ML25231A152

Indian Point Energy Center - License Amendment Request to Terminate Nuclear Regulatory Commission Preemption Authority

ML25231A152
Person / Time
Site:	Indian Point
Issue date:	07/23/2025
From:	Fleming J Holtec Decommissioning International, Holtec
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML25205A038	List: ML25204A155 ML25231A152
References
HDI-IPEC-25-015
Download: ML25231A152 (1)

Text

{{#Wiki_filter:HOLTEC SECUR~-+Y RELATED !N-FORMA-+IQN DECOMMISSIO'NING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 July 23, 2025 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Indian Point Energy Center Provisional Operating License No. DPR-05 Renewed Facility License No. DPR-26 and DPR-64 NRC Docket Nos. 50-003, 50-247, 50-286 and 72-051 Telephone (856) 797-0900 Fax(856)797-0909 10 CFR 73.15 (r)

Subject:

License Amendment Request to Terminate Nuclear Regulatory Commission Preemption Authority at Indian Point Energy Center In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.90, 10 CFR 73.15(r)(1 )(i) and 10 CFR 73.4, Holtec Decommissioning International, LLC (HDI) hereby requests U.S. Nuclear Regulatory Commission (NRC) review and approval of a license amendment request (LAR) to change the facility licenses (FL) to terminate the Indian Point Energy Center (IPEC) stand-alone preemption authority granted under Section 161 A, originally approved on January 5, 2016 (Reference 1 ). The Enclosure to this letter provides a description and evaluation of the proposed License Condition changes. The evaluation includes the regulatory evaluation, the no significant hazards consideration determination, and the environmental considerations. to the Enclosure of this letter provides a marked-up copy of the Indian Point 1 (IP1 ), Indian Point 2 (IP2), and Indian Point 3 (IP3) FL pages. to the Enclosure of this letter provides the replacement pages of the IP1, IP2, and IP3 FLs. The Enclosure to this letter contains Sensitive Unclassified Non-Safeguard Information-Security Related Information (SUNSI-SRI) and should be withheld in accordance with 10 CFR 2.390 (d)(1 ). A separate redacted copy of this letter will be made publicly available per 10 CFR 2.390(a). HDI requests review and approval of the proposed license amendments by December 15, 2025. Once approved, the license amendment will be implemented within 30 days of the date of the SECURITY RELATED INFORMATION +l=le-Att-ahments contain SeASit*ve Unclassified Non Safeguarel lnf.ormatie-n-8eel:lf-i-ty~ -~A-fer:mat-i&A-f&YNS-1~ HDI-IPEC-25-015

- ~--Rb-A-+e HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 license amendment. Telephone (856) 797-0900 Fax (856) 797-0909 This letter contains no new regulatory commitments. Should you have any questions or require additional information, please contact Mr. Walter Wittich, IPEC Licensing at 914-254-7212. I declare under the penalty of perjury that the foregoing is true and correct. Executed on July 23, 2025. Sincerely, Jean A. Fleming Jean Fleming 01g1L11y "9"IOO t,y Jr_,. A flc:l"IU'9

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Vice President of Licensing and Regulatory Affairs Holtec International References:

1. USNRC Letter dated January 5, 2016, "Indian Point Nuclear Generating Unit Nos. 1, 2, and 3-Issuance of Confirmatory Order and Conforming Amendments No. 58, 282, and 259 Concerning Standalone Weapons Preemption Authority." ADAMS Accession ML14259A218

Enclosure:

Description and Evaluation of Proposed Changes Attachments to the

Enclosure:

1. Proposed Change to IPEC Renewed Facility License Conditions (markups)

2. Proposed Change to IPEC Renewed Facility License Conditions (replacement pages) cc: (without Enclosure)

NRC Regional Administrator - NRC Region I NRC Project Manager, NMSS - IPEC NRC Region 1 Lead Inspector, Indian Point Units 1, 2 & 3 New York State Department of Public Service New York State Liaison Officer Designee, NYSERDA SCUR!T¥ REbA+-e-9-l~FORP.1/4+JON +Re l\tta4~ts eontain-SeA-si..tiv-ld-Rs!Bssi-flee--NeA-Safe§Har-El--l-Af-eFmation Security Related ffif.efmation (6Ut>JSI SRlt-HDI-IPEC-25-015

Se-GU-R +¥-RS:LATS:D !N FORJ.4-A+IQ.N HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Enclosure to HDI-IPEC-25-015 Telephone (856) 797-0900 Fax (856) 797-0909 Description and Evaluation of Proposed Changes License Amendment Request to Revise Indian Point Energy Center Facility Licenses to Terminate Stand-alone Preemption Authority The Attach*ments contain Sensitive Unclassified ~n Safeguard lnf.ermatieA---Seel:H:it-~tea ~nformation (SUNS! SRI). HDI-IPEC-25-015

SECURITY-RELATED INFORMATION HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 TABLE OF CONTENTS 1.0 INTRODUCTION AND DESCRIPTION

2.0 PROPOSED CHANGE

S

4.0 REGULATORY EVALUATION

Telephone (856) 797-0900 Fax(856)797-0909 5.0 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION 5.1 PRECEDENT 5.2 ENVIRONMENTAL CONSIDERATIONS

6.0 CONCLUSION

S 7.0 REFERENCES Se-GU-RITY RELA-TED INFO.~JIATION

rhe Attachments contain Sonsiti>,e Unclassified Non Safe~ IRff;)Fmatie~fi.ty-Re-late&

Information (SUNSI SRI). HDI-IPEC-25-015

HOLTEC DECOMMISSIONING INTERNATIONAL Se-CURIT¥ RELATED INFORP-J!ATION Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax(856)797-0909 1.0 INTRODUCTION AND DESCRIPTION In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.90, 10 CFR 73.15(r)(1 )(i) and 10 CFR 73.4, Holtec Decommissioning International, LLC (HDI) hereby requests U.S. Nuclear Regulatory Commission (NRC) review and approval of a license amendment request (LAR) to change the facility licenses (FL) to terminate the Indian Point Energy Center (IPEC) stand-alone preemption authority granted under Section 161A, originally approved on January 5, 2016 (Reference 1 ). On December 5, 2023, the NRC issued Amendment No. 68 to Provisional Operating License No. DPR-5 for Indian Point, Unit 1 (IP1 ), Amendment No. 301 to Renewed Facility License No. DPR-26 for Indian Point, Unit 2 (IP2), and Amendment No. 277 to Renewed Facility License No. DPR-64 for Indian Point, Unit 3 (IP3), which revised the 10 CFR Part 50 Renewed Facility Licenses (Fls) to reflect approval of the "Indian Point (IPEC) Independent Spent Fuel Storage Installation-Only Security, Training and Qu lific tio n Saf F -0 P P Ref ren 2 HDI respectfully requ sts the termination of he IP1 IP2 and IP3 facilit licenses' standalone preemption authority S-EGU-R-1-TY RELATED INFORMATION The AttaohFRents contain Sensitive Unclassified Non Safegl:laf~0A--eeel:l-fi~ Information (GUNSI SRI). HDI-IPEC-25-015

~

HOLTEC DE C OMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax(856)797-0909 provides a marked-up copy of the IP1, IP2, and IP3 FL pages. provides the replacement pages of the IP1, IP2, and IP3 Fls. HDI requests review and approval of the proposed license amendments by December 15, 2025. Once approved, the license amendment will be implemented within 30 days of the date of the license amendment.

2.0 PROPOSED CHANGE

S 2.1 Delete the following from Indian Point 1 License Condition 3.d (page 3) HD/ has been granted Commission authorization to use "stand alone preemption authority" under Section 161A of the Atomic Energy Act, 42 U.S.C. 2201a with respect to the weapons described in Section II supplemented with Section Ill of to its application submitted by \ letter dated August 20, 2013, as supplemented by letters dated November 21, 2013, and July 24, 2014, and citing letters dated April 27, 2011, and January 4, 2012. HD/ shall fully implement and maintain in effect the provisions of the Commission-approved authorization. 2.2 Delete the following from Indian Point 2 License Condition 2.H (page 5) HD/ has been granted Commission authorization to use "stand alone preemption authority" under Section 161A of the Atomic Energy Act, 42 U.S.C. 2201a with respect to the weapons described in Section II supplemented with Section Ill of to its application submitted by \ letter dated August 20, 2013, as supplemented by letters dated November 21, 2013, and July 24, 2014, and citing letters dated April 27, 2011, and January 4, 2012. HD/ shall fully implement and maintain in effect the provisions of the Commission-approved authorization. 2.3 Delete the following from Indian Point 3 License Condition 2.G (page 4) HD/ has been granted Commission authorization to use "stand alone preemption authority" under Section 161A of the Atomic Energy Act, 42 U.S.C. 2201a with SECURITY RELATED !-NFORP.4A-T-ION T-M--A-ttaGA-meA~n Sensitive Unolassified Non Safeguar:d Information Security Relates lnfer-matiefl~~ HDI-IPEC-25-015

HOLTEC DE C OMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax(856)797-0909 respect to the weapons described in Section II supplemented with Section Ill of to its application submitted by \ letter dated August 20, 2013, as supplemented by letters dated November 21, 2013, and July 24, 2014, and citing letters dated April 27, 2011, and January 4, 2012. HD/ shall fully implement and maintain in effect the provisions of the Commission-approved authorization

3.0 TECHNICAL EVALUATION

Section 161 A, "Use of Firearms by Security Personnel," to the Atomic Energy Act of 1954, as amended, conferred upon the NRG preemption authority to permit a licensee's security personnel to transfer, receive, possess, transport, import, and use certain firearms and devices notwithstanding local and State firearms laws, including regulations, that may prohibit or restrict these actions. reemption On December 5, 2023, the NRG issued Amendment No. 68 to Provisional Operating License No. DPR-5 for Indian Point, Unit 1 (IP1 ), Amendment No. 301 to Renewed Facility License No. DPR-26 for Indian Point, Unit 2 (IP2), and Amendment No. 277 to Renewed Facility License No. DPR-64 for Indian Point, Unit 3 (IP3), which revised the 10 CFR Part 50 Renewed Facility Licenses (FLs) to reflect approval of the "Indian Point (IPEC) Independent Spent Fuel Storage Installation-Only Security, Training and Qualification, and Safeguards Contingency Plan, Revision O" (ISFSl-O PSP) (Reference 2). Each facility's approved FL retained the revi usl h rized License Con ition f I n r m tion au h ri a Ii a e SeGY-R-I-T-Y-R-e-bA--TE~~.f--OR-!\.4A-TIO N

r-1:i:e-AftaGA-ments-eontain Sensitive UnolassiJied Non Safeguard lnrormat~-tee

~-Afur=matien (SUHSI SR-It. HDI-IPEC-25-015

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Telephone (856) 797-0900 Fax (856) 797-0909 SECURITY RELATED J~~JI

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HOLTEC DE C OMMISSIONING INTERNATIONAL ~ y RELATED !~JFORN +1-QN Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax(856)797-0909

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 73. 15 Authorization for use of enhanced weapons and preemption of firearms laws Subsection 73.15 (r) describes requirements regarding the termination, modification, suspension, and revocation of a licensee's Section 161 A authority. Licensees seeking termination or modification of their authority to possess enhanced weapons, or different types, calibers, gauges, or quantities of enhanced weapons, are required to apply to the NRC in accordance with § 73.4 and the license amendment provisions of§§ 50.90, 70.34, or 72.56 of this chapter. (ii) Licensees seeking to terminate their combined enhanced weapons authority and preemption authority must apply to the NRC in writing, under oath or affirmation, and in accordance with § 73.4, and the license amendment provisions of§ 50.90, § 70.34, or§ 72.56 of this chapter, as applicable. These licensees must have transferred or disposed of any enhanced weapons, in accordance with the provisions of paragraph (m) of this section, prior to the NRC approval of a request for termination of their authority.... 10 CFR 73. 17 Firearms background checks for armed security personnel. 10 CFR 73.17 (b) (13) A licensee who withdraws its application for Section 161A authority or who has its application disapproved by the NRC, must discontinue conducting firearms background checks. Alcohol, Tobacco, Firearms, and Explosives' (A TF's) regulations 27 CFR Part 478, "Commerce in Firearms and Ammunition", contains the Bureau of Alcohol, Tobacco, Firearms, and Explosives' (ATF's) regulations for obtaining and possessing a Federal firearms license (FFL) (18 U.S.C. Chapter 44) and other relevant requirements. 5.0 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION HDI has evaluated the proposed amendment to determine if a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below: SeCY-R!+Y RELATe-D-1-N~~ +Re-Attachments oontai n Sensi-tiv-...°'-Yfle~A-Safe~~u rity Related ~-A-fermatien-{SY M, I SR I). H DI-I PEC-25-015

HOLTEC SEC U RITY-RELATED-1-NF--ORPA ::i:<<>>J DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Response: No The Indian Point Energy Center (IPEC) Part 50 license(s) no longer authorize operation of the reactors or emplacement or retention of fuel into the reactor vessels. The irradiated fuel at IPEC is stored within the on-site Independent Spent Fuel Storage Installation (ISFSI) in dry casks. In this condition, the number of credible accidents or transients is significantly smaller than for a plant authorized to operate the reactor or emplace or retain fuel in the reactor vessels. The ISFSI storage pads are designed for the complete off-load of all spent fuel from the SFPs to dry fuel storage casks plus additional allowance for storage of reactor-related Greater than Class C (GTCC) waste storage casks. The ISFSl-O PSP reflects the ISFSI site configuration with all spent fuel removed from the spent fuel pool and stored within the ISFSI protected area (PA). With all spent fuel removed from the spent fuel pool, the accidents currently described in IPEC Defueled Safety Analysis Reports (DSAR) Chapter 6 are for events outside the ISFSI pad and the PA. The casks are stored and maintained in accordance with the provisions of the Holtec International HI-STORM 100 Cask System, Certificate of Compliance (CoC) No. 72-1014, and the associated Cask Final Safety Analysis Report (CFSAR). The HI-STORM 100 Cask System consists of spent nuclear fuel (SNF) residing within a fuel basket structure contained within a sealed metallic canister, or Multi-Purpose Canister (MPG). The HI-STORM 100 receives and contains the sealed MPC for long-term storage and provides gamma and neutron shielding, ventilation passages, missile protection, and protection against natural phenomena and accidents. Section 11.2 of the CFSAR provides the evaluation of accidents for the HI-STORM 100 Cask System, which satisfies the following minimum acceptance criteria: The MPC confinement boundary maintains radioactive material confinement. The MPC fuel basket structure maintains the fuel contents subcritical. The stored SNF can be retrieved by normal means. The system provides adequate shielding. The HI-STORM 100 Cask System provides confinement, radiation shielding, criticality control, and passive heat removal for the spent nuclear fuel and radioactive material in storage, independent of other facility structures, systems, and components (SSCs). SEGURl:rY RELATED INFQR--!\4A+IQN The Attach-R'lents cootaifl-SeR-sitiv-e--Yoolass#ied Non Safeguard lnfonllation Seount~ ~ HDI-IPEC-25-015

HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax(856)797-0909 The removal of preemption authority does not affect the ability of the Cask System and MPC to perform their functions as described in the CF SAR, nor can it affect the accidents described in the DSAR. Hence, the proposed amendment does not affect the ability of the Cask System to perform its design function, nor would it increase the likelihood of an accident previously evaluated. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of a previously evaluated accident or a reduction in the margin of safety.

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated Response: No The proposed amendments do not involve any physical alteration of any facility structures, systems, and components (SSCs) or Cask System components required to mitigate or prevent any accident previously evaluated and do not have a significant effect on the capability of any facility SSC or Cask System component to perform its design functions. Thus, the proposed amendment does not create any initiators or precursors of a new or different kind of accident than previously evaluated. Likewise, the proposed amendment does not create the possibility of a new failure mode associated with any SSC malfunction or personnel errors that could result in a new or different kind of accident. Since the proposed amendment does not significantly affect any Cask System components, the credible events for the ISFSI are not changed.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety Response: No The proposed amendment does not involve a significant change in any facility SSC or Cask System component's design, configuration, or operation. Therefore, the facility license changes associated with this proposed amendment do not affect the capability or manner in which the Cask System and the ISFSl-O storage pad perform their safety functions or the safety margins associated with their design and design function.

Therefore, the proposed amendment does not involve a significant reduction in the margin of safety. Based on the above, HDI concludes that the proposed amendment presents no significant SECURITY REbATED INF-ATIQJ.J

rhe AttachFl'lefl-t&eeA-tai-R-Se-A-si-t+ve-Y-Aslassified ~Jen SaieguarEl IArormatlon Security Related iA-fefmation (SUNSJ,~

HDI-IPEC-25-015

HOLTEC DECOMMISSIONING INTERNATIONAL S.....~R-!TY-RELATED !NF~MAT!m-J Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified. 5.1 PRECEDENT HDI is not relying on precedent for requesting termination of Section 161A preemption authority. 5.2 ENVIRONMENTAL CONSIDERATIONS HDI has evaluated this proposed amendment against the criteria for identifying licensing and regulatory actions requiring environmental assessment, in accordance with 10 CFR 51.21, and determined that it meets the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(12). The proposed amendment is being submitted under the provisions of 10 CFR Part 50 for approval of changes to the IPEC Facility License(s) and in accordance with 10 CFR Part 72. Activities associated with the proposed amendment do not involve any construction impacts and are consistent with plans described in NUREG-0586, "Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities,". The proposed amendment is administrative and limited to ISFSl-O PSP organizational and procedural matters. Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment or impact statement is not required to be prepared in connection with the proposed amendment.

6.0 CONCLUSION

Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed changes, (2) activities consistent with the approved changes will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. 7.0 REFERENCES

1) USN RC Letter dated January 5, 2016, "Indian Point Nuclear Generating Unit Nos. 1, 2, and 3-Issuance of Confirmatory Order and Conforming Amendments No. 58, 282, and 259 Concerning Standalone Weapons Preemption Authority." ADAMS Accession ML14259A218

2) USNRC Letter dated December 5, 2023, "Indian Point Nuclear Generating Unit Nos. 1, 2, And 3-Issuance of Amendment No. 68, 301 And 277 Regarding Changes to Implement SECURITY RELATED INFORMATION The Attaohme-ms-oontai~l::41-el~e§OOfe---lnfoFmation Security Relates Information (SUNSI SRI).

HDI-IPEC-25-015

HOLTEC DE C OMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax(856)797-0909 the Independent Spent Fuel Storage Installation Physical Security Plan." ADAMS Accession ML23339A044

3) HDI Letter dated November 19, 2024, "Indian Point Independent Spent Fuel Storage Installation-Only Security, Training and Qualification, and Safeguards Contingency Plan, Revision 2." HDI-IPEC-24-038.

4) Enforcement Action (EA) 13-092 "Order Designating an Interim Class of NRG-Licensed Facilities that are Eligible to Apply to the Commission for Authorization to Use the Authority Granted Under the Provisions of Section 161 A of the Atomic Energy Act of 1954, as Amended" (ADAMS Accession ML13121A459), Superseded March, 14, 2023 with Ru/emaking (88 FR 15882) as amended at 89 FR 51810, June 20, 2024.

SECURITY RELATED INFORMATION* The,l\ttaehme~oolassi-fied Non SafegU3F9--!nformation Seeurity Re~ Information (SUNS! ~ HDI-IPEC-25-015

SE-GU-Rl+-Y- £LATE~~ J.~MA-"RON HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 ATTACHMENT 1 To Enclosure to HDI-IPEC-25-015 Telephone (856) 797-0900 Fax(856)797-0909 Proposed Change to IPEC Renewed Facility License Conditions (markups) License Amendment Request to Revise Indian Point Energy Center Facility Licenses to Terminate Stand-alone Preemption Authority S ECURIT¥ RELATED-1-N-FORI\AA+JON +Ae-Att-aG"'1meR-t&teR*tatA-eeRS+ti*\~e-lJAe!.ass.i-~~-~ -Fity Rela~ed -~Rfefffiat~Jt, HDI-IPEC-25-015

HOL TEC DECOMMISSIONING INTERNATIONAL, LLC AND HOL TEC INDIAN POINT 2, LLC DOCKET NO. 50-003 INDIAN POINT NUCLEAR GENERATING STATION, UNIT NO. 1 PROVISIONAL OPERA TING LICENSE HDI has been grantea-Gemrnission authori:z:ation to use "stand alone p~ a-l:Rfl-efity~1:mder Section 161-A-ef---th-e-Atemie--Aei=gy Act, 42 U.S.G. 2201 a '.1ith respect to the* weapons described -iA-Sec4ien II supplemented with Section ll-1--ef-Attachment 1 ~ication submitted by \ letter dated August 20, 2012, as supplemented by - letters dated N-evemaer 21, 2012, and duly 24, 2014,and citing letters dated April 27, 2011, and January 4 2012. HDI shall fully implement and matffiai-R--ifl--e:ffe-t--tRe--- 13rovisions of the Gomm-iss-~hori:z:atian.

4.

Deleted

5.

Deleted.

6.

Deleted: (a) Deleted (b) Provisional Trust (i) The provisional trust agreement must be in a form acceptable to the NRC. (ii) Investments in the securities or other obligations of Holtec International or its affiliates, subsidiaries, successors, or assigns are and shall be prohibited. Except for investments tied to market indexes or other non-nuclear-sector mutual funds, investments in any entity owning one or more nuclear power plants are and shall be prohibited. (iii) The provisional trust agreement must provide that no disbursements or payments from the trust, other than for ordinary administrative expenses, shall be made by the trustee unless the trustee has first given the Director of the Office of Nuclear Reactor Regulation 30 days prior written notice of payment. The provisional trust agreement shall further contain a provision that no disbursements or payments from the trust shall be made if the trustee receives prior written notice of objection from the NRC. (iv) The provisional trust agreement must provide that the agreement cannot be amended in any material respect, or terminated, without 30 days prior written notification to the Director of the Office of Nuclear Reactor Regulation. (v) The appropriate section of the provisional trust agreement shall state that the trustee, investment advisor, or anyone else directing the investments made in the trust shall adhere to a "prudent investor" standard, as specified in 18 CFR 35.32(a)(3) of the Federal Energy Regulatory Commission's regulations. (vi) Use of assets in the provisional trust, in the first instance, shall be limited to the expenses related to decommissioning IP1 or IP2 as defined by the NRC in its regulations and issuances, and as provided in this license and any amendments thereto. Amendment No.,...SS

HOL TEC DECOMMISSIONING INTERNATIONAL, LLC AND HOL TEC INDIAN POINT 21 LLC DOCKET NO. 50-003 INDIAN POINT NUCLEAR GENERA TING STATION, UNIT NO. 2 RENEWED FACILITY LICENSE Amendment No. 299 Amendment No. ~

HOL TEC DECOMMISSIONING INTERNATIONAL. LLC AND HOL TEC INDIAN POINT 3, LLC DOCKET NO. 50-286 INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 RENEWED FACILITY LICENSE Amendment No. 275 HDI has been granted Commission authorization to use "stand alone preeFApt~ authority" under Section 161A of the AtoFAi~~ r-espeet-t-a--#l~cd in Seetien I ,i\ttaehFAent 1 to its-aJ9f)liea3/4i&fl--Sl:I-Bffiil:te1-ey-letror dated At:t§ust 20, 2013, as ~ lementea-by letters dated ~Jmmmber 21, 2013, al1h:k.Hy 24, 2014, a~Fl§- lette-FS-eatee--April 27, 201-1-;--afth:J,anuary 4, 2012. NOi shall fully implement and ma+ntain in effect the-J,fflVisions of tl'le Gornrnissien--af}l3rovcd author~ation. Amendment No. 2-7-6

SECURITY REb-ATE9-~ HOLTEC DECOMMISSIONING INTERNATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 ATTACHMENT 2 To Enclosure to HDI-IPEC-25-015 Telephone (856) 797-0900 Fax(856)797-0909 Proposed Change to IPEC Renewed Facility License Conditions (Replacement Pages) License Amendment Request to Revise Indian Point Energy Center Facility Licenses to Terminate Stand-alone Preemption Authority SECURITY RELATED INFORPAA-+!ON ~eamef-:l.ts-eAtain Sensitive LJ-nelassmed Nen Sare13uard Information Sesurity Related ffife.r-mat+~~.-1~ HDI-IPEC-25-015

HOL TEC DECOMMISSIONING INTERNATIONAL, LLC AND HOL TEC INDIAN POINT 21 LLC DOCKET NO. 50-003 INDIAN POINT NUCLEAR GENERATING STATION, UNIT NO. 1 PROVISIONAL OPERATING LICENSE

4.

Deleted

5.

Deleted.

6.

Deleted: (a) Deleted (b) Provisional Trust (i) The provisional trust agreement must be in a form acceptable to the NRC. (ii) Investments in the securities or other obligations of Holtec International or its affiliates, subsidiaries, successors, or assigns are and shall be prohibited. Except for investments tied to market indexes or other non-nuclear-sector mutual funds, investments in any entity owning one or more nuclear power plants are and shall be prohibited. (iii) The provisional trust agreement must provide that no disbursements or payments from the trust, other than for ordinary administrative expenses, shall be made by the trustee unless the trustee has first given the Director of the Office of Nuclear Reactor Regulation 30 days prior written notice of payment. The provisional trust agreement shall further contain a provision that no disbursements or payments from the trust shall be made if the trustee receives prior written notice of objection from the NRC. (iv) The provisional trust agreement must provide that the agreement cannot be amended in any material respect, or terminated, without 30 days prior written notification to the Director of the Office of Nuclear Reactor Regulation. (v) The appropriate section of the provisional trust agreement shall state that the trustee, investment advisor, or anyone else directing the investments made in the trust shall adhere to a "prudent investor" standard, as specified in 18 CFR 35.32(a)(3) of the Federal Energy Regulatory Commission's regulations. (vi) Use of assets in the provisional trust, in the first instance, shall be limited to the expenses related to decommissioning IP1 or IP2 as defined by the NRC in its regulations and issuances, and as provided in this license and any amendments thereto. Amendment No-:-XX

HOL TEC DECOMMISSIONING INTERNATIONAL, LLC AND HOL TEC INDIAN POINT 2, LLC DOCKET NO. 50-003 INDIAN POINT NUCLEAR GENERATING STATION, UNIT NO. 2 RENEWED FACILITY LICENSE Amendment No. XXX ENTIRE PAGE DELETED Amendment No. XXX

HOLTEC DECOMMISSIONING INTERNATIONAL, LLC AND HOL TEC INDIAN POINT 31 LLC DOCKET NO. 50-286 INDIAN POINT NUCLEAR GENERA TING UNIT NO. 3 RENEWED FACILITY LICENSE Amendment No. xxx ENTIRE PAGE DELETED Amendment No. xxx}}