ML15119A099
| ML15119A099 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 07/07/2015 |
| From: | Camper L Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | Sauger J ZionSolutions |
| Hickman J | |
| References | |
| TAC J52987, TAC J52988 | |
| Download: ML15119A099 (4) | |
Text
July 7, 2015 Mr. John Sauger General Manager Zion Restoration Project ZionSolutions LLC 101 Shiloh Blvd.
Zion, IL 60099-2797
SUBJECT:
ZION NUCLEAR POWER STATION, UNITS 1 AND 2 - REQUEST FOR EXEMPTION FROM CERTAIN SECURITY REQUIREMENTS IN 10 CFR PART 37 (TAC NOS. J52987 AND J52988)
Dear Mr. Sauger:
By letter dated March 13, 2014, (Agencywide Documents and Access Management System (ADAMS) Accession No. ML14073A069) as supplemented July 21, 2014, (ML14204A055), and February 5, 2015, (ML15040A133), ZionSolutions, LLC (ZS), pursuant to 10 CFR 37.11, Specific Exemptions, submitted a request for an exemption from certain security requirements in Part 37 of Title 10 of the Code of Federal Regulations (10 CFR Part 37), for the Zion Nuclear Power Station (ZNPS). These submittals are being withheld from public disclosure as Security-Related Information. Your request for exemption was based on certain alternative protective measures that did not meet the specific requirements of 10 CFR Part 37, but that you contended met the underlying purpose of the regulations.
On March 13, 2014, the NRC issued Enforcement Guidance Memorandum 2014-001: Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 And 52, (ML14056A151). This enforcement guidance memorandum (EGM) provided guidance for dispositioning violations associated with Part 37 of Title 10 of the Code of Federal Regulations (10 CFR), Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material, with respect to large components containing category 1 or category 2 quantities of radioactive material, or category 1 and category 2 quantities of radioactive material stored in robust structures at power reactor facilities licensed under 10 CFR Parts 50 and 52.
J. Sauger 2 Our review of your exemption request has determined that the facilities, conditions and planned actions as described in your request are consistent with the facilities, conditions and planned actions which qualify for enforcement discretion as described in the EGM. Therefore, the EGM provides an appropriate regulatory basis for your situation and obviates the need for an exemption. Based on the above, your request for exemptions from 10 CFR Part 37 is denied.
Should you wish to receive the discretion available under EGM 2014-001, you should retain a copy of the documentation related to your exemption request as this documentation will serve as your written analysis that describes the security measures you will use to detect, assess, and respond to an actual or attempted theft or diversion for your large components and robust structures. You are also reminded to retain a written analysis documenting that your security measures do not decrease the effectiveness of your 10 CFR Part 73 security plan.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions regarding this action please contact John Hickman at 301-415-3017 or John.Hickman@nrc.gov.
Sincerely, R/A Larry W. Camper, Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-295 and 50-304 License Nos.: DPR-39 and DPR-49 cc: Zion Service List
J. Sauger 2 Our review of your exemption request has determined that the facilities, conditions and planned actions as described in your request are consistent with the facilities, conditions and planned actions which qualify for enforcement discretion as described in the EGM. Therefore, the EGM provides an appropriate regulatory basis for your situation and obviates the need for an exemption. Based on the above, your request for exemptions from 10 CFR Part 37 is denied.
Should you wish to receive the discretion available under EGM 2014-001, you should retain a copy of the documentation related to your exemption request as this documentation will serve as your written analysis that describes the security measures you will use to detect, assess, and respond to an actual or attempted theft or diversion for your large components and robust structures. You are also reminded to retain a written analysis documenting that your security measures do not decrease the effectiveness of your 10 CFR Part 73 security plan.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions regarding this action please contact John Hickman at 301-415-3017 or John.Hickman@nrc.gov.
Sincerely, R/A Larry W. Camper, Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-295 and 50-304 License Nos.: DPR-39 and DPR-49 cc: Zion Service List ML15119A099 OFFICE RDB/PM RDB/LA RDB/BC NSIR OGC DWMEP/DD NAME JHickman CHolston BWatson SWastler ACoggins LCamper DATE 5/ 1 /15 5/ 4 /15 5/ 4 /15 5/ 18 /15 6/ 5 /15 6/ 25 /15 OFFICIAL RECORD COPY
Zion Nuclear Power Station, Units 1 and 2 Service List cc:
Ken Robuck Kelly F. Grahn President of Logistics, Processing and Senior Health Physicist, Unit Supervisor Disposal Group Bureau of Radiation Safety, Environmental EnergySolutions Management 423 West 300 South, Suite 200 Illinois Emergency Management Agency Salt Lake City, UT 84101 245 W Roosevelt Road, Building 8, Suite 55 West Chicago, IL 60185 John Sauger Senior VP & General Manager Mr. Kent McKenzie ZionSolutions LLC Emergency Management Coordinator 101 Shiloh Blvd. Lake County Emergency Management Zion, IL 60099-2797 Agency 1303 N. Milwaukee Avenue Gerard van Noordennen Libertyville, IL 60048-1308 VP Regulatory Affairs ZionSolutions, LLC Regional Administrator 101 Shiloh Blvd. U.S. NRC, Region III Zion, IL 60099-2797 2443 Warrenville Road Lisle, IL 60532-4352 Anthony Orawiec Decommissioning Plant Manager John E. Matthews ZionSolutions, LLC Morgan, Lewis & Bockius LLP 101 Shiloh Blvd. 1111 Pennsylvania Avenue, NW Zion, IL 60099-2797 Washington, DC 20004 Dan Shrum Tom Rielly, Executive Principal Senior VP Regulatory Affairs Vista 360 EnergySolutions 649 Innsbruck 423 West 300 South, Ste. 200 Libertyville, IL 60048 Salt Lake City, UT 84101 Director Spent Fuel & Decommissioning Russ Workman Strategy General Counsel Exelon Generation Company, LLC EnergySolutions 4300 Winfield Road 423 West 300 South, Suite 200 Warrenville, IL 60555 Salt Lake City, UT 84101 J. Bradley Fewell Alwyn C. Settles Associate General Counsel Section Head, Nuclear Facility Inspection Exelon Corporation, LLC Bureau of Nuclear Facility Safety 4300 Winfield Rd.
Illinois Emergency Management Agency Warrenville, IL 60555 1011 North St., PO Box 250 Mazon, IL 60444 Document Control Desk - Licensing Exelon Generation Company, LLC Mayor of Zion 4300 Winfield Road Zion, IL 60099 Warrenville, IL 60555