Decommissioning

Decommissioning is the process by which nuclear power plants are safely retired from service. The progression involves decontaminating the facility to reduce residual radioactivity, moving all used nuclear fuel from wet storage into dry storage, dismantling the structures, removing contaminated materials to appropriate disposal facilities and releasing the property for other uses. The owner remains accountable to the NRC until decommissioning has been completed and the agency has terminated its license.

In accordance with NRC regulations, decommissioning must be completed within 60 years of the plant ceasing operations. The nuclear site owner (or Licensee) may choose from three decommissioning strategies: DECON, SAFSTOR or ENTOMB. Historically, some nuclear plant owners have selected to place the plant in SAFSTOR, the NRC-approved option that allows the nuclear plant to be safely shuttered for several decades before decommissioning and site restoration is completed. Holtec’s approach to decommissioning and site restoration is to acquire shuttered nuclear plants and to safely and efficiently complete decommissioning activities decades sooner than if the previous plant owner were to continue to own the site.

The completion of decommissioning will result in the release of all portions of the site from the current NRC license, with the exception of the Independent Spent Fuel Storage Installation (ISFSI) – the area where spent nuclear fuel is stored in dry casks until the U.S. Department of Energy transfers the spent fuel offsite. Holtec has a pending application with the NRC for a Consolidated Interim Storage Facility in New Mexico, which could eventually store spent nuclear fuel from U.S. nuclear power plants.

Holtec’s commitment is to complete decommissioning of the sites safely and efficiently so that the land occupied by the site may be repurposed for an alternative use so local jobs can be created, and the town can regain lost tax revenue.

More than a dozen U.S. commercial reactors have completed or are in different stages of decommissioning. A much larger number of non-commercial reactors have been decommissioned as well.

Ensuring that the decommissioning is carried out safely is primarily the responsibility of the federal government which it exercises through the Nuclear Regulatory Commission. Many states also have citizens advisory panels that engage with the plant to understand and monitor the decommissioning process.

There has never been an instance of a worker receiving excessive dose in any decommissioning site. This is because the decommissioning activities are carried out using detailed procedures by highly trained workers.

Most communities would like the land occupied by the site to be repurposed for an alternative use so local jobs can be created, and the town can regain lost tax revenue.

HDI is a subsidiary of Holtec International and the NRC license holder for the nuclear plants the company acquires.

Holtec is now the licensed operator and owner of Oyster Creek and Pilgrim sites. A license transfer application has been submitted for Entergy’s Indian Point Energy Center. Once this application is approved, an ownership sale can take place. In the near future, license transfer application will be submitted for Palisades Nuclear Generating Station.

Given Holtec’s distinguished record of industry-leading financial performance over the years, along with the long-term contracts Holtec has worldwide, it is highly unlikely that the company would need bankruptcy protection. Consider the relevant facts and figures:

• Holtec has posted a profit in every year of operation going back to its inception in the 1980s.
• Holtec has consistently received the highest rating from Dunn and Bradstreet (the independent industry rating firm).
• Holtec has an ensured business backlog that currently extends to the 2040s.
• Holtec’s current market value, backed by large physical and intellectual assets (patents and proprietary technologies), is appraised at well over 3 billion dollars.
• Holtec has a large client base of over 100 large companies spread over 16 countries on five continents.
• Holtec holds a large number of certificates and licenses from the US NRC and many foreign countries that are immensely valuable to its clients.
• Holtec’s quality, safety and delivery performance (@ over 95%) are considered nothing short of spectacular in the nuclear industry.                                                  

Finally, the company excels in the most important metric which predicts future performance – client loyalty: Of the 118 nuclear plants that are Holtec’s customers, not one has ever ended its relationship with the company. A large loyal client base nourished by continuous stand-out performance guarantees the long-term stability that has been the hallmark of Holtec International throughout the years.

First and foremost, the safety of the site will be completely protected. The nuclear decommissioning trust fund, which is managed by an independent, highly regulated trustee will remain as an asset for use in the safe caretaking and decommissioning of the site. The NRC will continue to regulate the site. Given this, the decommissioning projects will suffer little disruption if the unthinkable were to happen and Holtec files for bankruptcy. In such an event, the company will have to be reorganized under Chapter 11 and its ownership may migrate to another company. However, the Decommissioning Trust Fund (DTF) will continue to be used exclusively for its purpose as is required by federal regulation; and cannot be diverted by the acquirer for another purpose, without a specific exemption from the NRC.

Holtec’s Decommissioning Management Manual (CD-31) ensures strong governance and controls are in place to ensure fund expenditures are prudent and checked using a Decommissioning Cost Control Committee (DCCC), and to ensure that the fund is managed in a manner that supports sufficient funding throughout the project using a Decommissioning Trust Fund Management Board. Holtec additionally has a Decommissioning Advisory Board made up of independent industry leadership at the executive level who advise on matters related to safety, risk and performance.

These autonomously constituted entities provide a web of checks and controls to ensure that the expenditures on the decommissioning projects are made responsibly.

The Decommissioning Cost Control Committee (DCCC) and Decommissioning Trust Fund Management Board are empowered to refuse additional withdrawals until the condition of cost exceedance is addressed. The continuous monitoring by the DCCC and the Board serve to protect the decommissioning projects from facing a financial deficit.

The number of workers varies through the duration of the project. It can reach as high as 300 during the peak of the dismantling period.

Decommissioning is a process of controlled deconstruction where our main objectives are safety of the workers, minimal accured dose to the work force, prevent spread of contamination, and security of the facility. The existing plant personnel who are skilled in the relevant disciplines will ply their skills in the decommissioning work effort. Other workers, hopefully most drawn from the local population, will be hired to carry out the program. Because the pace of work will vary as the project progresses, the size of the workforce will vary with it. We should state categorically that we are committed to employ local workers to the maximum extent possible at each site.

As with any industrial plant that stops production of its product, in this case electricity, workforce reductions occur. The workforce that remains on site are those needed to maintain the site in a safe condition. At some sites that close and go into SAFSTOR, once the nuclear fuel is placed in cannisters, the workforce typically reduces to around 50 or less For Holtec sites, the reduction will be somewhat less until completion of the decommissioning, as the staff on-site are needed support the active decommissioning. To show support for the employees at the sites, Holtec implements several ameliorative measures, viz:

• The jobs subject to elimination are announced well in advance of the date that the reduction will occur.
• The affected associates are encouraged to apply for the appropriate position (there are many) open across Holtec International.
• Those that desire to remain in the community are provided HR career assistance at their option.

Holtec has an exemplary record of worker safety in our manufacturing plants and at the numerous nuclear plants where we are rendering site services. This success is based on a diligently nurtured safety conscious work environment within our company supported by a program of intensive worker training. The operating procedures, based on Holtec’s Fleet Management Model, ensure that all decommissioning activities are carried out in the safest manner possible.

Part of decommissioning is moving the spent nuclear fuel from the spent fuel pool to an onsite dry storage facility called an Independent Spent Fuel Storage Installation (or ISFSI) which used to take five or more years after reactor shutdown. Holtec has dry storage systems, which allow the transfer to be done in less than three years. With the spent nuclear fuel on the ISFSI, other decommissioning activities can be safely started sooner and performed more efficiently.

Like any industrial project, the performance schedule of a decommissioning project may change if the primary drivers so dictate. The guiding principle in our decommissioning program is to carry out the projects with utmost safety of plant personnel, protection of the surrounding community and the environment by a tight control on confining contamination, minimum radiation dose to the workers, and prevention of release of gaseous or particulate radioactivity to the environment. While the company seeks to complete a project in the shortest schedule, the schedule is subject to amendment if the above guiding principles so dictate. Safety will never be compromised for schedule considerations.

Another factor is the financial performance of the DTF which is inextricably tied to the financial markets. A sharp and sustained slump in the market certainly has the potential to disrupt the pace of the decommissioning work. To ensure this potential is avoided, the funds are managed in such a way as to ensure that short term expenditures are invested in bonds and other more stable financial instruments, to limit any impact from a downturn in the market.