect an ISFSI-Only Configuration ML17244A0982017-10-12012 October 2017 NRC Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar ML17229B4842017-08-16016 August 2017 Request for Supplemental Documentation to Support Review of the Physical Security Plan ML16090A0292016-04-0505 April 2016 Request for Additional Information Related to Proposed Changes to Quality Assurance Program Manual, Vermont Yankee Nuclear Power Station ML16077A3452016-03-22022 March 2016 Request for Additional Information Related to 10 CFR 20.2002 Alternate Waste Disposal Request For Vermont Yankee Nuclear Power Station (CAC No. L53116) ML16069A0952016-03-0303 March 2016 Request for 20.2002 Disposal, Request for Additional Information CNRO-2015-00008, Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company2015-02-18018 February 2015 Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company ML14318A4002014-12-17017 December 2014 Vermont Yankee Nuclear and Big Rock Point - Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company (Tac Nos. MF3218 - MF3221) ML14289A3942014-11-21021 November 2014 Redacted, Request for Additional Information, Review of Revision 14 to the Physical Security Plan, Safeguards Contingency Plan, and Training and Qualification Plan Pursuant to 10 CFR 50.54(p)(2) BVY 14-069, Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E - Supplement 22014-10-21021 October 2014 Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E - Supplement 2 ML14192A8352014-08-19019 August 2014 Request for Additional Information, Exemption from 10 CFR 50.47 and Appendix E to Allow Reduced Emergency Plan Requirements and Revise Radiological Emergency Response Plan Consistent with Permanently Defueled Reactor ML14231A0172014-08-13013 August 2014 Technical Specifications Proposed Change No. 309, Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition - Supplement 4 ML14163A5902014-07-0101 July 2014 Request for Additional Information, Round 2, Amendment Request to Revise Site Emergency Plan for Permanently Defueled Condition to Reflect Change in On-Shift Staffing and Emergency Response Staffing ML14115A0292014-05-0505 May 2014 Request for Additional Information Regarding License Amendment Request for Emergency Plan Change ML14024A0412014-01-29029 January 2014 Request for Additional Information Regarding Entergy Request for Rescission of and Scheduler Relief from Order EA-13-109 on Reliable Hardened Containment Vents ML13311B0772013-11-26026 November 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation ML13304B4182013-11-0101 November 2013 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns ML13218A0122013-08-0606 August 2013 E-mail from R.Guzman to P.Couture, Request for Additional Information - Relief Requests ISI-04 Dated March 27, 2013 - Bvy 13-018 ML13205A1762013-07-24024 July 2013 Supplemental Request for Additional Information - Relief Request ISI-03 ML13179A4622013-07-0505 July 2013 Entergy Nuclear Operations, Inc., Decommissioning Funding Status Report Request for Additional Information Regarding the Decommissioning Funding Status Report ML13186A1142013-07-0505 July 2013 Email from R. Guzman to P.Couture Request for Additional Information - Relief Request ISI-02, Application of Code Case N-716 ML13165A2792013-06-20020 June 2013 Request for Additional Information Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (NRC Order EA-12-051) ML13163A2582013-06-17017 June 2013 Request for Additional Information - Response to March 12, 2012, Commission Order EA-12-049 to Modify Licenses Requirements for Mitigating Strategies for Beyond Design Basis External Events ML13149A2652013-05-28028 May 2013 Email from R. Guzman to P. Couture - Request for Additional Information Relief Request ISI-05 (TAC No. MF1194) -Updated RAI-2 (Revision 2) ML13130A0562013-05-0909 May 2013 E-mail from R.Guzman to P.Couture Request for Additional Information - Relief Request RR-P02 Dated February 1, 2013 - Bvy 13-008 ML13130A0472013-05-0808 May 2013 Email from R.Guzman to P.Couture Request for Additional Information - Relief Requests ISI-01 and ISI-03 Dated March 27, 2013 - Bvy 13-018 (TAC Nos. MF1196/1198) ML13119A2462013-04-29029 April 2013 Request for Additional Information, E-mail from R. Guzman to P. Couture Relief Request ISI-05 ML13097A0032013-04-0808 April 2013 Request for Additional Information Change to 10 CFR 50.63 Licensing Basis - SBO EDG ML13087A3922013-04-0202 April 2013 Request for Additional Information to Support the Review of Relief Request RR-P-01 ML13081A7522013-03-22022 March 2013 Email from R.Guzman to P.Couture Request for Additional Information for License Amendment Request to Change 10 CFR 50.63 Licensing Basis ML13077A2062013-03-20020 March 2013 Request for Additional Information Regarding 10 CFR 50.33 Financial Qualification Review ML13067A0912013-03-0808 March 2013 Request for Additional Information Change to TS 3.3.B Inoperable Control Rods ML13050A4692013-02-21021 February 2013 Request for Additional Information Change to Licensing Basis for Station Blackout Diesel Generator ML13018A4592013-01-15015 January 2013 Request for Additional Information - E-mail from R.Guzman to P.Couture Relief Request ISI-PT-02 Alternative to the System Leakage Test for Rv Head Flange Leakoff Lines ML1228403332012-10-10010 October 2012 Request for Additional Information - E-mail from R. Guzman to P. Couture License Amendment Request to Revise License Condition 3.P and 3.Q ML12278A3862012-10-0404 October 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2, and 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford, Request for Additional Information, Round 2, Amendment Request to Revise QA Program Manual and Staff Qualification TSs ML13070A2032012-09-17017 September 2012 Email from R. Guzman to R. Wanczyk and P. Outure Draft Request for Additional Information - LAR to Revise License Renewal Commitments One Time Inspection Program ML13070A1742012-09-10010 September 2012 Email from R. Guzman to R. Wanczyk Draft Request for Additional Information - LAR to Revise License Renewal Commitments Selective Leaching Program ML12122A8072012-05-0707 May 2012 Request for Additional Information Regarding Physical Security, Safeguards Contingency and Training and Qualification Plan, Revision 11 ML1300902982012-04-10010 April 2012 E-mail from J. Kim to J. Devincentis Request for Additional Information - Rod Worth Minimizer Bypass Allowance Amendment ML1209604492012-04-0505 April 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Request for Additional Information, Revise Quality Assurance Program Manual and Staff Qualification Technical Specificat ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic 2019-08-26
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REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE NORTHSTAR VERMONT YANKEE, LLC NORTHSTAR NUCLEAR DECOMMISSIONING COMPANY, LLC STATUS OF DECOMMISSIONING AND SPENT FUEL MANAGEMENT FUNDING FOR THE VERMONT YANKEE NUCLEAR POWER STATION By letters dated March 28, 2019 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML19087A318 and ML19087A276), Entergy Nuclear Operations, Inc.
(ENOI) submitted for U.S. Nuclear Regulatory Commission (NRC) review their reports on the status of decommissioning funding and funding for managing irradiated fuel for the Vermont Yankee Nuclear Power Station (VY). The NRC staff has reviewed the reports and determined that additional information from NorthStar Vermont Yankee, LLC (NorthStar VY) and Nuclear Decommissioning Company, LLC (NorthStar NDC) is necessary in order to complete its review.
Regulatory Basis for Request Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(8) states, in relevant part:
(v) After submitting its site-specific DCE required by paragraph (a)(4)(i) of this section, and until the licensee has completed its final radiation survey and demonstrated that residual radioactivity has been reduced to a level that permits termination of its license, the licensee must annually submit to the NRC, by March 31, a financial assurance status report. The report must include the following information, current through the end of the previous calendar year:
(A) The amount spent on decommissioning, both cumulative and over the previous calendar year, the remaining balance of any decommissioning funds, and the amount provided by other financial assurance methods being relied upon; (B) An estimate of the costs to complete decommissioning, reflecting any difference between actual and estimated costs for work performed during the year, and the decommissioning criteria upon which the estimate is based; (C) Any modifications occurring to a licensee's current method of providing financial assurance since the last submitted report; and (D) Any material changes to trust agreements or financial assurance contracts.
(vi) If the sum of the balance of any remaining decommissioning funds, plus earnings on such funds calculated at not greater than a 2 percent real rate of return, together with the Enclosure
amount provided by other financial assurance methods being relied upon, does not cover the estimated cost to complete the decommissioning, the financial assurance status report must include additional financial assurance to cover the estimated cost of completion.
(vii) After submitting its site-specific DCE required by paragraph (a)(4)(i) of this section, the licensee must annually submit to the NRC, by March 31, a report on the status of its funding for managing irradiated fuel. The report must include the following information, current through the end of the previous calendar year:
(A) The amount of funds accumulated to cover the cost of managing the irradiated fuel; (B) The projected cost of managing irradiated fuel until title to the fuel and possession of the fuel is transferred to the Secretary of Energy; and (C) If the funds accumulated do not cover the projected cost, a plan to obtain additional funds to cover the cost.
Request for Additional Information In its decommissioning financial assurance (DFA) and spent fuel management (SFM) reports, ENOI, the previous licensee of VY, stated:
In January 2019, Entergy Nuclear Vermont Yankee, LLC was acquired by NorthStar Nuclear Decommissioning Company, LLC, and after the acquisition, Entergy Nuclear Operations, Inc. (ENOI) was no longer the Licensee for Vermont Yankee. ENOI is submitting this report pertaining to Vermont Yankee because as of December 31, 2018, ENOI was the Licensee for the plant. Following the acquisition, ENOI is no longer responsible for Vermont Yankee decommissioning plans.
On October 11, 2018, the NRC issued an order approving the transfer of the VY license to NorthStar NDC and NorthStar VY (ADAMS Accession No. ML18242A638). While ENOI was the licensee as of December 31, 2018, NorthStar VY and NorthStar NDC became the licensees on January 11, 2019, prior to the March 31, 2019 reporting date. The reports submitted by ENOI do not reflect the costs or funding associated with the NorthStar accelerated decommissioning plan and schedule as approved by NRC in October 2018. Rather, the reports reflect costs and funding associated with the SAFSTOR methodology, the strategy chosen by ENOI prior to the transfer of the ownership and control of the VY license to NorthStar VY and NorthStar NDC, and their parent companies.
In accordance with NRC regulations in 10 CFR 50.82(a)(8)(v) - (vii), all licensees in decommissioning, including NorthStar VY and NorthStar NDC (as holders of the VY license),
are required to submit annual reports reflecting the status of decommissioning funding and spent fuel management. The NRC staff reviews these annual reports to determine whether licensees continue to provide sufficient funding to complete decommissioning and terminate the license, and to manage spent fuel until the Department of Energy takes title and possession of the fuel for long-term storage.
RAI 1
Provide revised decommissioning financial assurance and spent fuel management reports in accordance with 10 CFR 50.82(a)(8)(v)(B)-(D) and 10 CFR 50.82(a)(8)(vi)-(vii), reflecting costs and funding associated with NorthStars accelerated decommissioning plan and schedule, as approved by the NRC in its October 2018 license transfer order.