ML16309A341
| ML16309A341 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/04/2016 |
| From: | Monatesti S ES Enterprises |
| To: | Hawkens E R Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-387-LT-2, 50-388-LT-2, 72-28-LT-2, ASLBP 16-949-01-LT-BD01, License Transfer, RAS 51423 | |
| Download: ML16309A341 (5) | |
Text
Walsh Response - Talen Energy Corp. - Riverstone Holdings, LLC - Transfer Order 10 CFR 50.80 Sjm-ese10282016 DRAFT Rev2 Page 1 November 4, 2016
Reference:
Docket ID NRC-2016-0187 Docket Nos. 50-387, 50-388 & 72-28-LT-2 In the Matter of: Susquehanna Nuclear, LLC Susquehanna Steam Electric Station, Units 1 and 2 To: E. Roy Hawkens Chief Administrative Judge ASLBP No. 16-949-01-LT-BD01 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Cc: Attachment 1
Reference:
Response to Mr. Sensitive Unclassified Non-Safeguards Information From: Sabatini Monatesti President, ES Enterprises Inc. 919 Belair Drive Berwick, PA 18603
Introduction:
Mr. Walsh referenced dates and actions on my part that I believe require clarification. I provide a time line of my correspondence (Attachment 2); note FAX requesting Hearing dated October 11, 2016, and brief description for ASLBP review. In my request for hearing and review of SUNSI denial, I attempted to draw a clear correlation between risk mitigation, risk management and operational integrity. These elements clearly affect profit and loss, health and safety, and address the viability of a business, Susquehanna Steam Electric Station, Units 1 and 2, to continue to invest in it over the next 20 years of license. I used past references to characterize the actions of the parties to indicate that the players, noted as status quo by Mr. Walsh, demonstrated lack of adequate oversight in the past, e.g., $341 million loss, and possible ethics violations. These same players could be negligent in how they might mitigate risk in the future given that they reported failures in the past. The Vulnerability-Threat Matrix clearly shows that without a clear risk mitigation strategy we could all into question the effectiveness and efficiency with which Riverstone Holdings LLC will manage Susquehanna Nuclear Units 1 and 2. The relationship between Riverstone Holdings LLC expectations and Talen Energy was a clear risk outlined by Talen Energy.
Walsh Response - Talen Energy Corp. - Riverstone Holdings, LLC - Transfer Order 10 CFR 50.80 Sjm-ese10282016 DRAFT Rev2 Page 2 Situation: Access to Electronic Filing System has been a challenge. Metasystems Help Desk shared that VISTA was not a compatible operating system and that I would need to upgrade to use the NRC system. Ivan Venezuela was very helpful as was Deborah Davidson. I would not have traversed the navigation without their help.
Problem: Legal counsel for Riverstone Holdings LLC did not address the issue of Risk Management1, nor the cost associated with poor management of business risk2, nor the numerous issues associated with decommissioning3 or clarification of the many business factors involved in the transfer of the license. Need:
On October 11 I made a request for a hearing and additional information. I would like the ASLBP to approve my request.
Regards, Sabatini J. Monatesti 1 How to Oversee Risk, GE 2014 FORM 10-K 2 Business Risks and Cost of New Nuclear Power, Craig A. Severance, World Nuclear Industry Status Report 20017 3 Decommissioning Nuclear Facilities, September 2016, http://www.world-nuclear.org Walsh Response - Talen Energy Corp. - Riverstone Holdings, LLC - Transfer Order 10 CFR 50.80 Sjm-ese10282016 DRAFT Rev2 Page 3 ATTACHMENT 1 U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Mail Stop: O-7H4 Washington, DC 20555-0001 OCAA Mail Center E-mail: ocaamail@nrc.gov U.S. Nuclear Regulatory Commission Office of the Secretary of the Commission Mail Stop: O-4F00 Washington, DC 20555-0001 Hearing Docket E-mail: hearingdocket@nrc.gov Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop T-3F23 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Office of General Counsel Mail Stop O-14A44 Washington, DC 20555-0001 Beth Mizuno, Esq. William J. Froehlich, Chairman Atomic Safety and Licensing Board Panel Administrative Judge U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: william.forehlich@nrc.gov Cathy Scott, Esq. Jeremy Wachutka, Esq. E-mail: beth.mizun@nrc.gov cathy.scott@nrc.gov jeremy.wachutka@nrc.gov G. Paul Bollwerk, III Atomic Safety and Licensing Board Panel Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: paul.bollwerk@nrc.gov Pillsbury Winthrop Shaw Pittman LLP 2300 N Street NW Washington, DC 20037-1122 David Lewis, Esq. E-mail: david.lewis@pillsburylaw.com Dr. Gary S. Arnold Atomic Safety and Licensing Board Panel Administrative Judge U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: gary.arnold@nrc.gov Herald M. Speiser Rulemakings and Adjudications Staff Office of the Secretary U.S. Nuclear Regulatory Commission (301) 415-1675 Herald.Speiser@nrc.gov OCAAMAIL.Resources@nrc.gov IMCEAINVALID-Roy+20Hawkens@nrc.gov Catherine.Scott@nrc.gov Beth.Mizuno@nrc.gov Alan.wase@nrc.gov Emile.Julian@nrc.gov OGCMailCenter.Resources@nrc.gov Brian.Newell@nrc.gov Clara.Sola@nrc.gov Erik_helbing_esq@yahoo.com Susan.schwartz@pressenterprise.net Marande07@aol.com Vincent.kundrik@mail.house.gov Walsh Response - Talen Energy Corp. - Riverstone Holdings, LLC - Transfer Order 10 CFR 50.80 Sjm-ese10282016 DRAFT Rev2 Page 4 ATTACHMENT 2 March 2, 2016 Annual Assessment Letter for Susquehanna Steam Electric Stations, Units 1 and 2 (Report 05000397/2015006 and 05000388/2015006 NRC issued one Severity Level IV traditional enforcement violation to SSES April 19, 2016 Note, SJM, NRC list ML 15078A458, Talen Energy Susquehanna Steam Generation, request to build additional storage capacity on site for spent fuel rods April 20, 2016 Salem Twp. Zoning board grants appeal to nuke plant owner April 27, 2016 Letter, SJM to Dan Schroeder, NRC, Talen Energy Ethical Misconduct April 28, 2016 SJM, submission of Talen Ethics Violation, TALN-16-04-0004 April 29, 2016 Talen Energy Acknowledgement May 16, 2016 http://www.Pennlive.com ,Power failure triggers emergency shutdown at PA nuclear reactor May 18, 2016 SJM, Health and Safety review Susquehanna Site, Open House, NRC list ML 15078A458, NUC position problem statement May 19, 2016 SJM, complaint filed with U.S. Rep. Lou Barletta PA-11 May 25, 2016 SJM, post Talen Energy NRC Ethics Example, https://www.linkedin.com/pulse/talen-energy-nrc-ethics-example-sabatini-monatesti?trk=mp-reader-card May 28, 2016 SJM, Outline concerns regarding Talen Energy ethics, NRC list ML 15078A458 July 28, 2016 NRC Victor M. McCree, Executive Director For Operations to United States Representative, L. Barletta August 14, 2016 Berwick-area plant secure despite cuts October 11, 2016 SJM, ES Enterprises Inc. FAX, Secretary USNRC, Associate General Counsel, Request for Hearing and Information request - License Transfer October 11, 2016 Hearingdocket@nrc.gov acknowledges request for hearing and information October 17, 2016 SJM, email to Hearing.Docket@nrc.gov , Talen Energy License Transfer, SUNSI request under review, instructions for cert., access http://www.nrc.gov , Electronic Submittals October 20, 2016 Tanya Hood, denying SUNSI access October 24, 2016 SJM email to Hearing.Docket@nrtc.gov concerns outlined October 24, 2016 October 24, 2016 Shareholders vote to approve Riverstone takeover October 24, 2016 SJM, RE: Susquehanna Challenge to Access to SUNSI Denial, hearing.docket@nrc.gov October 25, 2016 I attempted to access site using VISTA, learned later Metasystems Help Desk that VISTA was not a compatible operating system, Ivan Venezuela was very helpful October 25, 2016 Access Granted to the Electronic Information Exchange Adjudicatory Service List October 25, 2016 E. Roy Hawkens, Chief Admin. Judge, posts my request, dated October 11, for hearing October 27, 2016 Top Executives at Riverstone Holdings Face Prospect of Returning More Than $300 Million, http://www.wsj.com October 27, 2016 Establishment of Atomic Safety and Licensing Board, ASLBP No. 16-949-01-LT-BD01 October 30, 2016 SJM electronic filing, Talen Energy Corp Riverstone Holdings LLC Transfer Order 10 CFR 5080 Walsh Response - Talen Energy Corp. - Riverstone Holdings, LLC - Transfer Order 10 CFR 50.80 Sjm-ese10282016 DRAFT Rev2 Page 5 November 1, 2016 Notice of Appearance T. J. V. Walsh, following outreach from Mr. Lewis, I deferred to NRC review November 2, 2016 Receipt of my submission acknowledged, Talen Energy Corp Riverstone Holdings LLC Transfer Order 10 CFR 5080 November 3, 2016 Receipt of my submission acknowledged, Talen Energy Riverside Holdings LLC Vulnerability Threat Matrix November 3, 2016 Motion for Leave to Respond to Mr. SabatiChallenge, David R. Lewis & Timothy J. V. Walsh, PWSP LLP