ML19289A004

Presentation Material for 10/17/19 Pre-Submittal Meeting Entergy to Holtec Proposed License Transfer Application

ML19289A004
Person / Time
Site:	Indian Point
Issue date:	10/17/2019
From:	Entergy Nuclear Operations, Holtec
To:	NRC/NRR/DORL/LPL1
Guzman R
References
EPID L-2019-LRM-0070
Download: ML19289A004 (15)

Text

Indian Point Energy Center NRC License Transfer Application Pre-Submittal Meeting 17 October 2019

Update on IPEC Status Current staffing level: ~875 utility and security employees Unit 2 to permanently cease operations by April 30, 2020 Unit 3 to permanently cease operations by April 30, 2021 Anticipate permanently defueling reactor within ~30 days post-shutdown Entergy expects to select more than 300 Decommissioning Organization employees from incumbent staff and transition prior to transaction closing Target filing Entergys PSDAR/DCE and related submittals in November 2019 Ongoing commitment to open and transparent communications with:

NY State Local stakeholders Employees 2

Transaction Overview Equity Purchase and Sale Agreement executed for the sale of the subsidiaries that own Units 1, 2, and 3 to Holtec subsidiary Nuclear Asset Management Company, LLC Post-sale, the subsidiaries will be renamed Holtec Indian Point 2, LLC (Holtec IP2) and Holtec Indian Point 3, LLC (Holtec IP3)

Holtec Decommissioning International, LLC (HDI) will become licensed operator HDI will contract with Comprehensive Decommissioning International, LLC (CDI) to serve as the Decommissioning General Contractor Holtec IP2/IP3 will own:

- Indian Point site, including associated assets (primarily the Indian Point Nuclear Decommissioning Trusts (NDTs)) and liabilities (primarily the decommissioning obligation)

- Title to spent nuclear fuel and DOE Standard Contract Indian Point Decommissioning Organization employees at the time of transaction closing will be offered positions with CDI Transaction closing dependent upon several conditions, including NRC license transfer approval 3

Holtec Nuclear Stewardship Nuclear Manufacturing Facility Owner Key Industry Partnerships Investing in Nuclear is an integral part of Holtec's long-term strategy 4

Holtec Decommissioning Fleet Strategy Establish, Implement & Advance Industry Decommissioning Improving Safety, Cost and Efficiency Fleet-Based Qualified and Approach Procedures & Processes Experienced Personnel Based on nuclear industry fleet HDI/CDI leadership depth of model Adopt NRC-approved site programs, experience in plant operations and processes and procedures decommissioning Maximize standardization Integrate site organization familiar Maintain compliance with site with plant operations and safety license & NRC regulations Drive lessons learned across standards sites Utilize experienced industry Maintain, protect & control spent Allow for cross site reviews and vendors for specialty work challenges in key areas by nuclear fuel experienced personnel Availability of both Holtec and SNC- Oversight to ensure proper Drive technological innovation to Lavalin experienced personnel enhance safety and efficiency implementation 5

Holtec Team

• Spent fuel management and nuclear services

• Entergy Fleet spent fuel cask/storage vendor Provide resources and oversight to support the safe, compliant operation of the acquired sites

• Licensed operator for all decommissioning sites in the Holtec fleet, including IPEC Wholly-owned Holtec subsidiary

• Extensive decommissioning project experience

• Decommissioning General Contractor (DGC) for the Holtec fleet including iPEC Jointly-owned by Holtec/SNC-Lavalin 6

Entergys SAFSTOR vs. Holtecs Accelerated DECON Entergys SAFSTOR Timeline - Decommissioning occurs sequentially (Unit 1, 2 then 3)

Fuel Transfer SAFSTOR Dormancy D&D/LT 2020 (IP2) 2024 2062* 2069 2077 2021 (IP3) End Dry Storage Holtecs Planned Accelerated DECON Timeline Fuel Transfer D&D/SR ISFSI Operations, Final ISFSI Decommissioning &

Site Restoration 2021 2024 2036 Holtec Decommissioning Complete/NRC License Ownership Amended to ISFSI Only Accelerates Partial Site Release Enabling Site Re-Purposing from 2077 to 2036

• Assumes DOE Fuel Pick-Up Complete in 2062 for IP2 and IP3 Note: Dates subject to change 7

Financial Qualifications IPEC NDTs satisfy 10 CFR 50.75(e)(1)(i) as a prepayment method of providing decommissioning financial assurance NDTs (including the IP1 and IP2 Provisional Trust) will be owned by Holtec IP2/IP3 NDT balances were approximately $2.1 billion total as of September 30, 2019 Projected NDT values at transaction closing will be sufficient to fund the costs of radiological decommissioning, spent fuel management, and site restoration for all three units under the Holtec plan LTA will include financial data supporting the adequacy of the NDT funds including the following:

- Decommissioning, spent fuel management and site restoration costs by category

- Annualized decommissioning cost estimate with reasonable contingency assumptions

- Cash flow analysis NDT values at closing are sufficient to meet the 10 CFR 50.75(e)(1)(i) prepayment method of providing financial assurance 8

Technical Qualifications HDI will integrate existing IPEC knowledge and incumbent staff to support HDI site organization HDI will adopt existing NRC-approved programs, processes and procedures for IPEC Existing IPEC site organization at the time of license transfer will be integrated into the CDI site organization including:

• Plant Operations

• Emergency Planning

• Security HDI will have full control and oversight over CDI, including the site organization HDI/CDI team will jointly conduct transition readiness assessments with Entergy prior to license transfer HDI is technically qualified to ensure compliance with the NRC licenses and regulations 9

Technical Qualifications HDI/CDI team possesses extensive experience in nuclear operating, decommissioning, and spent fuel management Ability to draw from Holtecs technical resources (R&D, engineering, manufacturing facilities) and experienced personnel to support decommissioning Oyster Creek and Pilgrim experience HDI managed by senior Holtec personnel Draw from existing corporate nuclear programs (e.g.,: QA, project management)

Ability to draw from CDIs and SNC-Lavalins technical resources and experience in decommissioning Extensive experience in decommissioning planning, project management and engineering, decommissioning cost estimating, waste management Management team experience on Zion, Magnox, research reactor and other decommissioning projects 10

HDI Decommissioning Organization HDI Holtec Executive President &

Committee CNO HDI VP Quality Assurance and Nuclear Oversight HDI Senior Vice President &

Chief Operating Officer CDI President HDI HDI HDI HDI VP Regulatory and VP Engineering Chief Financial Officer HDI -IPEC VP Technical Support Environmental Affairs Site VP CDI - IPEC Decommissioning General Manager IPEC Incumbent Regulatory Spent Fuel Radiation Waste Decommissioning Project Organization at the time Affairs Management Protection Management Projects Controls of License Transfer 11

Other License Transfer Requirements Spent Fuel Management Holtec IP2/IP3, under Holtec ownership, will own SNF rights and obligations pursuant to DOE standard contracts Holtec will be responsible for ISFSI decommissioning Spent fuel management activities funded by NDTs, contingent on NRC approval of exemption request to be submitted by Holtec Foreign ownership, control, and domination (FOCD)

No FOCD issues Holtec Board of Directors are all U.S. Citizens Holtec and the licensee entities are not owned, controlled or dominated by any foreign person 12

Other License Transfer Requirements (contd)

Nuclear Insurance Holtec will obtain onsite property damage insurance coverage and offsite nuclear liability coverage as required Proof of the coverage will be provided to the NRC prior to license transfer 13

License Transfer Accelerates Decommissioning LTA satisfies NRC requirements/guidance:

- Technical qualifications

- Financial qualifications for decommissioning funding

- Foreign ownership and insurance requirements License transfer is in the public interest:

- Prompt decommissioning of IPEC (~15 years post sale)

- Utilizes incumbent IPEC employees

- Potential repurpose of site by the owner

- Holtec commitment to local community and to be a fair partner 14

Next Steps: Regulatory Plan Activity Target Date License Transfer Application (joint submittal with Entergy) November 2019 DECON PSDAR including site-specific DCE November 2019 Revised Spent Fuel Management Plan November 2019 Exemption request to use NDT funds for SFM and Site November 2019 Restoration Request License Transfer Application approval November 2020 15