PNP 2024-014, Request for USNRC to Rescind Approved Exemption Requests for 140.11(a)(4) and 50.54(w)(1), Reduction of Insurances
| ML24283A094 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/09/2024 |
| From: | Fleming J Holtec, Holtec Palisades |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| HDI PNP 2024-014 | |
| Download: ML24283A094 (1) | |
Text
22780 Blue Star Highway, Covert, MI 49043 HDI PNP 2024-014 10 CFR 50.12 October 9, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Renewed Facility Operating License No. DPR-20 NRC Docket Nos. 50-255 and 72-007
Subject:
Palisades Nuclear Plant +/- Request for USNRC to Rescind Approved Exemption Requests for 140.11(a)(4) and 50.54(w)(1), Reduction of Insurances
Dear Sir or Madam:
On October 26, 2022, Holtec Decommissioning International, LLC (HDI) submitted two exemptions requests. The first submittal (Reference 1) requested an exemption to reduce the required level of primary offsite liability insurance in accordance with 10 CFR 140.11(a)(4) from
$450 million to $100 million and to eliminate the requirement to carry secondary financial protection for Palisades Nuclear Plant (PNP). This exemption was approved by the United States Nuclear Regulatory Commission (USNRC) on December 26, 2023 (Reference 3).
The second exemption submittal (Reference 2) requested an exemption to reduce the minimum coverage limit of onsite property damage insurance in accordance with 10 CFR 50.54(w)(1) from $1.06 billion to $50 million for PNP. This exemption was approved by the USNRC on December 22, 2023 (Reference 4).
Recently, HDI has notified the USNRC about restart activities and the anticipated schedule for exiting decommissioning (Reference 5). Therefore, in support of PNP restart activities the approved exemptions are no longer warranted.
HDI hereby requests the NRC rescind Palisades Nuclear Plant +/- Exemption from the Requirements of 10 CFR 140.11(a)(4) Concerning Offsite Primary and Secondary Liability Insurance and Amendment No. 14 To Indemnity Agreement No. B-40 (EPID L-2022-LLE-0031)
(Reference 3) and Palisades Nuclear Plant +/- Exemption from the Requirements of 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance (EPID L-2022-LLE-0032)
(Reference 4). HDI also requests recission no later than docketing withdrawal of 10 CFR 50.82 certifications per exemption requested (Reference 5).
This letter contains no new and no revised regulatory commitments.
Should you have any questions or require additional information, please contact Jim Miksa, Regulatory Assurance Manager at (269)764-2945.
HDI PNP-2024-014 Page 2 of 2 Respectfully, Jean A. Fleming Vice President, Licensing and Regulatory Affairs Holtec International
References:
- 1)
Holtec Decommissioning International, LLC letter to U.S. Nuclear Regulatory Commission, Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance, dated October 26, 2022 (ADAMS Accession No. ML22299A059)
- 2)
Holtec Decommissioning International, LLC letter to U.S. Nuclear Regulatory Commission, Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance, dated October 26, 2022 (ADAMS Accession No. ML22299A062)
- 3)
U.S. Nuclear Regulatory Commission letter to Holtec International, Palisades Nuclear Plant +/- Exemption from the Requirements of 10 CFR 140.11(a)(4) Concerning Offsite Primary and Secondary Liability Insurance and Amendment No. 14 To Indemnity Agreement No. B-40 (EPID L-2022 LLE-0031), dated December 26, 2023 (ADAMS Accession No. ML23192A077)
- 4)
U.S. Nuclear Regulatory Commission letter to Holtec International, Palisades Nuclear Plant +/- Exemption from the Requirements of 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance (EPID L-2022 LLE-0032), dated December 22, 2023 (ADAMS Accession No. ML23191A522)
- 5)
Holtec Decommissioning International, LLC letter to U.S. Nuclear Regulatory Commission, Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82, dated September 28, 2023 (ADAMS Accession No. ML23271A140) cc:
NRC Region III Regional Administrator NRC Senior Resident Inspector +/- Palisades Nuclear Plant NRC Project Manager +/- Palisades Nuclear Plant Designated Michigan State Official