PNP 2023-015, License Termination Plan, Revision 4

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License Termination Plan, Revision 4
ML23136A882
Person / Time
Site: Big Rock Point  File:Consumers Energy icon.png
Issue date: 05/16/2023
From: Fleming J
Holtec Decommissioning International, Holtec
To:
Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
HDI PNP 2023-015
Download: ML23136A882 (1)
v • d • e


Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 HOLTEC Telephone (856) 797-0900 DECOMMISSION I NG Fax (856) 797-0909 INTERNATIONAL HDI PNP 2023-015 10 CFR 50.71(e)

May 16, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Big Rock Point Docket No. 50-155 and 72-043 Facility Operating License No. DPR-6

Subject:

Big Rock Point License Termination Plan, Revision 4 In accordance with 10 CFR 50.71(e), Maintenance of records, making of reports, Holtec Decommissioning International, LLC (HDI) on behalf of Holtec Palisades, LLC (Holtec Palisades) hereby submits an update, Revision 4, to the Big Rock Point (BRP)

License Termination Plan (LTP). Revision 4 is a general update that reflects the current final phase status of the BRP decommissioning project.

The LTP revisions were reviewed in accordance with 10 CFR 50.59, Changes, tests and experiments, and have no effect on the license conditions of the BRP (DPR-6) license through amendment number 129. No parameters specified in the LTP were altered that would require prior NRC approval. of this letter contains a summary of the changes for Revision 4 to the BRP LTP. contains LTP replacement pages for Chapters 1,3,5,7, and 8. Chapters 2, 4, and 6 were not revised in revision 4. A single page is provided in Enclosure 2 for Chapters 2, 4, and 6, which should be placed at the beginning of these chapters to indicate that the chapters were not changed due to Revision 4 to the LTP.

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 Engineer at (269) 764-2945.

I declare under penalty of perjury that the foregoing is true and correct. Executed on May 16, 2023.

HDI PNP 2023-015 Page 2 of 2 Respectfully, Jean A. Fleming Digitally y

signed by Jean A. Fleming Date: 2023.05.16 11:31:02 -04'00' Jean A. Fleming Vice President, of Licensing, Regulatory Affairs & PSA Holtec International

Enclosures:

1. Big Rock Point License Termination Plan Revision 4 Summary

Attachment:

Big Rock Point License Termination Plan Revision Matrix, Revision 4

2. Big Rock Point License Termination Plan Revision 4 Replacement Pages cc: NRC Region Ill Regional Administrator NRC Decommissioning Inspector - Big Rock Point NRC NMSS Project Manager - Big Rock Point Michigan Department of Environmental Quality

HDI PNP 2023-015 Page 1 of 4 Enclosure 1 to HDI PNP 2023-015 Big Rock Point License Termination Plan Revision 4 Summary

HDI PNP 2023-015 Page 2 of 4 Big Rock Point License Termination Plan Revision 4 Summary

1. License Termination Plan Revision History Big Rock Point (BRP) license termination plan (LTP) Revision 3 was submitted to the NRC on July 17, 2013. It was a general update to the September 25, 2005, Revision 2 LTP to reflect the completion of phase 1, "BRP restoration project," which included NRC approval for unrestricted use of both impacted and nonimpacted land, leaving only the Independent Spent Fuel Storage Installation (lSFSI) parcel located on a non-impacted part of the site.

Since issuance of LTP Revision 3 the only notable change was the transfer of the BRP operating license from Entergy Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) as approved by an NRC Order on 12/13/2021, Reference 1, and conforming amendment 129 issued on June 28, 2022, Reference 2. Listed below, for reference, is a chronology of notable events significant to the decommissioning activities at the BRP site:

  • August 29, 1997 - Operation permanently ceased
  • September 20, 1997 - Fuel permanently removed from the BRP reactor vessel and site name changed from "Big Rock Point Nuclear Plant" to "Big Rock Point Restoration Project."
  • March 24, 2005 - NRC approves License Amendment Request 126 that incorporates the LTP into BRP site license.
  • September 27, 2005 - BRP Plant submits to the NRC Revision 2 to the Big Rock Point LTP.
  • January 8, 2007 - Release of the power reactor and non-ISFSI portions of the site from the BRP License per NRC Letter, "Big Rock Point -

Release of Land from Part 50 License for Unrestricted Use."

  • April 6, 2007 - License transfer of the BRP ISFSI to Entergy Palisades LLC, project name changed from "Big Rock Point Restoration Project" to "Big Rock ISFSI."
  • July 17, 2013 - BRP Plant submits to the NRC Revision 3 to the Big Rock Point LTP.
  • December 13, 2021 - License transfer of the BRP ISFSI to Holtec Palisades, LLC approved by NRC commission order.
  • June 28, 2022 - Conforming license amendment 129 issued by NRC to reflect transfer of the BRP license to Holtec Palisades, LLC as owner and Holtec Decommissioning International as operating authority.

HDI PNP 2023-015 Page 3 of 4

2. Listing of Revision 4 Notable Changes BRP LTP Revision 3 is a general update to incorporate changes due to transfer of the operating license from Entergy Palisades, LLC, to Holtec Palisades, LLC (Holtec Palisades) as owner and Holtec Decommissioning International, LLC (HDI) as operating authority.

Coincident with license transfer implementation BRP adopted HDIs Decommissioning Quality Assurance Program (DQAP). Finally, the LTP was revised to reflect that HDI submitted an annual Decommissioning Funding Status report for BRP in March of 2023. A summary of the more notable changes are provided below:

Chapter 1 - General Information Section 1.3 In this section, and throughout the document, the following title changes were incorporated to reflect the current facility owner and operating authority. The facility owner, Entergy Palisades, LLC, was changed to Holtec Palisades, LLC (Holtec Palisades) and the operating authority was changed from Entergy Nuclear Operations, Inc. (ENOI) to Holtec Decommissioning International, LLC (HDI), (References 1 and 2).

Section 1.4 In this section, and throughout the document, the following title changes were incorporated to reflect the current quality assurance program title.

The quality assurance title was changed from. Quality Assurance Program Manual or QAPM, was changed to Decommissioning Quality Assurance Program or DQAP.

Section 1.5 In this section, the Entergy Nuclear Operations, Inc. contracted low-level waste disposal facilities were replaced by the Holtec Decommissioning International, LLC facility.

Chapter 2 - Site Characterization This section was not revised.

Chapter 3 - Identification of Remaining Site Dismantlement Activities Other than the listed Chapter 1 changes that are applicable throughout the document, no additional notable changes were made to this section.

Chapter 4 - Site Remediation Plan This section was not revised.

Chapter 5 - Final Status Survey Plan Other than the listed Chapter 1 changes that are applicable throughout the document, no additional notable changes were made to this section.

Chapter 6 - Compliance with the Radiological Criteria for License Termination This section was not revised.

HDI PNP 2023-015 Page 4 of 4 Chapter 7 - Update of Site Specific Decommissioning Costs In addition to the listed Chapter 1 changes that are applicable throughout the document, this section was revised to reflect the March 31, 2023, HDI report on the status of decommissioning funding for BRP, Reference 3. Also, identified the 2012 decommissioning cost estimates as historical to preclude revision of Table 7-2 each year based on the NRC required annual decommissioning cost status reports.

Chapter 8 - Supplement to the Environmental Report Other than the listed Chapter 1 changes that are applicable throughout the document, no additional notable changes were made to this section.

3. Conclusion Revision 4 of the LTP reflects the transfer of the BRP operating license owner from Entergy Palisades, LLC to Holtec Palisades, LLC (Holtec Palisades) and authorized operator from Entergy Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI).

Further, the revisions were reviewed in accordance with 10 CFR 50.59 and have no effect on the license conditions of the BRP license through amendment number 129. No parameters specified in the LTP were altered that would require prior NRC approval.

4. References
1. U.S. Nuclear Regulatory Commission, Letter to Entergy Nuclear Operations, Inc.,

Palisades Nuclear Plant and Big Rock Point Plant - Order Approving Transfer of Licenses and Draft Conforming Administrative License Amendments (EPID No.

L-2020-LLM-0003), NRC ADAMS Accession Package Number ML21292A155, dated December 13, 2021

2. U.S. Nuclear Regulatory Commission, Letter to Holtec Decommissioning International, LLC, Palisades Nuclear Plant and Big Rock Point Plant - Issuance of Amendments Nos.

129 and 273 RE: Order Approving Transfer of Licenses and Conforming Administrative License Amendments (EPIDs L-2022-LLM-0002 and L-2020-LLM-0003), NRC ADAMS Accession Number ML221173A173, dated June 28, 2022

3. Holtec Decommissioning International, LLC, Letter to the U.S. Nuclear Regulatory Commission, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), NRC ADAMS Accession Number ML23090A140, dated March 31, 2023
5. Attachments
1. Big Rock Point License Termination Plan Revision Matrix, Revision 4

HDI PNP 2023-015 Page 1 of 14 Attachment 1 Big Rock Point License Termination Plan Revision Matrix, Revision 4 CHAPTER 1 - GENERAL INFORMATION Section Page Revision Basis Revised first paragraph, second sentence from Transfer of NRC License from Entergy Palisades, LLC to Entergy Palisades, LLC to Holtec Palisades, Holtec Palisades, LLC was approved by NRC Order 1.3 1-2 LLC (Holtec Palisades) issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2.

Added bullet under second paragraph, Transfer of NRC License from Entergy Palisades, LLC to License transfer of the BRP ISFSI to Holtec Palisades, LLC was approved by NRC Order Holtec Palisades, LLC as Owner and issued on 12/13/2021, Reference 1, and associated 1.3 1-2 Holtec Decommissioning International, conforming amendment 129 issued on June 28, 2022, LLC (HDI) as Operating Authority on Reference 2 June 28, 2022 Revised first paragraph, first sentence from Transfer of NRC License operating authority from Entergy Palisades Entergy LLCs to Holtec Nuclear Operations, Inc. to Holtec Decommissioning Decommissioning International, LLC (HDI) International, LLC (HDI) was approved by NRC Order 1.4.1 1-3 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 Revised second paragraph, first sentence, from Big Rock point plant adopted HDIs Decommissioning Entergys Quality Assurance Program Manual Quality Assurance Program as the Quality Assurance 1.4.1 1-3 to HDIs Decommissioning Quality Assurance Program Manual under 50.54a review. This occurred Program coincidental with license transfer.

HDI PNP 2023-015 Page 2 of 14 CHAPTER 1 - GENERAL INFORMATION Section Page Revision Basis Transfer of NRC License operating authority from Entergy Nuclear Operations, Inc. to Holtec Decommissioning Revised sixth paragraph, first sentence from International, LLC (HDI) was approved by NRC Order 1.4.1 1-4 Entergy Palisades LLC, to HDI issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 Transfer of NRC License operating authority from Entergy Nuclear Operations, Inc. to Holtec Decommissioning Revised first paragraph, second sentence from International, LLC (HDI) was approved by NRC Order 1.5.3 1-6 issued on 12/13/2021, Reference 1, and associated Entergy Palisades LLCs, to HDIs conforming amendment 129 issued on June 28, 2022, Reference 2 Transfer of NRC License operating authority from Entergy Nuclear Operations, Inc. to Holtec Decommissioning Revised first paragraph, fifth sentence from International, LLC (HDI) was approved by NRC Order 1.5.3 1-6 Palisades Entergy LLC to HDI issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2

HDI PNP 2023-015 Page 3 of 14 CHAPTER 1 - GENERAL INFORMATION Section Page Revision Basis Revised first paragraph, fifth sentence from HDI has contracted Waste Control Specialists, LLC in Andrews, Texas for disposal of BRP low-level waste.

low-level waste disposal facilities in Barnwell, South Caroline and Clive, Utah 1.5.3 1-6 to a low-level waste disposal facility in Andrews, Texas Transfer of NRC License operating authority from Entergy Nuclear Operations, Inc. to Holtec Decommissioning Revised second paragraph, first and second International, LLC (HDI) was approved by NRC Order 1.5.3.1 1-6 sentences from Entergy Palisades LLC to issued on 12/13/2021, Reference 1, and associated HDI conforming amendment 129 issued on June 28, 2022, Reference 2 Transfer of NRC License from Entergy Palisades, LLC to Revised third paragraph, first sentence from Holtec Palisades, LLC was approved by NRC Order 1.5.7 1-8 Entergy Palisades LLC to Holtec Palisades, issued on 12/13/2021, Reference 1, and associated LLC conforming amendment 129 issued on June 28, 2022, Reference 2.

HDI PNP 2023-015 Page 4 of 14 CHAPTER 1 - GENERAL INFORMATION Section Page Revision Basis Revised contact information from Removed personal information from the License Termination Plan (LTP) and left the current contact by Mr. Lawrence R. Potter position. This is an administrative change to prevent ISFSI Supervisor revision to the LTP as individuals change positions.

and 1.7 1-10 Email: lpotte1@entergy.com to ISFSI Manager Transfer of NRC License from Entergy Palisades, LLC to Holtec Palisades, LLC was approved by NRC Order Revised figure Legend, first bullet from Fig. 1-2 1-12 issued on 12/13/2021, Reference 1, and associated Entergy to Holtec Palisades, LLC conforming amendment 129 issued on June 28, 2022, Reference 2.

CHAPTER 2 - SITE CHARACTERIZATION Section Page Revision Basis All All No Changes were made to this chapter in None Revision 4

HDI PNP 2023-015 Page 5 of 14 CHAPTER 3 - IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES Section Page Revision Basis Revised second paragraph, first sentence from Transfer of NRC License operating authority from Entergy Entergy Palisades LLCs to Holtec Nuclear Operations, Inc. to Holtec Decommissioning Decommissioning International, LLC (HDI)s International, LLC (HDI) was approved by NRC Order 3.1 3-1 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 Revised second paragraph, third sentence from Transfer of NRC License operating authority from Entergy Entergy Palisades LLC to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 3.1 3-1 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 Revised third paragraph, first sentence, from Big Rock point plant adopted HDIs Decommissioning Entergy Palisades LLCs Quality Assurance Quality Assurance Program as the Quality Assurance 3.1 3-1 Program Manual (QAPM) to HDIs Program Manual under 50.54a review. This occurred Decommissioning Quality Assurance Program coincidental with license transfer.

(DQAP)

Revised fifth paragraph, second sentence from Transfer of NRC License operating authority from Entergy Entergy Palisades LLC to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 3.1 3-1 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2

HDI PNP 2023-015 Page 6 of 14 CHAPTER 3 - IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES Section Page Revision Basis Revised second paragraph, second and third Big Rock point plant adopted HDIs Decommissioning sentences, from QAPM to DQAP Quality Assurance Program as the Quality Assurance 3.2 3-2 Program Manual under 50.54a review. This occurred coincidental with license transfer.

Added bullet under third paragraph, Transfer of NRC License from Entergy Palisades, LLC to Amendment 129, December 13, 2021. Holtec Palisades, LLC was approved by NRC Order Approval of Transfer of Facility issued on 12/13/2021, Reference 1, and associated 3.2 3-2 Operating License No. DPR-06 to Holtec conforming draft amendment 129.

Palisades, LLC and Operating Authority to Holtec Decommissioning International, LLC.

Revised first paragraph, sixth sentence from Transfer of NRC License operating authority from Entergy Entergy Palisades LLC to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 3.4 3-3 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 Revised first paragraph, first sentence from Transfer of NRC License operating authority from Entergy Entergy Palisades LLC to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 3.4.1 3-4 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2

HDI PNP 2023-015 Page 7 of 14 CHAPTER 3 - IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES Section Page Revision Basis Revised first paragraph, first sentence from Transfer of NRC License operating authority from Entergy Entergy Palisades, LLC to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 3.5.3 3-4 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 CHAPTER 4 - SITE REMEDIATION PLAN Section Page Revision Basis No Changes were made to this chapter in None ALL ALL Revision 4 CHAPTER 5 - FINAL STATUS SURVEY PLAN Section Page Revision Basis Revised first paragraph, fifth sentence from Transfer of NRC License operating authority from Entergy Entergy Palisades LLC to Holtec Nuclear Operations, Inc. to Holtec Decommissioning Decommissioning International, LLC International, LLC (HDI) was approved by NRC Order 5.1.2 5-1 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2

HDI PNP 2023-015 Page 8 of 14 CHAPTER 6 - COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION Section Page Revision Basis No Changes were made to this chapter in None ALL ALL Revision 4 CHAPTER 7 - UPDATE OF SITE SPECIFIC DECOMMISSIONING COSTS Section Page Revision Basis Revised fourth paragraph, first sentence from Transfer of NRC License from Entergy Palisades, LLC to Entergy Nuclear Palisades, LLC to Holtec Holtec Palisades, LLC was approved by NRC Order 7.1 7-1 Palisades, LLC (Holtec Palisades) issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2.

Revised sixth paragraph, second sentence Transfer of NRC License from Entergy Palisades, LLC to added, in 2007 and then to Holtec Palisades, Holtec Palisades, LLC was approved by NRC Order 7.1 7-1 LLC in 2022. issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2.

Revised sixth paragraph, by replacing third Holtec Decommissioning International, LLC, Letter to the sentence, U.S. Nuclear Regulatory Commission, Report on Status of Decommissioning Funding for Reactors and Independent 7-1 This revision to the LTP contains the updated Spent Fuel Storage Installations - Holtec 7.1 and decommissioning cost estimate for the final Decommissioning International, LLC (HDI), Reference 3.

7-2 phase of decommissioning as provided in the letter (ENOC-12-00039) from Entergy Nuclear Operations, Inc. to the U.S. Nuclear Regulatory

HDI PNP 2023-015 Page 9 of 14 CHAPTER 7 - UPDATE OF SITE SPECIFIC DECOMMISSIONING COSTS Section Page Revision Basis Commission - ISFSI Decommissioning Funding Plans (10 CFR 72.30), December 13, 2012.

with the following three sentences, In December 2021, after submission of the license application but before transfer of the BRP license to HDI, Entergy filed an updated cost estimate of approximately $2.8 million (2021 dollars) in the triennial update to its 10 CFR 72.30(c) report (Reference 7-7). HDI will file the next BRP triennial update in 2024. For purposes of the 2022 annual 10 CFR 50.82(a)(8)(v) financial assurance status report, HDI has escalated the prior ENOI estimate into 2022 dollars. This revision to the LTP contains this financial assurance status report for the final phase of decommissioning, reference letter HDI PNP 2023-010 from Holtec Decommissioning International, LLC, to the U.S.

Nuclear Regulatory Commission -

Decommissioning Funding Status Report per 10 CFR 50.82(a)(8)(v), March 31, 2023.

Revised first paragraph, first sentence from The cost information provided in table 7-2 is constantly Decommissioning Costs and to changing as noted in the annual financial status reports 7-4 Decommissioning Costs (Historical) and and triennial updates. Therefore, it is more accurate to 7.2.2 and mark the listed costs as Historical and reference the 7-5 also added the following Note, annual cost status and triennial cost updates. Refer to Holtec Decommissioning International, LLC, Letter to the

HDI PNP 2023-015 Page 10 of 14 CHAPTER 7 - UPDATE OF SITE SPECIFIC DECOMMISSIONING COSTS Section Page Revision Basis Note: The attached ISFSI Decommissioning U.S. Nuclear Regulatory Commission, Report on Status of Costs listed in table 7-2 are based on 2012 Decommissioning Funding for Reactors and Independent dollars and are therefore considered historical. Spent Fuel Storage Installations - Holtec ISFSI Decommissioning Funding Plans, which Decommissioning International, LLC (HDI), Reference 3.

includes costs, are updated every three years in accordance with 10 CFR 72.30, Financial assurance and recordkeeping for decommissioning, paragraph (c),

10 CFR 72.30(c). The status of decommissioning funds are updated annually in accordance with 50.82(a)(8)(v).

Added (Historical) to title of table 7-2 Revised first paragraph, second sentence from Transfer of NRC License operating authority from Entergy Entergy Nuclear Palisades, LLC to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 7.2.3 7-6 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 Revised second paragraph, first sentence from Transfer of NRC License operating authority from Entergy Entergy Nuclear Palisades, LLC to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 7.2.3 7-6 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2

HDI PNP 2023-015 Page 11 of 14 CHAPTER 7 - UPDATE OF SITE SPECIFIC DECOMMISSIONING COSTS Section Page Revision Basis Revised first paragraph, first sentence from Transfer of NRC License operating authority from Entergy Entergy Nuclear Operations, Inc. to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 7.3 7-6 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 Revised second paragraph, first sentence from Transfer of NRC License operating authority from Entergy Entergy Nuclear Operations, Inc. to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 7.3 7-6 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2

HDI PNP 2023-015 Page 12 of 14 CHAPTER 7 - UPDATE OF SITE SPECIFIC DECOMMISSIONING COSTS Section Page Revision Basis Added references 7-7 References added to support Chapter 7, Section 7.1 statements.

Letter from Entergy Nuclear Operations, Inc.

(Entergy) to U.S. Nuclear Regulatory Commission, ISFSI Decommissioning Funding Plans (10 CFR 72.30), December 15, 2021 (ADAMS Accession, No. ML21349A37) and 7-8 7.4 7-7 Letter (HDI PNP 2023-010) from Holtec Decommissioning International, LLC to the U.S.

Nuclear Regulatory Commission, Report on Status of Decommissioning Funding for Reactors and Independent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 31, 2023 (ADAMS Accession No. ML23090A140)

HDI PNP 2023-015 Page 13 of 14 CHAPTER 8 - SUPPLEMENT TO THE ENVIRONMENTAL REPORT Section Page Revision Basis Revised third paragraph, third sentence from Transfer of NRC License operating authority from Entergy Entergy Nuclear Palisades, LLC to Holtec Nuclear Operations, Inc. to Holtec Decommissioning Decommissioning International, LLC (HDI) International, LLC (HDI) was approved by NRC Order 8.2 8-4 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 Revised third paragraph, fourth sentence from Transfer of NRC License operating authority from Entergy Entergy Nuclear Palisades, LLC to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 8.2 8-4 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 Revised fourth paragraph, first sentence from Transfer of NRC License from Entergy Palisades, LLC to Entergy Nuclear Palisades, LLC to Holtec Holtec Palisades, LLC was approved by NRC Order issued 8.4.1.1 8-5 Palisades, LLC (Holtec Palisades) on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2.

Revised first paragraph, first sentence from Transfer of NRC License operating authority from Entergy Entergy Nuclear Palisades, LLC to HDI Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 8.5.2.8 8-23 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2

HDI PNP 2023-015 Page 14 of 14 CHAPTER 8 - SUPPLEMENT TO THE ENVIRONMENTAL REPORT Section Page Revision Basis Revised first paragraph, fifth sentence from Transfer of NRC License operating authority from Entergy Entergys to HDIs Nuclear Operations, Inc. to Holtec Decommissioning International, LLC (HDI) was approved by NRC Order 8.5.2.8 8-23 issued on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2 Revised legend first item from Entergy to Transfer of NRC License from Entergy Palisades, LLC to Figure Holtec Palisades, LLC Holtec Palisades, LLC was approved by NRC Order issued 8-29 8-1 on 12/13/2021, Reference 1, and associated conforming amendment 129 issued on June 28, 2022, Reference 2.

Deleted Entergy from figure 8-4 title This is considered an editorial change since the property Figure 8-32 owner in 2007, Entergy is not relevant to the aerial image 8-4 of the Big Rock Point ISFSI.

REFERENCES:

1. U.S. Nuclear Regulatory Commission, Letter to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant and Big Rock Point Plant - Order Approving Transfer of Licenses and Draft Conforming Administrative License Amendments (EPID No.

L-2020-LLM-0003), NRC ADAMS Accession Package Number ML21292A155, dated December 13, 2021

2. U.S. Nuclear Regulatory Commission, Letter to Holtec Decommissioning International, LLC, Palisades Nuclear Plant and Big Rock Point Plant - Issuance of Amendments Nos. 129 and 273 RE: Order Approving Transfer of Licenses and Conforming Administrative License Amendments (EPIDs L-2022-LLM-0002 and L-2020-LLM-0003), NRC ADAMS Accession Package Number ML22173A173, dated June 28, 2022
3. Holtec Decommissioning International, LLC, Letter to the U.S. Nuclear Regulatory Commission, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), NRC ADAMS Accession Number ML23090A140, dated March 31, 2023

HDI PNP 2023-015 Enclosure 2 Big Rock Point License Termination Plan Revision 4 Replacement Pages Chapter 1 - General Information 7 Pages Follow

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023 1.3 SITE DESCRIPTION AND HISTORICAL BACKGROUND Big Rock Point ISFSI1 is located in Charlevoix County, Michigan, approximately four miles northeast of Charlevoix, Michigan, and approximately eleven miles west of Petoskey, Michigan, on the northern shore of Michigans Lower Peninsula. The BRP site is owned by Holtec Palisades, LLC (Holtec Palisades). Figure 1-1 shows the original BRP site. Figure 1-2 shows the current Big Rock Point ISFSI site. The BRP Nuclear Plant was a boiling water reactor rated at 75mW electric, designed by General Electric Company.

For the BRP Nuclear Plant, Operating License Docket No. 50-155 (License Number DPR-6) and General Independent Spent Fuel Storage Installation (ISFSI) License Docket Number 72-043, events of significance are:

Provisional Operating License issued August 30, 1962 Initial Criticality achieved September 27, 1962 Initial Power Operation achieved December 8, 1962 Commercial Operation began March 29, 1963 Full-Term Operating License issued May 1, 1964 Power level increased from 157 MWt to 240 MWt May 1964 Operation permanently ceased August 29, 1997 Fuel permanently removed from the reactor vessel September 20, 1997 All Spent Nuclear Fuel (SNF), Special Nuclear Material (SNM), and Greater Than Class C (GTCC) waste stored on an Independent Spent Fuel Storage Installation (ISFSI) on May 2, 2003 Termination of the NRC License for the power reactor and non-ISFSI related portions of the site on January 8, 2007 License transfer of the BRP ISFSI to Entergy Palisades LLC on April 6, 2007 License transfer of the BRP ISFSI to Holtec Palisades, LLC as Owner and Holtec Decommissioning International, LLC (HDI) as Operating Authority on June 28, 2022 The Post Shutdown Decommissioning Activities Report (PSDAR) was submitted in accordance with 10 CFR 50.82(a)(4) on September 19, 1997, along with other documents associated with decommissioning (Offsite Dose Calculation Manual, Defueled Technical Specifications, Defueled Emergency Plan, and Emergency Plan Exemption) [Reference 1-4]. On September 23, 1997, Consumers Energy notified the NRC of the permanent cessation of operations and the permanent removal of all fuel assemblies from the reactor pressure vessel and their placement into the spent fuel pool [Reference 1-5]. Following the cessation of operations, Consumers Energy began decommissioning BRP.

1 On April 6, 2007 the site name was changed from Big Rock Point Restoration Project to Big Rock Point Independent Spent Fuel Storage Installation (ISFSI) upon transfer of the license.

Page 1-2

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023 1.4 DECOMMISSIONING APPROACH 1.4.1 Overview This chapter provides an overview of Holtec Decommissioning International, LLC (HDI) approach to the final phase of decommissioning the BRP site. References to the chapter in the LTP, where details are provided concerning the particular step or stage of the decommissioning process, are given in parentheses. Upon the decision to permanently cease power operations at BRP in 1997, Consumers Energy began characterization activities (Chapter 2, Site Characterization). This characterization effort, performed to the guidelines of NUREG-1575, included a historical site assessment (HSA); hydrogeological investigation; and measurements, samples and analyses to further define the present radiological conditions of the site. This effort also addressed the status of the site relative to non-radioactive contamination from hazardous and other state-regulated materials.

The final phase of decommissioning activities at BRP shall be conducted in accordance with the BRP Updated Final Hazards Summary Report (UFHSR),

Defueled Technical Specifications, HDIs Decommissioning Quality Assurance Program, the existing 10 CFR Part 50 license, and the requirements of 10 CFR 50.82(a)(6) and (a)(7). If a decommissioning activity requires prior NRC approval under 10 CFR 50.59(c)(2) or a change to the BRP Defueled Technical Specifications or license, a submittal shall be made to the NRC for review and approval before implementation of the activity in question. Decommissioning activities are conducted in accordance with the BRP Defueled Technical Specifications, PSDAR, Radiation Protection Program, Off-Site Dose Calculation Manual (ODCM), and EN-IS-101, Industrial Safety and Health Program. These programs are established and available for inspection by the NRC.

Activities that will be conducted during the final phase of decommissioning will not pose any greater radiological or safety risk than those conducted during the initial phase of decommissioning. Radiological assessments of the Radiation Protection Program are performed annually pursuant to 10 CFR 20.1101(c). Radiological data compiled during the initial phase of decommissioning validated that Big Rocks PSDAR conclusion that projected dose for decommissioning fell well within NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities estimates [References 1-2 and 1-14] was accurate.

The initial site characterization, together with HSA and hydrogeological investigations, provided the basis for selection of the dose modeling scenarios and critical groups used to address possible future uses of the site. The computer code used for dose modeling calculated the Derived Concentration Guideline Levels (DCGLs) as approved in the LTP. Derived Concentration Guideline Levels correspond to a dose to the average member of the selected critical group that is as low as reasonably achievable (ALARA) and does not exceed the total effective dose equivalent (TEDE) 25 mrem/year criteria for unrestricted use (Chapter 4, Site Remediation Plan, and Chapter 6, Compliance with the Radiological Criteria for License Termination).

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BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023 The letter from the U.S. Nuclear Regulatory Commission to Consumers Energy, Big Rock Point Plant, dated March 24, 2005, Issuance of Amendment 126 to Approve the License Termination Plan demonstrated that the NRC acknowledged the land area upon which the ISFSI was constructed was radiologically non-impacted. To validate the radiological status of the ISFSI land areas prior to construction of the ISFSI, radiological surveys were performed which confirmed the non-impacted radiological status of the land area. The ISFSI was then constructed and made operational. The spent fuel and Greater Than Class C waste was then transferred from the reactor containment building to the ISFSI in accordance with the requirements of the Radiation Protection Program maintaining the radiologically non-impacted status of the ISFSI. Due to the design of the spent fuel storage system with no designed effluent pathways, it is not anticipated that the ISFSI will become radiologically impacted during ISFSI operations, and therefore, no remediation will be required to terminate the license.

HDI intends to demolish the ISFSI pad structure and release the demolition debris to a State of Michigan licensed landfill.

1.4.2 Phased Release Approach to License Termination At the time of the LTP submittal, Consumers Energy chose a phased release approach for release of land from the operating license as follows:

First Phase - Release of the majority of the site land, including non-impacted and areas impacted by power generation activities (approximately 2.281 km2 or 563.6 acres). The majority of the site land was released from the license on January 8, 2007 and, Final Phase - Release the portion of the site associated with ISFSI operations (approximately 0.1 km2 or 20 acres).

The basis of approach for the final phase of decommissioning is that the ISFSI will be operated such that it would meet the criteria of NUREG-1757, Consolidated Decommissioning Guidance Section 7.4 Group 2: Unrestricted Release Using Screening Criteria; No Decommissioning Plan Required.

NUREG-1757 provides the following:

Group 2 facilities may have residual radiological contamination present in building surfaces and soils. However, licensees are able to demonstrate that their facilities meet the provisions of 10 CFR 20.1402 (Radiological Criteria for Unrestricted Use) by applying the screening approach dose analysis described in Chapter 6.

Additionally, licensees in Group 2 typically possess historical records of material receipt, use, and disposal, such that quantifying past radiological material possession and use may be developed with a high degree of confidence.

Furthermore, these licensees have radiological survey records that characterize the residual radiological contamination levels present within the facilities and at their sites. That is, they are able to demonstrate residual radiological contamination levels Page 1-4

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023 1.5.2 Site Characterization Chapter 2 of the LTP discusses the original site characterization as it applied to potential radiological and non-radiological material contamination onsite at the time of the LTP submittal.

Based upon the original site characterization and routine radiological surveys of the ISFSI from the beginning of ISFSI operations, the land upon which the ISFSI is located continues to be classified as non-impacted (Figure 1-2). If a condition arises that changes the radiological status of the ISFSI, the land area will be appropriately characterized in accordance with the methodology previously outlined in this LTP.

Confirmation of the non-impacted status of the ISFSI area will be conducted when the spent fuel and Greater Than Class C waste is removed from the site.

1.5.3 Identification of Remaining Site Dismantlement Activities Chapter 3 of the LTP discusses identification of remaining site dismantlement activities. HDIs primary goals are to maintain the safe storage of spent fuel until transfer to the DOE, to decommission the BRP ISFSI safely, to monitor and control radiological hazards should they exist to maintain the radiological non-impacted status of the ISFSI land areas. The ISFSI will be surveyed for release and sent for disposal or recycled locally. Should there be contaminated material that cannot be decontaminated, it will be sent to an offsite radioactive waste processor or directly to a licensed low-level radioactive waste disposal site. Currently, HDI has access to a low-level waste disposal facility in Andrews, Texas.

1.5.3.1 Future Decommissioning Activities and Tasks The remaining decommissioning activities include transfer of the spent fuel and Greater Than Class C waste to the DOE, the survey and release of the concrete storage overpacks, ISFSI storage pad and cask transfer equipment; and the assessment of ISFSI operations history and radiological surveys to confirm the non-impacted status of the ISFSI land areas.

HDI continues to operate the ISFSI under a general license pursuant to10 CFR Parts 50 and 72. HDI will amend this LTP if necessary to complete decommissioning of the ISFSI once the fuel is transferred to a permanent Department of Energy storage facility.

1.5.4 Site Remediation Plans Chapter 4 of the LTP describes the various methods to be used during the BRP ISFSI decommissioning to reduce the levels of radioactivity to those which meet the NRC radiological release criteria in 10 CFR 20.1402, Radiological Criteria for Unrestricted Use. BRP intends to release the site for unrestricted use upon license termination. No post-remediation activities are anticipated. As the ISFSI will be operated to maintain a radiological non-impacted status, remediation of ISFSI land areas will not be required.

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BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023 The cost estimate focuses on the remaining work, detailed by each activity associated with the decommissioning, including the costs of labor, materials, equipment, energy, and services. The decommissioning estimate includes a comparison of estimated costs with the present funds set aside for decommissioning and a description of the means to ensure there will be sufficient funds for completing decommissioning.

Holtec Palisades, LLC owns a 100% undivided interest in the BRP ISFSI and provides financial assurance for decommissioning through the use of an external sinking fund, funded by rates that are established by cost of service ratemaking regulation. Following 35 years of electric power generation, BRP was voluntarily shut down by Consumers Energy on August 29, 1997, and immediately entered into decommissioning. In accordance with 10 CFR 50.82(a)(8)(iii), a detailed, site-specific cost estimate was prepared for Consumers Energy and docketed with the NRC in its submittal of the BRP PSDAR.

1.5.8 Supplement to the Environmental Report Chapter 8, Supplement to the Environmental Report, satisfies the requirements stated in:

10 CFR 50.82(a)(9)(ii)(G)

A supplement to the Environmental Report pursuant to 10 CFR 51.53 shall be submitted describing any new information or significant environmental change associated with the licensees proposed termination activities.

10 CFR 51.53(d)

Post operating license stage each applicant for a license amendment approving a license termination plan or decommissioning plan under paragraph 50.82 of this chapter either for unrestricted use or based on continuing use restrictions applicable to the site shall submit with its application the number of copies specified in paragraph 51.55, of a separate document, entitled Supplement to Applicants Environmental Report - Post Operating License Stage, which will update Applicants Environmental Report - Operating License Stage, as appropriate, to reflect any new information or significant environmental change associated with the proposed activities with respect to the planned storage of spent fuel.

Decommissioning activities will be accomplished with no significant adverse environmental impacts as described in Chapter 8. Decommissioning and license termination activities remain bounded by decommissioning activities described in:

The PSDAR, NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (FGEIS), and NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination on NRC Licensed Facilities [Reference 1-15].

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_ _ _ _ _ _ _ _04/15/2023 BRP LICENSE TERMINATION PLAN CHAPTER 1, GENERAL INFORMATION _

Revision 4 I

1.7 LICENSE TERMINATION PLAN INFORMATION CONTACT For information or comments regarding the BRP LTP, please contact the following party:

ISFSI Manager Big Rock Point ISFSI 10269 U.S. 31 North Charlevoix, MI 49720 231-237-2302 Page 1-10

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023 I

I I

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---=,-,- I I I NON-IMPAC TED I AREA I

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Holtec Palisades, LLC Boundary Consumers Energy Boundary Non-Impacted Area Figure 1-2. Big Rock Point ISFSI Non-Impacted Land Areas Page 1-12

HDI PNP 2023-015 Enclosure 2 (Continued)

Big Rock Point License Termination Plan Revision 4 Replacement Pages Chapter 2 - Site Characterization No changes were made to this chapter as a result of Revision 4 to the LTP.

Replace Chapter 2 Revision 3 Cover Page One Page Follows

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 2, SITE CHARACTERIZATION 04/15/2023 This chapter was compiled in April 2003 and revised in July 2004 prior to LTP approval by the NRC. It remains a historical summary of plant operational and early decommissioning characterization data.

No changes were made to this chapter as a result of Revision 4 to the License Termination Plan (LTP).

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HDI PNP 2023-015 Enclosure 2 (continued)

Big Rock Point License Termination Plan Revision 4 Replacement Pages Chapter 3 - Identification of Remaining Site Dismantlement Activities Four Pages Follow

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 3, IDENTIFICATION OF REMAINING 04/15/2023 DECOMMISSIONING ACTIVITIES 3.0 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES

3.1 INTRODUCTION

In accordance with 10 CFR 50.82 (a)(9)(ii)(B), the License Termination Plan (LTP) must identify the major dismantlement and decontamination activities. This chapter was written following the guidance of NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, and Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, and will discuss those remaining dismantlement activities as of April 6, 2007 [References 3-15 and 3-17]. Information is presented to demonstrate that these activities will be performed in accordance with10 CFR Part 50 and will not be inimical to the common defense and security or to the health and safety of the public pursuant to 10 CFR 50.82(a)(10). Information that demonstrates that these activities will not have a significant effect on the quality of the environment is provided in LTP Chapter 8, Supplement to the Environmental Report.

Holtec Decommissioning International, LLC (HDI)s primary goals are to maintain the continued safe storage of spent fuel at the Big Rock Point (BRP) Independent Spent Fuel Storage Installation (ISFSI) and to decommission the ISFSI safely after transfer of the spent fuel and Greater Than Class C (GTCC) waste. As of May 2, 2003, all spent nuclear fuel, special nuclear material, and Greater Than Class C waste material was relocated to the ISFSI from the spent fuel pool. HDI will decontaminate and dismantle the ISFSI facility in accordance with the DECON alternative, as described in NUREG-0586, Final Generic Environmental Impact Statement (FGEIS)

[Reference 3-12].

Decommissioning activities at BRP shall be conducted as discussed in this LTP and in accordance with the Defueled Technical Specifications, HDIs Decommissioning Quality Assurance Program (DQAP), the BRP 10 CFR Part 50 license, and the requirements of 10 CFR 50.82(a)(6) and (a)(7). If an activity requires prior NRC approval under 10 CFR 50.59(c)(2) or a change to the BRP Defueled Technical Specifications or license, a submittal shall be made to the NRC for review and approval before implementation of the activity in question.

Activities conducted during decommissioning will not pose any greater radiological or safety risk than those conducted during former plant operations. Decommissioning activity radiological risk is bounded by previously analyzed radiological risk for former operating activities that occurred during major maintenance and outage evolutions.

The activities described in Section 3.4 include future decommissioning activities of the ISFSI site. Table 3-1 contains a list of future decommissioning activities to be performed by HDI or its contractors.

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BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 3, IDENTIFICATION OF REMAINING 04/15/2023 DECOMMISSIONING ACTIVITIES 3.2 DECOMMISSIONING OVERVIEW Decommissioning activities for the former power reactor and associated land areas were initiated following the decision to permanently cease BRP power operations on August 29, 1997. At that time, BRP performed evaluations of major plant structures, systems, and components (SSCs) to determine what function, if any, these SSCs would be expected to perform during decommissioning. Each major plant SSC was evaluated to determine if the SSC, in its entirety or any portion thereof, was important for the safe storage of the spent fuel (ISSSF), was important for the monitoring and control of radiological hazards (IMCRH), or was needed to perform a function during the decommissioning and decontamination (D&D) of the plant.

Big Rock Point administrative procedures specify the standard methods of accomplishing plant activities and processes. They are the documents used to implement the requirements of the DQAP. This DQAP ensures that BRP complies with the requirements of 10 CFR 50, Appendix B for quality assurance. Examples of administrative processes controlled by procedures include: ALARA (as low as reasonably achievable) reviews, radiation protection (including airborne and contamination control), effluent and environmental monitoring, radioactive waste processing (including transportation and release requirements), safety programs, control of design basis (modification and work package procedures), and final status surveys.

A work control process is applied for decommissioning to document work performed and apply plant processes and controls to the activities. If a decommissioning activity requires NRC review pursuant to 10 CFR 50.59, an amendment to the BRP Defueled Technical Specifications (DTS) or license will be submitted. As of June 12, 2013, NRC review for BRP license amendments associated with decommissioning activities included the following:

Amendment 120, December 24, 1998. Approval of the Defueled Technical Specifications (DTS).

Amendment 121, January 13, 2000. Deletion of the definition of site boundary and removal of site map.

Amendment 122, September 28, 2001. DTS reflected control of heavy loads, spent fuel handling considerations, and installation of a single-failure proof crane.

Amendment 123, July 18, 2002. License was revised to include the approved ISFSI Security Plan reference.

Amendment 124, September 11, 2002. Addition of Spent Fuel Pool applicability statements.

Amendment 125, March 19, 2004. Issuance of Amendment Related to the Transfer of all Spent Fuel Storage from the Spent Fuel Pool into Dry Cask Storage.

Amendment 126, March 24, 2005. Approval of the License Termination Plan.

Amendment 127, April 11, 2007. Approval of Transfer of Facility Operating License No. DPR-06.

Amendment 129, December 13, 2021. Approval of Transfer of Facility Operating License No. DPR-06 to Holtec Palisades, LLC and Operating Authority to Holtec Decommissioning International, LLC.

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BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 3, IDENTIFICATION OF REMAINING 04/15/2023 DECOMMISSIONING ACTIVITIES 3.3 COMPLETED DECOMMISSIONING ACTIVITIES AND TASKS 3.3.1 Summary Consumers Energy completed the first phase of decommissioning for the BRP power reactor and associated land areas with notification that the NRC approved release of this land from the BRP license on January 8, 2007 (Reference 3-20).

3.3.2 Description of Completed Activities Consumers Energy completed decommissioning activities in accordance with the License Termination Plan as approved by Amendment 126 dated March 24, 2005, Approval of the License Termination Plan.

3.4 REMAINING DECOMMISSIONING ACTIVITIES The focus of this section is on the demolition of the BRP ISFSI structures. Table 3-1 is a list of future decommissioning activities planned at the BRP ISFSI. The activities listed are intended to provide an overview of the remaining decommissioning activities and an estimated time schedule for those activities.

There is no intent to revise this LTP when schedule changes occur. Schedules provided in this section are for general guidance and illustrative purposes only.

Current schedules will be finalized upon notification by the Department of Energy of intent to receive the spent fuel and Greater Than Class C waste. The assumptions and philosophy of HDI for the remaining BRP demolition activities are as follows:

General demolition activities are consistent with clean-to-dirty approach.

Demolition activities in open areas involving structures with known or suspected contamination require radiological control and isolation to prevent cross- or re-contamination by air or water pathways.

Excavated locations may remain open to support ongoing work.

Groundwater and surface water control measures are required for all excavations where the potential exists for migration of radioactive or hazardous materials.

Final Status Survey (FSS) will not be required for license termination.

Table 3-1. Remaining Decommissioning Activities Activity Projected Date Transport Fuel to DOE Repository 1st Quarter Verify Radiological Non-Impacted Status of Facility 1st Quarter NRC/ORISE Verification of Radiological Non-Impacted Status 1st Quarter Demolish ISFSI Structures 2nd Quarter Dispose of Demolition Debris 2nd Quarter Terminate License 3rd Quarter Page 3-3

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 3, IDENTIFICATION OF REMAINING 04/15/2023 DECOMMISSIONING ACTIVITIES 3.4.1 Decontamination and Demolition of Structures HDI intends to operate the BRP ISFSI such that it will maintain its radiological non-impacted status. Therefore, decontamination activities are not expected.

Should minor diffuse contamination be identified, the standard industry decontamination methods including wiping, washing, vacuuming, scabbling, spalling, and abrasive blasting will be employed. Selection of the preferred method is based on the specific situation and appropriate radiological controls necessary to protect the workforce and environment, and to maintain the radiological non-impacted status of the ISFSI land areas. Structures or portions of structures that cannot be sufficiently decontaminated will be disposed of as radioactive waste. Approved administrative procedures and processes control decontamination activities. These controls ensure that wastewater is collected and airborne contamination controls are used, as necessary, and all releases are monitored.

3.4.1.1 Demolition Debris Disposal Clean demolition debris will be disposed of at a State of Michigan licensed landfill.

Any radiologically contaminated debris that may be generated will be disposed of at a facility licensed to receive radioactive waste.

3.5 CURRENT RADIOLOGICAL STATUS AND EXPOSURE ESTIMATES 3.5.1 Occupational Exposure The cumulative occupational exposure for the first phase of decommissioning was less than the 700 to 1600 person-rem estimate of NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities

[Reference 3-12]. The occupational exposure operating history for the BRP ISFSI since release from the license of the former power reactor and associated land areas is an average of 0 person-rem per year. The estimated total nuclear worker exposure for the remaining decommissioning activities is estimated to be less than 1 person-rem.

3.5.2 Public Exposure Continued application of BRPs Radiation Safety Program, Radiological Effluent Technical Specification Program, and Radiological Environmental Monitoring Program assures public protection in accordance with 10 CFR Part 20 and 10 CFR Part 50, Appendix I. Environmental monitoring data provides that there has been no public exposure due to ISFSI operations. There is no expected public exposure expected due to the remaining decommissioning activities.

3.5.3 Estimate of Quantity of Radioactive Material to be Shipped for Disposal or Processing HDI intends to operate the BRP ISFSI such that it will maintain its radiological non-impacted status. Therefore, the estimate of the quantity of radioactive material to be shipped is 0 cubic feet.

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HDI PNP 2023-015 Enclosure 2 (Continued)

Big Rock Point License Termination Plan Revision 4 Replacement Pages Chapter 4 - Site Remediation Plan No changes were made to this chapter as a result of Revision 4 to the LTP.

Replace Chapter 4 Revision 3 Cover Page One Page Follows

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 4, SITE REMEDIATION PLAN 04/15/2023 This chapter provides the site remediation plan, actions, impact of the radiation protection program, and an as low as reasonably achievable (ALARA) evaluation.

No changes were made to this chapter as a result of Revision 4 to the License Termination Plan (LTP).

TABLE OF CONTENTS 4.0 SITE REMEDIATION PLAN ....................................................................................... 1

4.1 INTRODUCTION

......................................................................................................... 1 4.2 REMEDIATION ACTIONS .......................................................................................... 1 4.2.1 Structures, Systems and Components ................................................................... 1 4.2.2 Soil and Water ........................................................................................................... 2 4.3 REMEDIATION ACTIVITY IMPACT ON THE RADIATION PROTECTION PROGRAM.................................................................................................................. 2 4.3.1 Commitment to Radiation Protection Procedures ................................................. 2 4.4 ALARA EVALUATION ............................................................................................... 2

4.5 REFERENCES

............................................................................................................ 4 Page 4-i

HDI PNP 2023-015 Enclosure 2 (continued)

Big Rock Point License Termination Plan Revision 4 Replacement Pages Chapter 5 - Final Status Survey Plan One Page Follows

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 5, FINAL STATUS SURVEY PLAN 04/15/2023 5.0 FINAL STATUS SURVEY PLAN

5.1 INTRODUCTION

The Big Rock Point (BRP) Final Status Survey (FSS) Plan was prepared for the initial phase of decommissioning using the applicable regulatory and industry guidance. The plan was used to develop the site procedures and work instruction used to perform the FSS of the BRP site.

5.1.1 Purpose The initial phase of the decommissioning FSS Plan described the final survey process used to demonstrate that the BRP site complied with radiological criteria for unrestricted use specified in 10 CFR 20.1402, i.e., annual dose limit of 25 mrem plus ALARA for all dose pathways. Nuclear Regulatory Commission (NRC) regulations applicable to radiation surveys are found in 10 CFR 50.82(a)(9)(ii)(D) and 10 CFR 20.1501(a) and (b).

5.1.2 Scope Big Rock Point has been approved to release the site land using a phased approach.

The first phase included the majority of the site land which was released from the NRC License. The second and final phase of site release includes the Independent Spent Fuel Storage Installation (ISFSI) following spent fuel removal and facility dismantlement. Once both these phases are complete the BRP site license under 10 CFR Part 50 will be terminated. It is possible that release of non-impacted portions of the site could occur prior to completing demolition activities, should Holtec Decommissioning International, LLC management decide accordingly.

The FuelSolutionsTM W74 Canister Storage Final Safety Analysis Report, Chapter 7, Confinement, provides that confinement of all radioactive materials in the FuelSolutionsTM Storage System is provided by a FuelSolutionsTM canister. The design of the FuelSolutionsTM W74 canister confinement boundary assures that there are no credible design basis events that would result in a radiological release to the environment.

Due to the design of the spent fuel storage system with no designed effluent pathways it is not anticipated that the ISFSI will become radiologically impacted during ISFSI operations, thus it is anticipated that remediation and FSS will not be necessary to release the site from the NRC License.

Therefore, the basis approach for the final phase of decommissioning is that the ISFSI will be operated such that it would meet the criteria of NUREG-1757, Consolidated Decommissioning Guidance, Section 7.4, Group 2: Unrestricted Release Using Screening Criteria; No Decommissioning Plan Required.

5.2 REFERENCES

5-1 Letter from U.S. Nuclear Regulatory Commission to Consumers Energy, Big Rock Point - Release of Land from Part 50 License for Unrestricted Use, January 8, 2007 Page 5-1

HDI PNP 2023-015 Enclosure 2 (Continued)

Big Rock Point License Termination Plan Revision 4 Replacement Pages Chapter 6 - Compliance with the Radiological Criteria for License Termination No changes were made to this chapter as a result of Revision 4 to the LTP.

Replace Chapter 6 Revision 3 Cover Page One Page Follows

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 6, COMPLIANCE WITH THE RADIOLOGICAL 04/15/2023 CRITERIA FOR LICENSE TERMINATION This chapter provides the basis for the dose models used to develop site-specific DCGLs as approved by the NRC on March 24, 2005.

No changes were made to this chapter as a result of Revision 4 to the License Termination plan (LTP).

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HDI PNP 2023-015 Enclosure 2 (continued)

Big Rock Point License Termination Plan Revision 4 Replacement Pages Chapter 7 - Update of Site Specific Decommissioning Costs 6L[Pages Follow

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 04/15/2023 DECOMMISSIONING COSTS 7.0 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS

7.1 INTRODUCTION

In accordance with 10 CFR 50.82(a)(9)(ii)(F), Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Plants, and 10 CFR 72.30, Financial Assurance and Recordkeeping for Decommissioning, the site-specific cost estimate and funding plans are provided in this chapter.

The License Termination Plan (LTP) must:

Provide an estimate of the remaining decommissioning costs and compare the estimated costs with the present funds set aside for decommissioning. The financial assurance instrument required per 10 CFR 72.30(e)(2) must be funded to the amount of the cost estimate. If there is a deficit in present funding, the LTP must indicate the means for ensuring adequate funds to complete the decommissioning.

The decommissioning cost estimate should include an evaluation of the proposed practices and procedures for the decontamination of the site and facilities, and for disposal of residual radioactive materials after all spent fuel, high-level radioactive waste, and reactor-related Greater Than Class C (GTCC) waste have been removed in order to provide reasonable assurance that the decontamination and decommissioning of the ISFSI at the end of its useful life will provide adequate protection to the health and safety of the public.

Holtec Palisades, LLC (Holtec Palisades) owns a 100% undivided interest in the Big Rock Point (BRP) Independent Spent Fuel Storage Installation (ISFSI) and provides financial assurance for decommissioning through the use of a Parent Company Guarantee.

Following 35 years of electric power generation, BRP was voluntarily shut down by Consumers Energy on August 29, 1997, and immediately entered into decommissioning. In accordance with 10 CFR 50.82(a)(8)(iii), a detailed site-specific cost estimate was prepared by TLG Services for Consumers Energy and docketed with the NRC in its submittal of the BRP Post Shutdown Decommissioning Activities Report (PSDAR) [References 7-2 and 7-1]. Pursuant to State of Michigan requirements to prepare and file decommissioning cost estimate updates with the Michigan Public Service Commission (MPSC) at three-year intervals, an estimate update was prepared by TLG Services in 2000 and filed in March 2001 as a follow-up to a site-specific decommissioning cost estimate filed with the MPSC in March 1998 [References 7-2 and 7-3]. Since the submittal of the LTP, Consumers Energy, in compliance with State of Michigan requirements, contracted TLG Services to prepare an estimate update in 2003. This update was filed with the MPSC in March 2004, and served as the cost basis for Revision 2 of the LTP [Reference 7-4].

Consumers Energy completed the first phase of decommissioning and subsequently received NRC approval to release from the license the power reactor and associated land areas. The NRC license for the BRP ISFSI and associated land areas was subsequently transferred to Entergy Nuclear Palisades, LLC in 2007 and then to Holtec Palisades, LLC in 2022. In December 2021, after submission of the license Page 7-1

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 04/15/2023 DECOMMISSIONING COSTS application but before transfer of the BRP license to HDI, Entergy filed an updated cost estimate of approximately $2.8 million (2021 dollars) in the triennial update to its 10 CFR 72.30(c) report, Reference 7-7. HDI will file the next BRP triennial update in 2024. For purposes of the 2022 annual 10 CFR 50.82(a)(8)(v) financial assurance status report, HDI has escalated the prior ENOI estimate into 2022 dollars, Reference 7-8. This revision to the LTP contains this financial assurance status report for the final phase of decommissioning, reference letter HDI PNP 2023-010 from Holtec Decommissioning International, LLC, to the U.S. Nuclear Regulatory Commission - Decommissioning Funding Status Report per 10 CFR 50.82(a)(8)(v),

March 31, 2023.

7.2 DECOMMISSIONING COST ESTIMATE 7.2.1 Cost Estimate Description and Methodology The methodology used to develop the cost estimate is as described in 10 CFR 72.30(c). The estimate considers (1) Spills of radioactive material producing additional residual radioactivity in on site subsurface material; (2) Facility modifications; (3) Changes in authorized possession limits; and (4) Actual remediation costs that exceed the previous cost estimate.

Table 7-1, Significant Quantities and Physical Dimensions provides the estimates of the total radioactive waste and clean debris based upon the following key assumptions:

x Decommissioning estimate is based on the current configuration of the ISFSI.

x Due to the design of the storage system, no radioactive surface contamination is expected.

x Two of the seven spent fuel overpacks contain low levels of neutron-induced residual radioactivity that would necessitate remediation.

x A small portion of the ISFSI pad (directly underneath the two overpacks) will be activated to a level that would require remediation.

x Prior to ISFSI pad construction, the existing soils and imported fill soils were verified to be radiologically non-impacted.

x Low-level radioactive waste disposal costs are based upon Entergys negotiated rates.

x Decommissioning will be performed by an independent contractor.

x Contingency has been added at an overall rate of 25% consistent with the contingency evaluation criteria referenced in NUREG-1757.

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BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 04/15/2023 DECOMMISSIONING COSTS 7.2.2 Summary of the Site-Specific Decommissioning Cost Estimate Table 7-2, ISFSI Decommissioning Costs (Historical) and Waste Volumes provides the site-specific cost estimate with the 25% contingency.

Note: The attached ISFSI Decommissioning Costs listed in table 7-2 are based on 2012 dollars and are therefore considered historical. ISFSI Decommissioning Funding Plans, which includes costs, are updated every three years in accordance with 10 CFR 72.30, Financial assurance and recordkeeping for decommissioning, paragraph (c), 10 CFR 72.30(c). The status of decommissioning funds are updated annually in accordance with 50.82(a)(8)(v).

Page 7-4

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 04/15/2023 DECOMMISSIONING COSTS Table 7-2. ISFSI Decommissioning Costs (Historical) and Waste Volumes Costs Waste (thousands, 2012 dollars) Volume Person-Hours NRC / NRC Removal Packaging Transport Disposal Other Total (ft3) Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 146 146 - 928 - -

Decontamination/Demolition (activated liner removal) 13 4 27 72 53 170 1,282 116 - -

License Termination (radiological surveys) - - - - 446 446 - 3,574 - -

Subtotal 13 4 27 72 645 762 1,282 4,618 - -

Supporting Costs NRC and NRC Contractor Fees and Costs - - - - 209 209 - - - 776 Insurance - - - - 34 34 - - - -

Security (industrial) - - - - 94 94 - 2,479 - -

Entergy Oversight Staff - - - - 141 141 - - 1,881 -

Subtotal - - - - 478 478 - 2,479 1,881 776 Total (w/o contingency) 13 4 27 72 1,123 1,240 1,282 7,097 1,881 776 Total (w/25% contingency) 16 6 34 91 1,404 1,550 - - - -

Page 7-5

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 07/15/2023 DECOMMISSIONING COSTS 7.2.3 Spent Fuel Management Completion of the BRP final phase of decommissioning is dependent upon the DOEs ability to remove spent fuel from the site. Until that time, HDI will continue to operate the ISFSI, which was constructed for interim storage of the spent fuel, in accordance with license requirements.

Similar to non-radiological site restoration costs, HDI recognizes that the costs to operate an ISFSI and other spent fuel related costs fall outside the NRC definition of decommissioning. Therefore, those costs are not included within the estimates provided herein.

7.3 DECOMMISSIONING FUNDING

PLAN HDI, in compliance with 10 CFR 72.30(e)(2) [Reference 7-5], provides financial assurance for the decommissioning of the BRP ISFSI through the use of a Parent Company Guarantee.

As demonstrated in their recent submittal of the Financial Test for Decommissioning Funding Parent Guarantee, HDI [Reference 7-6] provides decommissioning assurance in the amount of $5 million for the NRC radiological decommissioning costs.

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BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 07/15/2023 DECOMMISSIONING COSTS

7.4 REFERENCES

7-1 Big Rock Point Post Shutdown Decommissioning Activities Report (PSDAR),

Revision 2, March 26, 1998 7-2 TLG Services, Inc., Decommissioning Cost Study for the Big Rock Point Nuclear Plant, March 26, 1998 7-3 TLG Services, Inc., Decommissioning Cost Study for the Big Rock Point Nuclear Plant, March 22, 2001 7-4 TLG Services, Inc., Decommissioning Cost Update for the Big Rock Point Nuclear Plant, March 22, 2004 7-5 Letter (ENOC-12-00039) from Entergy Nuclear Operations, Inc. to the U.S. Nuclear Regulatory Commission - ISFSI Decommissioning Funding Plans (10 CFR 72.30),

December 13, 2012 7-6 Letter (ENOC-13-00009) from Entergy Nuclear Operations, Inc. to the U.S. Nuclear Regulatory Commission - Financial Test for Decommissioning Funding Parent Guarantee for the year ending December 31, 2012, March 29, 2013 7-7 Letter from Entergy Nuclear Operations, Inc. (Entergy) to U.S. Nuclear Regulatory Commission, ISFSI Decommissioning Funding Plans (10 CFR 72.30),

December 15, 2021 (ADAMS Accession, No. ML21349A37) 7-8 Letter (HDI PNP 2023-010) from Holtec Decommissioning International, LLC to the U.S. Nuclear Regulatory Commission, Report on Status of Decommissioning Funding for Reactors and Independent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 31, 2023 (ADAMS Accession No. ML23090A140)

Page 7-7

HDI PNP 2023-015 Enclosure 2 (continued)

Big Rock Point License Termination Plan Revision 4 Replacement Pages Chapter 8 - Supplement to the Environmental Report Five Pages Follow

BRP LICENSE TERMINATION PLAN Revision 4

_ _ _ _ _ _ _ _04/15/2023 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT _ I termination activities planned at BRP. This additional information forms the basis for the conclusions provided in Section 8.7.

8.2 SITE DESCRIPTION AFTER UNRESTRICTED RELEASE This section presents a summary of the final condition of the site at the conclusion of the final phase of decommissioning and license termination activities.

At the time of license termination, the site will meet the radiological criteria for unrestricted release as defined in 10 CFR 20.1402, in addition to applicable State of Michigan criteria for release of the site.

The only site buildings now in existence were constructed to support Dry Fuel Storage. These buildings have associated utilities (electric, phone, sanitary) which were installed to support the ISFSI. The BRP ISFSI will be demolished and Holtec Decommissioning International, LLC (HDI) will determine the disposition of the support buildings and utilities at the time of final phase dismantlement. HDI will determine the use of the ISFSI and associated land areas after license termination.

Consumers Energy retains ownership of the former power reactor and associated land areas and will determine the future use of that site.

8.3 PSDAR UPDATE FOR REMAINING DISMANTLEMENT AND DECONTAMINATION ACTIVITIES The License Termination Plan, Chapter 3 identifies and details the remaining final phase dismantlement activities that are scheduled to be completed in support of license termination and unrestricted release. These activities have been compared to the descriptions provided in the PSDAR with no changes identified.

8.3.1 Post-Shutdown Decommissioning Activities Report Description The BRP PSDAR was submitted to the NRC under the provisions of 10 CFR 50.82(a)(7). The PSDAR described planned decommissioning activities, a schedule for their accomplishment, estimate of expected decommissioning costs, and provided the basis for concluding the environmental impacts associated with site-specific decommissioning activities will be in compliance with 10 CFR 50.82(a)(6)(ii) [Reference 8-12]. Consumers Energy Co. dismantled the BRP power reactor and associated land areas in accordance with the DECON option found acceptable to the NRC in its FGEIS.

Page 8-4

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 04/15/2023 8.3.2 Impacts of Decommissioning Activities The final phase decommissioning requirements are incorporated into the LTP, as approved by the NRC, and into site procedures and programs, as necessary

[Reference 8-39]. Subsequent sections in this chapter of the LTP provide additional information regarding environmental effects of the final phase of decommissioning.

8.4 BIG ROCK POINT SITE ENVIRONMENTAL DESCRIPTION The information contained in this section is a summary based on the BRP ER developed for decommissioning [Reference 8-7]. The purpose of this section is to provide an overview of the site and regional environmental information. In general, the information contained in this section is derived directly from the ER, where new or different information is provided; the appropriate reference is also included.

8.4.1 Geography and Demography 8.4.1.1 Site Location Description The BRP ISFSI site is located near the northeast shore of Lake Michigan in Charlevoix County in the northern part of Michigan's Lower Peninsula. The site is approximately 60 miles northeast of Traverse City, Michigan, and 225 miles north-northwest of Detroit. The closest population centers are the cities of Charlevoix, 3.5 miles southwest, and Petoskey, 11 miles east of the ISFSI site. The site is owned by Holtec Palisades, LLC (Holtec Palisades) and occupies approximately 107 acres (0.433 km2). Figure 8-1 depicts the property boundaries and Owner-Controlled Area at the time the LTP was submitted and Figure 8-2 shows the current site boundaries and the ISFSI area. Figure 8-3 shows an aerial view of the BRP site and surrounding land prior to the first phase of decommissioning and Figure 8-4 shows an aerial view of the BRP ISFSI site and surrounding land. The Owner-Controlled Area is identical to plant property boundaries.

Page 8-5

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 04/15/2023 Reasonable control measures will be utilized to minimize the quantities of fugitive dust. Excavation of soils and concrete demolition may include the use of wet suppression to minimize the generation of fugitive dust.

The controlled dismantlement and packaging of the ISFSI pad and concrete storage casks will preclude fugitive dust from becoming an ambient air quality concern during the final phase of decommissioning. The closest national ambient air quality Category 1 area is the Seney National Wildlife Refuge located approximately 70 miles northwest of the BRP site. The location of the Seney National Wildlife Preserve is generally considered upwind of the prevailing wind direction. There are no Category 1 areas within 100 miles downwind of the BRP site.

8.5.2.5 Aquatic Ecology No adverse impacts to the aquatic flora or fauna are anticipated from the final phase of decommissioning activities as the activities will not adjoin Lake Michigan and the beachfront.

8.5.2.6 Terrestrial Ecology No additional land area is expected to be utilized to complete decommissioning.

Therefore, no additional impacts to site flora and fauna are anticipated.

8.5.2.7 Threatened and Endangered Species No adverse impact to any identified species is anticipated since they are not present in locations expected to be impacted by decommissioning activities. Prior to initiation of any decommissioning activities that could potentially affect endangered shoreline species, additional surveys will be conducted using up-to-date listings to identify the existence of threatened or endangered species near areas that may be impacted.

8.5.2.8 Occupational Safety HDI is committed to the safe decommissioning of BRP. The Safety Program provides the basis for controlling safety during decommissioning activities. The primary objective of the Safety Program is to protect workers and visitors from industrial hazards that have the potential of developing during decommissioning activities and to achieve an injury and incident-free workplace. The Safety Program establishes and maintains a safe workplace for workers, contractors, and visitors through procedures and guidelines to be used to reduce industrial hazards and risks.

HDIs Industrial Safety and Health Program defines specific programs and requirements to ensure worker protection [Reference 8-3].

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BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 04/15/2023 CD I.AKE: MICHIGAN

( PrOltU

/

/ /

/ ,,..... ..._ _ _ _..J

- - - Ho/lee Palisades, LLC Property Boundary

- - Consumers Energy Property Boundary Figure 8-1. Big Rock Point Site Boundary Map Page 8-29

BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 04/15/2023 Figure 8-4. Aerial Image of Big Rock Point ISFSI (As of 2007)

Page 8-32

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