Letter Sequence Other |
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EPID:L-2019-LLM-0003, Site Specific Decommissioning Cost Estimate (Approved, Closed) EPID:L-2020-LLE-0010, Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) (Approved, Closed) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, ... further results|Request]]
- Acceptance
- Supplement, Supplement
Results
Other: ML19112A318, ML20006E044, ML20024F053, ML20024F063, ML20026A002, ML20091J918, ML20091J919, ML20091L448, ML20092G718, ML20297A321, ML20297A325, ML20297A360, ML20309A853, ML20316A008, ML20318A379, ML21126A008, ML21126A013, ML21147A553
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MONTHYEARML18066A0442018-03-0202 March 2018 March 2, 2018 Vermont Yankee Settlement Agreement Project stage: Request ML18066A7352018-03-0202 March 2018 Settlement Agreement Between Entergy, Northstar, State of Vermont Agencies, and Others Related to the Proposed Purchase and Sale of the Vermont Yankee Nuclear Station (License DPR-28, Docket No. 50-271) Project stage: Request 3F0618-02, Site Specific Decommissioning Cost Estimate2018-06-27027 June 2018 Site Specific Decommissioning Cost Estimate Project stage: Request ML18156A1792018-08-15015 August 2018 Issuance of Amendment to Change the Permanently Defueled Project stage: Request BVY 18-033, Registration of Spent Fuel Cask Use and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2018-08-16016 August 2018 Registration of Spent Fuel Cask Use and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool Project stage: Request ML18242A6392018-10-11011 October 2018 Safety Evaluation of License Transfer Request (License DPR-28, Docket Nos. 50-271 and 72-59 Project stage: Request ML19077A2322019-03-18018 March 2019 Applicants Answer Opposing the Commonwealth of Massachusetts Petition for Leave to Intervene and Hearing Request Project stage: Request ML19091A1892019-04-0101 April 2019 Watch Reply to Applicants Answer Opposing Pilgrim Watch Petition for Leave to Intervene and Hearing Request Project stage: Request ML19116A1622019-04-26026 April 2019 Watch Motion to Supplement Its Motion to Intervene and Request for Hearing. New Information Project stage: Request ML19112A3182019-06-20020 June 2019 FRN - Exemption for HDI to Use Oyster Creek Nuclear Decommissioning Trust Fund Re Request for License Transfer from Exelon Project stage: Other ML19177A0802019-06-26026 June 2019 Nuclear Generating Plant (CR-3) - Notification of Revised Post-Shutdown Decommissioning Activities Report (Revised PSDAR) Project stage: Request ML19210E4702019-07-29029 July 2019 Transmittal of Response to NRC Request for Additional Information Regarding Request for Direct and Indirect License Transfers, RAI-PFPB-1 and - 2 Project stage: Response to RAI ML19247B4312019-09-0303 September 2019 Application of the Commonwealth of Massachusetts for a Stay of the Effectiveness of the NRC Staff Actions Approving the License Transfer Application and Request for an Exemption to Use the Decommissioning Trust Fund for Non-Decommissioning Project stage: Request ML19329C9922019-11-21021 November 2019 LTR-19-0459 Senator Charles Schumer, Et Al., Letter to Holtec Regarding Oversight of the Decommissioning Process and the Potential Transfer of Indian Points Nuclear Regulatory Commission License from Entergy Corporation to Holtec Internatio Project stage: Request NL-19-084, Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments2019-11-21021 November 2019 Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments Project stage: Request ML19329B3242019-11-25025 November 2019 Watch Motion to Supplement Its February 20, 2019 Motion to Intervene and Request for Hearing, Its April 1, 2019 Reply to Petitioners, and Its May 3, 2019 Motion to Supplement Project stage: Request DCL-19-082, Site-Specific Decommissioning Cost Estimate2019-12-0404 December 2019 Site-Specific Decommissioning Cost Estimate Project stage: Request ML19343C6922019-12-0909 December 2019 Applicants Answer Opposing Pilgrim Watchs Third Motion to Supplement Its Motion to Intervene and Request for Hearing Project stage: Request ML19347D4152019-12-13013 December 2019 Motion of the Commonwealth of Massachusetts to Amend Its Petition with New Information Project stage: Request ML19354A6982019-12-19019 December 2019 Post Shutdown Decommissioning Activities Report Including Site-Specific Decommissioning Cost Estimate for Indian Point Nuclear Generating Units 1, 2, and 3 Project stage: Request ML20003E1522020-01-0303 January 2020 Acceptance Review Determination (E-mail Dated 1/3/19) Entergy-Holtec License Transfer Application Project stage: Acceptance Review ML20007E9182020-01-0707 January 2020 Applicants Answer Opposing the Commonwealth of Massachusetts Second Motion to Supplement Its Petition with New Information Project stage: Request ML20006E0442020-01-14014 January 2020 Notice of Consideration of Approval of Transfers of Renewed Facility Operating Licenses and Conforming Amendments, and Opportunity for a Hearing Project stage: Other ML20006E1222020-01-15015 January 2020 Individual Federal Register Notice for Consideration of Approval of Transfer of Licenses and Conforming Amendments Project stage: Request ML20017A2902020-01-17017 January 2020 Supplement to Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments Project stage: Supplement ML20023B3292020-01-21021 January 2020 LTR-20-0019 Senator Charles Schumer, Et Al., Letter Request for NRC to Extend the Public Comment Period for the License Transfer for Indian Point Project stage: Request ML20043E1232020-02-0505 February 2020 Declaration of George W. Heitzman in Support of New York Petition Project stage: Request ML20043F2732020-02-0505 February 2020, 10 February 2020, 12 February 2020 New York State Petition for Leave to Intervene and for Hearing with Supporting Declarations Project stage: Request ML20043E1252020-02-10010 February 2020 Declaration of Alyse L. Peterson in Support of New York Petition Project stage: Request ML20026A0022020-02-10010 February 2020 Proposed Post-Shutdown Decommissioning Activities Report and Site-Specific Decommissioning Cost Estimate Project stage: Other ML20026A0012020-02-11011 February 2020 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML20024F0632020-02-11011 February 2020 Extension of Comment Period for Notice of Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments and Opportunity for a Hearing Project stage: Other ML20043E1212020-02-12012 February 2020 Declaration of Warren K. Brewer in Support of New York Petition Project stage: Request ML20043F5302020-02-12012 February 2020 Petition of Riverkeeper, Inc. to Intervene and for a Hearing Project stage: Request ML20043F0542020-02-12012 February 2020 Petition by the Town of Cortlandt, Village of Buchanan, and Hendrick Hudson School Districts for Leave to Intervene and Hearing Request Project stage: Request ML20043E1282020-02-12012 February 2020 Declaration of Chiara Trabucchi in Support of New York Petition Project stage: Request ML20043C5392020-02-12012 February 2020 Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) Project stage: Request ML20043E1222020-02-12012 February 2020 Declaration of Daniel J. Evans in Support of New York Petition Project stage: Request ML20043E1262020-02-12012 February 2020 Declaration of Timothy B. Rice in Support of New York Petition Project stage: Request ML20024F0532020-02-13013 February 2020 Extension of Comment Period Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments Project stage: Other ML20056F0952020-02-13013 February 2020 Concerns Pertaining to Gas Transmission Lines at the Indian Point Nuclear Power Plant Project stage: Request ML20066H3532020-02-23023 February 2020 Comment from Robert Powell on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) Project stage: Request ML20066H3652020-02-23023 February 2020 Comment from David Johnson on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) Project stage: Request ML20055G1112020-02-23023 February 2020 Comment from Sarah Eggleston on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) Project stage: Request ML20055G1172020-02-23023 February 2020 Comment from Daniel Lucas on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) Project stage: Request ML20055G1182020-02-23023 February 2020 Comment from Dolores Jones on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) Project stage: Request ML20055G1192020-02-23023 February 2020 Comment from Janelle Peotter on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) Project stage: Request ML20057F7132020-02-23023 February 2020 Comment from Ervine Kimerling on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) Project stage: Request ML20057F7102020-02-23023 February 2020 Comment from Daniel Levy on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) Project stage: Request ML20066H3672020-02-23023 February 2020 Comment from Dennis Phayre on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021) Project stage: Request 2019-06-20
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Text
November 10, 2020 Rich Guzman, Senior Project Manager Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, 0-9C7 11555 Rockville Pike Rockville, MD 20852-2738
Subject:
Indian Point Decommissioning Trust Fund Exemption Request
Dear Mr. Guzman:
The State of New York has received the February 12, 2020, request from Holtec Decommissioning International, LLC (HDI) related to Indian Point Nuclear Generating Units 1, 2, and 3 (Indian Point). The request seeks exemption from provisions of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv). If granted by NRC, the exemption would allow HDI to use the Indian Point nuclear decommissioning trust funds for spent fuel management and site restoration activities. The exemption would also allow such withdrawals without prior notification to the NRC.
New York State opposes this exemption. The State incorporates by reference its letters dated March 24, 2020 (ML20091J663) and October 7, 2020 (ML20281A635), and adds the following:
For the reasons more fully described in its February 12, 2020 petition to intervene (ML200443E128), the State does not believe Holtec has adequately estimated the costs associated with radiological decommissioning, site restoration, and spent fuel management at the Indian Point. The State has requested a hearing, and the NRC should not grant Holtecs exemption request (or the license transfer application) until the issues raised in the States petition are adjudicated or that petition is denied.
Spent fuel management is different from decommissioning and site restoration. Holtec proposes to spend some $630 million dollars in decommissioning trust money on spent fuel management, which is a licensee operating expense and a federal government obligation. Holtec will recover a substantial portion of these non-decommissioning costs from the U.S. Department of Energy (DOE), either through settlement or in litigation. The NRC should not permit Holtec to use ratepayer funds to underwrite spent fuel management costs that will ultimately be borne by DOE. If the NRC does permit Holtec to use decommissioning trust money for this non-decommissioning expense, it should require Holtec to
return DOE reimbursements to the Indian Point trusts or to another trust instrument until radiological decommissioning is complete.
Holtec also seeks an exemption to use decommissioning trust monies for non-radiological decommissioning. The NRC has no jurisdiction over this aspect of the Indian Point decommissioning process. New York State Public Service Commission (PSC) orders expressly authorize the collection of funds for site restoration. 1 Neither Holtec nor Entergy has responded to State requests regarding the disposition of these funds; to the extent the funds have been commingled with radiological decommissioning funds, this runs afoul of the PSCs orders. Because site restoration is a state-law issue, the NRC may not exercise jurisdiction over ratepayer funds collected to pay for site restoration under state authority.
If you have any questions or concerns, please contact me.
Sincerely, Alyse Peterson, P.E.
Senior Advisor 1 See, e.g., 1992 WL 12790173, *43 (N.Y. Pub. Serv. Commn, Apr. 14, 1992).