ML19234A357

Notification of Expected Date of Transfer of Ownership of Nuclear Unit to Holtec Pilgrim, LLC; Notification of Satisfactory Documentary Evidence of Insurance; and Notification of Receipt of All Required Regulatory Approvals

ML19234A357
Person / Time
Site:	Pilgrim
Issue date:	08/22/2019
From:	Brian Sullivan Entergy Nuclear Operations
To:	Document Control Desk, Office of New Reactors
References
2.19.051
Download: ML19234A357 (8)

Text

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Tel 508-830-8899 Brian R. Sullivan Site Vice President 10 CFR 50.80 10 CFR 50.90 10 CFR 72.50 2.19.051 August 22, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Notification of Expected Date of Transfer of Ownership of Nuclear Unit to Holtec Pilgrim, LLC; Notification of Satisfactory Documentary Evidence of Insurance; and Notification of Receipt of all Required Regulatory Approvals Pilgrim Nuclear Power Station NRC Docket Nos. 50-293 and 72-1044 Renewed Facility Operating License No. DPR-35 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 indirect transfer of the Pilgrim Nuclear Power Station (PNPS)

Renewed Facility Operating License No. DPR-35 and the generally licensed Pilgrim Independent Spent Fuel Storage Installation to Holtec, and the direct transfer of ENOIs operating authority to Holtec Decommissioning International, LLC. The closing of the transfer is expected to occur on August 26, 2019.

Additionally, as discussed in Reference 2, Holtec Pilgrim, LLC (Holtec Pilgrim) and Holtec Decommissioning International, LLC (HDI) have obtained nuclear liability insurance for Pilgrim Nuclear Power Station from American Nuclear Insurers (ANI). A copy of Reference 2 is provided as Enclosure 1. As discussed in Reference 3, Holtec Pilgrim and HDI have also obtained nuclear property insurance for Pilgrim Nuclear Power Station from Nuclear Electric Insurance Limited (NEIL). A copy of Reference 3 is provided as Enclosure 2. These documents provide evidence that the appropriate insurance required of a licensee under 10 CFR 140.11(a)(4) and 10 CFR 50.54(w) of the Commissions regulations have been obtained.

Furthermore, Holtec Pilgrim and HDI have entered into a decommissioning operator services agreement that provides for HDI to act as the agent for Holtec Pilgrim and for Holtec Pilgrim to pay HDIs costs of post shutdown operations, including decommissioning and spent fuel management costs. This satisfies the associated regulatory commitment included in Reference 4.

2.19.051 Page 3 of 3

References:

1) NRC Letter to ENOI, "Order Approving Direct and Indirect Transfer of License and Conforming License Amendment" (EPID L-2018-LLO-0003)(ML19170A101), dated August 22, 2019

2) Letter from ANI to NRC, "Holtec Pilgrim, LLC and Holtec Decommissioning International, LLC NRC Operating License Transfer for Pilgrim Nuclear Power Station," dated July 25, 2019

3) Letter from NEIL to NRC, "Entergy Corporation - License Transfer to Holtec Pilgrim, LLC," dated August 19, 2019

4) Letter ENOI to NRC, "Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment; and Request for Exemption from 10 CFR 50.82(a)(8)(i)(A)," (ML18320A031), dated November 16, 2018 cc: NRC Director - Nuclear Reactor Regulation NRC Director - Nuclear Material Safety and Safeguards NRC Region I Administrator NRC Senior Resident Inspector - Pilgrim Nuclear Power Station NRC Project Manager - Pilgrim Nuclear Power Station

Enclosure 1 2.19.051 Letter from Jason Martinez ANI to NRC Document Control Desk dated July 25, 2019, regarding Nuclear Liability Insurance for Pilgrim Nuclear Power Station

Jason Martinez, CPCU, ARM, ARe Director, Underwriting July 25, 2019 Attn: Document Control Director, Office of Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 205550001 Re: Holtec Pilgrim, LLC and Holtec Decommissioning International, LLC NRC Operating License Transfer for Pilgrim Nuclear Power Station To Whom It May Concern, This letter confirms that American Nuclear Insurers will write nuclear liability insurance for the Pilgrim Nuclear Power Station, located in Plymouth, MA, upon the transfer of the NRC operating license from Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc. to Holtec Pilgrim, LLC and Holtec Decommissioning International, LLC.

Effective as of the transaction close date, which is expected to be on or before August 1, 2019, ANI will amend the policy and certificates for the Pilgrim Nuclear Power Station as follows:

a. Facility Form Policy No. NF 0188: ANI will amend the named insured to Holtec Pilgrim, LLC and Holtec Decommissioning International, LLC in lieu of Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc.

b. Master Worker Certificate No. NW 0573: ANI will amend the named insureds to Holtec Pilgrim, LLC and Holtec Decommissioning International, LLC in lieu of Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc.

c. SFP Certificate No. N 0031: ANI will amend the named insureds to Holtec Pilgrim, LLC and Holtec Decommissioning International, LLC in lieu of Entergy Nuclear Generation Company and Entergy Nuclear Operations, Inc.

d. SFP Certificate No. N 0031: ANI will add Holtec Pilgrim, LLC and Holtec Decommissioning International, LLC to the Bond for payment of retrospective premiums. The SFP certificate period will be amended per the effective NRC license transfer date.

American Nuclear Insurers 95 Glastonbury Blvd., Suite 300 Glastonbury, CT 06033-4453 jmartinez@nuclearinsurance.com Voice: (860) 682-1341 Fax: (860) 659-0002

Attn: Document Control July 25, 2019 Page 2 The commitment to write insurance for Pilgrim Nuclear Power Station remains valid thru December 31, 2019. In the event the license transfer occurs after this date, ANI will review the existing circumstances prior to reinstating our commitment to provide insurance.

Please feel free to contact me with any questions or concerns.

Yours sincerely, Jason Martinez, CPCU, ARM, ARe Director, Underwriting C: Holtec - Pam Cowan, Andrea Sterdis, and Jason Day Conner Strong & Buckelew - Frank Proctor Entergy - Ron Rispoli & Megin Murphy Stephens - Tricia Brazil

Enclosure 2 2.19.051 Letter from NEIL to NRC, "Entergy Corporation - License Transfer to Holtec Pilgrim, LLC,"

dated August 19, 2019

NEIL~ -

Nuclear Electric Insurance Limited 1201 N Market St Suite 1100 Wilmington, DE 19801 USA office + 302 888 3000 fax + 302 888 3007 August 19, 2019 Mr. Eric Olvera U.S. Nuclear Regulatory Commission OWFN - 07C2A Washington, DC 20555-001 Re: Entergy Corporation - License Transfer to Holtec Pilgrim, LLC

Dear Mr. Olvera:

This letter confirms that Nuclear Electric Insurance Limited will write a Nuclear Liability and Decontamination Insurance Policy for Holtec Pilgrim, LLC as the owner of 100% of the Pilgrim Nuclear Power Station. A Nuclear Liability and Decontamination Insurance Policy will be effective upon close of the transfer of the facility license to own the plant from Entergy Corporation.

The combined limits on the above referenced policy will satisfy the NRC required minimum insurance limit of $1.06 billion for this site.

This commitment to write Nuclear Liability and Decontamination Insurance Policy for Holtec Pilgrim, LLC for a twelve-month policy period remains valid through August 26, 2019. If the asset transfer takes place after that date, we will review the circumstances before re-stating our commitment.

Sincerely,

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

John Oehler (NEIL)

Kate Fowler (NEIL)

Ken Manne (NEIL)

Peter Cavanaugh (NEIL)