ML22294A162

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Request for Extension of Order Approving Transfer of the License for Zion Nuclear Power Station, Units 1 and 2, from Zionsolutions, LLC to Constellation Energy Company, LLC
ML22294A162
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 10/19/2022
From: Sauger J
EnergySolutions
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
ZS-2022-045
Download: ML22294A162 (1)


Text

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ZIONSOLUTIONSL-lC _ _ _ _ _ _ __ An EnergySallltfons Company October 19, 2022 ZS-2022-045 U.S. Nuclear Regulatory I

Commission ATTN: Document Control Desk Washington, DC 20555-0001 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50~295 and 50-304 I

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Subject:

Request for Extension of Order Approving Transfer of the License for Zion Nuclear Power Station, Units 1 and 2, from ZionSolutions, LLC to Constellation Energy Company, LLC

References:

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1) Letter from Ken Robuck (EnergySolutions) and J. Bradley Fewell (Exelon Generation Company( LLC), to U.S. Nuclear Regulatory Commission, "Application for License Transfers:and Conforming Administrative License Amendments," dated July 24, 2018
2) Letter froµi Gerard van Noordennen (ZionSolutions, LLC), to U.S. Nuclear Regulatory Commission, "Supplemental Information Regarding Application for License Transfers and Conf6rming Administrative License Amendments," dated January 21, 2019
3) Letter froinI John B. Hickman (U.S. Nuclear Regulatory Commission), to John Sauger, (EnergySolutions), "Order Approving Transfer of the Licenses from ZionSolutions, LLC to Exelon:Generation Company, LLC and Conforming Administrative License Amendm~nts (EPID L-2018-LLA-0217), "dated November 26, 2019 I
4) Letter froin Gerard van Noordennen (ZionSolutions, LLC), to U.S. Nuclear Regulatory Commission, "Request for Extension of Order Approving Transfer of License for Zion Nuclear P:ower Station, Units 1 and 2," dated August 27, 2020
5) Letter froin John W. Lubinski (U.S. Nuclear Regulatory Commission), to John Sauger, I

(EnergySqlutions), "Order Extending the Effectiveness of the Approval of the Transfer of the Licenses from ZionSolutions, LLC to Exelon Generation Company, LLC and Conforming Administrative License Amendments (EPID L-2020-LLO-0007),"

dated October 21, 2020

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6) Letter from Gerard van Noordennen (ZionSolutions, LLC), to U. S. Nuclear Regulatory Commission, "Request for Extension of Order Approving Transfer of License for Zion Nuclear Power Station, Units 1 and 2," dated April 15, 2021 I
7) Letter from John B. Hickman (U.S. Nuclear Regulatory Commission), to John Sauger, (EnergyS6lutions), "Order Approving Transfer of the Licenses from ZionSolutions, LLC to Exelon !Generation Company, LLC and Conforming Administrative License Amendm~nts (EPID L-2018-LLA-0217), "dated May 12, 2021
8) Letter from Gerard van Noordennen (Z/onSolutions, LLC), to U. S. Nuclear Regulatory Commission, "Request for Extension of Order Approving Transfer of License for Zion Nuclear P~wer Station, Units 1 and 2," dated August 17, 2021 I

101 Shiloh Boulevard, Zion

  • IL 60099 (2~4) 789-4016
  • Fax: (224) 789-4008
  • www.zionsolutionscompany.com I

I ZionSolutions, LLC:

ZS-2022-045  :

Page 2 of 3

9) Letter fro:µi Marlayna Doell (U.S. Nuclear Regulatory Commission), to John Sauger, (EnergySblutions), "Order Extending the Effectiveness of-the Approval of the Transfer of the Licenses from ZionSolutions, LLC to Exelon Generation Company, LLC and Conforming Administrative License Amendments (EPID L-2020-LLO-0007),"

dated August 31, 2021 I

10) Letter from Kimberly Conway (U.S. Nuclear Regulatory Commission), to John Sauger, (Energy Solutions), "Regulatory Audit Plan Regarding ZionSolutions' Response to the Request for Additional Information Related to Partial Site Release and Recent Site Survey Attivities, " dated July 19, 2022
11) Letter froin Gerard van Noordennen (ZionSolutions, LLC), to U. S. Nuclear Regulatory Commission, "License Amendment Request for the License Termination Plan, Zion Nuclear Ppwer Station, Units 1 and 2," dated March 23, 2022 By letter dated July 2~, 2018 (Reference 1), as supplemented by letter dated January 21, 2019 (Reference 2), ZionSqlutions, LLC (ZS) and Exelon Generation Company, LLC (EGC) submitted an application requesting U.S. Nuclear Regulatory Commission (NRC) consent for the direct transfer of ZS's Facility Operating License Nos. DPR-39 and DPR-48, for Zion Nuclear Power Station, Units 1 and 2, respectively (Zion), and the associated general license to the Zion Independent Spent Fuel Storage Installation, to EGC. Specifically, ZS and EGC requested that the NRC consent to the direct transfer of ZS' s ownership interest in, and management authority of, Zion back to EGC upon the completion of decommissioning activities at the ZNPS site. ZS and EGC also requested approval of conforming amendments to the licenses pursuant to 10 CPR 50.80 and 10 CPR 50.90.

Upon completion of its review, the NRC issued an Order providing consent of the proposed license transfers, subject to the condition described in the order, and approval of the conforming license amendments (Enclos-dre 1 to Reference 3). The Order states, in part, that should the proposed direct license transfers not be completed within one year of the Order's date of issuance, the Order shall become null and void; provided, however, that upon written application and for good cause shown, such date may be ext~nded by order. The Order was extended for six months upon ZionSolutions' request based on continuing NRC review of the Final Status Survey Reports (FSSRs) and their associated Release R~cords (References 4 and 5). The Order was extended again for six months upon ZionSolutions' request based on continuing NRC review of the Final Status Survey Reports (FSSRs) and their associated R;elease Records (References 6 and 7). Due to a lack ofNRC resources, the order was again extended to November 26, 2022 (References 8 and 9).

The purpose of this letter is to request that the effectiveness of the order approving the transfer of licenses and conforming amendments be extended another six months. The extension would allow sufficient time to complete NRC review of the of the FSSRs and their associated Release Records.

ZionSolutions, LLC  !

1 ZS-2022-045 Page 3 of 3 There is good cause to extend the existing approval. We were informed that the NRC review will restart on November 14, 2022 using the results of a recently completed audit (Reference 10) of the FSSRs and their asso6iated Release Records. Based on the lack of dedicated resources to complete the NRC review, the "NRC Staff has indicated that additional time will be needed to address any questions or potential:issues identified by the NRC during the audit. To date, the NRC has also been unable to provide an acceptance review and review schedule for the associated license amendment request submitted on March 23, 2022 (Reference 11). The extension would allow adequate time for the NRC to complete their review if dedicated resources were provided. A final determination regarding the release ?f land for umestricted use is needed since the reports and release records were submitted two and a half years ago.

In accordance with 10 CPR 50 .91 (b )(1 ), a copy of this submittal has been sent to the State of Illinois.

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There are no regulatory commitments made in this submittal. If you should have any questions regarding this submitfal, please contact Gerard van Noordennen at (860) 462-9707.

I Respectfully, JO h n ' j\John 1

1

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1Digitally signed by Sauger I /, ,.

Sa U g err_:./::l_J'.:>at~2022.10.19 10:24:18 -04'00' I

John Sauger 1 President Reactor D&D Division and CNO cc: Kimberly Comyay, Project Manager, U.S. NRC Shaun Anderson, Chief, Decommissioning Branch, U.S. NRC I

Jane Marshall, Director, Decommissioning, Uranium Recovery and Waste Programs Division, U.S. NRC John Lubinski, Director, Office of Nuclear Material, Safety and Safeguards, U.S. NRC John Giessner, Region III Administrator, U.S. NRC Zion Nuclear Power Station, Units 1 and 2, License Transfer Service List

I Zion Nuclear Power Station, Units 1 and 2, License Transfer Service List Ken Robuck Steven A. Reynolds President and CEO Manager, Nuclear Facility Inspection EnergySolutions . Division of Nuclear Safety I

299 South Main Street, Suite 1700 Illinois Emergency Management Agency I

Salt Lake City, UT 8:4111 245 W. Roosevelt Road, Units 55 & 56 i West Chicago, Illinois 60185 John Sauger President and Chief Nuclear Officer Kelly F. Grahn, Senior Health Physicist Reactor D&D i Illinois Emergency Management Agency EnergySolutions Division of Nuclear Safety 121 W. Trade Street,: Suite 2700 245 W Roosevelt Road, Building 8, Suite 55 Charlotte, NC 28202: West Chicago, IL 60185 Todd Eiler William P. Mazzeno Vice President  : Emergency Management Coordinator I

D&D Engineering/Projects Lake County Emergency Management EnergySolutions Agency 121 W. Trade Street,! Suite 2700 1303 N. Milwaukee Avenue Charlotte, NC 28202 Libertyville, IL 60048-1308 I

Russ Workman General Counsel EnergySolutions 299 South Main Stre~t, Suite 1700 Salt Lake City, UT 8~ 111 I