NCI advises the plant owner on licensee requirements and provides oversight activities that meet owner requirements. NCI serves as an agent of the plant owner.
NCI’s typical scope of work involves assessing the adequacy of operating procedures and practices, personnel qualifications, training programs, risk management tools, cost control protocols, supplier screening systems, security programs (including cyber security) and personnel safety programs. NCI performs continuing assessment of the project’s quality assurance and safety metrics, cyber-security infrastructures, aging management of the fuel in dry storage, 10 CFR 72 compliance of the fuel storage system, and on-site storage of Low-Level Waste (LLW). For Holtec International’s decommissioning projects, prior to close of the transaction, NCI acts as an agent of the owner to ensure that Holtec Decommissioning International (HDI) is in full compliance with commercial agreements. Subsequent to the transaction close, NCI ensures that the required regulations are executed without infraction. In the post-close phase, NCI advises on the licensee’s obligations and assumes all other oversight functions and activities that typically belong in the realm of the nuclear plant’s owner. This includes performance of owner’s duties such as securing necessary site permits and assembling a qualified team of specialists to conduct periodic programmatic assessments.
NCI is also tasked with monitoring the withdrawals from the Decommissioning Trust Fund (DTF) in compliance with the applicable owner financial procedures, NRC guidelines, and IRS statutes. Another key function of NCI includes an independent assessment of the investment strategies for the DTF that accords with Holtec’s conservative investment policy and emphasizes the fund’s resilience in the face of market volatility.
Corporate Independence: NCI is administratively independent from other Holtec entities. NCI’s management chain leads directly to the CEO of Holtec International. NCI’s administrative independence from other Holtec operating entities engaged in decommissioning such as HDI is a critical feature of its organizational structure.
The oversight function of NCI in decommissioning projects is summarized below. They encompass the principal goals of the decommissioning project which the NCI personnel are expected to keep as foremost considerations in their project execution plan.
NCI’s Principal Oversight Functions
- The decommissioning program is optimized to ensure protection of public health and safety which must trump speed and expediency, while maintaining efficiency.
- Operational measures have been established to ensure the risk of spread of contamination at any time is minimized.
- The oversight function means a procedure-guided invigilation as well as a fresh contemplation into “what if” scenarios that may bear upon safety.
- The dry storage operations will be carried out ALARA.
- Provisions of Holtec’s QA program are faithfully applied across all operations including Root Cause Evaluation & Corrective Action Requests,
- There are large margins of safety against heavy load handling operations in excess of those mandated by NUREG-0612 and ANSI-14.6.
- The operating procedures are focused to prevent injury to the workers.
- Maximum capacity casks are developed, licensed and utilized to minimize the number of off-site shipments of non-fissile radioactive waste.
- The quantity of the radioactive water is minimized by precise decontamination of contaminated structures and systems.
- The decommissioning project plan is focused on developing a practicable approach for re-purposing of the site.
- The workers employed to carry out decommissioning are trained to the highest standards of safety and craftsmanship.
- An effective program of refresher training for the workers has been implemented.
- The execution of the project will adhere to Holtec’s QA program in every applicable respect.
- The project will leverage the large body of lessons-learned literature accumulated by Holtec’s site services teams.
- The security of the site is safeguarded by qualified personnel and effective procedures.
- The requirements by state and federal authorities are incorporated in the decommissioning procedures and observed throughout the project.
- Measures have been adopted to minimize disruption to the local commercial traffic during off-site shipment of waste.
- A robust self-assessment process for safety-significant operations has been developed and implemented.
- Withdrawals from DTF are prudently made and are well supported as to their need.
- Insurance commitments and requirements are maintained.