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| | issue date = 09/05/2013 | | | issue date = 09/05/2013 |
| | title = 9/5/13 Email from R.Guzman to J.Azulay Regarding 2.206 (Tim Judson) Petition Vermont Yankee, Fitzpatrick, and Pilgrim (G20130211) | | | title = 9/5/13 Email from R.Guzman to J.Azulay Regarding 2.206 (Tim Judson) Petition Vermont Yankee, Fitzpatrick, and Pilgrim (G20130211) |
| | author name = Guzman R V | | | author name = Guzman R |
| | author affiliation = NRC/NRR/DORL/LPLI-1 | | | author affiliation = NRC/NRR/DORL/LPLI-1 |
| | addressee name = Azulay J | | | addressee name = Azulay J |
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| | docket = 05000271, 05000293, 05000333 | | | docket = 05000271, 05000293, 05000333 |
| | license number = | | | license number = |
| | contact person = Guzman R V | | | contact person = Guzman R |
| | case reference number = 2.206, G20130211 | | | case reference number = 2.206, G20130211 |
| | document type = E-Mail, Letter | | | document type = E-Mail, Letter |
| | page count = 2 | | | page count = 2 |
| }} | | }} |
| | |
| | =Text= |
| | {{#Wiki_filter:Guzman. Richard From: Guzman, Richard Sent: Thursday, September 05, 2013 4:32 PM To: 'Jessica Azulay' Cc: 'Tim Judson' |
| | |
| | ==Subject:== |
| | RE: another question about our petition Ms. Azulay, I am responding to your letter dated August 29, 2013, in which you were concerned that the Entergy subsidiaries were not being included in the NRC's 2.206 review. Just as all four licensees {Le., Entergy Nuclear Operations, Inc. {operator of all three reactors who jOintly possesses the licenses wIthe other Entergy subsidiaries - Entergy Nuclear Vermont Yankee, LLC (owner of Vermont Yankee); Entergy Nuclear FitzPatrick, LLC (owner of FitzPatrick); and Entergy Nuclear Generation Co.{owner of Pilgrim) - were jOintly referred to as "Entergy" in the petition, the federal register notice (FRN) was intended to do the same. However, I understand your concern, as the FRN only made mention of the petitioners' request for enforcement action against "Entergy Nuclear Operations, Inc. {Entergy)." |
| | To clarify, the NRC's 2.206 Petition Review Board's intent is not to exclude the Entergy subsidiaries - namely, Entergy Nuclear Fitzpatrick, LLC; Entergy Nuclear Vermont Yankee, LLC; and Entergy Nuclear Generation Co. |
| | - from its evaluation. The PRB understands that the Petitioners' are requesting investjgation and enforcement action against Entergy Nuclear Operations, Inc. as well as the Entergy subsidiaries that jointly possess the licenses for the three reactors that are subject of the Petition; the PRB has accepted the Petitioners' request for 2.206 consideration, and will review the petition accordingly. |
| | Thank you for comment letter and interest on this matter. |
| | Rich Guzman Sr. Project Manager NRRjDORLjLPLl-1 US NRC 301-415-1030 From: Jessica Azulay [mailto:jessica@allianceforagreeneconomy.org] |
| | Sent: Thursday, August 29, 2013 1:38 PM To: Guzman, Richard |
| | |
| | ==Subject:== |
| | another question about our petition Mr. Guzman, In reading the federal register notice, we have some questions about the scope of the investigation NRC will conduct. Please see attached. |
| | Jessica Azulay Jessica Azulay Staff Organizer A"iance for a Green Economy 315.480.1515 jessica@allianceforagreeneconomy.org |
| | |
| | 2013 East Genesee Street AG E York Syracuse, NY 13210 Alliance for a Green Economy 315.480.1515 agreenewyork.org info@aqreenewyork.org Richard Guzman August 29, 2013 G20 130211 Petition Manager U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mr. Guzman: |
| | On behalf of the petitioners in 2.206 petition G20 130211, I have a few questions regarding the Federal Register Notice "ADAMS Accession No. ML13154A331." |
| | The notice only makes mention of our request for enforcement against Entergy Nuclear Operations, Inc. Yet, our petition clearly includes requests for investigation and enforcement action against Entergy Nuclear FitzPatrick, LLC, owner of FitzPatrick; Entergy Nuclear Vermont Yankee, LLC, owner of Vermont Yankee; and Entergy Nuclear Generation Co., owner of Pilgrim. |
| | We would like to know whether the NRC intends to include these in the investigation and determination of financial qualifications for operating the reactors named in our petition. Our position, as outlined in our petition, is that the relationship between the above mentioned entities and Entergy Nuclear Operations is an important aspect of the financial qualifications question. In our view, NRC must determine which Entergy entity bears financial responsibility for each of these troubled reactors, and which makes the day-to-day decisions that could impact safety. It must be determined which assets can be called upon to maintain the reactor, sustain an outage and/or pay for the consequences of an accident. Those are the entities that must be investigated and tested for compliance with the financial qualifications regulations. |
| | The financial relationships among the various Entergy corporate entities is very complex, involving not just the licensees, but the Entergy business units that carry out power marketing: namely, Entergy Nuclear Power Marketing (ENPM) and Entergy Wholesale Commodities. It is our understanding that the holders of the ownership licenses (ENF LLC, ENVY LLC, and ENGC LLC) derive their revenues through sales to Entergy Nuclear Power Marketing and/or other EWC business units, and that ENO, holder of the operating licenses, bills the the owner-licensees for its expenses. |
| | This complex set of internal financial relationships raises even thornier questions about the impact of Entergy's insufficient sales revenues on operational decision-making and nuclear safety. While it is clear from the evidence already at hand that Entergy is in violation of the financial qualifications regulations, it is impossible for NRC to conduct a thorough review of our petition without evaluating the finances of the owner-licensees, as well as the operator-licensee, since the latter derives its revenues from billing the former, and it is the former's finances that are perhaps the greatest limiting factor. |
| | We hope that the inclusion of Entergy's subsidiaries named in our petition has not been lost, as might seem the case from reading the federal register notice. Will you please clarify which entities NRC will be looking at to determine financial qualifications? |
| | Sincerely, |
| | --------------/s/-------------- |
| | Jessica Azulay, Organizer Alliance for a Green Economy}} |
|
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Category:E-Mail
MONTHYEARML24024A1372024-01-24024 January 2024 NRR E-mail Capture - Final Snsb RAI Regarding FitzPatrick Amendment to Modify Safety Relief Valves Setpoint Lower Tolerance ML24017A1112024-01-17017 January 2024 NRR E-mail Capture - Acceptance of Requested Licensing Action Amendment Request to Adopt TSTF-529, Clarifyuse and Applicaion Rules, Revision 4 ML23264A7992023-09-21021 September 2023 NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC Fleet Request License Amendment Request to Adopt TSTF-580, Revision 1 ML23261C3982023-09-0808 September 2023 Acceptance Review of Amendment to Update the Fuel Handling Accident Analysis ML23244A2662023-09-0101 September 2023 Acceptance of Requested Licensing Action Amendment Request to Modify Surveillance Requirement 3.4.3.1, Safety Relief Valves Setpoint Lower Tolerance ML23237B3972023-08-24024 August 2023 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Alternative Request to Use Updated BWRVIP Guidelines ML23194A1822023-08-0303 August 2023 Acceptance Review for LAR Re SRM 3.3.1.2 ML23163A2292023-06-12012 June 2023 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of License Amendment Request to Adopt TSTF-580, Revision 1 ML22354A2622022-12-20020 December 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Request to Use Certain Provisions of the 2019 Edition of the ASME BPV Code, Section XI ML22335A2802022-11-0404 November 2022 11-4-2022 Email Transmitting Draft Questions Pertaining to Pilgrim ISFSI Exemption Request ML22270A0422022-09-26026 September 2022 Acknowledgement Email for Holtec'S Request for Reporting Exemption with Regards to the Pilgrim ISFSI Annual Radioactive Effluent Release Report (Docket No. 05000293) NRC-2100-2022, EN 55999 Valcor Coil Shell Assemblies Final Notification (004)2022-09-12012 September 2022 EN 55999 Valcor Coil Shell Assemblies Final Notification (004) NRC 2110-2022, EN 55999 - Valcor Engineering Corporation (009)2022-07-18018 July 2022 EN 55999 - Valcor Engineering Corporation (009) ML22154A1622022-05-26026 May 2022 Letter and Email from Save Our Bay/Diane Turco Regarding Irradiated Water Release from Pilgrim ML22124A2672022-05-0404 May 2022 Request for Additional Information for James A. FitzPatrick Nuclear Power Plant TSTF-505 ML22041B5362022-02-10010 February 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541 ML22020A0642022-01-13013 January 2022 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative for Repair of Water Level Instrumentation Partial Penetration Nozzles ML22007A2602021-12-0606 December 2021 E-mail from P. O'Brien, Holtec, to A. Snyder, NRC, on Pilgrim Effluent Discharge ML22063A4742021-11-29029 November 2021 Acceptance of Requested Licensing Action License Amendment Request to Eliminate Selected Response Time Testing ML21301A0672021-10-28028 October 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Amendment Request to Adopt TSTF-541 ML21287A6192021-10-14014 October 2021 E-mail from S. Phillips, MEMA, to A. Snyder, NRC, Pilgrim Nuclear Power Station, Commonwealth of Massachusetts Consultation Response to Amendment Review for Emergency Preparedness ML21267A0012021-09-23023 September 2021 E-mail from A. Snyder, NRC, to A. Sterdis, Holtec, - Pilgrim Nuclear Power Station - Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E Acceptance Review ML21266A2772021-09-23023 September 2021 HDI Clarification of Exemption Requested from 10 CFR 20, Appendix G, Section Iii.E ML21266A2512021-09-23023 September 2021 Consultation with Commonwealth of Massachusetts Regarding Proposed Amendment Application for Emergency Plan and Emergency Action Levels ML21257A3832021-09-15015 September 2021 E-mail from A. Snyder, NRC, to A. Sterdis, Holtec, - Pilgrim Nuclear Power Station - Follow-on Request Re Request for Additional Information 2 Pilgrim - License Amendment Request Independent Spent Fuel Storage Installation Only Emergency Pl ML21256A1902021-09-10010 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21252A0482021-09-0707 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet Alternative Request for Repair of Water Level Instrumentation Partial Penetration Nozzles ML21246A2072021-09-0303 September 2021 Acceptance of Requested Licensing Action License Amendment Request to Adopt 10 CFR 50.69 ML21246A2112021-09-0303 September 2021 Acceptance of Requested Licensing Action License Amendment Request to Adopt TSTF-505 ML21215A3502021-08-0303 August 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Amendment Request to Adopt TSTF-554 ML21211A5162021-07-22022 July 2021 Consultation Response from Commonwealth of Massachusetts Regarding Proposed Pilgrim ISFSI Only Physical Security Plan ML21211A5912021-07-22022 July 2021 Consultation Response from Commonwealth of Massachusetts Regarding Proposed Pilgrim ISFSI Only Technical Specifications ML21200A1522021-07-13013 July 2021 Consultation Request to Commonwealth of Massachusetts Regarding Proposed Pilgrim Isfi Only Physical Security Plan ML21200A2352021-07-13013 July 2021 Consultation Request to Commonwealth of Massachusetts Regarding Proposed Pilgrim ISFSI Only Technical Specifications ML21187A0522021-07-0606 July 2021 Fitz RAI Regarding FitzPatrick Amendment Request to Modify SR 3.5.1.6 ML21176A1842021-06-25025 June 2021 Email from HDI Regarding Pilgrim Nuclear Power Station Training ML21246A2142021-06-23023 June 2021 Acceptance of Requested Licensing Action Regarding License Amendment Request to Adopt TSTF-264 ML21180A0582021-06-17017 June 2021 Email from Region I Regarding Pilgrim Nuclear Power Station Inspection - EA-13-132 ML21154A0132021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21154A0142021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21154A0112021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21144A2132021-05-24024 May 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21144A1072021-05-17017 May 2021 Acceptance of Requested Licensing Action License Amendment Request to Adopt TSTF-582 ML21117A0442021-04-26026 April 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21097A0402021-04-0606 April 2021 E-Mail Consult with Commonwealth of Mass Re - Amendment Application - Physical Security Plan for the Pilgrim Nuclear Power Station ML21084A2532021-03-24024 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Transfer Application ML21075A1582021-03-15015 March 2021 E-mail from T. Silko to J. Parrott, NMSS, Vermont Yankee on the State of Vermont Comments on the Review of the Draft Final SER and EA for 20.2002 Alternate Disposal Request ML21062A0652021-03-0101 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21049A2572021-02-18018 February 2021 Request for Additional Information Byron/Dresden Proposed Changes to Site Emergency Plans to Support Post-Shutdown and Permanently Defueled Conditions (EPID-2020-LLA-0240 & EPID-2020-LLA-0237) ML21033A8552021-02-0202 February 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet Alternative Request to Expand the Use ASME Codes Cases N-878 and N-880 2024-01-24
[Table view] Category:Letter
MONTHYEARIR 05000333/20230042024-02-0707 February 2024 Integrated Inspection Report 05000333/2023004 and Independent Spent Fuel Storage Installation Inspection Report 07200012/2023001 ML24037A0102024-02-0606 February 2024 Requalification Program Inspection L-24-002, Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G2024-02-0202 February 2024 Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G BVY 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 ML24018A0012024-01-18018 January 2024 Notification of Commercial Grade Dedication Inspection (05000333/2024010) and Request for Information ML23342A1182024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan ML24004A2302024-01-0808 January 2024 Project Manager Reassignment ML23356A0832024-01-0404 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0058 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) 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 L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 JAFP-23-0065, License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4, and Administrative Changes to the Technical Specifications2023-12-14014 December 2023 License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4, and Administrative Changes to the Technical Specifications ML23278A1292023-12-14014 December 2023 Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines BVY 23-029, Proof of Financial Protection2023-12-12012 December 2023 Proof of Financial Protection IR 05000333/20234012023-12-0808 December 2023 Cybersecurity Inspection Report 05000333/2023401 (Cover Letter Only) RS-23-126, Request for Exemption from 10 CFR 2.109(b)2023-12-0707 December 2023 Request for Exemption from 10 CFR 2.109(b) JAFP-23-0069, Supplemental Response to Part 73 Exemption Request Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements2023-12-0707 December 2023 Supplemental Response to Part 73 Exemption Request Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements ML23334A1822023-11-30030 November 2023 Biennial Report for the Defueled Safety Analysis Report Update, Technical Specification Bases Changes, 10 CFR 50.59 Evaluation Summary, and Regulatory Commitment Change Summary November 2021 Through October 2023 BVY 23-028, Pre-Notice of Disbursement from Decommissioning Trust2023-11-28028 November 2023 Pre-Notice of Disbursement from Decommissioning Trust JAFP-23-0057, and Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-22022 November 2023 and Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation 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 JAFP-23-0064, Emergency Plan Document Revision2023-11-15015 November 2023 Emergency Plan Document Revision IR 05000333/20230032023-11-13013 November 2023 Integrated Inspection Report 05000333/2023003 JAFP-23-0063, Registration of Spent Fuel Cask Use2023-11-13013 November 2023 Registration of Spent Fuel Cask Use L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point 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 ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums BVY 23-025, Pre-Notice of Disbursement from Decommissioning Trust2023-11-0202 November 2023 Pre-Notice of Disbursement from Decommissioning Trust ML23306A0992023-11-0202 November 2023 and Indian Point Energy Center, Notification of Changes in Schedule in Accordance with 10 CFR 50.82(a)(7) L-23-011, 10 CFR 72.48 Biennial Change Summary Report2023-10-27027 October 2023 10 CFR 72.48 Biennial Change Summary Report IR 05000333/20230102023-10-26026 October 2023 Biennial Problem Identification and Resolution Inspection Report 05000333/2023010 JAFP-23-0059, Registration of Spent Fuel Cask Use2023-10-24024 October 2023 Registration of Spent Fuel Cask Use IR 05000333/20233012023-10-19019 October 2023 Initial Operator Licensing Examination Report 05000333/2023301 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans 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 IR 05000293/20234012023-08-31031 August 2023 NRC Inspection Report No. 05000293/2023401 & 2023001 (Cover Letter Only) JAFP-23-0048, Supplemental Information for License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis2023-08-31031 August 2023 Supplemental Information for License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis JAFP-23-0050, Physical Security Plan, Revision 242023-08-31031 August 2023 Physical Security Plan, Revision 24 IR 05000333/20230052023-08-31031 August 2023 Updated Inspection Plan for James A. FitzPatrick Nuclear Power Plant (Report 05000333/2023005) JAFP-23-0047, Correction to the 2022 Annual Radioactive Effluent Release Report2023-08-30030 August 2023 Correction to the 2022 Annual Radioactive Effluent Release Report BVY 23-022, Pre-Notice of Disbursement from Decommissioning Trust2023-08-23023 August 2023 Pre-Notice of Disbursement from Decommissioning Trust ML23228A1342023-08-16016 August 2023 Licensed Operator Positive Fitness-For-Duty Test IR 05000271/20230012023-08-15015 August 2023 Northstar Nuclear Decommissioning Company, Llc., Vermont Yankee Nuclear Power Station, - NRC Inspection Report 05000271/2023001 IR 05000333/20230022023-08-0707 August 2023 Integrated Inspection Report 05000333/2023002 RS-23-087, Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor2023-08-0404 August 2023 Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor IR 05000293/20230022023-08-0404 August 2023 NRC Inspection Report No. 05000293/2023002 JAFP-23-0040, License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis2023-08-0303 August 2023 License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis 2024-02-07
[Table view] |
Text
Guzman. Richard From: Guzman, Richard Sent: Thursday, September 05, 2013 4:32 PM To: 'Jessica Azulay' Cc: 'Tim Judson'
Subject:
RE: another question about our petition Ms. Azulay, I am responding to your letter dated August 29, 2013, in which you were concerned that the Entergy subsidiaries were not being included in the NRC's 2.206 review. Just as all four licensees {Le., Entergy Nuclear Operations, Inc. {operator of all three reactors who jOintly possesses the licenses wIthe other Entergy subsidiaries - Entergy Nuclear Vermont Yankee, LLC (owner of Vermont Yankee); Entergy Nuclear FitzPatrick, LLC (owner of FitzPatrick); and Entergy Nuclear Generation Co.{owner of Pilgrim) - were jOintly referred to as "Entergy" in the petition, the federal register notice (FRN) was intended to do the same. However, I understand your concern, as the FRN only made mention of the petitioners' request for enforcement action against "Entergy Nuclear Operations, Inc. {Entergy)."
To clarify, the NRC's 2.206 Petition Review Board's intent is not to exclude the Entergy subsidiaries - namely, Entergy Nuclear Fitzpatrick, LLC; Entergy Nuclear Vermont Yankee, LLC; and Entergy Nuclear Generation Co.
- from its evaluation. The PRB understands that the Petitioners' are requesting investjgation and enforcement action against Entergy Nuclear Operations, Inc. as well as the Entergy subsidiaries that jointly possess the licenses for the three reactors that are subject of the Petition; the PRB has accepted the Petitioners' request for 2.206 consideration, and will review the petition accordingly.
Thank you for comment letter and interest on this matter.
Rich Guzman Sr. Project Manager NRRjDORLjLPLl-1 US NRC 301-415-1030 From: Jessica Azulay [1]
Sent: Thursday, August 29, 2013 1:38 PM To: Guzman, Richard
Subject:
another question about our petition Mr. Guzman, In reading the federal register notice, we have some questions about the scope of the investigation NRC will conduct. Please see attached.
Jessica Azulay Jessica Azulay Staff Organizer A"iance for a Green Economy 315.480.1515 jessica@allianceforagreeneconomy.org
2013 East Genesee Street AG E York Syracuse, NY 13210 Alliance for a Green Economy 315.480.1515 agreenewyork.org info@aqreenewyork.org Richard Guzman August 29, 2013 G20 130211 Petition Manager U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mr. Guzman:
On behalf of the petitioners in 2.206 petition G20 130211, I have a few questions regarding the Federal Register Notice "ADAMS Accession No. ML13154A331."
The notice only makes mention of our request for enforcement against Entergy Nuclear Operations, Inc. Yet, our petition clearly includes requests for investigation and enforcement action against Entergy Nuclear FitzPatrick, LLC, owner of FitzPatrick; Entergy Nuclear Vermont Yankee, LLC, owner of Vermont Yankee; and Entergy Nuclear Generation Co., owner of Pilgrim.
We would like to know whether the NRC intends to include these in the investigation and determination of financial qualifications for operating the reactors named in our petition. Our position, as outlined in our petition, is that the relationship between the above mentioned entities and Entergy Nuclear Operations is an important aspect of the financial qualifications question. In our view, NRC must determine which Entergy entity bears financial responsibility for each of these troubled reactors, and which makes the day-to-day decisions that could impact safety. It must be determined which assets can be called upon to maintain the reactor, sustain an outage and/or pay for the consequences of an accident. Those are the entities that must be investigated and tested for compliance with the financial qualifications regulations.
The financial relationships among the various Entergy corporate entities is very complex, involving not just the licensees, but the Entergy business units that carry out power marketing: namely, Entergy Nuclear Power Marketing (ENPM) and Entergy Wholesale Commodities. It is our understanding that the holders of the ownership licenses (ENF LLC, ENVY LLC, and ENGC LLC) derive their revenues through sales to Entergy Nuclear Power Marketing and/or other EWC business units, and that ENO, holder of the operating licenses, bills the the owner-licensees for its expenses.
This complex set of internal financial relationships raises even thornier questions about the impact of Entergy's insufficient sales revenues on operational decision-making and nuclear safety. While it is clear from the evidence already at hand that Entergy is in violation of the financial qualifications regulations, it is impossible for NRC to conduct a thorough review of our petition without evaluating the finances of the owner-licensees, as well as the operator-licensee, since the latter derives its revenues from billing the former, and it is the former's finances that are perhaps the greatest limiting factor.
We hope that the inclusion of Entergy's subsidiaries named in our petition has not been lost, as might seem the case from reading the federal register notice. Will you please clarify which entities NRC will be looking at to determine financial qualifications?
Sincerely,
/s/--------------
Jessica Azulay, Organizer Alliance for a Green Economy