ML24344A069
| ML24344A069 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Indian Point, Oyster Creek, Pilgrim, Big Rock Point |
| Issue date: | 12/09/2024 |
| From: | Fleming J Holtec Decommissioning International |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| HDI-PII-016, HDI-OC-24-046, HDI-IPEC-24-047, HDI-PNP-2024-048, HDI-BRP-2024-003 | |
| Download: ML24344A069 (1) | |
Text
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-24-046 HDI-PIL-24-016 HDI-IPEC-24-047 HDI PNP 2024-048 HDI BRP 2024-003 Page 1 of 3 10 CFR 140.15 December 9, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility License No. DPR-16 NRC Docket No. 50-219 and 72-15 Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket No. 50-293 and 72-1044 Indian Point Nuclear Generating Stations 1, 2, and 3 Provisional Operating License No. DPR-5 Renewed Facility Operating License Nos. DPR-26 and DPR-64 NRC Docket Nos. 50-3, 50-247, 50-286 and 72-051 Palisades Nuclear Plant Renewed Facility Operating License No. DPR-20 NRC Docket No. 50-255 and 72-007 Big Rock Point License No. DPR-6 NRC Docket No. 50-155 and 72-043
Subject:
Proof of Financial Protection 10 CFR 140.15 In accordance with 10 CFR 140.15 Proof of Financial Protection, Holtec Decommissioning International, LLC (HDI) hereby provides proof of financial protection in the form of nuclear energy liability insurance for the HDI sites, Oyster Creek Nuclear Generating Station, Pilgrim Nuclear Power Station, Indian Point Nuclear Generating Stations 1, 2, & 3, Palisades Nuclear Plant and Big Rock Point Independent Spent Fuel Storge Installation.
HDI continues to maintain offsite nuclear liability coverage in accordance with 10 CFR 140.11 (a)(4) or per approved exemption for Oyster Creek, Pilgrim and IPEC (References 2-4).
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-24-046 HDI-PIL-24-016 HDI-IPEC-24-047 HDI PNP 2024-048 HDI BRP 2024-003 Page 2 of 3 On October 9, 2024, HDI requested the NRC to rescind the approved exemption requests for 140.11(a)(4) and 50.54(w)(1), Reduction of Insurances for Palisades Nuclear Plant (Reference 1).
The Attachment to this letter has the Certificates of Liability Insurance, which satisfies the requirement to provide proof of financial protection per the requirements of 10 CFR 140.15(a)(1).
There are no regulatory commitments contained in this submittal.
If you have any questions or require further information, please contact me at (856) 797-0900, x3578.
Respectfully, Jean A. Fleming Vice President of Licensing and Regulatory Affairs Holtec International
References:
- 1. Requested the USNRC to Rescind Approved Exemption Requests for 140.11(a)(4) and 50.54(w)(1), Reduction of Insurances Palisades Nuclear Plant (ADAMS Ascension No. ML24283A094 letter dated October 9, 2024)
- 2. Exemption from 10 CFR 140.11(a)(4) - Primary and Secondary Liability Insurance - Oyster Creek Nuclear Generating Station (ADAMS Ascension No.
ML19129A364 letter dated June 12, 2019)
- 3. Exemption from 10 CFR 140.11(a)(4) - Primary and Secondary Liability Insurance, Pilgrim Nuclear Power Station (ADAMS Accension No. ML19282A036 letter dated January 6, 2020)
- 4. Exemption from 10 CFR 140.11(a)(4) - Primary and Secondary Liability Insurance, Indian Point Units 1, 2 and 3 (ADAMS Accension No. ML23100A143 letter dated November 16, 2023)
- 5. Exemption from 10 CFR 140.11(a)(4) - Primary and Secondary Liability Insurance - Palisades Nuclear Plant (ADAMS Ascension No. ML23192A007 letter dated December 26, 2023)
Attachment:
Certificates of Liability Insurance Digitally signed by Jean A. Fleming DN: cn=Jean A. Fleming, c=US, o=Holtec Decommissioning International, LLC, ou=Regulatory and Environmental Affairs, email=J.Fleming@Holtec.com Date: 2024.12.09 09:35:15 -05'00' Jean A.
Fleming
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-24-046 HDI-PIL-24-016 HDI-IPEC-24-047 HDI PNP 2024-048 HDI BRP 2024-003 Page 3 of 3 cc:
NRC Regional Administrator - Region I NRC Regional Administrator - Region III NRC NMSS Project Manager (Oyster Creek, Palisades, and Big Rock)
NRC NMSS Project Manager (Pilgrim and IPEC)
NRC Region 1 Lead Inspector, Indian Point Units 1, 2 & 3 NRC Region 1 Lead Inspector, Oyster Creek NRC Region 1 Lead Inspector, Pilgrim Nuclear Power Station NRC Region 3 Lead Inspector, Palisades, and Big Rock New York State Department of Public Service New York State Liaison Officer Designee, NYSERDA New Jersey DEP - Assistant Commissioner, Air Quality, Energy and Sustainability New Jersey Bureau of Nuclear Engineering, Assistant Director Radiation Protection Element Commonwealth of Massachusetts, Director, Massachusetts Emergency Management Agency State of Michigan
SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS.
INSURER(S) AFFORDING COVERAGE INSURER F :
INSURER E :
INSURER D :
INSURER C :
INSURER B :
INSURER A :
NAIC #
NAME:
CONTACT (A/C, No):
FAX E-MAIL ADDRESS:
PRODUCER (A/C, No, Ext):
PHONE INSURED REVISION NUMBER:
CERTIFICATE NUMBER:
COVERAGES IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.
If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).
THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.
OTHER:
(Per accident)
(Ea accident)
N / A SUBR WVD ADDL INSD THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.
PROPERTY DAMAGE BODILY INJURY (Per accident)
BODILY INJURY (Per person)
COMBINED SINGLE LIMIT AUTOS ONLY AUTOS AUTOS ONLY NON-OWNED SCHEDULED OWNED ANY AUTO AUTOMOBILE LIABILITY Y / N WORKERS COMPENSATION AND EMPLOYERS' LIABILITY OFFICER/MEMBER EXCLUDED?
(Mandatory in NH)
DESCRIPTION OF OPERATIONS below If yes, describe under ANY PROPRIETOR/PARTNER/EXECUTIVE E.L. DISEASE - POLICY LIMIT E.L. DISEASE - EA EMPLOYEE E.L. EACH ACCIDENT ER OTH-STATUTE PER LIMITS (MM/DD/YYYY)
POLICY EXP (MM/DD/YYYY)
POLICY EFF POLICY NUMBER TYPE OF INSURANCE LTR INSR DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)
EXCESS LIAB UMBRELLA LIAB EACH OCCURRENCE AGGREGATE OCCUR CLAIMS-MADE DED RETENTION $
PRODUCTS - COMP/OP AGG GENERAL AGGREGATE PERSONAL & ADV INJURY MED EXP (Any one person)
EACH OCCURRENCE DAMAGE TO RENTED PREMISES (Ea occurrence)
COMMERCIAL GENERAL LIABILITY CLAIMS-MADE OCCUR GEN'L AGGREGATE LIMIT APPLIES PER:
POLICY PRO-JECT LOC CERTIFICATE OF LIABILITY INSURANCE DATE (MM/DD/YYYY)
CANCELLATION AUTHORIZED REPRESENTATIVE ACORD 25 (2016/03)
© 1988-2016 ACORD CORPORATION. All rights reserved.
CERTIFICATE HOLDER The ACORD name and logo are registered marks of ACORD HIRED AUTOS ONLY CLE-006745805-03 N
0 01/01/2025 Nuclear Energy Liability A
11/19/2024 Washington, DC 20555-0001 Document Control Desk CN102263520-STND-NEL-25-26 See Attached Acord 101 Insurance 01/01/2026 30 South 17th Street Marsh USA LLC Philadelphia, PA 19103 Krishna P. Singh Technology Campus Holtec International Camden, NJ 08104 1 Holtec Boulevard See Attached Acord 101 U.S. Nuclear Regulatory Commission American Nuclear Insurers Attachment
ACORD 101 (2008/01)
The ACORD name and logo are registered marks of ACORD
© 2008 ACORD CORPORATION. All rights reserved.
THIS ADDITIONAL REMARKS FORM IS A SCHEDULE TO ACORD FORM, FORM NUMBER:
FORM TITLE:
ADDITIONAL REMARKS ADDITIONAL REMARKS SCHEDULE Page of AGENCY CUSTOMER ID:
LOC #:
AGENCY CARRIER NAIC CODE POLICY NUMBER NAMED INSURED EFFECTIVE DATE:
- 3. SITE #3 - Indian Point
- 1. SITE #1 - Pilgrim Station of the New York City and forty-four miles east of Providence, Rhode Island NF -0179 8/15/1969 $500 Million POLICY NUMBER: POLICY EFFECTIVE: LIMIT OF LIABILITY:
POLICY NUMBER: POLICY EFFECTIVE: LIMIT OF LIABILITY:
NAMED INSURED [LISTED ON POLICY]: Oyster Creek Environmental Protection, LLC and Holtec Decommissioning International, LLC NF -0164 10/3/1967 $100 Million POLICY NUMBER: POLICY EFFECTIVE: LIMIT OF LIABILITY:
3 NW-0566 8/15/1969 $500 Million**
NF -0100 1/1/1961 $100 Million LOCATION OF NUCLEAR FACILITY: Palisades Nuclear Plant, located approximately five (5) miles south of South Haven, Michigan in Covert Township, Van Buren County, Michigan
2 Certificate]
Types of Insurance: NF - [Facility Form], NW- [Master Worker Certificate], NS - [US Domestic Suppliers & Transporters], FS - [Foreign Suppliers & Transporters], N - [Secondary Financial Protection Philadelphia end of December 31st of the calendar year in which the Effective Date of this Certificate occurs, notice will be delivered in accordance with the policy provisions. Otherwise this Certificate shall terminate as of Insured named herein, with respect to the Nuclear Facility at the Location shown and/or with respect to the Insured's operations described herein. If such policy is cancelled or otherwise terminated prior to the
the end of such December 31st. A Certificate will NOT be issued for any subsequent calendar year unless requested in writing.
CERTIFICATE OF NUCLEAR ENERGY LIABILITY INSURANCE This is to certify that there is in force as of the effective date of this Certificate a Nuclear Energy Liability Insurance Policy issued by members of American Nuclear Insurers as indicated (Companies), to the
Certificate of Liability Insurance
- 2. SITE #2 - Oyster Creek CN102263520 NW-0530 1/1/1961 $500 Million**
LOCATION OF NUCLEAR FACILITY: Indian Point Energy Center is located on the east bank of the Hudson River in the Village of Buchanan in upper Westchester County, New York. It is about 24 miles north LOCATION OF NUCLEAR FACILITY: Pilgrim Station in the Town of Plymouth, Plymouth County, Massachusetts, on the western shore of Cape Cod Bay, thirty-eight miles southeast of Boston, Massachusetts, NF -0188 10/1/1970 $100 Million NAMED INSURED [LISTED ON POLICY]: Holtec Pilgrim, LLC and Holtec Decommissioning International, LLC NW-0529 1/1/1961 $500 Million**
NW-0558 10/3/1967 $500 Million**
POLICY NUMBER: POLICY EFFECTIVE: LIMIT OF LIABILITY:
NAMED INSURED [LISTED ON POLICY]: Holtec Palisades, LLC and Holtec Decommissioning International, LLC
LOCATION OF NUCLEAR FACILITY: Oyster Creek Generating Station, located in Lacey Township, Ocean County, New Jersey, approximately two miles south of the community of Forked River, about two
Marsh USA LLC Krishna P. Singh Technology Campus Holtec International Camden, NJ 08104 1 Holtec Boulevard NW-0573 10/1/1970 $500 Million**
NAMED INSURED [LISTED ON POLICY]: Holtec Indian Point 2, LLC, Holtec Indian Point 3, LLC and Holtec Decommissioning International, LLC miles inland from the shore of Barnegat Bay and seven miles west-north-west of Barnegat Light.
25
- 4. SITE #4 - Palisades COVERAGE FOR NUCLEAR FACILITIES:
ACORD 101 (2008/01)
The ACORD name and logo are registered marks of ACORD
© 2008 ACORD CORPORATION. All rights reserved.
THIS ADDITIONAL REMARKS FORM IS A SCHEDULE TO ACORD FORM, FORM NUMBER:
FORM TITLE:
ADDITIONAL REMARKS ADDITIONAL REMARKS SCHEDULE Page of AGENCY CUSTOMER ID:
LOC #:
AGENCY CARRIER NAIC CODE POLICY NUMBER NAMED INSURED EFFECTIVE DATE:
reference thereto. Such limit may have been reduced by payment of claims or claims expenses.
3 3
THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER.
Philadelphia POLICY NUMBER: POLICY EFFECTIVE: LIMIT OF LIABILITY:
NAMED INSURED [LISTED ON POLICY]: Holtec Palisades, LLC and Holtec Decommissioning International, LLC NW-0536 8/30/1962 $500 Million**
NF -0117 8/30/1962 $44.4 Million
- 5. SITE #5 - Big Rock Point
Michigan, on the northen shore of Michigan's lower peninsula.
LOCATION OF NUCLEAR FACILITY: Big Rock Point is located in Charlevoix County, Michigan, approximately four miles northeast of Charlevoix, Michigan, and approximately eleven miles west of Petoskey, Certificate of Liability Insurance CN102263520
issued shall amend, extend or alter the coverage afforded by the policy. The Limit of Liability shown above may have been reduced by payment of claims or claims expenses.
COMMENTS/NOTES:
- Master Worker Certificate - This limit is shared by all Certificates to the Master Worker Policy of which each Certificate is a part and is subject to all of the provisions of such Policy and Certificate having Marsh USA LLC Krishna P. Singh Technology Campus Holtec International Camden, NJ 08104 1 Holtec Boulevard 25 The insurance afforded by the policy(ies) is subject to the exclusions, conditions and other provisions of the policy(ies). Neither this Certificate nor any contract or other document with respect to which it is