ML21301A178
| ML21301A178 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 10/28/2021 |
| From: | Sauger J, Stoddard D Dominion Energy Kewaunee, Energy Solutions |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML21301A177 | List: |
| References | |
| 21-352 | |
| Download: ML21301A178 (43) | |
Text
CONFIDENTIAL COMMERCIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 & 10 CFR 9.17
~ Dominion ENERGY SOLUTIONS Energy ~'
October 28, 2021 --
10 CFR 50.80 10 CFR 50.90 10 CFR 72.50
U.S. Nuclear Regulatory Commission Serial No.: 21-352 Attention: Document Control Desk NRA/SS: RO Washington, DC 20555 Docket Nos.: 50 -305 72-64 License No.: DPR-43
DOMINION ENERGY KEWAUNEE, INC.
KEWAUNEE POWER STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING APPLICATION FOR ORDER APPROVING TRANSFER OF CONTROL OF KEWAUNEE POWER STATION LICENSE AND CONFORMING LICENSE AMENDMENTS
By letter dated May 10, 2021, (Agencywide Documents Access and Management System (ADAMS)Accession No. ML21131A141), Dominion Energy Kewaunee, Inc. ("DEK"), and EnergySo/utions, LLC ("EnergySolutions") (together with DEK, the "Applicants")
submitted an application requesting that the U.S. Nuclear Regulatory Commission
("NRC") consent to the transfer of control of Renewed Facility Operating License No. DPR-43 ("License") for Kewaunee Power Station (KPS) and the general license for the Kewaunee independent spent fuel storage installation from Dominion Nuclear Projects, Inc. (Dominion), the parent entity of the licensee, to EnergySo/utions. This application was supplemented by a letter from EnergySolutions dated May 13, 2021 (ADAMS Accession No. ML21145A083), which provided the proposed Post-Shutdown Decommissioning Activities Report, Revision 2 for KPS.
By letter dated September 30, 2021 (ADAMS Package No. ML21257A062), the NRC issued a request for additional information (RAI) related to the application. The letter requested that a response to the RAI or a written request for additional time to respond, including the proposed response date and a brief description of the reason, be provided within 30 days from the date of the letter. On October 7, 2021, the NRC staff conducted a conference call with the Applicants to clarify the request.
C of Attachment 1 contains confidential commercial and financial information.
EnergySo/utions requests that this information be withheld from public disclosure
NOTE: ATTACHMENT 1, ENCLOSURE 1C TO THIS LETTER CONTAINS "CONFIDENTIAL COMMERCIAL INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF ATTACHMENT 1, ENCLOSURE 1C, THIS LETTER IS "DECONTROLLED."
Serial No. : 21-352 Docket Nos. 50 -305/72 - 64 Page 2 of 6
pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 2.390, as described in the Affidavit in Enclosure 1 B of Attachment 1.
The response to the RAI, as provided in Attachment 1, is submitted in accordance with 10 CFR 50.4, "Written communications," and has been executed in a signed original document under oath or affirmation pursuant to 10 CFR 50.30(b), "Oath or affirmation." provides resumes for planned management positions within Kewaunee Solutions, Inc (a subsidiary of Energy Solutions), in support of the response to RAl-4. A new regulatory commitment made in this RAI response is contained in Attachment 3.
In accordance with 10 CFR 50.91 (b)(1 ), a copy of this submittal has been sent to the State of Wisconsin.
Should you have any questions o r require additional information, please contact Craig D.
Sly, Manager, Nuclear Feet Licensing (Dominion), at (804) 273-2 784.
Sincerely,
Daniel G. Stoddard auger President and Chief Nuclear Preside t D&D and Chief Nuclear Officer Officer Dominion Energy Kewaunee, Inc. EnergySo!utions, LLC
Attachments:
- 1. Response to Request for Additional Information Regarding Application for Order Approving Transfer of Control of Kewaunee Powe r Station License and Conforming License Amendments Enclosure 1A: Non-Confidential Version of Response Enclosure 1 B : Affidavit for Withholding Confidential Information Enclosure 1 C : Confidential Version of Response
2. Resumes for Planned Management Positions within Kewaunee Solutions, Inc.
3. List of Regulatory Commitments Serial No.: 21-352 Docket Nos. 50-305/72-64 Page 3 of 6
cc: w/Enclosures
Mr. Karl Sturzebecher NRC Project Manager - Kewaunee Power Station U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
U.S. Nuclear Regulatory Commission Region Ill 2443 Warrenville Road, Suite 210 Lisle, Illinois 60532-4352
Daniel G. Stoddard President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.
5000 Dominion Blvd Glen Allen, VA 23060
William S. Blair General Counsel Dominion Energy Kewaunee, Inc.
120 Tredegar St.
Richmond, VA 23219
Paul M. Bessette Morgan, Lewis & Beckius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004-2541
Kenneth W. Robuck President and Chief Executive Officer EnergySolutions, LLC 121 West Trade Street, Suite 2700 Charlotte, NC 28202
John T. Sauger President D&D and Chief Nuclear Officer EnergySo/utions, LLC 121 West Trade Street, Suite 2700 Charlotte, NC 28202 Serial No.: 21-352 Docket Nos. 50-305/72-64 Page 4 of 6
Russell G. Workman General Counsel Secretary EnergySo/utions, LLC 299 South Main Street, Suite 1700 Salt Lake City, UT 84111
Daniel F. Stenger Hogan Lovells US LLP 555 13th St NW Washington, DC 20004
Gerard P. Van Noordennen Senior Vice President Regulator Affairs EnergySolutions, LLC 121 West Trade Street Charlotte, NC 28202
cc: w/o Confidential Financial Enclosure 1 C
Manager, Radiation Protection Section Wisconsin Department of Health Services Serial No. : 21-352 Docket Nos. 50-305/72-64 Page 5 of 6
AFFIRMATION
I, Daniel G. Stoddard, state that I am the President and Chief Nuclear Officer of Dominion Energy Kewaunee, Inc. ("DEK ") and that I am duly authorized to execute and file this application on behalf of DEK. To the best of my knowledge and belief, the statements contained in this document with respect to DEK are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by employees and/or consultants of the company. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
I declare under penalty of perjury that the foregoing is true and correct:
Executed on October 28, 2021.
Oo.-.~
Serial No.: 21-352 Docket Nos. 50-305/72-64 Page 6 of 6
AFFIRMATION
I, John T. Sauger, state that I am the President D&D and Chief Nuclear Officer of EnergySolutions, LLC ("EnergySolutions") and that I am duly authorized to execute and file this application on behalf of Energy Solutions. To the best of my knowledge and belief, the statements contained in this document with respect to EnergySolutions are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by employees and/or consultants of the company. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
I declare under penalty of perjury that the foregoing is true and correct:
Executed on October 28, 2021.
CONFIDENTIAL COMMERCIAL INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 & 10 CFR 9.17
Serial No.21-352 Docket Nos. 50-305/72-64
ATTACHMENT 1
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING APPLICATION FOR ORDER APPROVING TRANSFER OF CONTROL OF KEWAUNEE POWER STATION LICENSE AND CONFORMING LICENSE AMENDMENTS
Kewaunee Power Station Dominion Energy Kewaunee, Inc.
Energy Solutions, LLC
NOTE: ATTACHMENT 1, ENCLOSURE 1C CONTAINS "CONFIDENTIAL COMMERCIAL INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF ENCLOSURE 1C OF ATTACHMENT 1, THIS ATTACHMENT IS "DECONTROLLED."
Serial No.21-352 Docket Nos. 50-305/72-64
ENCLOSURE1A
NON-CONFIDENTIAL VERSION OF RESPONSE
Kewaunee Power Station Dominion Energy Kewaunee, Inc.
EnergySolutions, LLC Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1A Page 1 of 12
By letter dated May 10, 2021, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21131A141), Dominion Energy Kewaunee, Inc. ("DEK"), and EnergySolutions, LLC ("EnergySolutions") (together with DEK, the "Applicants")
submitted an application requesting that the U.S. Nuclear Regulatory Commission
("NRC") consent to the transfer of control of Renewed Facility Operating License No. DPR-43 ("License") for Kewaunee Power Station (KPS) and the general license for the Kewaunee independent spent fuel storage installation (ISFSI) from Dominion Nuclear Projects, Inc. (Dominion), the parent entity of the licensee, to EnergySolutions. This application was supplemented by a letter from EnergySolutions dated May 13, 2021 (ADAMS Accession No. ML21145A083), which provided the proposed Post-Shutdown Decommissioning Activities Report (PSDAR), Revision 2 for KPS.
By letter dated September 30, 2021, the NRC issued a request for additional information (RAI) related to the application. The letter requested that a response to the RAI or a written request for additional time to respond, including the proposed response date and a brief description of the reason, be provided within 30 days from the date of the letter.
On October 7, 2021, the NRC staff conducted a conference call with the Applicants to clarify the request.
The non-confidential version of the response to the RAI are provided in this attachment.
Financial RA/s
The NRC's regulations at Title 10 of the Code of Federal Regulations (10 CFR) 50. 80 and
- 72. 50 state that no license, or any right thereunder, shall be transferred, directly or indirectly, through transfer of control of the license, unless the Commission gives its consent in writing. The regulation at 10 CFR 50. B0(c) states, in part, that "the Commission will approve an application for the transfer of a license, if the Commission determines: (1)
That the proposed transferee is qualified to be the holder of the License; and (2) That the transfer of the license is otherwise consistent with applicable provisions of law, regulations, and orders issued by the Commission pursuant thereto."
The regulation at 10 CFR 50.33(f) requires that an application for a license to operate a utilization facility provide "information sufficient to demonstrate to the Commission the financial qualification of the applicant to carry out, in accordance with regulations in this chapter, the activities for which the permit or license is sought." The regulation further states that, as applicable, the following should be provided:
(4) Each application for a[n]... operating license... submitted by a newly-formed entity organized for the primary purpose of constructing and/or operating a facility must also include information showing:
Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1 A Page 2 of 12
(i) The legal and financial relationships it has or proposes to have with its stockholders or owners; (ii) The stockholders' or owners' financial ability to meet any contractual obligation to the entity which they have incurred or proposed to incur; and (iii) Any other information considered necessary by the Commission to enable it to determine the applicant's financial qualification.
(5) The Commission may request an established entity or newly-formed entity to submit additional or more detailed information respecting its financial arrangements and status of funds if the Commission considers this information appropriate. This may include information regarding a licensee's ability to continue the conduct of the activities authorized by the license and to decommission the facility.
In addition to requirements in 10 CFR Part 50, certain regulations in 10 CFR Part 72 apply to a generally licensed ISFSI, as listed in 10 CFR 72.13(c), including 10 CFR 72.30(b)
(f); that regulation includes provisions for demonstration of financial assurance for decommissioning of a generally licensed ISFSI.
RAl-1 (Contingency)
NUREG-1757, Vol. 3, Rev. 1, "Consolidated Decommissioning Guidance" (ADAMS Accession No. ML12048A683), states, in part:
In general, a contingency of 25 percent applied to the sum of all estimated decommissioning costs should be adequate, but in some cases a higher contingency may be appropriate. The 25 percent contingency factor provides reasonable assurance for unforeseen circumstances that could increase decommissioning costs and should not be reduced or eliminated simply because foreseeable costs are low. Proposals to apply the contingency only to selected components of the cost estimate, or to apply a contingency lower than 25 percent, should be approved only in circumstances when a case-specific review has determined that there is an extremely low likelihood of unforeseen increases in the decommissioning costs....
Accordingly, the NRG staff requests additional information regarding the reason for including a lower contingency amount than suggested. The staff could not find a justification of why the decommissioning cost estimate did not meet the recommended 25 percent contingency. Provide, for NRG staff consideration, a justification for using less than the recommended 25 percent contingency for the cost of decommissioning Kewaunee.
Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1 A Page 3 of 12
Response to RAl-1
Section 1.1 of NUREG-1757, Vol. 3, ("Purpose and Applicability,") states:
This volume does not apply to licensees under 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities." Regulatory Guide 1.159, Revision 1, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," issued October 2003, provides guidance on financial assurance for these licensees.
Based on this excerpt, the referenced guidance (NUREG-1757 Vol. 3, Rev. 1) is not considered directly applicable. Regulatory Guide 1.159, Revision 1 does recommend contingency for unexpected costs, but it does not recommend 25% or any other specific percentage of contingency.
The following considerations limit the likelihood of unforeseen increases in decommissioning costs:
License Termination:
- 1. EnergySo/utions performed site-specific quantity evaluations for KPS and compared KPS to other EnergySolutions projects (including historical data) to estimate the volume of contaminated material at the site. Contaminated material includes surface and subsurface soil material, buildings and building materials, and equipment containing residual radioactivity. The contaminated material will require remediation to meet the criteria for license termination. Based on the estimates and comparisons, the potential for underestimating the volume of material and cost to remediate that material is decreased.
- 2. EnergySolutions has provided services to decommissioning projects similar to Kewaunee, which enhances their ability to estimate radioactive waste volumes.
EnergySo/utions also owns Low-Level Radioactive Waste (LLRW) disposal sites.
EnergySolutions' experience providing direct decommissioning services and the capability to directly dispose of LLRW for KPS eliminates third-party schedule delays, therefore reducing the potential for unforeseen increases in waste burial costs, which are typically one of the largest components of decommissioning costs.
Spent Fuel Management:
- 3. Many decommissioning projects that typically can incur large unforeseen costs have already been completed at KPS, thereby reducing cost uncertainties. These include (a) all irradiated nuclear fuel has been removed from the spent fuel pool and the pool storage racks have been disposed of offsite; (b) the KPS physical security plan footprint has been reduced to the ISFSI pad area; and (c) the emergency plan footprint has been reduced to the ISFSI pad area, including elimination of requirements for offsite emergency response. The cost uncertainties Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1 A Page 4 of 12
associated with completion of these projects have been eliminated as the projects have been completed.
Site Restoration:
- 4. Site Restoration, or greenfield activities, includes the demolition of radiologically clean buildings and site structures, placement of clean fill materials, and completion of grading and re-vegetation of the site. Site Restoration work has lower potential for unforeseen cost increases when compared to License Termination, thus allowing for lower contingencies.
In conclusion, the potential for unforeseen cost increases is reduced by the current site specific condition of the facility, EnergySo/utions' decommissioning experience and ownership of LLRW disposal sites, and the use of historical data for waste volume estimation. Therefore, case-specific circumstances applicable to the PSDAR, Revision 2 cost estimate provide assurance that the contingency amounts are reasonable.
RAl-2 (U.S. Department of Energy Breach of Contract)
In 10 CFR 50.54(bb), the NRG requires, in part, a licensee to submit, for NRG review and preliminary approval, the program by which the licensee intends to manage and provide funding for the management of all spent fuel at the reactor following permanent cessation of operation of the reactor until title to the spent fuel and possession of the spent fuel is transferred to the U.S. Department of Energy (DOE) for its ultimate disposal.
Accordingly, the NRG staff requests additional information regarding the proposed DOE reimbursements process and scope that would be relied upon in the site-specific decommissioning cost estimate (SSDCE) for spent fuel management. The staff is unable to reconcile the DOE reimbursements as scheduled and therefore clarification is necessary. A/so, provide a more detailed explanation of the DOE reimbursements for breach of the standard contract. In addition, it is not apparent to the staff the source of the numbers in the SSDCE cash flow description. Therefore, provide, for NRG staff consideration, such references.
Response to RAl-2
Background:
As shown in the "Sinking Fund Analysis" in PSDAR, Revision 2, Table 1A-2, one source of funds for spent fuel management is the nuclear decommissioning trust (NOT). After accounting for decommissioning requirements, sufficient funds exist in the NOT to support maintenance of the ISFSI and decommissioning activities without reliance on DOE reimbursement through partial site release and up through January 1, 2031. Reliance on the KPS NOT to support spent fuel management activities through this period is consistent with an exemption issued by the NRC to DEK on May 21, 2014 (ADAMS Accession No. ML13337A287).
Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1A Page 5 of 12
For the period between partial site release and decommissioning of the ISFSI (2031-2055), it is anticipated that additional funds will be required for spent fuel management beyond the assets in the NOT. As shown in the Sinking Fund Analysis in Table 1A-2, DOE reimbursements provide additional funding for Spent Fuel Management costs after January 1, 2031.
Pursuant to DOE Contract DE-CR01-83NE44429 ("KPS Standard Contract"), DOE has ultimate responsibility for collection and permanent disposal of the spent nuclear fuel at KPS. As a result of DOE's breach of the KPS Standard Contract, DOE is responsible for the costs related to the current storage of the spent nuclear fuel at the KPS ISFSI. DOE has consistently reimbursed contract holders over the years for these costs through settlement agreements or through litigation.
Given the long and consistent history of Standard Contract spent fuel litigation, the NRC Staff found in the Order Approving the License Transfer Request for Vermont Yankee (ADAMS Accession No. ML18248A096) and other similar License Transfer approvals (ADAMS Accession No. ML19305B131 for Beaver Valley Units 1 & 2, ML20069A027 for Crystal River Unit 3, ML20279A373 for Three Mile Island Unit 2, etc.) "that the assumption of DOE reimbursement is a reasonable source of additional funding. In recent years, DOE reimbursements have become more consistent and predictable despite the longevity of the litigation process and complexity of DOE standard settlement agreements."
RAl-2, part a.
Accordingly, the NRG staff requests additional information regarding the proposed DOE reimbursements process and scope that would be relied upon in the site-specific decommissioning cost estimate (SSDCE) for spent fuel management. The staff is unable to reconcile the DOE reimbursements as scheduled and therefore clarification is necessary.
Response to RAl-2, part a.
Energy Solutions has estimated that [ ] of future Spent Fuel Management costs will be reimbursed by DOE. EnergySolutions believes [ ] is realistic and conservative for the following reasons: (i) Spent Fuel Management costs are relatively stable and predictable after, as at KPS, the ISFSI is constructed, and the spent fuel is transferred from the spent fuel pool to dry cask storage on the ISFSI pad; (ii) case law provides important guidance regarding the types of damages recoverable from DOE, establishing that DOE is responsible for reasonable costs of spent fuel storage incurred as a result of DOE's failure to accept spent fuel for disposal (for example, see Sacramento Municipal Utility District v. United States, 70 Fed. Cl. 332 (2006); Yankee Atomic Electric Company
- v. United States, Court of Federal Claims Case Number 13-584 C; Maine Yankee Atomic Power Company v. United States, Court of Federal Claims Case Number 13-585 C; and Connecticut Yankee Atomic Power Company v. United States, Court of Federal Claims Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1 A Page 6 of 12
Case Number 13-586 C); and (iii) EnergySolutions consulted with qualified experts experienced in DOE recovery proceedings in order to arrive at a reasonable and conservative recovery percentage considering that spent fuel management costs are stable with all KPS spent fuel in ISFSI storage.
The total DOE Reimbursements of [ J shown in Table 1A-2 of the PSDAR represent [ ] of the total Spent Fuel Management Costs of $231,321,000 shown in Table 4-1. The estimated DOE Reimbursement of [ ] in fiscal year 2031 represents [ J of the total of Spent Fuel Management costs of [ ]
estimated for fiscal years 2021 through 2030. However, the NOT is sufficient to cover Decommissioning activities during years 2021-2030 without relying on DOE reimbursement, and therefore DOE reimbursement is not credited during this time. In 2031, the NOT will be reduced to [ ], at which point Kewaunee Solutions will begin to rely on DOE reimbursements to ensure the NOT remains adequately funded to cover spent fuel management costs during the period between 2031 to 2055.
Footnote C in Table 1A-2 of the PSDAR, Revision 2 states that credit for DOE reimbursements starts in 2031. Though not explicitly stated, Table 1A-2 additionally assumes an [ J reimbursement rate from DOE in years 2021-2030, as shown in the Table RAl-2-1 below.
Table RAl-2-1: Annual SFM Costs and Estimated DOE Reimbursement (2021 -2030)
Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1A Page 7 of 12
The column for DOE reimbursement in Table 1A-2, Sinking Fund Analysis, will be updated in the next revision to the PDSAR to include a footnote for the years 2021-2030 providing the above explanation.
RAl-2, part b.
Also, provide a more detailed explanation of the DOE reimbursements for breach of the standard contract.
Response to RAl-2, part b.
See explanation in "Background" subsection above.
RAl-2, part c.
In addition, it is not apparent to the staff the source of the numbers in the SSDCE cash flow description. Therefore, provide, for NRG staff consideration, such references.
Response to RAl-2, part c.
The references for the source of numbers in the SSDCE cash flow description from the Sinking Fund Analysis (Table 1A-2) are provided below:
Beginning Balance NOT
The KPS Sinking Fund Analysis assumes a starting NOT value of $800M (see footnote A of Table 1A-2) at the closing of the transaction described in the License Transfer Application. The most recent annual decommissioning funding status report made by DEK (ADAMS Accession No. ML21084A800) shows an adjusted fund balance of $780M as of December 31, 2020. This number was adjusted to $800M to account for the change to the fund balance as of March 31, 2021. Thereafter, the KPS Sinking Fund Analysis accounts for taxes on unrealized gains, resulting in a beginning balance of approximately
$730M in the NOT upon completion of the transfer of control of KPS to Energy Solutions.
Annual Spending
The decommissioning cost summary is provided in Table 4-1 of the PSDAR, Revision 2.
A detailed cost estimate associated with the decommissioning of KPS is provided in Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1 A Page 8 of 12
Enclosure 1A, Table 1A-1 "Decommissioning Cost Estimate" (Confidential). The KPS Sinking Fund Analysis (Table 1A-2), Annual Spending column presents the anticipated spending for each fiscal year through 2055 in alignment with the Schedule Information presented in Figure 1A-1 and the Decommissioning Cost Estimate in Table 1A-1.
DOE Reimbursements
As explained above, DOE Reimbursements have been estimated at [ ] of the estimated Spent Fuel Management costs. The total DOE Reimbursements shown in Table 1A-2 of [ ] represent [ ] of the Total Spent Fuel Management Costs shown in PSDAR, Revision 2, Table 4-1 of $231,321,000. The DOE Reimbursement in fiscal year 2031 of [ ] represents [ ] of Spent Fuel Management costs incurred from fiscal years 2021 through 2030 of [ ] which are shown in the Table RAl-2-1 above.
NOT Earnings
NOT Earnings are based on a Real Rate of Return of 2.0%, per 10 CFR 50.75(e)(1 )(i),
applied to the average of the NOT Beginning Balance, and the NOT Ending Balance less NOT Earnings (Beginning Balance NOT less Annual Spending plus DOE Reimbursements).
Ending Balance NOT
The NOT Ending Balance is equal to the NOT Beginning Balance less Annual Spending plus DOE reimbursements plus NOT Earnings.
Technical RA/s
As part of its technical review, the NRG staff uses the guidance in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition," Chapter 13, "Conduct of Operations," Section 13.1.1, Revision 6, "Management and Technical Support Organization" (ADAMS Accession No. ML15005A449 ), and Sections 13. 1. 2 - 13. 1. 3, Revision 7, "Operating Organizations" (ADAMS Accession No. ML15007A296); Regulatory Guide 1.8, Revision 4, "Qualification and Training of Personnel for Nuclear Power Plants" (ADAMS Accession No. ML19101A395); and American Nuclear Society I American National Standards Institute (ANSI/ANS) 3.1-2014, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants."
RAl-3 (Specific Provisions)
As per NUREG-0800, Section 13.1.1, paragraph I.4.c, the description of the specific provisions which have been made for uninterrupted technical support for operations should be part of the description of the organization for a license transfer application.
Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1 A Page 9 of 12
In the Kewaunee Post-Shutdown Decommissioning Activities Reporl, Revision 2, attached to the supplemental letter dated May 13, 2021, the Dominion spent fuel management plan is identified and described on page 5. However, it is unclear whether EnergySolutions intends to follow this plan following the consummation of the proposed license transfer transaction. Accordingly, describe EnergySolutions' commitment to the existing Dominion spent fuel management plan identified on page 5 and whether EnergySolutions has any specific changes in activities, timing of the implementation, and updates to the original plan. Provide any supporling analyses and evaluations, as appropriate.
Response to RAl-3
PSDAR, Revision 2, Section I1.C, "Spent Fuel Management," states that spent fuel maintained at KPS is located in the ISFSI and will remain there until acceptance by the DOE, consistent with the current DEK Irradiated Fuel Management Plan (IFMP). PSDAR, Revision 2 discusses changes to the timeline for DOE acceptance of spent fuel and points to Section Ill of the PS DAR for schedule updates. PS DAR, Revision 2 now predicts that DOE will start accepting spent fuel in 2050 as opposed to the previously predicted date of 2021. As a result of the change to the DOE acceptance schedule, the funds required to maintain the ISFSI over this extended period and decommission it thereafter, and the source offunds for spent fuel management, must also be updated to reflect the predicted 2050 acceptance date.
EnergySolutions commits to providing an updated IFMP, in accordance with 10 CFR 50.54(bb), within 90 days after license transfer (see Regulatory Commitment in of this RAI response letter). The updated IFMP will include the projected cost and schedule for managing spent fuel, and will reflect the adjustments that will occur as a result of EnergySolutions becoming the licensee.
RAl-4 (Technical Qualifications)
More information is needed to determine the technical qualifications of the proposed transferee, as required under 10 CFR 50. 80. Specifically, furlher detail on the responsibilities and experience of the on-site dismantlement managers identified in, "Pre-Closing and Post-Closing Organizational Charis," of the application is needed to determine the qualifications of the persons who will be filling those positions.
The Applicants provided the resumes for some of the planned positions identified in Figure 2.3, "Kewaunee Solutions, Inc. Organization," in Enclosure 2 of the application.
However, the resumes were not provided for the following planned management positions identified in Figure 2.3: Radiation Protection Manager, Licensing Manager, Engineering Manager, Safety Manager, and Quality Assurance Manager. Accordingly, provide the resumes for the individuals that are proposed to fill these positions that have not yet been provided so that the NRG staff will be able to complete its determination of whether the proposed transferee is technical qualified to be the holder of the license.
Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1A Page 10 of 12
Response to RAl-4
Resumes showing the qualifications and experience of Managers presented in Figure 2.3 are included in Attachment 2 of this RAI response letter. Specifically, resumes are provided for the following individuals:
- David Villicana, Radiation Protection Manager
- Pamela Fergen, Licensing Manager
- Todd Eiler, Engineering Manager
- Keith Moss, Safety Manager
- Anthony Bejma, Quality Assurance Manager
Furthermore, these individuals meet the qualifications committed to in Appendix D, Section 3.1 of the Kewaunee Solutions Decommissioning Quality Assurance Plan submitted on October 4, 2021 (ADAMS Accession No. ML21277A246):
Facility staff responsible for the safe storage of nuclear fuel and selected decommissioning activities shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions as defined in approved procedures except for the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
RAl-5 (Technical Support)
NUREG-0800, Section 13.1.1 and Sections 13.1.2 - 13.1.3 indicate that the objective of a review of license transfers under 10 CFR 50. 80 is to ensure that the corporate management is involved with, informed of, and dedicated to the safe decommissioning of the plant. In addition, the review is to ensure that sufficient technical resources will be provided to adequately accomplish this objective and that there are sufficient interface arrangements and controls between the applicant and the major support organizations that the applicant will be responsible for and oversee.
More information is needed to evaluate any proposed changes to the current technical organization that would result from the proposed transfer and to evaluate the supporting technical resources that would be used for the decommissioning operations provided that the transfer is approved.
Accordingly, describe the difference between the current Dominion organizational structure for Kewaunee and that of the proposed organization after the consummation of the proposed transaction. If a function under the current organization will not be carried over to the proposed organization, explain why. Identify if there are any planned support agreements between Dominion post-Closing and EnergySolutions' strategic partners and how they fit into the planned Kewaunee Solutions organization chart in Enclosure 2 of the application. Also, identify if these supporting organizations would provide support to operations at the site. If so, identify where they would provide support in the organization Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1 A Page 11 of 12
and also identify the lines of communication and authority that these supporting organization would have in the overall proposed transferee's organization.
Response to RAl-5
See Dominion Support Agreement Organizational Chart in Figure RAl-5-1.
The existing DEK site employees will be retained at the site, as Dominion Energy employees. Dominion Energy and EnergySolutions have developed three support agreements (see Enclosure 1 B of License Transfer Application) to ensure the technical functions are carried over post-Closing. The three agreements are 1) ISFSI Management Services Agreement, 2) D&D Site Consulting Agreement, and 3) Transition Services Agreement. Per the ISFSI Management Services Agreement, these employees will manage the ISFSI for the Licensee. Per the D&D Site Consulting Agreement, DEK site employees will support and consult on the D&D activities, as needed, including historical site assessments, fire protection, operations, etc. The Transition Services Agreement ensures that the required records will be transferred and that information technology functions are retained. These support agreements are intended to ensure the previously performed Protection Services (Security), Operation & Maintenance, Engineering, and Radiation Protection & Chemistry functions are maintained at the ISFSI. The agreements also support continued compliance with the applicable regulatory requirements (Emergency Planning, Access Authorization, Records Retention, etc.). The existing DEK employees will continue to perform their duties in substantially the same manner as during the twelve (12) month period immediately preceding the date of License Transfer, and for a minimum of eight years after the License Transfer.
The agreements will be managed by the Kewaunee Solutions Project Director through direct lines of communication with the Dominion Energy Kewaunee Site Director.
Beyond the support agreements between EnergySolutions and Dominion Energy, there are no planned strategic partners or subcontractors that will be in decision-making roles.
Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1A Page 12 of 12
Dominion Energy Support Agreement Organizational Chart
!Kewaunee Site Di recto ~1 Kewaunee Solutions I Project Director
Administrative I-Assistant
'
- I Manager - Nuclear Manager-Nuclear Manager-Nuclear Manager - Radiation Operations & Engineering/Technical Protection Services Maintenance Support Protection & Chemistry I Coordinator Nuclear I Nuclear Environmental Security Programs - Engineer/Technical,... Compliance I - ISFSI Shift Supervisor Support Coordinator I Coordinator-I I FFD/Access Programs Records & Information Radiological Support
- Maintenance Specialist - Analyst -- Coordinator I Supervisor Nuclear I Security Shift -
I IT Support Coordinator I Assistant Supervisor I Nuclear I Security Shift
Nuclear Security & Alarm I I Specialist
Figure RAl-5-1: Dominion Support Agreement Organizational Chart Serial No.: 21-352 Docket Nos. 50-305/72-64
ENCLOSURE1B
AFFIDAVIT FOR WITHHOLDING CONFIDENTIAL INFORMATION
Kewaunee Power Station Dominion Energy Kewaunee, Inc.
EnergySo/utions, LLC Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1 B Page 1 of 2
10 CFR2.390 AFFIDAVIT OF RUSSELL G. WORKMAN
I, Russell G. Workman, General Counsel and Secretary ofEnergySolutions, LLC.
("Energy Solutions"), state that:
- 1. I am authorized to execute this affidavit on behalf of Energy Solutions.
- 2. Energy Solutions is providing information in support of the above-described, "Response to Request for Additional Information Regarding Application for Order Approving Transfer of Control of Kewaunee Power Station License and Confom1ing License Amendments." Enclosure 1 C of the Application contains trade secrets and financial information, including proprietary aspects to the decommissioning of Kewaunee Power Station ("KPS"), which constitute proprietary commercial and financial information that should be held in confidence by the NRC pursuant to the policy reflected in 10 CPR 2.390(a)(4) and 10 CPR 9.l 7(a)(4), because:
- a. This information is and has been held in confidence by Energy Solutions and its affiliates.
- b. This information is of a type that is held in confidence by Energy Solutions and its affiliates, and there is a rational basis for doing so because the information contains sensitive trade secret or financial information concerning the decommissioning approach offered by Energy Solutions for KPS, as well as the terms of the purchase of Dominion Energy Kewaunee, Inc. by EnergySolutions.
- c. This information is being transmitted to the NRC in confidence.
- d. This information is not available in public sources and could not be gathered readily from other publicly available information.
- e. Public disclosure of this information would create substantial hann to the competitive position of Energy Solutions and its affiliates by disclosing the terms of a unique transaction to other parties whose commercial interests may be averse to those of Energy Solutions.
Serial No.: 21-352 Docket Nos. 50-305/72-64 Attachment 1, Enclosure 1 B Page 2 of 2
- 3. Accordingly, EnergySolutions requests that Enclosure IC to the "Response to Request for Additional Information Regarding Application for Order Approving Transfer of Control of Kewaunee Power Station License and Conforming License Amendments" be withheld from public disclosure pursuant to 10 CPR 2.390(a)(4) and 9.17(a)(4).
EnergySolutions, LLC
Russel G. Workman General Counsel and Secretary
STATE OF UTAH
COUNTY OF SALT LAKE
Subscribed and swoo&-me, a Notary Public, in and for the County and State above named, this ~y of *, 2021. ~ ~
~~-
My Commission Expires: ~/~/c<.CJd.5
~ DEBBIE THOMAS i '\\ NOTARY PUBLIC
- STATE OF UTAH
-~./ My Comm. Exp. 08/18/2025.... Commission# 719719 Serial No.: 21-352 Docket Nos.: 50-305/72-64
ATTACHMENT 2
RESUMES FOR PLANNED MANAGEMENT POSITIONS WITHIN KEWAUNEE SOLUTIONS, INC.
Kewaunee Power Station Dominion Energy Kewaunee, Inc.
EnergySolutions, LLC Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 1 of 17
ENERGY SOLUTIONS
DAVID VILLICANA
Radiation Protection Manager
Experience Summary:
Over thirty years' experience working as a Radiation Protection Professional, with a current position of Radiation Protection Manager, and Training Manager. National Registry of Radiation Protection Technologists (NRRPT) registered and certified as a Project Manager Professional. Past assign ments include Emergency Plan Manager, Radiation Protection (RP) Manager, Radiation Protection Supervisor over dry fuel storage and containment decommissioning, ALARA Project Manager -
CANDU, ALARA Manager, General Supervisor over ALARA and RP Operations, INPO Certified RP Instructor, Radiological Engineer, RP Instrument Supervisor and RP Technician. Experience: BWR, PWR, PWRH (CANDU) plants and plant decommissioning projects. Overall strengths are Change Agent, Analyst, Planner, and implementation with a strong capability to lead others.
Education & Certifications:
University of St Francis
- Master of Science in Training and Development Siena Heights University
- Bachelor of Applied Science, Computer Information System Certifications and Training
- Certified as a Project Management Professional (PMP)
- Registered Radiation Protection Technician with the National Registry of Radiation Protec tion Technologists (NRRPT)
- Oak Ridge Associated Universities (ORAU) Applied Health Physics Training - ORAU Multi Agency Radiation Survey and Site Investigation Manual (MARSSIM) Training
Military:
United States Marine Corps (Active Duty/Reserve)
- Rank - Sergeant United States Air Force (Reserve)
- Rank - Staff Sergeant
Employment History:
March 2016 to Present (2021)
Energy Solutions Radiation Protection Manager I Training Manager/ Waste Manager Zion /TMl-2 / Kewaunee
- Radiation Protection Manager responsibility for Zion decommissioning
- Training Manager responsibility for Zion, TMl-2 and Kewaunee decommissioning projects
- Waste Manager responsibility for Zion
- TMl-2 Risk Manager Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 2 of 17
ENERGY SOLUTIONS Villicana Pa e 2 of 4
- The transition of programs between ZionSolutions and Exelon
- Managed the Radiological Environmental Monitoring Program (REMP), Radiological Effluent Technical Specifications (RETS), Radiological Groundwater Protection Program (RGPP) programs, and RP Projects
- Emergency Preparation (EP) Manager - Facilitate the transition of Emergency Plan Program from Site to ISFSI only
- Manage Open Air Demolition airborne monitoring
- RP and Training Project close out
March 2015 to March 2016 Energy Solutions Radiation Protection Manager La Crosse BWR (LACBWR)
- Revitalized the Radiation Protection program at LACBWR
- Prepared and transitioned the project from a SAFSTOR site to a D&D site
- Developed RP procedures before going into full decommissions mode.
- Managed and updated radiation protection programs for the client before the license trans-fer.
- Managed and resolved NRC and ANI issues and concerns
- Worked and oversaw all aspects of the Radiation Protection program.
- Oversaw final cleanup of sumps and tanks containing liquids or sludge
June 2013 to March 2015 Energy Solutions RP Operations Supervisor, Dry Fuel Storage ZionSolutions Restoration Project
- Developed RP fuel support program
- Supervised Radiation Protection Technicians (RPTs)
- Oversight of Containment Work
June 2012 to June 2013 Bruce Power - Bruce Power Canada ALARA Manager/Project Manager - Bartlett Nuclear Inc. Consultant
- Reviewed and revised ALARA planning against industry best practices
- Developed ALARA strategies for the projects group to initiate in station projects
- Lead Root Cause Investigator for Radiation Protection Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 3 of 17
ENERGY SOLUTIONS Villicana Pa e 3 of 4
May 2008 to June 2012 Palisades Nuclear Plant - Entergy ALARA Manager, Radiological Engineer Outages/ALARA Outage Supervisor
- Responsibilities included ALARA Outage planning and managing collective radiation expo sure (CRE) HIT teams.
- Managed projects with significant CRE impacts
- Supervised the ALARA program and personnel
- Revamped the ALARA process and plans to follow a project management methodology
- Responsible for all outage planning.
- Supported emergency planning organization.
- Developed and instituted the Micro ALARA Plan that reviewed all work to reduce the dose further. The process was accepted into the work management process at Palisades.
- Responsible for training RP staff and site staff.
- Managed the Station ALARA Committee
January 2007 to May 2008 Point Beach Nuclear Plant - Florida Power & Light (FPL)
Radiation Protection General Supervisor
- Oversaw RP supervisors and RPTs - Improved the professional standard of existing super visors. Guided change and increased technical rigor through the upgrade of processes and procedures changes. Utilized RPTs in Outage HIT teams. This resulted in an overall in crease in technical rigor of the RP department.
- Curriculum Review Committee Chairperson for RPT Training program - on arrival at the sta tion, RP line ownership of training was in question. Over the period of a year, line ownership of training was turned around and no longer proved to be a concern for the site. The INPO Accredited Training Visit in February 2008 identified no issues in the RP training program.
- The overall achievement was setting processes in place in the RP organization that dealt with High Radiation Area (HRA)/Locked LHRA violations, which allowed RP to get an INPO category 1 in June of 2009.
August 2005 to December 2006 Nuclear Management Company, Monticello Nuclear Power Plant Senior Technical Instructor
- Responsible for the Radiation Protection Technician Training Program
- Focused Self-Assessment and Root Cause Evaluations
- Promoted to General Supervisor at Point Beach Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 4 of 17
ENERGY SOLUTIONS Villicana Pa e 4 of 4
May 2005 Westinghouse, Prairie Island ALARA Coordinator I Radiological Engineer Steam Generators
- Oversaw Steam Generator work, to include exposure and contamination control.
- Provided dose reports, attended Station ALARA Committee meetings, and represented Westinghouse in radiological concerns.
January 2004 to March 2005 AmerenUE, Callaway Radiation Chemistry Training Supervisor
- Developed project plans to manage the program owner's training program.
- Responsible for identifying training needs, performing need analysis, developing training material, scheduling training and instructing in the classroom. Solicited the program owner on performance deficiencies to be corrected using training.
- Facilitated job analysis, created new task analysis, updated qualifications, and lesson plan material.
September 2003 to October 2003 Venture - Newberg/Perini Stone and Webster, Morris IL ALARA Coordinator/ Radiological Engineer
- Outage Support
January 2003 to February 2003 Bartlett Nuclear, Quad Cites Radiological Engineer/ Consultant
- Developed a white paper identifying stellite components within the plant system with rec ommendations to mitigate satellite components installation.
December 2000 to December 2002 Exelon, Business Services Company, Chicago, Illinois
- Training Implementation Coordinator/Quality Assurance for the PassPort Work Management program to transmission and distribution of Commonwealth Edison and EPS to Exelon.
April 1981 to December 2000 Exelon Nuclear, Dresden, Morris, Illinois
- Radiological Engineer
- First Line Supervisor
- Training Specialist/ Instructional Technologist
- Radiation Protection Instrument Supervisor
- Robotics and Remote Technology/ALARA Engineer
- Radiation Protection Technician Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 5 of 17
ENERGY SOLUTIONS
PAMELA FERGEN, PH.D.
Licensing Manager
Licensing Engineer/Project Manager with 16 years of experience providing support in areas of nuclear training, mechanical engineering, regulatory programs, and licensing document development, reviews, and submittals. Licensing expertise has been provided in support of nuclear operations, new build, and decommissioning.
Education & Certifications:
Ph.D. in Mechanical Engineering,
- Old Dominion University, Norfolk, VA
8.5. in Mechanical Engineering
- Old Dominion University, Norfolk, VA
Employment History:
2019-Present (2021)
Energy Solutions Nuclear Licensing Manager Corporate Licensing Manager/LaCrosseSo/utions Licensing Manager:
- Perform corporate D&D licensing manager functions including:
Procedure development and review (e.g., TMl-2 D&D procedures)
Regulatory correspondence (e.g., prepare and review regulatory correspondence for decommissioning sites)
Functional area manager support (e.g., licensing lead for Final Status Survey Final Re ports produced by the radiation protection group)
Act as the Licensing Manager for LaCrosseSo/utions.
Serve as a member of the Project Operations Review Committee
2018-2019 Southern Nuclear Company, contract position with E-Group Licensing Engineer, Senior Consultant Licensing Engineer for Vogtle Units 3&4:
- Prepared and reviewed license amendment requests and exemptions, including first of a kind requests to transfer operator exam pass letters and credit tests completed at the first AP1000 site(s)
- Acted as the licensing lead for the training department and the Fukushima project group; duties including consulting activities and preparation of licensing document change requests
- Acted as the licensing lead for Cyber Security initiatives; responsibilities included facilitating in spection planning meetings, preparing and reviewing licensing basis changes to the cyber se curity plan, and interacting with the regulator Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 6 of 17
ENERGY SOLUTIONS Fergen Pa e 2 of 4
2017-2018 NuScale, contract position with Enercon Licensing Engineer/Project Manager, Senior Consultant Licensing Engineer for Small Modular Reactor (SMR) Project:
- Developed Combined Operating License (COL) action items; facilitated reviews of COL items, by Subject Matter Experts (SM Es) and managers, following research of regulation and prece dence; presented findings to program owners and project managers
- Identified technical deliverables necessary to support COL applicant
2015-2017 South Carolina Electric & Gas (SCE&G), contract position with ATR Licensing Engineer/Project Manager, Senior Consultant Licensing Engineer for SCANA Units 2&3:
- Project Manager responsible for coordinating reviews and approvals of licensing change pack ages; act as the liaison between SCE&G and Westinghouse
- Ensured design change packages were properly implemented, reviewed revisions to licensing documents
- Reviewed and approved design change packages created by Westinghouse and sites
- Created License Amendment Requests and departure packages
Licensing Engineer for the Fukushima Response Organization:
- Managed VC Summer Diverse & Flexible Mitigation Capability (FLEX)/ Spent Fuel Pool Level Instrumentation (SFPLI) audit preparations
- Prepared Fukushima related correspondence including the six-month updates for the FLEX and SFPLI Overall Integrated Plans and the Phase II Staffing Analysis
- Authored the Final Integrated Plan for FLEX for Unit 1
2014-2015 Westinghouse Electric Company, contract position with System One Licensing Engineer for US AP1000:
Licensing Engineer, Senior Consultant
- Prepared and verified 50.59 like evaluations and License Amendment Requests for the AP1000; worked with customers to ensure quality products
- Evaluated engineering design changes with respect to regulatory requirements
- Assisted with project management duties, including customer interface and meeting facilitation
2013-2014 Brunswick Steam Electric Plant, contract position with Sun Technical Licensing Engineer Consultant Licensing Engineer for the Fukushima Response Organization:
- Prepare, review and submit regulatory correspondence related to Fukushima efforts.
- Assisted site leads and project managers to ensure requirements were met and schedules were maintained; participated in site audits and assessments
- Gathered information from industry and NRC correspondence to determine site requirements; tracked commitments
- Reviewed engineering documents produced by internal organization and vendors
- Interfaced with NRC on all matters related to Fukushima Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 7 of 17
ENERGY SOLUTIONS Fergen Pa e 3 of 4
2012-2013 URS Mechanical/Project Engineer Mechanical Engineer in URS's Energy and Construction Group:
- Prepared, reviewed and verified System Design Descriptions, Piping & Instrumentation Dia-grams and Data Sheets for PWR systems
2009-2012 Progress Energy Senior Licensing and Regulatory Programs Engineer/Instructor Senior Licensing and Regulatory Programs Engineer at Robinson Nuclear Plant:
- Completed 10 CFR 50.59 training and USA Regulatory Affairs Training and Qualification of fered by Certrec Corporation
- Wrote regulatory correspondence including Licensee Event Reports, Event Notification Worksheets, Nuclear Regulatory Commission Bulletin responses and program submissions
- Performed Reportability worksheets, process licensing document changes, conduct self assessments. Interacted with Resident Inspectors. Coordinated inspection activity.
- Acted as the INPO coordinator and submitted the nuclear plant's monthly performance indi cator data through INPO's Consolidated Data Entry
Senior Instructor at a nuclear power plant:
- Qualified as an instructor using the Systematic Approach to Training (SAT) and Analysis, Design, Development, Implementation and Evaluation (ADDIE) processes. Conducted train ing audits and investigations.
- Prepared lesson plans and taught fundamental classes to auxiliary operators
2008-2009 Callidus Technologies by Honeywell Senior Mechanical Engineer Design engineer within the thermal oxidizer group of a combustion equipment company:
- Used Advanced Pressure Vessel Software to design pressure vessels
- Introduced standardization techniques to improve efficiency; implemented changes
2004-2008 Naval Nuclear Power Training Command Instructor/Program Manager Instructor at Naval Nuclear Power Training Command. Primary duty as instructor for Enlisted Math ematics and Chemistry/ Material Science/ Radiological Fundamentals. Used ADDIE/SAT process.
Also served as Command Managed Equal Opportunity (EO) Officer:
- Instructed students in various course; prepared lessons and exam modification; counseled students and conducted study sessions
- Studied the effectiveness of Nuclear Power School's Math modules; audited programs and procedures; determined a correlation between student success and module usage; results were used to implement a student study plan
- Revamped the command managed equal opportunity program; revised student and staff in doctrination training leading to a reduction in EO complaints Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 8 of 17
ENERGY SOLUTIONS Fergen Pa e 4 of 4
2001-2002 M&G Electronics Mechanical Supervisor/Project Manager Directed assembly of all panel prototypes and samples. Interfaced with project engineers, buyers, sales department and inventory personnel. Responsible for approval of new parts:
- Supervised 12 personnel in the production of prototypes
- Developed and implemented a scheduling and planning technique to increase productivity and meet and/or exceed customer deadlines
2000-2001 John Deere Project Manager/Engineer Project responsibility for the complete renovation of the Engineering Department. Project Manager with tasks including design, scheduling, budgeting and managing of personnel:
- Planned and managed all aspects of a building renovation; supervised company mainte nance personnel as well as department contractors on site
- Improved department lighting, heating and air conditioning; incorporated ergonomic work areas and designed a more efficient office layout Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 9 of 17
ENERGYSOLUTIONS
Engineering Manager
Experience Summary:
Mr. Eiler provides more than 14 years of engineering and project management experience in the nuclear industry with an extensive background in civil and structural engineering, and construction management.
Education & Professional Affiliations:
- B.S., Civil Engineering, Cal Poly San Luis Obispo, 2005
- M.S., Civil Engineering, Virginia Tech, 2007
- Professional Engineer (Civil), NC, FL
- Project Management Professional (PMP)
- ASCE/SEI, PMI
Employment History:
2017 to Present (2021)
Energy Solutions Director - Engineering & Projects
- Zion D&D General Manager
- Responsible for developing, maintaining and executing the D&D Division's engineering pro gram and procedures. Provides support to SONGS, TMl-2, Zion, La Crosse, Fort Calhoun and other decommissioning projects.
- Successfully directed over a dozen projects with revenue approaching $100M, without a single lost-time accident. Signature projects include:
SONGS U1 Reactor Pressure Vessel (RPV) transport and disposal Fort Calhoun Large Components (2 Steam Generators, Reactor Head, Pressurizer)
Surry Rotor Casings (1.8M pounds)
2014-2020 Nustruc PLLC President Prairie Island & Fort Calhoun FLEX Buildings
- Supported PFES, LLC in the role of structural engineer for the following projects: Prairie Island FLEX Building, Fort Calhoun FLEX building. Served as Project Manager for a coal ash investigation at Duke Marshall Steam Station using Frequency Domain Electromagnetic technology.
Catawba and Oconee FLEX Building
- Served as Civil / Structural Task Manager at Duke Energy's Catawba and Oconee Nuclear Power Plants during construction of their FLEX storage buildings for SGT, LLC.
China CPR-1000 New Build Support US AP-1000 New Build Support Calvert Cliffs Engineering Support Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 10 of 17
ENERGY SOLUTIONS Eiler Pa e 2 of 3
2014-2015 Southern California Edison, SONGS (Wachs)
Task Manager
- Organized, managed, coordinated and oversaw the refurbishment of the K-10/20/20 building for use by Major Projects during the decommissioning of SONGS. Completed this project on time and 30% under budget using union labor.
- Integral team member for development and review of RFP and bid selection process for $?OM Cold and Dark project. Developed independent resource loaded level 3 schedule to compare to bidders.
- Reviewed numerous civil and structural engineering documents for conformance and feasibility.
2013-2014 Westinghouse, Cranberry, PA Structural Engineer
- Provided structural and mechanical engineering assistance in support of eight (8) AP-1000 nuclear power plants in the US and China.
- Worked extensively to ASME Boiler & Pressure Vessel Code (BPVC) Section Ill regarding welding and fabrication issues related to the AP-1000 containment vessel.
- Field support was provided remotely and revolved around responses to Requests for Information (RFls), Non-Conformance Reports (NCRs), Field Change Requests and other emergent issues.
2011-2013 Areva Structural Engineer
TVA Sequoyah Unit 2 Steam Generator Replacement Project
- Served as Resident Structural Engineer. Developed safety related mix design for containment opening, acting field engineer for outside lift system foundation, concrete roof superstructure frame, reactor containment reinforcing and bar-lock installation and oversaw safety-related concrete placement of containment opening. Structural engineer for large reinforced concrete containment structure to house irradiated steam generators.
AREVA U.S. EPR Design Certification
- Supported AREVA with their U.S. EPR 1600 MWe design in the role of structural engineer in support of the license application. Designed large floor slabs in accordance with ACI 349 and verified calculations of fuel pool walls.
2007-2011 Bechtel Structural Engineer
- Supported Bechtel at multiple projects in various roles.
o A key accomplishment was developing calculations in support of Yucca Mountain License Application to the NRC. Developed finite element models, performed linear, non-linear, pushover analyses. etc.
o Field Engineer for SONGS U-3 Steam Generator Replacement Project (SGRP) and Florida Power & Light (FP&L) St. Lucie Extended Power Uprate (EPU) projects.
Designed, procured and lead installations of multiple steel structures.
Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 11 of 17
ENERGY SOLUTIONS Eiler Pa e 3 of 3
o Construction engineer for Radiological Laboratory Utility Office Building (RLOUB) facility at Los Alamos National Laboratory. Lead the installation of the seismic bracing supports for the mechanical, electrical systems of the facility.
Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 12 of 17
ENERGY SOLUTIONS
KEITH MOSS
Safety Manager
Experience Summary:
Environmental, Health, and Safety Management Professional with global experience in new build Engineering, Procurement & Construction (EPC), operations, maintenance, and decommissioning projects. Experience covers nuclear, fossil, hydro, solar, combined cycle, simple cycle, cogeneration, alternative fuel, transmission/distribution, chemical, oil & gas, manufacturing projects and fixed facilities. Experienced and able to build and lead teams in project development, front end planning, program development and execution of domestic and international EPC projects.
Successfully worked with organizational team members to implement Zero Injury techniques and improve the culture of safety within various organizations.
Education & Professional Affiliations:
- B.S., Occupational Safety & Health, Columbia Southern University, Orange Beach, AL
- Board of Certified Safety Professionals - Certified Safety Professional #22482
- American Society of Safety Professionals - Professional Member
- American Nuclear Society
- Nuclear Industrial Safety & Health Association -Associate Member
Employment History:
April 2017 to Present (2021)
Energy Solutions Corporate Health & Safety Director, Nuclear Waste Services, Decommissioning & Demolition Health, Safety & Environmental (HSE) Director for global Nuclear D&D/Waste Management organization. Responsible for HSE program development and implementation globally. Focus on personnel safety, injury prevention, human performance improvement, environmental protection, medical services, OCIP/CCIP participation and management, industrial hygiene, leading indicator metrics, auditing, emergency response, fitness for duty, worker training and qualification.
March 2014 to March 2017 Flour Power, HSE Director HSE Director for Power Division, which includes EPC Power Construction domestic and international projects, Power Maintenance group, Nuclear and Renewable Energy Sectors.
Responsible for HSE program development and implementation for the power group globally.
Focusing on the areas of personnel safety, injury prevention, environmental protection, medical services, Owner Controlled Insurance Program (OCIP)/Contractor Controlled Insurance Program (CCIP) participation and management, industrial hygiene, leading indicator metrics, auditing, emergency response, fitness for duty, worker training and qualification.
Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 13 of 17
ENERGY SOLUTIONS Moss Pa e 2 of 3
June 2013 to May 2014 Chicago Bridge & Iron Plant Services, HSE Director HSE Director for Plant Services, Power Maintenance group. Responsible for HSE program implementation for Fossil and Nuclear power generation facilities across the US. Focused on the areas of personnel safety, injury prevention, environmental protection, medical services, OCIP participation and management, industrial hygiene, leading metrics, auditing, emergency response, fitness for duty, worker training and qualification.
February 2012 to June 2013 Mitsubishi Nuclear Energy Systems Power, Corporate ES&H Director Environment, Safety & Health (ES&H) Director for nuclear new build division of Mitsubishi Heavy Industries. Responsible for ES&H program development and implementation for their first US based new nuclear construction projects. Developed ES&H process manual, established program for human performance, Safety Conscious Work Environment (SCWE) program, nuclear safety culture, injury prevention, environmental protection, medical services, industrial hygiene, leading metrics, auditing, emergency response, fitness for duty, worker training and qualification.
November 2008 to January 2012 The Shaw Group Power, ES&H Director - Nuclear New Build ES&H Director for Nuclear Division of Shaw's Power Group. Responsible for ES&H program devel opment and implementation for first two US based new nuclear construction projects in over 20 years. Focusing on the areas of personnel safety, injury prevention, environmental protection, med ical services, OCIP management, industrial hygiene, leading metrics, auditing, emergency re sponse, fitness for duty, worker training and qualification.
November 2004-November 2008 Southern Company Power, Construction Services ES& Manager Construction Services division ES&H Manager responsible for the development and administration of environmental, safety and health program that encompassed new generation projects, (combined cycle and simple cycle), environmental upgrades, retrofit and new generation projects for operating companies across the Southeastern region. Responsible for the placement and development of safety professionals to support project needs, contractor selection and contract safety management programs for generation projects.
May 1996 to November 2004 Fluor Constructors International, Inc HSE Manager Manage Health, Safety and Environment department and administer the corporate safety programs for new build EPC projects. This included actual development of site-specific safety manuals and training program based upon the projects schedule, OSHA and EPA regulations. Assessed acci dent investigations to include root cause analysis and safety inspections. Coordinated the Injury Management program and Workers' Compensation claims.
Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 14 of 17
ENERGY SOLUTIONS Moss Pa e 3 of 3
April 1994 to January 1996 G*UB*MK Constructors (a Joint Venture of Gilbert Commonwealth, Union Boiler and Morrison Knudsen), POWER GENERATION Area Safety Manager Initiated and administered on site safety and health programs for Fossil Fuel and Hydroelectric construction and maintenance operations at the Tennessee Valley Authority (TVA) facilities.
Responsibilities included programs at six different capital and maintenance hydroelectric and fossil generation projects in the Tennessee, Kentucky, Alabama, Georgia and North Carolina areas.
December 1991 to April 1994 Fluor Constructors International, Inc.
Safety Manager Ensured contract and safety adherence during power generation projects including boiler Powder River Basin (PRB) coal conversion, capital projects at existing power units, retrofit activities and outage projects at locations in Kentucky, Tennessee, and Indiana.
June 1990 to December 1991 Martin Marietta Energy Systems, Inc.
Health Physics Technician Ensured compliance with DOE radiation protection standards at uranium enrichment facility.
Contamination control, survey and categorization of existing facilities, personnel monitoring, whole body counts and bioassay monitoring for potential uptake of radioactive materials. DOE "L" security clearance
June 1989 to June 1990 D. D. Page and Associates Safety Supervisor Development and administration of new build emulsion project safety and health program for Air Products chemical plant expansion project.
July 1987 to June 1989 Fluor Constructors International, Inc.
Safety Supervisor Project Safety Supervisor for new build boiler and maintenance Power Generation projects.
Ensured development and implementation of site and corporate safety program requirements, orientation and training of craft/staff employees, manage industrial hygiene programs as needed.
Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 15 of 17
ENERGY SOLUTIONS
ANTHONY ("TONY") R. BEJMA
Quality Assurance Manager
Experience Summary:
Mr. Bejma has over 30 years in project management, Quality Assurance (QA), records programs, and spent fuel activities, primarily in commerical nuclear industry projects, including over 15 years engaged in decommissioning services. He has provided corporate level oversight and QA support for EnergySolutions D&D projects, including Zion, La Crosse, and SONGS Units 2 & 3. He provided consulting services for the transition of the Humboldt Bay plant from SAFSTOR to decommissioning. As a Dry Fuel Storage QA Engineer, he provided oversight for spent nuclear transfer activities and documentation at the Yankee Rowe, Trojan, and Maine Yankee plants during decommissioning. Provided project planning and execution of spent fuel pol re-racking projects at the Maanshan and Chinshan sites in Taiwan.
Education & Certifications:
- M.A., Asian Studies, Florida State University
- B.A., Philosophy and Asian Studies, University of South Florida
- A.S., Manufacturing Design, Ball State University
Employment History:
May 2020- Present (October 2021)
Consultant, Various Decommissioning and Dry Fuel Assignments Provided consulting services including:
- Dry Fuel Component documentation review, Three Mile Island (Unit 1)
- D&D program and procedure development, Three Mile Island (Unit 2)
- D&D Corrective Actions / Cause Evaluations, various projects
- QA program development and D&D programs transition planning, Kewaunee
May 2016 - January 2020 Energy Solutions Vice President, Quality Assurance Provided corporate level oversight and specialized QA support for the Zion, La Crosse and SONGS decommissioning projects. Led the development of the decommissioning QA program at SONGS and established staffing, procedures, and audits to ensure a successful start to the decommissioning transition for Units 2 & 3. Provided guidance for activities associated with spent nuclear fuel transfer projects and decommissioning activities, including transition from operations to active DEGON tasks, developed corporate QA programs and procedures supporting decommissioning.
Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 16 of 17
ENERGY SOLUTIONS Bejma Pa e 2 of 3
July 2015-April 2016 Consultant, Various Decommissioning and Dry Fuel Assignments Provided consulting services including:
- Dry Fuel project closeout and QA Manager turnover at Zion
- La Crosse QA program revisions
- Maine Yankee fire protection procedure review and revisions
October 2010 -July 2015 EnergySo/utions/ZionSo/utions, Zion Nuclear Station Director of Quality Assurance Established and implemented the QA program for the decommissioning project following a prolonged SAFSTOR period. This included all oversight activities and processes (audits, surveillances, and inspections), supplier evaluation, procurement evaluation, QA/QC staff development, etc. Successfully established and managed QA oversight and QA inspection efforts for the Dry Fuel Transfer and Greater-Than-Class-C (GTCC) projects for over a year.
Authored strategic QA program revisions associated with NRC License Amendments. Served key role in providing vision, guidance and focus on post-Fuel Transfer Operations (FTO) site wide procedure reduction initiative.
November 2009 - May 2010; January 2009 -April 2009 Humboldt Bay Nuclear Plant Consultant Provided consulting services for the QA program and records strategy for decommissioning.
Developed and implemented QA program changes. Developed and implemented on-site processing of records, including program and procedure changes specific to the Independent Spent Fuel Storage Installation (ISFSI) and decommissioning records. Provided consulting services during the transition of the plant from SAFSTOR to decommissioning. Identified and executed Engineering and Design Control procedures reduction project.
April 2007 -July 2008 Yankee Rowe/Connecticut Yankee/Maine Yankee Documentation Manager Obtained, reviewed and filed spent nuclear fuel records and wrote ISFSI procedures.
October 2006 - April 2007 Bradwell Nuclear Site, United Kingdom (UK)
Project Manager Managed the Waste Inventory & Characterization project for the Bardwell decommissioning, on schedule and under budget for an international consortium. Responsible for all work planning, scheduling, cost control and contract management.
Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 2, Page 17 of 17
ENERGY SOLUTIONS Bejma Pa e 3 of 3
May 2001 -September 2006 Various Decommissioning Sites Decommissioning Documentation/QA Engineer/Corrective Actions Coordinator positions Provided consulting services for documentation management, QA and Quality Control processes, and Corrective Actions Program (CAP) for dry fuel storage projects.
- Yankee Rowe (July 2004-September 2006)
- Maine Yankee (July 2003 - July 2004)
- Trojan (July 2002 - July 2003)
- Maine Yankee (May 2001 - July 2002)
Other Nuclear Work Experience:
- From 1986 to 2001, for Underwater Construction Corporation, performed Project Management and QA/QC services for numerous spent fuel pool re-rack and other nuclear diving projects.
- During 1994 - 1995, Project Manager for the Maanshan plant (Taiwan) re-rack project, for the procurement and mobilization phase - responsible for project planning, including procurement, procedures, crew selection, and site mobilization. Also directed the spent fuel re-rack work at Chinshan.
- Other re-rack projects were conducted in the UK (Sizewell) and the U.S. (Maine Yankee, Nine Mile Point, Wolf Creek, Callaway, Davis Besse, Comanche Peak and Fermi nuclear plants).
Serial No.: 21-352 Docket Nos.: 50-305/72-64
ATTACHMENT 3
LIST OF REGULATORY COMMITMENTS
Kewaunee Power Station Dominion Energy Kewaunee, Inc.
EnergySo/utions, LLC Serial No.: 21-352 Docket Nos.: 50-305/72-64 Attachment 3 Page 1 of 1
The following list identifies regulatory commitments in Attachment 1 to this letter ("Response to Request for Additional Information Application for Order Approving License Transfer and Conforming License Amendments"). Any other actions discussed in the submittal represent intended or planned actions. They are described only as information and are not Regulatory Commitments.
TYPE REGULATORY COMMITMENT CONTINUING COMPLETION ONE-TIME SCHEDULED ACTION COMPLIANCE DATE EnergySolutions commits to X Within 90 days after providing an updated Irradiated license transfer Fuel Management Plan, in accordance with 10 CFR 50.54(bb).