|
|
Line 26: |
Line 26: |
|
| |
|
| ==Dear Mr. Bakken III:== | | ==Dear Mr. Bakken III:== |
| By letter dated February 9, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17045A140), Entergy Nuclear Operations, Inc. (ENOI), Entergy Nuclear Vermont Yankee, LLC (ENVY), NorthStar Vermont Yankee, LLC (NorthStar VY), and NorthStar Nuclear Decommissioning Company, LLC (NorthStar NDC) (together, Applicants)submitted an application for direct and indirect license transfers for Vermont Yankee Nuclear Power Station (VY) from ENOI and ENVY to NorthStar NDC and NorthStar VY. Specifically the Applicants requested written consent to transfer the Vermont Yankee Renewed Facility Operating License No. DPR-28 and the generally licensed Independent Spent Fuel Storage Installation to the named entities. | | By letter dated February 9, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17045A140), Entergy Nuclear Operations, Inc. (ENOI), Entergy Nuclear Vermont Yankee, LLC (ENVY), NorthStar Vermont Yankee, LLC (NorthStar VY), and NorthStar Nuclear Decommissioning Company, LLC (NorthStar NDC) (together, Applicants) submitted an application for direct and indirect license transfers for Vermont Yankee Nuclear Power Station (VY) from ENOI and ENVY to NorthStar NDC and NorthStar VY. Specifically the Applicants requested written consent to transfer the Vermont Yankee Renewed Facility Operating License No. DPR-28 and the generally licensed Independent Spent Fuel Storage Installation to the named entities. |
| The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific requests are found in the enclosed request for additional information (RAI). The NRC staff requests that a response to the RAIs be provided within 30 days of the date of this letter. | | The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific requests are found in the enclosed request for additional information (RAI). The NRC staff requests that a response to the RAIs be provided within 30 days of the date of this letter. |
|
| |
|
Letter Sequence RAI |
---|
EPID:L-2017-LLM-0002, Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment and Notification of Amendment to Decommissioning Trust Agreement (Approved, Closed) |
|
MONTHYEARBVY 17-005, Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment and Notification of Amendment to Decommissioning Trust Agreement2017-02-0909 February 2017 Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment and Notification of Amendment to Decommissioning Trust Agreement Project stage: Request BVY 17-027, Supplemental Information Regarding Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment and Notification of Amendment ...2017-08-22022 August 2017 Supplemental Information Regarding Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment and Notification of Amendment ... Project stage: Supplement BVY 17-028, Notification of Schedule Change for Preparations for Dismantling and Decontamination2017-08-28028 August 2017 Notification of Schedule Change for Preparations for Dismantling and Decontamination Project stage: Request ML17313A4312017-11-0303 November 2017 NRC Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar Project stage: RAI BVY 17-043, Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar2017-12-0404 December 2017 Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar Project stage: Response to RAI ML18009A4592017-12-22022 December 2017 Supplemental Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar Project stage: Supplement ML18066A0442018-03-0202 March 2018 March 2, 2018 Vermont Yankee Settlement Agreement Project stage: Request ML18143B4842018-05-21021 May 2018 Submittal of Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar Project stage: Response to RAI BVY 18-016, Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar for the Vermont Yankee Nuclear Power Station2018-05-21021 May 2018 Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar for the Vermont Yankee Nuclear Power Station Project stage: Response to RAI ML18150A3152018-05-25025 May 2018 Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) Project stage: Request ML18183A2202018-06-28028 June 2018 Supplemental Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar Project stage: Supplement ML18242A6382018-10-11011 October 2018 Approval of License Transfer Request Project stage: Request ML18249A3572018-10-11011 October 2018 Letter Approving License Transfer Request (License DPR-28, Docket Nos. 50-271 and 72-59) Project stage: Other ML18249A3232018-10-11011 October 2018 Letter Approving License Transfer Request (License DPR-28, Docket Nos. 50-271 and 72-59) Project stage: Other BVY 18-044, Notification of Amendment to Decommissioning Trust Agreement2018-12-0707 December 2018 Notification of Amendment to Decommissioning Trust Agreement Project stage: Other ML18347B3582019-01-11011 January 2019 Conforming License Amendment for Direct and Indirect License Transfer. Amendment No. 271 to License No. DPR-28 (License DPR-28, Docket Nos. 50-271 and 72-59) Project stage: Request ML18347B3602019-01-11011 January 2019 Letter: Vermont Yankee Nuclear Power Station - Issuance of Amendment Application for Order Approving Direct and Indirect Transfer of Renewed Facility Operating License and Independent Spent Fuel Storage Installation General License. Project stage: Approval ML18347B3592019-01-11011 January 2019 12-13-18-License Transfer Conforming Amendment Markup Project stage: Other ML18353B4982019-01-15015 January 2019 Issuance of Amendment No. 14 to Indemnity Agreement No. B-49 (License DPR-28, Docket Nos. 50-271 and 72-59) Project stage: Approval 2018-10-11
[Table View] |
|
---|
Category:Letter
MONTHYEARBVY 24-005, Report of Investigation Pursuant to 10 CFR 20, Appendix G2024-01-30030 January 2024 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 24-004, Report of Investigation Pursuant to 10 CFR 20, Appendix G2024-01-23023 January 2024 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 24-003, Nuclear Onsite Property Damage Insurance2024-01-0404 January 2024 Nuclear Onsite Property Damage Insurance BVY 24-001, Pre-Notice of Disbursement from Decommissioning Trust2024-01-0202 January 2024 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-030, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-12-20020 December 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-029, Proof of Financial Protection2023-12-12012 December 2023 Proof of Financial Protection BVY 23-028, Pre-Notice of Disbursement from Decommissioning Trust2023-11-28028 November 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-027, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-11-21021 November 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-026, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-11-13013 November 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-025, Pre-Notice of Disbursement from Decommissioning Trust2023-11-0202 November 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-023, License Amendment Request Addition of License Condition 3.K, License Termination Plan; Proposed Change No. 3172023-10-10010 October 2023 License Amendment Request Addition of License Condition 3.K, License Termination Plan; Proposed Change No. 317 IR 07200059/20234012023-10-0505 October 2023 Independent Spent Fuel Storage Installation Security Inspection Report 07200059/2023401 BVY 23-022, Pre-Notice of Disbursement from Decommissioning Trust2023-08-23023 August 2023 Pre-Notice of Disbursement from Decommissioning Trust IR 05000271/20230012023-08-15015 August 2023 Northstar Nuclear Decommissioning Company, Llc., Vermont Yankee Nuclear Power Station, - NRC Inspection Report 05000271/2023001 BVY 23-021, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-08-0202 August 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-020, Pre-Notice of Disbursement from Decommissioning Trust2023-08-0202 August 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-019, Update to 2022 Radiological Effluent Release Report2023-07-24024 July 2023 Update to 2022 Radiological Effluent Release Report BVY 23-018, Update to Nuclear Onsite Property Damage Insurance2023-07-12012 July 2023 Update to Nuclear Onsite Property Damage Insurance BVY 23-017, Pre-Notice of Disbursement from Decommissioning Trust2023-06-29029 June 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-015, Report of Investigation Pursuant to 1O CFR 20, Appendix G2023-06-0505 June 2023 Report of Investigation Pursuant to 1O CFR 20, Appendix G BVY 23-016, 10 CFR 72.48 Report2023-06-0505 June 2023 10 CFR 72.48 Report BVY 23-014, Pre-Notice of Disbursement from Decommissioning Trust2023-05-31031 May 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-013, 2022 Radiological Environmental Operating Report2023-05-10010 May 2023 2022 Radiological Environmental Operating Report BVY 23-011, 2022 Radiological Effluent Release Report2023-05-10010 May 2023 2022 Radiological Effluent Release Report BVY 23-012, Pre-Notice of Disbursement from Decommissioning Trust2023-05-0202 May 2023 Pre-Notice of Disbursement from Decommissioning Trust ML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment BVY 23-009, 2022 Individual Monitoring NRC Form 5 Report2023-04-24024 April 2023 2022 Individual Monitoring NRC Form 5 Report BVY 23-008, Pre-Notice of Disbursement from Decommissioning Trust2023-04-0606 April 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 23-007, Report of Investigation Pursuant to 10 CFR 20, Appendix G2023-03-29029 March 2023 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 23-006, Status of Decommissioning and Spent Fuel Management Fund for Year Ending 20222023-03-29029 March 2023 Status of Decommissioning and Spent Fuel Management Fund for Year Ending 2022 BVY 23-005, Nuclear Onsite Property Damage Insurance2023-03-13013 March 2023 Nuclear Onsite Property Damage Insurance BVY 23-004, Pre-Notice of Disbursement from Decommissioning Trust2023-03-0202 March 2023 Pre-Notice of Disbursement from Decommissioning Trust ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities IR 05000271/20220022023-02-22022 February 2023 Northstar Nuclear Decommissioning Company, LLC, Vermont Yankee Nuclear Power Station - NRC Inspection Report No. 05000271/2022002 BVY 23-003, Pre-Notice of Disbursement from Decommissioning Trust2023-01-31031 January 2023 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-030, Documentary Evidence of Performance Bond2022-12-30030 December 2022 Documentary Evidence of Performance Bond ML22347A2792022-12-21021 December 2022 Independent Spent Fuel Storage Installation Security Inspection Plan Dated December 21, 2022 IR 05000271/20224012022-12-15015 December 2022 NRC Inspection Report No. 05000271/2022401, Northstar Nuclear Decommissioning Company, LLC, Vermont Yankee Nuclear Power Station, Vernon, Vermont (Letter Only) BVY 22-028, Re Proof of Financial Protection2022-11-28028 November 2022 Re Proof of Financial Protection BVY 22-027, Bvy 22-027; Pre-Notice of Disbursement from Decommissioning Trust for Vermont Yankee Nuclear Power Station2022-11-11011 November 2022 Bvy 22-027; Pre-Notice of Disbursement from Decommissioning Trust for Vermont Yankee Nuclear Power Station BVY 22-026, Pre-Notice of Disbursement from Decommissioning Trust2022-10-31031 October 2022 Pre-Notice of Disbursement from Decommissioning Trust ML22273A1492022-10-0404 October 2022 Review of Decommissioning Funding Status 2022 BVY 22-025, Pre-Notice of Disbursement from Decommissioning Trust2022-10-0404 October 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-023, Pre-Notice of Disbursement from Decommissioning Trust2022-09-0101 September 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-022, Report of Investigation Pursuant to 10 CFR 20, Appendix G2022-08-22022 August 2022 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 22-021, Report of Investigation Pursuant to 10 CFR 20, Appendix G2022-08-16016 August 2022 Report of Investigation Pursuant to 10 CFR 20, Appendix G BVY 22-020, Pre-Notice of Disbursement from Decommissioning Trust2022-08-0101 August 2022 Pre-Notice of Disbursement from Decommissioning Trust IR 05000271/20220012022-08-0101 August 2022 NRC Inspection Report No. 05000271/2022001, Northstar Nuclear Decommissioning Company, LLC, Vermont Yankee Nuclear Power Station, Vernon, Vermont BVY 22-019, Pre-Notice of Disbursement from Decommissioning Trust2022-07-0606 July 2022 Pre-Notice of Disbursement from Decommissioning Trust BVY 22-013, Notification of Revised Decommissioning Cost Estimate2022-06-17017 June 2022 Notification of Revised Decommissioning Cost Estimate 2024-01-04
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML19224A4722019-08-26026 August 2019 VY Report on Status of Decommissioning Funding for Shutdown Reactors Enclosure ML18094B0922018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to B. S. Ford RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for ISFSI Docket Nos.: 72-43, 72-51, 72-1044, 72-07, 72-12, and 72-59) ML18045A8172018-04-0505 April 2018 Request for Additional Information on Vermont Yankee License Transfer Request (License DPR-28, Docket No. 50-271) ML17341A3842017-12-14014 December 2017 Request for Additional Information Regarding License Amendment Request to Change Physical Security Plan to Reflect an ISFSI-Only Configuration ML17313A4312017-11-0303 November 2017 NRC Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar ML17279B1452017-10-24024 October 2017 Request for Additional Information Regarding the License Amendment Request to Change the Emergency Plan and Emergency Action Level Scheme to Reflect an ISFSI-Only Configuration ML17244A0982017-10-12012 October 2017 NRC Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar ML17229B4842017-08-16016 August 2017 Request for Supplemental Documentation to Support Review of the Physical Security Plan ML16090A0292016-04-0505 April 2016 Request for Additional Information Related to Proposed Changes to Quality Assurance Program Manual, Vermont Yankee Nuclear Power Station ML16077A3452016-03-22022 March 2016 Request for Additional Information Related to 10 CFR 20.2002 Alternate Waste Disposal Request For Vermont Yankee Nuclear Power Station (CAC No. L53116) ML16069A0952016-03-0303 March 2016 Request for 20.2002 Disposal, Request for Additional Information CNRO-2015-00008, Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company2015-02-18018 February 2015 Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company ML14318A4002014-12-17017 December 2014 Vermont Yankee Nuclear and Big Rock Point - Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company (Tac Nos. MF3218 - MF3221) ML14289A3942014-11-21021 November 2014 Redacted, Request for Additional Information, Review of Revision 14 to the Physical Security Plan, Safeguards Contingency Plan, and Training and Qualification Plan Pursuant to 10 CFR 50.54(p)(2) BVY 14-069, Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E - Supplement 22014-10-21021 October 2014 Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E - Supplement 2 ML14192A8352014-08-19019 August 2014 Request for Additional Information, Exemption from 10 CFR 50.47 and Appendix E to Allow Reduced Emergency Plan Requirements and Revise Radiological Emergency Response Plan Consistent with Permanently Defueled Reactor ML14231A0172014-08-13013 August 2014 Technical Specifications Proposed Change No. 309, Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition - Supplement 4 ML14163A5902014-07-0101 July 2014 Request for Additional Information, Round 2, Amendment Request to Revise Site Emergency Plan for Permanently Defueled Condition to Reflect Change in On-Shift Staffing and Emergency Response Staffing ML14115A0292014-05-0505 May 2014 Request for Additional Information Regarding License Amendment Request for Emergency Plan Change ML14024A0412014-01-29029 January 2014 Request for Additional Information Regarding Entergy Request for Rescission of and Scheduler Relief from Order EA-13-109 on Reliable Hardened Containment Vents ML13311B0772013-11-26026 November 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation ML13304B4182013-11-0101 November 2013 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns ML13218A0122013-08-0606 August 2013 E-mail from R.Guzman to P.Couture, Request for Additional Information - Relief Requests ISI-04 Dated March 27, 2013 - Bvy 13-018 ML13205A1762013-07-24024 July 2013 Supplemental Request for Additional Information - Relief Request ISI-03 ML13179A4622013-07-0505 July 2013 Entergy Nuclear Operations, Inc., Decommissioning Funding Status Report Request for Additional Information Regarding the Decommissioning Funding Status Report ML13186A1142013-07-0505 July 2013 Email from R. Guzman to P.Couture Request for Additional Information - Relief Request ISI-02, Application of Code Case N-716 ML13165A2792013-06-20020 June 2013 Request for Additional Information Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (NRC Order EA-12-051) ML13163A2582013-06-17017 June 2013 Request for Additional Information - Response to March 12, 2012, Commission Order EA-12-049 to Modify Licenses Requirements for Mitigating Strategies for Beyond Design Basis External Events ML13149A2652013-05-28028 May 2013 Email from R. Guzman to P. Couture - Request for Additional Information Relief Request ISI-05 (TAC No. MF1194) -Updated RAI-2 (Revision 2) ML13130A0562013-05-0909 May 2013 E-mail from R.Guzman to P.Couture Request for Additional Information - Relief Request RR-P02 Dated February 1, 2013 - Bvy 13-008 ML13130A0472013-05-0808 May 2013 Email from R.Guzman to P.Couture Request for Additional Information - Relief Requests ISI-01 and ISI-03 Dated March 27, 2013 - Bvy 13-018 (TAC Nos. MF1196/1198) ML13119A2462013-04-29029 April 2013 Request for Additional Information, E-mail from R. Guzman to P. Couture Relief Request ISI-05 ML13097A0032013-04-0808 April 2013 Request for Additional Information Change to 10 CFR 50.63 Licensing Basis - SBO EDG ML13087A3922013-04-0202 April 2013 Request for Additional Information to Support the Review of Relief Request RR-P-01 ML13081A7522013-03-22022 March 2013 Email from R.Guzman to P.Couture Request for Additional Information for License Amendment Request to Change 10 CFR 50.63 Licensing Basis ML13077A2062013-03-20020 March 2013 Request for Additional Information Regarding 10 CFR 50.33 Financial Qualification Review ML13067A0912013-03-0808 March 2013 Request for Additional Information Change to TS 3.3.B Inoperable Control Rods ML13050A4692013-02-21021 February 2013 Request for Additional Information Change to Licensing Basis for Station Blackout Diesel Generator ML13018A4592013-01-15015 January 2013 Request for Additional Information - E-mail from R.Guzman to P.Couture Relief Request ISI-PT-02 Alternative to the System Leakage Test for Rv Head Flange Leakoff Lines ML1228403332012-10-10010 October 2012 Request for Additional Information - E-mail from R. Guzman to P. Couture License Amendment Request to Revise License Condition 3.P and 3.Q ML12278A3862012-10-0404 October 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2, and 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford, Request for Additional Information, Round 2, Amendment Request to Revise QA Program Manual and Staff Qualification TSs ML13070A2032012-09-17017 September 2012 Email from R. Guzman to R. Wanczyk and P. Outure Draft Request for Additional Information - LAR to Revise License Renewal Commitments One Time Inspection Program ML13070A1742012-09-10010 September 2012 Email from R. Guzman to R. Wanczyk Draft Request for Additional Information - LAR to Revise License Renewal Commitments Selective Leaching Program ML12122A8072012-05-0707 May 2012 Request for Additional Information Regarding Physical Security, Safeguards Contingency and Training and Qualification Plan, Revision 11 ML1300902982012-04-10010 April 2012 E-mail from J. Kim to J. Devincentis Request for Additional Information - Rod Worth Minimizer Bypass Allowance Amendment ML1209604492012-04-0505 April 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Request for Additional Information, Revise Quality Assurance Program Manual and Staff Qualification Technical Specificat ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic 2019-08-26
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 3, 2017
A. Christopher Bakken III President and Chief Executive Officer Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jacksonville, MS 39213-1995
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REQUEST FOR DIRECT AND INDIRECT LICENSE TRANSFERS FROM ENTERGY TO NORTHSTAR (EPID NO. L-2017-LLM-0002)
Dear Mr. Bakken III:
By letter dated February 9, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17045A140), Entergy Nuclear Operations, Inc. (ENOI), Entergy Nuclear Vermont Yankee, LLC (ENVY), NorthStar Vermont Yankee, LLC (NorthStar VY), and NorthStar Nuclear Decommissioning Company, LLC (NorthStar NDC) (together, Applicants) submitted an application for direct and indirect license transfers for Vermont Yankee Nuclear Power Station (VY) from ENOI and ENVY to NorthStar NDC and NorthStar VY. Specifically the Applicants requested written consent to transfer the Vermont Yankee Renewed Facility Operating License No. DPR-28 and the generally licensed Independent Spent Fuel Storage Installation to the named entities.
The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific requests are found in the enclosed request for additional information (RAI). The NRC staff requests that a response to the RAIs be provided within 30 days of the date of this letter.
The RAIs identified in this letter are based on the NRC staff's review of the original license transfer request, submitted on February 9, 2017, the August 22, 2017 supplemental information submittal (ADAMS Accession No. ML17234A141), and the notification of significant decommissioning schedule change dated August 28, 2017 (ADAMS Accession No.
ML17248A468).
Please contact me at (301) 415-6634 if you have any questions. Sincerely, /RA/ Jack D. Parrott, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-271 and 72-59 License No.: DPR-28
Enclosure:
RAI cc w/encl: Vermont Yankee ListServ Vermont Yankee Service List
SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING DIRECT AND INDIRECT LICENSE TRANSFERS FROM ENTERGY TO NORTHSTAR (EPID NO. L-2017-LLM-0002), DATED NOVEMBER 3, 2017
DISTRIBUTION: PUBLIC MHenderson, NRR MDusaniwskyj, NRR STurk, OGC AGhosh, OGC JParrott, NMSS ABowers, NRR BWatson, NMSS AKock, NMSS JTappert, NMSS
ADAMS Accession No.: ML17313A431 *by email OFFICE NMSS/DUWP/RDB NRR/DIRS/IFIBNRR/DIRS/IFIBNRR/DIRS/IFIB: BC NMSS/DUWP/RDB: BC NAME JParrott MHenderson* MDusaniwskyj* ABowers* BWatson DATE 9/5/2017 9/6/2017 9/15/2017 9/8/2017 10/12/2017 OFFICIAL RECORD COPY Enclosure US NUCLEAR REGULATORY COMMISSION REQUEST FOR ADDITIONAL INFORMATION REGARDING THE DIRECT AND INDIRECT LICENSE TRANSFER REQUEST FOR VERMONT YANKEE NUCLEAR POWER STATION DOCKET NOS. 50-271 & 72-59 By letter dated February 9, 2017 (ML17045A140), the Applicants submitted a request for the direct and indirect license transfer of VY from ENOI and ENVY to NorthStar NDC and NorthStar VY. Specifically, the Applicants requested written consent to transfer the Vermont Yankee Renewed Facility Operating License No. DPR-28 and the generally licensed VY Independent Spent Fuel Storage Installation (ISFSI) in accordance with Section 184 of the Atomic Energy Act, and Title 10 of the Code of Federal Regulations (CFR), sections 10 CFR 50.80 and 10 CFR 72.50. NRC regulations at 10 CFR 50.80 require the Commission's written consent for transfer of an operating license under Part 50 of the same chapter. Specifically, 10 CFR 50.80(c) states, in part, that "the Commission will approve an application for the transfer of a license, if the Commission determines: (1) That the proposed transferee is qualified to be the holder of the license; and (2) That the transfer of the license is otherwise consistent with applicable provisions of law, regulations, and orders issued by the Commission pursuant thereto." NRC regulations at 10 CFR 50.33(f) require that the applicant for a license to operate a utilization facility "provide information sufficient to demonstrate to the Commission the financial qualification of the applicant to carry out, in accordance with regulations in this chapter, the activities for which the permit or license is sought." The regulation further states that, as applicable, the following should be provided:
. . . .
(4) Each application for a[n]. . . operating license . . . submitted by a newly-formed entity organized for the primary purpose of constructing and/or operating a facility must also include information showing: (i) The legal and financial relationships it has or proposes to have with its stockholders or owners; (ii) The stockholders' or owners' financial ability to meet any contractual obligation to the entity which they have incurred or proposed to incur; and (iii) Any other information considered necessary by the Commission to enable it to determine the applicant's financial qualification. (5) The Commission may request an established entity or newly-formed entity to submit additional or more detailed information respecting its financial arrangements and status
- 2 - of funds if the Commission considers this information appropriate. This may include information regarding a licensee's ability to continue the conduct of the activities authorized by the license and to decommission the facility. In addition to requirements in 10 CFR Part 50, certain regulations in 10 CFR Part 72 apply to a generally licensed ISFSI, as listed in 10 CFR 72.13(c), including 10 CFR 72.30(b)-(f); that regulation includes provisions for demonstration of financial assurance for decommissioning of a generally licensed ISFSI.
Financial RAIs The NRC staff is continuing to review the Applicants' submittal. To verify that there is adequate funding for the decommissioning of VY, spent fuel management, and ISFSI decommissioning, the NRC staff has the following requests for information:
RAI - 1: On page 4 of the application, the Applicants stated, in part: -The NDT will also provide up to $20 million in revolving funds for the spent fuel management costs necessary to maintain the ISFSI, subject to replenishment from recovery of claims under the Standard Contract, consistent with the requirements of 10 CFR 50.54(bb) and 50.82(a)(8)(vii). The requirements of 10 CFR 50.82(a)(8)(i)(A) restrict the use of decommissioning trust funds to withdrawals for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in 10 CFR 50.2. This definition does not include activities associated with spent fuel management. Therefore, an exemption from 10 CFR 50.82(a)(8)(i)(A) would be needed to use funds from the decommissioning trust fund for spent fuel management.
On June 23, 2015, the NRC issued an exemption to ENOI that, among other things, permitted ENOI to make withdrawals from the nuclear decommissioning trust (NDT) fund for spent fuel management in accordance with ENOI's Irradiated Fuel Management Plan and Post Shutdown Decommissioning Activities Report (PSDAR) (80 FR 35992). Please state whether the Applicants intend to apply for an exemption from 10 CFR 50.82(a)(8)(i)(A), or provide the rationale for why the Applicants believe that the exemption issued to ENOI to use decommissioning trust funds for spent fuel management in accordance with ENOI's Irradiated Fuel Management Plan and PSDAR would also apply to NorthStar VY upon transfer of the VY license, including applicability of the rationale that supports ENOI's exemption.
Also, it is unclear whether the potential recovery of claims against the U.S. Department of Energy under the Standard Contract constitutes a reliable source of funds. Please provide the rationale as to why the Applicants believe that if NorthStar VY uses the NDT fund for non-radiological decommissioning costs, such as spent fuel management, that these funds will be replenished.
- 3 - RAI - 2: On page 4 of the application, the Applicants further stated, in part:
-NorthStar will provide a parental financial Support Agreement to NorthStar VY in the amount of $125 million to assure that it is able to meet its financial and regulatory obligations to maintain and decommission VY and comply with all NRC requirements until the Licenses are terminated.
Provide additional information on the calculations used to determine the adequacy of the $125 million parental financial Support Agreement to NorthStar VY for payment of spent fuel management until the Department of Energy is scheduled to take receipt of fuel in 2052. Specifically, in your discussion, include the time period by which the Support Agreement is anticipated to be executed by NorthStar VY and whether a percentage growth of those monies (annually) has been considered.
RAI - 3:
Explain the principal characteristics of the parental financial Support Agreement provided in the application as Enclosure 6, and provide the rationale for using the parental financial Support Agreement in lieu of a parent company guarantee or some other financial assurance mechanism as a means for decommissioning financial assurance, as described in 10 CFR 50.75(e)(1)(iii). Technical RAIs The NRC staff considered the following regulations and guidance for the technical qualification evaluation: 10 CFR 50.40(b), "Common Standards"; 10 CFR 50.80, "Transfer of Licenses"; the applicable section of 10 CFR 72.50, "Transfer of License" (Section 72.50(a) for the transfer of general licenses); Standard Review Plan (SRP) NUREG-0800, Section 13.1.1, "Management and Technical Support Organization," and Sections 13.1.2 - 13.1.3, "Operating Organizations";
Regulatory Guide 1.8, Revision 3, May, 2000, Qualification and Training of Personnel for Nuclear Power Plants; and American Nuclear Society/ American National Standards Institute (ANS/ANSI) 3.1-2014, Selection, Qualification and Training of Personnel for Nuclear Power Plants.
RAI - 4:
More information is needed to determine the technical qualifications of the proposed transferee, as required under 10 CFR 50.40(b), 50.80(b)(1) and 50.80 (c)(1).
Further detail on both the responsibilities and experience of the senior managers identified on the organization chart in Enclosure 3 to the application (Attachment 1) is needed to determine the qualifications of the persons who will be filling those positions.
In addition to the resumes provided for the key management personnel in the application, please provide the resumes for each named person in the management positions identified in the planned NorthStar NDC organization chart in Enclosure 3 of the application, namely the QA
- 4 - Manager, Health & Safety Manager, ISFSI/Plant Manager, D&D Operations Manager, Remediation Manager, Waste Manager, and Compliance Engineering Manager. For those management positions without a named individual please provide a description of the position responsibilities.
Please identify the individual on the organization chart who would be considered the "Site Manager," or the onsite person who would have the ultimate responsibility for day to day operations at the site; in addition, describe the responsibilities of the manager responsible for radiological protection and the experience of that person if one has been named.
Also, Attachment 1, Section 4b, "Strategic Partner Experience and Expertise," of the application lists four university research reactors, at the Universities of Buffalo, Arizona, Illinois and Washington, as successful NorthStar decontamination and decommissioning projects. It is mentioned that NorthStar has been, or will be, involved with decommissioning at the Hanford and Savannah River sites, at several university laboratories, and at ten reactor sites in the United Kingdom. Please provide information regarding NorthStar's management and technical role in these decommissioning projects. For each project, please describe NorthStar's role as either the principal lead contractor or subcontractor and the technical services it provided at these sites.
RAI - 5:
SRP NUREG-0800, Section 13.1.1, "Management and Technical Support Organization," and Sections 13.1.2 - 13.1.3, "Operating Organizations," indicate that the objective of a review of license transfers under 10 CFR 50.80 is to ensure that the corporate management is involved with, informed of, and dedicated to the safe decommissioning of the plant. In addition, the review is to ensure that sufficient technical resources will be provided to adequately accomplish this objective and that there are sufficient interface arrangements and controls between the applicant and the major support organizations that the applicant will be responsible for and oversee.
More information is needed to evaluate any proposed changes to the current technical organization as a result of the transfer and to evaluate the supporting technical resources that will be used for the decommissioning operations. Please describe how the current Entergy organizational chart for decommissioning the VY facility will change if the application is approved by the NRC. If a function under the current organization will not be carried to the organization proposed by the Applicants, please explain why. NorthStar NDC identified the ability to leverage the experience of its parent, NorthStar Group Services Inc., and strategic partners AREVA, Burns & McDonnell, and Waste Control Specialists, named in the application as support for performing the decommissioning, decontamination and site restoration of the VY facility. Please identify where the parent company and strategic partners fit into the planned NorthStar NDC organization chart in Enclosure 3 of the application. Also, please identify where in the organization these supporting organizations would provide support to operations at the site, and identify the lines of communication and authority these supporting organization would have in the overall
- 5 - organization.