ML18033B152
| ML18033B152 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/06/2016 |
| From: | Rielly T Vista 360 |
| To: | John Hickman Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML18033B152 (3) | |
Text
Hickman, John From: Tom Rielly <tr649@sbcglobal.net>
Sent: Wednesday, January 06, 2016 2:20 PM To: Hickman(NMSS), John
Subject:
[External_Sender] Re: Fw: December 1, 2015 Public Meeting Hi John, Understood and accepted, hope you have a good recovery and a healthy 2016.
Thank you for the clarifications and additional insight on the 10 CFR 50.83 process and release.
As mentioned at the last Public Meeting (10 CFR 50.83), Vista 360 ( and the public as we would see it) do not oppose the request or the pending release of the land involved in the process. Thank you also for the use of clarifying visuals used at the last meeting and those conveyed to us. As you may know and understand outside the regulatory landscapes local communities struggle with the issues of economic impact and local and state taxation and businesses such the utility owners so while everything at Zion regarding the land is what it is FOR THE GENERAL PUBLIC due to the plotting and recording of land parcels it is difficult for them to sort all this out. Vista 360 gets a fair number of calls on this area. Your presentation visuals which you gave to us post meeting have helped in clarifying the terra firma related to the process.
FYI, Exelon Generation LLC has communicated with Vista 360, they have not made any determination on future land use or corporate plans for either the pending release or at full release of the available land excluding the isfsi and switch yard and infrastructure moving forward upon license termination so no granting of a Vista 360 option to purchase ( for public use and enjoyment) will be considered presently. Our interest is formally noted.
You have clarified that no financial reviews were conducted or required under 10CFR 50.83 which is understandable as is your response. As stated previously, from the get go of the Zion Decommissioning & Site Restoration Project the public has been very concerned about the subject of finances, oversight and outcomes. We see-this as continuing and probably expending due to the position the NRC now espouses towards the end of the project (previous LTP Public Meeting) that it has nothing to do with finances.As this mindset and position is the regulatory dictum so be it but that doesn't excuse the NRC from reasonable responsibilities and we see the Commission being out on a very weak limb if there has been any kind of financial chicanery or corporate self dealing any where along the line. Vista 360 sees the public ( the beneficiaries of Nuclear Regulation) as being entitled to fair and honest treatment in any Decommissioning & Site Rehabilitation Project and in the area of finances this has not been the case as there have been no reasonable full disclosures or project transparencies in this area, the licensee has not earned our Trust nor that of the public as a result of their long standing posture. Remember the NRC and its front line regulating Headquarters Team helped enable this Zion Decommissioning&.
Site Rehabilitation Model and did so under the prominent banner of "Stewardship" which begs the question for whom seeing as the previous licensee and the current successor licensees have no financial skin or equity in the game?
We can't think for moment that the NRC Commission as individually sitting commissioners understood what they were affirming and approving in a macro sense and that it was a given factor and known dimension that there was no oversight or regulation whatsoever regarding finances in what amounts to the largest Decommissioning & Site Rehabilitation in U.S.
Nuclear History being undertaken by a Limited Liability Company with what amounted to at the onset ( also since and presently} a questionably financially qualified corporate parent and related structure in a whole new and unproven model of Decommissioning & Site Rehabilitation.
Trust Documents as you may know carry a standard of reason and as you may know or now be advised, the licensee, Zion Solutions under its 2 iterations of ownership (approved license transfers by the NRC) and 2 successive officers/
general managers at ZS LLC to date have maintained by narrative pronouncements during infrequent local company public meetings for now going on 5+ years that in fact everything they do - Zion Solutions LLC in regard to finances which is usually presented on a single abbreviated slide with narrative comment on the Zion Decommissioning & Site Rehabilitation Project (almost a $1.0 BIL Project at conclusion) is done so in the context of" everything we do {ZS) is fully regulated and overseen by the U.S. Nuclear Regulatory Commission and in addition to that we are required to make annual filings" Vista 360 is a public interest leadership group and making predictions is not coincident with our mission but I guess as we are at the beginning of 2016 that we will make a gratuitous prediction- it will be very challenging and difficult under the given circumstances for the U.S. Nuclear Regulatory Commission to detach itself from the TAR BABY of finances it embraced and opined to and approved on this Zion Decommissioning & Site Rehabilitation project at it's onset. We can only hope that the Zion Decommissioning & Site Rehabilitation Project is in its entirety concluded efficiently, effectively and honestly benefiting all concerned.
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Thank you Thomas P. Rielly Executive Principal Vista 360 From: "Hickman(NMSS), John" <John.HickmanNMSS@nrc.gov>
To: Tom Rielly <tr649@sbcglobal.net>
Cc: "Watson, Bruce" <Bruce.Watson@nrc.gov>
Sent: Tuesday, January 5, 2016 3:25 PM
Subject:
RE: Fw: December 1, 2015 Public Meeting
- Tom, Sorry for the delay. Between the holidays and my involvement in an automobile accident I have missed some time. Answers are below in red.
John From: Tom Rielly [1]
Sent: Monday, January 04, 2016 5:05 PM To: Hickman(NMSS), John Cc: Watson, Bruce
Subject:
[External_Sender] Fw: December 1, 2015 Public Meeting Happy New Year!
The questions below went unanswered
Forwarded Message -----
From: Tom Rielly <tr649@sbcglobal.net>
To: "john.hickman@nrc.gov" <john.hickman@nrc.gov>
Sent: Thursday, December 3, 2015 6:22 AM
Subject:
December 1, 2015 Public Meeting
- John, The proposed release of a portion of the Zion Nuclear Power Station site as we understood pursuant to the meeting of Tuesday December 1, 2015 was formally covered under or by license designation land incorporated in the LTP submittal and LTP update formally submitted previously to the NRC but is now being processed under 10CFR 50.83 for release and all other statutory and regulatory requirements must continue to be met.
Please confirm that .our perspectives are correctly stated by the above.
The portion of the Zion Nuclear Power Station site that is proposed to be released under the 10. CFR 50.83 process was included in the LTP submittal as part of the property to be released from the license prior to transfer of the license back to Exelon. (The ISFSI area will remain under the Part 50 license for transfer back to Exelon.) The licensee has the option at any time to request the release from the license of any portion of the site using the 50.83 process. Prior to approval of the LTP the 50.83 process is the only methodology for release of a portion of the site from the license. At all times the licensee is expected to meet our regulatory requirements.
2
Regarding the proposed release of land connected to the operating license nos. DPR-39 and DPR-48 and NRC Docket Nos 50-295 & 50-304 and related documents previously submitted to the NRC involving License Termination Plan updates of Site Specific Decommissioning Costs :
Did the NRC request and then review estimates incorporated in the TLG Services, Inc. document related to submitals?
There are no financial evaluation requirements related to a 50.83 partial site release. The NRC did not perform any financial review related to the partial site release request since none are required.
In any evaluations to date in addressing the 10CFR 50.83 process, were any Decommissioning Trust Funds used or expended related to preparing the characterization of the acreage under the request?
As stated, the NRC did not perform any financial review related to the partial site release request. A financial review will be performed as part of the LTP review.
Amounts & Time Frames if so ..
Thank you Tom Rielly Executive Principal Vista 360 3