ML25365A986
| ML25365A986 | |
| Person / Time | |
|---|---|
| Site: | 99902049 |
| Issue date: | 12/31/2025 |
| From: | Holtec, SMR |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25365A983 | List: |
| References | |
| 300-USNRC-123 | |
| Download: ML25365A986 (0) | |
Text
Pioneer Units 1 & 2 Construction Permit Application Part I 300-USNRC-123 Enclosure I General and Financial Information 17 pages follow
Holtec International Copyrighted Material December 2025 - Revision 0 Page i Pioneer Units 1 and 2 Limited Work Authorization General and Financial Information*
Table of Contents Chapter Title Page 1
Description of Planned Activities...................................................................................... 1-1 1.1 Non-Construction Activities............................................................................................. 1-1 1.2 Installation of Permanent Support of Excavation Walls................................................... 1-2 1.3 LWA Construction Activities............................................................................................ 1-2 2
General and Financial Information................................................................................... 2-1 2.1 General Information........................................................................................................ 2-1 2.1.1 Description of Applicant..................................................................................... 2-1 2.1.2 License Type..................................................................................................... 2-4 2.1.3 Construction Schedule....................................................................................... 2-4 2.1.4 Technical Qualifications..................................................................................... 2-5 2.1.5 Foreign Ownership, Control, or Domination....................................................... 2-6 2.1.6 Restricted Data and Classified National Security Information............................. 2-6 2.2 Financial Qualifications................................................................................................... 2-6 2.2.1 Estimated Project Costs..................................................................................... 2-7 2.2.2 Financial Capacity Plan..................................................................................... 2-8 2.2.3 Financial Statements........................................................................................ 2-11 2.3 References................................................................................................................... 2-13 List of Tables Table 2-1 Corporate Information Required by 10 CFR 50.33(d)(3).......................................... 2-2 Table 2-2 Project Cost Estimate (2025 $)................................................................................ 2-7 Table 2-3 Summary of Holtec International Year-End 2024 Balance Sheet........................... 2-12 List of Figures Figure 2-1 Corporate Organization.......................................................................................... 2-1
- Redacted information in this document is marked by double bolded brackets ((( ))) and constitutes proprietary commercial and financial information that is being withheld pursuant to 10 CFR 2.390(a)(4) and the attached affidavit.
Description of Planned Activities Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 1-1 1 Description of Planned Activities In accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.10, License required; limited work authorization, SMR, LLC (SMR), on behalf of Palisades SMR, LLC, hereby submits the enclosed application requesting the U.S. Nuclear Regulatory Commission (NRC) review and approval of a limited work authorization (LWA) to begin construction of a dual-unit SMR-300 plant located at the Palisades Energy Center (PEC) in Covert, Michigan. The units are individually named Pioneer Unit 1 and Pioneer Unit 2.
This submittal is the first part (Part 1) of a construction permit application for a utilization facility under 10 CFR Part 50 to authorize the construction of a dual-unit SMR-300 plant, consisting of two SMR-300 individual small modular reactors. This Part 1 includes a request for an LWA, an exemption from 10 CFR 50.10(d) to authorize certain construction activities prior to issuance of a full construction permit, an exemption from 10 CFR 50.10(c) to allow permanent installation of retaining walls, and an exemption from 10 CFR 50.33(f)(1) and 10 CFR Part 50 requirements to identify specific sources of funding at this stage of the project. Part 2 will include the remaining information to support issuance of the construction permit and will be filed no later than 18 months after this Part 1 submittal.
Holtec International (Holtec) is performing non-construction activities, as defined by 10 CFR 50.10(a) and Holtec plans to perform additional non-construction activities prior to LWA approval. These activities are described in Section 1.1.
SMR requests an exemption to allow installation of permanent support of excavation (SOE) walls (a construction activity) prior to LWA approval. The exemption request is included in Enclosure IV of this application. The activities addressed by this exemption request are described in Section 1.2.
SMR requests approval to perform construction activities under the LWA, consistent with 10 CFR 50.10(d). In addition, SMR requests an exemption to allow construction activities beyond those permitted by 10 CFR 50.10(d). The exemption request is included in Enclosure IV of this application. The construction activities are described in Section 1.3.
Descriptions of the Pioneer Units 1 and 2 structures, systems, and components (SSCs) to be installed are provided in the preliminary safety analysis report (PSAR) included as Enclosure II of this application.
1.1 Non-Construction Activities Site characterization and other non-construction activities have been ongoing at PEC since 2024. A permitting plan, including applicable environmental and construction permits, has been established and implemented to acquire appropriate local, state, and federal permits.
Site preparation activities will include demolition of current structures, clearing and grading of the site, paving access roads and parking lots, and establishment of access control. Holtec will establish drainage, erosion control, and stormwater management. Construction support will commence, including installation of temporary power, fuel storage tanks, a concrete batch plant, and structural module fabrication areas.
Excavation and the installation of certain non-safety-related SSCs that do not meet the definition of a construction activity in 10 CFR 50.10(d) will be installed. These activities may commence
Description of Planned Activities Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 1-2 prior to or after approval of this LWA application, and the activities will continue during the LWA construction period.
Non-construction activities will include:
Install buried piping for the Raw Water System (RWS), Circulating Water System (CRS),
and Service Water System (SWS).
Install associated basins and cooling towers for the CRS and SWS.
Install intake and outfall structures in Lake Michigan.
Fabricate but not install modules for the SMR-300 major structures.
Establish the Turbine Building (TB) foundation and install the turbine pedestal.
1.2 Installation of Permanent Support of Excavation Walls Permanent SOE walls will be used for the major structures, including the unitized Containment Structures (CSs), the shared Reactor Auxiliary Building (RAB), the unitized Intermediate Buildings (IBs) and the unitized TBs. An exemption request is included in Enclosure IV of this application to request approval to allow installation of the permanent SOE walls prior to issuance of the LWA.
1.3 LWA Construction Activities After approval of the LWA, Holtec will perform soil improvement to enhance the physical and mechanical properties of the soil within the excavation and install foundations for CSs (one for each unit), the RAB (shared between the two units) and for the IBs (one for each unit). A single basemat supports both CSs and a portion of the shared RAB (the portion that is plant south, referred to as the RAB-S). The remainder of the RAB (RAB-N) is supported by a separate basemat at a shallower elevation.
An exemption request is included in Enclosure IV of this application to allow additional construction activities under the LWA.
The additional construction activities for each unit include installation of the following:
Steel-concrete containment vessel (SCCV) from the foundation to plant grade level Interior, below-grade structures of the SCCV, specifically:
o Bio-shield wall o Passive core makeup water tank walls o Spent fuel pool walls o Walls surrounding the reactor pressure vessel cavity o Steam generator support block o Walls surrounding steam generator support block o Walls surrounding the Chemical and Volume Control System regenerative heat exchanger o Elevator shaft walls o Reactor coolant pump support blocks Transfer girder.
Structural steel for the TB.
CRS pumps and valves.
Below-grade IB walls.
Description of Planned Activities Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 1-3 The additional construction activities for the site include installation of:
RAB-S exterior, below-grade walls and interior, below-grade walls and columns.
RAB-N exterior, below-grade walls and interior, below-grade walls and columns.
Underground electrical duct banks.
RWS basin.
Below-grade fire loop piping, associated isolation/segmentation valves, and outdoor hydrants.
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-1 2 General and Financial Information 2.1 General Information This construction permit application (CPA) is being submitted by SMR, LLC on behalf of Palisades SMR, LLC, a wholly-owned subsidiary of Holtec International, for the construction of a dual-unit SMR-300 plant located at the Palisades Energy Center (PEC) in Covert, Michigan.
2.1.1 Description of Applicant Palisades SMR, LLC is a special purpose entity formed to support development and financing of the Project and to serve as the NRC-licensed owner. Palisades SMR, LLC is a direct, wholly owned subsidiary of Nuclear Asset Management Company, LLC (NAMCO). NAMCO is a direct, wholly owned subsidiary of Holtec Power, Inc. Holtec Power is a direct, wholly owned subsidiary of Holtec International. Figure 2-1 provides an organizational chart with the applicable organizational structure of the owning and operating entities for Pioneer Units 1 and 2.
Figure 2-1 Corporate Organization Holtec International is a Delaware corporation and the ultimate parent company of all the relevant entities who will own and operate the Project. Holtec International, through its direct subsidiary SMR, LLC, is responsible for the development of the Project during the design, licensing, and construction of the Project.
The general corporate information required by 10 CFR 50.33(d)(3) regarding Holtec International, SMR, LLC, Holtec Power, NAMCO, and Palisades SMR, LLC, including identification of their principal officers and directors, is provided in Table 2-1.
Because Palisades SMR, LLC is a newly formed entity, the information required by 10 CFR 50.33(f)(4) is included herein. Palisades SMR, LLC is a Delaware limited liability company whose sole member is NAMCO. As of the date of this CPA, Palisades SMR, LLC has no liabilities and no assets. The real property on which the Project will be constructed is
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-2 currently owned by Holtec Palisades, LLC, the licensed owner of the Palisades Nuclear Plant.
Prior to commencement of nuclear construction, Holtec Palisades will ensure that Palisades SMR, LLC has the appropriate rights with respect to the Project site. Such arrangements will be subject to Holtec Palisades compliance with NRC regulations governing the existing Palisades facility and satisfaction of any loan covenants made to the U.S. Department of Energy (DOE) in connection with Holtec Palisades financing of the Palisades Nuclear Plant restart. The SMR-300 design is owned by SMR, LLC. Prior to commencement of nuclear construction, Holtec International will ensure that Palisades SMR, LLC is appropriately capitalized to carry out the obligations of Palisades SMR, LLC during construction (including satisfying contractual payment obligations or financing covenants).
As Palisades SMR, LLCs sole member, NAMCO, holds 100% of the membership interests in Palisades SMR, LLC. Palisades SMR, LLC is governed by its sole member with delegated authority to officers, all of whom are listed in Table 2-1. These individuals are ultimately accountable to the Holtec International Executive Committee, the members of which are listed in Table 2-1.
Holtec International is currently supplying funding and support services for the Projects development, including design, licensing, and permitting. Employees of Holtec International or its subsidiaries will be responsible for the administration of the Project during design, licensing, and construction. Through its Executive Committee, Holtec International will exercise typical corporate parent approval and oversight of Palisades SMR, LLC during development and construction, including budgetary approvals, hiring decisions for senior management, and approval of major Project cost and schedule decisions.
Holtec International is the ultimate parent company of all the entities described in Table 2-1.
Holtec International is a privately held corporation. It is owned by its shareholders as follows:
(1) The Great Banyan Trust, 36.33% ownership interest; and (2) Multi-Decades Trust, 63.67%
ownership interest. These trusts are controlled by Dr. Krishna Singh, who is a U.S. citizen.
Table 2-1 Corporate Information Required by 10 CFR 50.33(d)(3)
NAME:
Holtec International STATE OF INCORPORATION:
Delaware BUSINESS ADDRESS:
Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104 DIRECTORS:
Dr. Krishna P. Singh, Chair Martha J. Singh, Vice Chair S. Amy Singh, Secretary
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-3 EXECUTIVE COMMITTEE:
Dr. Krishna P. Singh, Chief Executive Officer Kelly D. Trice, President Pankaj Chaudhary, President - Corporate Projects, Manufacturing and Supply Chain J. Scott Thomson, President - Holtec Government and Security International; Chief Governance Officer Dr. Richard Springman, President - Global Clean Energy Opportunities Debabrata Mitra-Majumdar, President - Heat Transfer Division Joy Russell, Senior V.P. and Chief Commercial Officer William F. Gill, IV, V.P. and General Counsel All the directors are U.S. citizens. All the principal officers of Holtec International, including all Holtec Executive Committee members, are U.S. citizens, with the same corporate address as Holtec International.
NAME:
Holtec Power, Inc.
STATE OF INCORPORATION:
Delaware BUSINESS ADDRESS:
Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104 DIRECTORS:
Pankaj Chaudhary Dr. Stefan Anton EXECUTIVE COMMITTEE:
Pankaj Chaudhary, President Dr. Stefan Anton, Vice President Thomas P. Howe, Treasurer William F. Gill, IV, Secretary All the directors and principal officers of Holtec Power, Inc. are U.S. citizens, with the same corporate address as Holtec Power, Inc.
NAME:
Nuclear Asset Management Company, LLC STATE OF FORMATION: Delaware BUSINESS ADDRESS:
Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104 MANAGING MEMBER:
Holtec Power, Inc.
PRINCIPAL OFFICERS:
Kelly D. Trice, President Troy Geauthreaux, Treasurer and Chief Financial Officers William F. Gill, IV, Secretary Jason Day, Assistant Secretary All the principal officers of Nuclear Asset Management Company, LLC are U.S. citizens, with the same corporate address as Nuclear Asset Management Company, LLC.
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-4 NAME:
Palisades SMR, LLC STATE OF FORMATION: Delaware BUSINESS ADDRESS:
Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104 MANAGING MEMBER:
Nuclear Asset Management Company, LLC PRINCIPAL OFFICERS:
Kelly D. Trice, President Thomas Howe, Chief Financial Officer and Treasurer Jean Fleming, Vice President, Licensing and Regulatory Affairs Justin Hawkins, Executive Director - SMR William F. Gill, IV, Secretary Jason Day, Assistant Secretary All the principal officers of Palisades SMR, LLC are U.S. citizens, with the same corporate address as Palisades SMR, LLC.
2.1.2 License Type This submittal is the first part (Part 1) of a construction permit application for a utilization facility under 10 CFR Part 50 to authorize the construction of a dual-unit SMR-300 plant. This Part 1 includes a request for a limited work authorization (LWA), an exemption from 10 CFR 50.10(d) to authorize certain construction activities prior to issuance of a full construction permit, an exemption from 10 CFR 50.10(c) to allow permanent installation of retaining walls, and an exemption from 10 CFR 50.33(f)(1) and 10 CFR Part 50 requirements to identify specific sources of funding at this stage of the project. Pursuant to 10 CFR 2.101(a)(9), this Part 1 includes general corporate and financial information, an environmental report, applicable portions of the preliminary safety analysis report (PSAR) for the activities described in Section 1.3 of Enclosure I of this application, and a redress plan for those activities. Part 2 will include the remaining information to support issuance of the construction permit and will be filed no later than 18 months after this Part 1 submittal. At the appropriate Project phase, Palisades SMR, LLC will apply for an operating license and applicable license(s) governing the possession or use of byproduct material, source material, or special nuclear material under 10 CFR Parts 30, 40, and 70, as applicable.
2.1.3 Construction Schedule Palisades SMR, LLC requests that NRC establish a review schedule that supports issuance of the LWA and exemption from 10 CFR 50.10(d) by December 31, 2026, to support commencement of the limited construction activities described in Section 1.3 of Enclosure I of this application in 2027.
Subject to Palisades SMR, LLCs submittal of Part 2 of the application and NRCs issuance of a construction permit, Palisades SMR, LLC expects to begin full-scope nuclear construction in the fourth quarter in 2028. Construction of both units is expected to be completed by the end of 2031.
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-5 2.1.4 Technical Qualifications Holtec International (Holtec), which is led by Dr. Krishna Singh, is an integrated technologies enterprise providing innovative solutions, equipment, and services to the global nuclear, solar, geothermal, and fossil power generation sectors of the energy industry. Holtec brings a broad corporate resume of accomplishments in nuclear projects in the U.S. and abroad, a substantial list of ongoing and satisfactorily completed nuclear projects (including many turnkey projects),
and a long safety and quality record that demonstrates its commitment to nuclear safety and excellence.
As an industry leader in nuclear fuel management systems, Holtec has extensive experience in providing safety-related services to operating commercial power plants, as well as in designing, manufacturing, and installing safety-related equipment, and possesses in-house capabilities to design, engineer, analyze, construct, and deploy the technologies to manage used nuclear fuel discharged from nuclear reactors. Holtec holds several certificates of compliance for dry storage systems and has decades of experience implementing those systems under NRC quality assurance programs.
Holtec is the ultimate upstream parent company of the licensed owner and decommissioning operator of four Part 50 commercial reactor sites that have permanently ceased power operations and are in various states of decommissioning: Oyster Creek, Pilgrim, Indian Point, and Big Rock Point. Holtec is also the upstream parent of the licensed owner and operator of the Palisades Nuclear Plant, the large light water reactor adjacent to the Project. Through its subsidiaries, Holtec personnel have overseen the first-of-a-kind restart of the Palisades Nuclear Plant following its shutdown in 2022. NRC recently approved the technical qualifications of Holtecs subsidiary, Palisades Energy, LLC, to operate the Palisades Nuclear Plant upon the resumption of full power operations. Palisades Energy has training programs accredited by the National Nuclear Accrediting Board. Palisades Energy is expected to serve as the licensed operator of the Project following its completion.
Holtec, through its subsidiary SMR, LLC, has invested in and developed the SMR-300 design for over a decade. Holtecs reactor designs have received cost-share funding from DOE via the Advanced Reactor Demonstration Program (ARDP). The SMR-300 is an advanced pressurized light water reactor designed to use commonly available nuclear fuel assemblies and able to leverage existing fleet operating experience. The design was developed to leverage Holtecs existing manufacturing infrastructure to support modular fabrication of key components. The SMR-300 design is described in more detail in the PSAR.
Holtec has teamed with Hyundai Engineering and Construction Co., Ltd. (HDEC) to support site-specific engineering and balance-of-plant design and to serve as general construction contractor for the Project, through its domestic subsidiary, Hyundai America, Inc., HDEC is a Korean engineering, procurement, and construction (EPC) firm and leading international nuclear contractor. The company has constructed over a dozen nuclear plants in South Korea and recently served as lead contractor for the four APR-1400 Barakah units in the United Arab Emirates.
The Projects supply-chain will include established nuclear industry vendors, including Framatome for fuel design and supply, and Mitsubishi Electric Corporation for instrumentation and control (I&C) platform integration.
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-6 2.1.5 Foreign Ownership, Control, or Domination Holtec is a privately held corporation owned by domestic trust companies that are in turn controlled by a U.S. citizen. It is led by its Chief Executive Officer, a U.S. citizen, and management of the company is vested in the Holtec executive leadership team, including the Executive Committee members listed in Table 2-1. All the members of the Holtec Executive Committee are U.S. citizens. All the managers and principal officers of Palisades SMR, LLC and the intermediate Holtec International subsidiaries are U.S. citizens. As such, Palisades SMR, LLC will not be owned, controlled, or dominated by any foreign person.
2.1.6 Restricted Data and Classified National Security Information In accordance with 10 CFR 50.37, Agreement limiting access to Classified Information, Palisades SMR, LLC agrees that it will appropriately safeguard such information and will not permit any individual to have access except as authorized under 10 CFR Part 25, Access Authorization and/or 10 CFR Part 95, Facility Security Clearance and Safeguarding of National Security Information and Restrict Data.
2.2 Financial Qualifications 10 CFR 50.33(f)(1) requires a construction permit application to include estimates of total construction costs and related fuel cycle costs, and sufficient information to demonstrate that the applicant has reasonable assurance of obtaining the funds necessary to cover those costs.
10 CFR Part 50, Appendix C, requires newly-formed companies that are not rate-regulated utilities (such as Palisades SMR, LLC) to specifically identify the source(s) of funds that will be used to cover the costs of construction. The Commission has recognized the difficulty (if not impossibility) of making this showing with a high degree of specificity at the early stage of a project, particularly given that submission of the initial NRC application is often a prerequisite to obtaining financing. Accordingly, in SRM-SECY-13-0124 (Reference 1), the Commission directed staff to undertaking rulemaking to amend the requirements of Part 50 to more closely track the showing required for Part 70 fuel cycle facilities, that the applicant appears to be financially qualified. Following this direction to staff, the Commission approved an exemption from these Part 50 requirements in connection with its issuance of the South Texas Project, Units 3 and 4 combined licenses in 2015 (Reference 2). Staff developed a proposed rule and regulatory basis document to address the issue for all Part 50 applicants (References 3 and 4).
In SRM-SECY-18-0026, the Commission directed staff to instead address this topic in Part 53 rulemaking, which is still in process (Reference 5).
The financial realities that motivated the Commission to address this topic a decade ago have not changed. Accordingly, Enclosure IV of this application includes an exemption request from the parts of 10 CFR 50.33(f)(1) and Part 50, Appendix C, that require Palisades SMR, LLC to identify specific source(s) of funds in this initial application. Instead, Palisades SMR, LLC requests that it be allowed to demonstrate its qualifications under the 10 CFR Part 70 standard, that the applicant appears to be financially qualified.
The section that follows includes Palisades SMR, LLCs Financial Capacity Plan consistent with NRC staffs guidance in Reference 4, the requirements of 10 CFR 70.23(a)(5), the exemption granted to the South Texas Project owners in Reference 2, and the information provided more recently by similarly-situated applicants who requested exemptions from these same Part 50 requirements for the same reasons (References 6 and 7).
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-7 Together with the cost estimate below, which has been prepared in accordance with established nuclear industry cost-estimation principles, this information demonstrates Palisades SMR, LLCs level of understanding of the size and scope of the Project, including the level of capital necessary to undertake the project, and the organizational and human resources, experience, skills, and expertise required to obtain proper financing and ultimately finance the project, when appropriate.
2.2.1 Estimated Project Costs The Project cost basis is an Association for the Advancement of Cost Engineering (AACE)
Class 3 estimate developed jointly by Holtec International and HDEC. Supporting data is consistent with the guidelines provided in AACE Recommended Practice 115R-21: Cost Estimate Classification System for Nuclear Projects. The estimate basis includes a substantial collection of direct estimates from Holtec Internationals factories for the Nuclear Steam Supply System and major mechanicals. HDEC is intended to lead construction activities and developed bid pricing for construction scopes in support of the estimate using both local and U.S.
nation-wide construction companies. Supply chain estimates by both Holtec International and HDEC developed the remaining costs of the production plant. Transmission and Distribution cost estimates are based on analysis by Sargent & Lundy. Palisades SMR, LLCs costs are developed through direct benchmarking of U.S. utility led projects. Fuel costs were developed using publicly available information from leading uranium suppliers and validated through quotation with Framatome. Note that the costs in Table 2-2 are the full Project costs, not just those that would be authorized by the requested LWA and exemption from 10 CFR 50.10(d).
Table 2-2 Project Cost Estimate (2025 $)
(a) Total nuclear production plant costs Total Project: ((
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Engineering & Licensing: ((
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Procurement: ((
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Construction: ((
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Intake/Outfall System: ((
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(b) Transmission, distribution, and general plant costs Total Project: ((
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T&D: ((
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Security: ((
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Indirects & Overheads: ((
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Owners Admin/Services: ((
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(c) Nuclear fuel inventory cost for first core Total Project: ((
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Unit 1: ((
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Unit 2: ((
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Total estimated cost Total Project: ((
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(overnight, 2025 USD)
- Redacted information in this section constitutes proprietary commercial and financial information and is being withheld pursuant to 10 CFR 2.390(a)(4) and the attached affidavit.
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-8 An AACE Class 2 estimate will be completed prior to the start of nuclear construction.
2.2.2 Financial Capacity Plan Anticipated Financing Structure The Project was recently selected to receive $400 million in cost-shared funding from DOE for the Generation III+ small modular reactor award authorized by the Consolidated Appropriations Act of 2024 (PL 118-42). Subject to finalization of the award agreement, these funds are expected to support certain engineering, licensing, procurement, and pre-construction activities.
The DOE award will reduce near-term private capital requirements for the Project and, together with Holtecs ongoing private investment, will support Project funding and continued schedule progress during the most difficult portion of a nuclear project to finance (pre-construction development costs incurred ahead of regulatory approvals or construction). The DOE award is expected to reflect 50/50 cost sharing; i.e., the private portion is expected to also be
$400 million. Holtec will fund the private portion of these cost-shared funds. Of note, DOEs selection criteria included a review of the commercial viability of the project and the applicants ability to obtain full financing for construction. ((
))*
Palisades SMR, LLC plans to finance up to 80% of the construction cost of the Project via a construction loan. Holtec is working on Palisades SMR, LLCs behalf to secure a loan guarantee from the DOEs Office of Energy Dominance Financing (OEDF, formerly the Loan Program Office) under Title XVII of the Energy Policy Act of 2005, as amended. Holtec has completed the part I loan application process and is preparing to submit its part II loan application for the Project. Part II loan applications are made after screening for part I is complete and after OEDF requests the part II application.
Palisades SMR, LLCs affiliate, Holtec Palisades, LLC, recently obtained a $1.52 billion Title XVII loan guarantee from OEDF to support the Palisades Nuclear Plant restart projectthe second such loan guarantee issued for a nuclear project. Holtec International provided the equity contribution for the Palisades loan. While some pre-construction work has begun on the SMR-300 construction project, the capital requirements for the Palisades restart project will not impact the capital requirements for the SMR-300 construction. Palisades is expected to achieve commercial operations in the first quarter of 2026. Holtec also previously obtained $148 million cost-share award through DOEs ARDP to support development of the SMR-300 design.
In addition to the OEDF loan guarantee, Palisades SMR, LLC and Holtec are evaluating alternative public and private construction financing, but the Title XVII loan guarantee process is currently the expected path.
The remaining 20% equity contribution will be made up of Holtecs private investment in the Project accrued to the date of loan closing, additional third-party private investment, and other sources of capital.
- Redacted information in this section constitutes proprietary commercial and financial information and is being withheld pursuant to 10 CFR 2.390(a)(4) and the attached affidavit.
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-9 Holtecs share of the equity contribution is planned to be funded from operating profit. As a result of its mainline nuclear services businesses, Holtec maintains a healthy balance sheet and cash flow with minimal levels of debt. ((
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((
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The Project is expected to qualify for tax credits and adders above the base credit under Section 48E of the Internal Revenue Code. Holtec has experience with financing structures to leverage nuclear energy tax credits and the compliance requirements associated with various tax credit adders. Financing for the Palisades restart project is supported by similar Section 45Y tax credits.
Organizational Experience and Capabilities Holtecs management team has extensive experience executing and financing large nuclear projects, including prior success obtaining federal and state financial support. Several members of Holtecs Executive Committee members and the officers of Palisades SMR, LLC led the development and negotiation of the Title XVII loan guarantee from OEDF for the Palisades restart project, the parallel grant from the State of Michigan, offtake agreements with regional power cooperatives, and tax credit monetization strategies for the Palisades Section 45Y production tax credits. Several members of the same team worked to support DOEs selection of the Project for the Gen III+ SMR cost-sharing funds. Holtecs team is staffed with a number of nuclear industry veterans that have a broad set of experiences on large capital projects across the existing fleet.
At the enterprise level, Holtecs capital spend since 2020 is in excess of ((
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Capital expenditures have largely been financed directly from Holtec operating revenues, without the need for significant long-term debt other than the Palisades restart loan. Holtec
- Redacted information in this section constitutes proprietary commercial and financial information and is being withheld pursuant to 10 CFR 2.390(a)(4) and the attached affidavit.
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-10 maintains typical revolving credit facilities at the parent level, but those are not expected to support financing of the Project.
While the Project will be the largest capital project financed by Holtec to date, it iteratively builds on the Holtec teams experience and ongoing engagement with key financial partners, including DOE, the State of Michigan, regional electric providers, large load customers, and tax credit market participants. Holtec has successfully obtained one (of three) DOE loan guarantees for a nuclear project, ARDP funds that supported development of the SMR design, and the most-recent DOE Gen III+ cost-shared funds for near-term development costs (the most difficult portion of a nuclear project to finance). Coupled with the significant equity investment Holtec has already made in the Project and the nimbleness Holtec enjoys as a private company (which, among other things, enabled Holtec to close the Palisades restart DOE loan guarantee less than six months after conditional commitment), Palisades SMR, LLC has the institutional capabilities necessary to obtain the financing required for the Project at the appropriate project phase.
((
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Proposed License Condition Consistent with NRC guidance in Reference 4, Palisades SMR, LLC proposes the license condition below to require Palisades SMR, LLC to demonstrate the availability of funding at the appropriate project phase. Note that this license condition differs slightly from the example license condition included in Reference 4 because the only construction activities that would be authorized by approval of this Part 1 application are those covered by the LWA and related exemption from 10 CFR 50.10(d). This limited construction scope is described in Section 1.3.
The estimated cost of this limited construction scope is ((
))* It is possible that Palisades SMR, LLC may not have closed the financing for the full construction project by the time the limited construction work is scheduled to begin. Palisades SMR, LLC will identify the source(s) of funds that are in place at that time to ensure that the limited construction work is adequately funded. Prior to commencement of full construction scope, which will require issuance of a construction permit, Palisades SMR, LLC will make available evidence that the full construction scope is financed.
License condition:
The licensee will notify the NRC at least 60 days prior to the applicable milestone that the following are available for inspection:
- 1. prior to commencement of limited construction scope (as defined in 10 CFR 50.10(a))
authorized by NRC to proceed prior to issuance of a construction permit:
a cost estimate for such limited construction work; and
- Redacted information in this section constitutes proprietary commercial and financial information and is being withheld pursuant to 10 CFR 2.390(a)(4) and the attached affidavit.
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-11 documentation demonstrating the availability of funding to cover the costs of the limited construction work, including closing documents, if available, funds on deposit in account(s) controlled by the licensee, parent or affiliate funding that is committed to the project, or capital from other sources that is committed to the project.
- 2. prior to commencement of the full construction scope authorized by a construction permit:
an updated cost estimate for the full construction scope; documentation justifying any variances from the original cost estimate provided in the application; and documentation demonstrating that the licensee has secured financing to meet the updated cost estimate for the project, including closing documents or documented proof of parent and affiliate assurances, or capital from other sources that reflect financing for the project.
Conclusion Palisades SMR, LLC understands the capital needs of the Project and the need to secure financing ahead of nuclear construction. The proposed license condition will ensure that Palisades SMR, LLC has demonstrated its ability to fund activities as they are authorized by the NRC.
2.2.3 Financial Statements Appendix C to 10 CFR Part 50 contemplates that the construction permit applicant will provide its annual financial report and certain interim financial statements, as applicable. Appendix C and Reference 4 both recognize that newly-formed entities like Palisades SMR, LLC will not be in a position to submit statements reflecting prior operations. Pursuant to 10 CFR 50.71(b), each holder of a construction permit, once issued, is required to submit an annual financial report, including certified financial statements, to the NRC upon issuance of such reports.
To support NRCs review of Palisades SMR, LLCs ability to finance the Project, including by reliance on equity contributions of its ultimate parent, Holtec International, Palisades SMR, LLC is providing a summary of Holtec Internationals year-end 2024 balance sheet in Table 2-3 below. Holtec International 2025 financial statements are expected to be finalized in the first quarter of 2026. Once final, Palisades SMR, LLC will make available Holtec Internationals 2025 consolidated financial statements for NRC inspection, if requested.
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-12 Table 2-3 Summary of Holtec International Year-End 2024 Balance Sheet (Dollars in Thousands)
December 31, 2024 2023 Assets Cash and cash equivalents
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Accounts and contracts receivable
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Nuclear decommissioning trust funds
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Costs and estimated earnings in excess of billings
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Property and equipment, net and inventories
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Other assets
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Total assets
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Liabilities and stockholders equity Accounts and notes payable
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Billings in excess of costs and estimated earnings
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Asset retirement obligations
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Unearned income and Deferred grant income
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Deferred income tax liabilities
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Other liabilities
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Total liabilities
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Stockholders equity:
Common Stock and additional paid-in capital
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Retained earnings
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Total stockholders equity
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Total liabilities and stockholders equity
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- Redacted information in this section constitutes proprietary commercial and financial information and is being withheld pursuant to 10 CFR 2.390(a)(4) and the attached affidavit.
General and Financial Information Pioneer Units 1 & 2 Construction Permit Application, Part 1 General and Financial Information Holtec International Copyrighted Material December 2025 - Revision 0 Page 2-13 2.3 References
- 1.
USNRC, Policy Options for Merchant (Non-Electric Utility) Plant Financial Qualifications, SRM-SECY-13-0124, April 2014 (ADAMS Accession No. ML14114A358).
- 2.
USNRC, Final Safety Evaluation Report for the South Texas Project Units 3 and 4 Combined License Application, Chapter 1, September 2015 (ADAMS Accession No. ML15271A126).
- 3.
USNRC, Proposed Rule: Financial Qualifications Requirements for Reactor Licensing, SECY-18-0026, March 2014 (ADAMS Accession No. ML17172A536).
- 4.
USNRC, Financial Qualifications for Reactor Licensing Rulemaking, Regulatory Basis Document, October 2016 (ADAMS Accession No. ML15322A185).
- 5.
USNRC, Proposed Rule: Financial Qualifications Requirements for Reactor Licensing, SRM-SECY-18-0026, July 2022 (ADAMS Accession No. ML22195A097).
- 6.
TerraPower, LLC, Revision to Exemption Request from 10 CFR 50.33(f) and 10 CFR 50 Appendix C Financial Qualification Documentation Requirements and Revision to the General and Financial Information of the Kemmerer Power Station Unit 1 Construction Permit Application, September 2025 (ADAMS Accession No. ML25251A127).
- 7.
Long Mott Energy, LLC, Long Mott Generating Station Construction Permit Application, Part V - Non-Applicabilities and Exemptions, March 2025 (ADAMS Accession No. ML25090A065).