ML20357B152
| ML20357B152 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/22/2020 |
| From: | Richard Guzman NRC/NRR/DORL/LPL1 |
| To: | Couture P Entergy Nuclear Operations |
| Guzman R | |
| References | |
| ML20344A406 | |
| Download: ML20357B152 (3) | |
Text
1 Guzman, Richard From:
Couture III, Philip <pcoutur@entergy.com>
Sent:
Tuesday, December 22, 2020 7:43 PM To:
Guzman, Richard Cc:
Cruz Perez, Zahira
Subject:
[External_Sender] RE: Entergy IPEC - Pre-Notice of Disbursement from Decommissioning Trusts -
- Rich, Thisreflectswhatwediscussedtoday.
PhilCouture Manager,FleetLicensingPrograms EntergyNuclearOperations 6013685102(Work) 8608611894(Cell)
From:Guzman,Richard<Richard.Guzman@nrc.gov>
Sent:Tuesday,December22,20205:23PM To:CoutureIII,Philip<pcoutur@entergy.com>
Cc:CruzPerez,Zahira<Zahira.CruzPerez@nrc.gov>
Subject:
RE:EntergyIPECPreNoticeofDisbursementfromDecommissioningTrustsML20344A406
- Phil, Shown below is a summation of the staffs understanding of the take-aways discussed on todays clarification call. Please confirm it is accurate and whether there are any additional intended points that we may have missed.
The up to $40M proposed to be withdrawn from the IP1 Decommissioning Trust Fund (DTF) would be to reimburse Entergy for legitimate decommissioning expenses that Entergy had incurred between 2001 and the present, and covers primarily labor costs incurred by Entergy. Entergy considers the $40 million disbursement would be for legitimate decommissioning activities per definition of decommission under 10 CFR 50.2, and that the
$40M is encompassed by the $59.3M of pre-transfer withdrawals from the IP1 DTF that were assumed and cited in the license transfer application. This is the first disbursement pre-notice from Entergy regarding the Unit IP1 DTF. An additional disbursement request will likely be made in 2021, prior to completion of the license transfer, reflecting previous expenses incurred as cited in the 11/21/2019 Entergy License Transfer Application and Holtecs Post Shutdown Decommissioning Activity Report. Finally, the withdrawal from the IP1 DTF would not affect the opening IP1 DTF balance used in the staffs cash-flow analysis that supported the staffs determination that the license transfer application was acceptable.
2
- Thanks, Rich Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-9C7 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov From:Guzman,Richard Sent:Monday,December21,20206:09PM To:CoutureIII,Philip(pcoutur@entergy.com)<pcoutur@entergy.com>
Subject:
RE:EntergyIPECPreNoticeofDisbursementfromDecommissioningTrustsML20344A406
- Phil, Please use the following conference line no. for our 12/22, 2pm clarification call:
Dial-In No.: 888-395-6890 Participant Passcode: 1503641 As discussed, the NRC staff would like to discuss the licensees clarification for the below items regarding the December 9, 2020, letter, which states, in part, that the disbursement for Unit 1 will be for license termination expenses incurred for IP1, not to exceed $40,000,000.
For what license termination activity expenses is the disbursement request for Unit 1 being made; are these expenses contained in the site-specific cost estimate (SSCE) that was provided to the NRC (i.e.,
the SSCE as provided in the 11/21/19 license transfer application (LTA) and 12/19/19 Holtec PSDAR)?
Has Entergy determined these expenses are for legitimate decommissioning activities (i.e., do such activities meet the definition provided in 10 CFR 50.2, under decommission)?
Are these expenses reflected as part of the footnote in Attachment D of Enclosure 1 to the 11/21/19 LTA (and Table 5-1a of the PSDAR), Indian Point Nuclear Generating Unit 1 Decommissioning Cash Flow Analysis, which states in part, the 2021 Beginning of Year NDT balance reflects the fund value post-closure of the sale transition. The value used is based on the October 31, 2019 Unit 1 NDT fund balance and includes deductions for estimated ENOI and HDI pre-closure costs of approximately
$59.3M.
Will the transfer of $40 million from the Unit 1 DTF affect the cash flow assumptions and other information provided to the NRC by the Applicants (Entergy and Holtec) in its 11/21/19 LTA and 12/19/19 PSDAR?
- Thanks, Rich Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-9C7 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov
3 From:Mahan,Cecil<cmahan@entergy.com>
Sent:Wednesday,December09,20203:52PM To:Lew,David<David.Lew@nrc.gov>;Floyd,Nik<Niklas.Floyd@nrc.gov>;Guzman,Richard
<Richard.Guzman@nrc.gov>;alyse.Peterson@nyserda.ny.gov Cc:Gaston,RonaldWilliam<rgasto1@entergy.com>;CoutureIII,Philip<pcoutur@entergy.com>;Mirzai,Mahvash
<mmirzai@entergy.com>
Subject:
[External_Sender]EntergyIPECPreNoticeofDisbursementfromDecommissioningTrustsML20344A406 All PleasefindattachedsubjectletterEntergyIPECPreNoticeofDisbursementfromDecommissioningTrustsdated 12/09/2020.
Thanks,Howard Howard Mahan Sr. Staff Engineer - Fleet Licensing Entergy Services, LLC. - Nuclear 1340 Echelon Parkway - Jackson, MS 39213 Direct: 601-368-5080 Cell: 205-492-5893 cmahan@entergy.com Thismessageisintendedfortheexclusiveuseoftheintendedaddressee.Ifyouhavereceivedthismessageinerroror arenottheintendedaddresseeorhisorherauthorizedagent,pleasenotifymeimmediatelybyemail,discardany papercopiesanddeleteallelectronicfilesofthismessage.