ML22343A190

Acceptance Review: Palisades Proposed Exemption from 10 CFR 140.11 (a)(4) – Primary and Secondary Liability Insurance

ML22343A190
Person / Time
Site:	Palisades
Issue date:	12/09/2022
From:	Tanya Hood Reactor Decommissioning Branch
To:	Fleming J Holtec Decommissioning International
T. Hood, NMSS/DUWP/RDB, 301-415-1387
References
EPID L-2022-LLE-0031
Download: ML22343A190 (2)

Text

1 Tanya Hood From:

Tanya Hood Sent:

Friday, December 09, 2022 12:43 PM To:

J.Fleming@holtec.com Cc:

j.miksa@holtec.com; Marlayna Doell

Subject:

Acceptance Review: Palisades Permanent Exemption Requests for Palisades from 0 CFR 140.11 (a)(4)

Primary and Secondary Liability Insurance

SUBJECT:

PALISADES NUCLEAR PLANT - ACCEPTANCE OF REQUESTED LICENSING ACTION RE:

PROPOSED EXEMPTIONS FROM 10 CFR 140.11 (a)(4) - PRIMARY AND SECONDARY LIABILITY INSURANCE (EPID L-2022-LLE-0031)

Dear Jean Fleming:

By letter dated October 26, 2022 (Agencywide Documents Access and Management System Accession No. ML22299A059), Holtec Decommissioning International, LLC (Holtec), on behalf of Holtec Palisades, LLC, requested authorization for a permanent exemption from the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 140.11, Amounts of financial protection for certain reactors, for the Palisades Nuclear Plant (Palisades) that would reduce the required level of primary offsite liability insurance from

$450,000,000 to $100,000,000 and eliminate the requirement for Palisades to carry secondary financial protection.

The purpose of this e-mail is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this exemption request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

The NRC staff has reviewed your application and concluded that it does provide technical information in sufficient detail to enable the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed exemption in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review as compared to the detailed technical review, there may be instances in which issues that impact the NRC staffs ability to complete the detailed technical review are identified despite completion of an adequate acceptance review. If additional information is needed, you will be advised by separate correspondence.

There is an ongoing review of Holtecs Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR 50, Appendix E, which was submitted on July 11, 2022 (ML22192A134). Approval of these exemptions will be necessary before this exemption can be implemented, and any concerns identified during the NRCs review of the Palisades emergency planning exemptions may impact this exemption request.

Therefore, based on the information provided in your submittal, the NRC staff has estimated that this licensing request will take approximately 260 hours0.00301 days <br />0.0722 hours <br />4.298942e-4 weeks <br />9.893e-5 months <br /> to complete. The NRC staff expects to complete this review in approximately 9 months, which is July 31, 2023. If there are emergent complexities or challenges in our review that would cause changes to the initial forecasted completion date or significant changes in the forecasted hours, the reasons for the changes, along with the new estimates, will be communicated during the routine interactions with the assigned project manager.

2 These estimates are based on the NRC staffs initial review of the application and they could change, due to several factors including requests for additional information, unanticipated addition of scope to the review.

Additional delay may occur if the submittal is provided to the NRC in advance or in parallel with industry program initiatives or pilot applications.

If you have any questions, please contact me.

Tanya E. Hood, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards 301-415-1387