ML25150A035
| ML25150A035 | |
| Person / Time | |
|---|---|
| Site: | Crane  (DPR-050) |
| Issue date: | 05/29/2025 |
| From: | Moore D Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| CCEC-25-001 | |
| Download: ML25150A035 (1) | |
Text
Crane Clean Energy Center 2625 River Road Middletown, PA 17057 www.constellation.com CCEC-25-001 10 CFR Part 50, Appendix B 10 CFR 50.59(d)(3) 10 CFR 50.71(c)
May 29, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Christopher M. Crane Clean Energy Center Renewed Facility License No. DPR-50 NRC Docket No. 50-289
Subject:
Request for Rescission of Partial Exemption from Certain Record Retention Requirements In Reference 1, Constellation Energy Generation (CEG) stated that CEG would request rescission of NRC-approved decommissioning-related exemptions as part of the Christopher M. Crane Clean Energy Center (CCEC) transition out of decommissioning. This letter provides CEGs request for NRC to rescind the partial exemption from certain record retention requirements previously issued in Reference 2. CEG requests recission of the partial exemption on the date that CCEC transitions from a decommissioning licensing basis to an operating reactor licensing basis (ORLB), coincident with the exemption request from 10 CFR 50.82(a)(2) submitted in Reference 3, if approved by NRC.
By letter dated July 12, 2019 (Reference 4), Exelon Generation Company, LLC1, submitted to NRC an exemption request from:
10 CFR 50, Appendix B, Criterion XVII, which requires certain records to be retained consistent with applicable regulatory requirements for a duration established by the licensee; 10 CFR 50.59(d)(3), which requires certain records to be maintained until termination of an operating licensing issued under this part; and, 10 CFR 50.71(c), which requires certain records to be retained for the period specified by the appropriate regulation, license condition, or technical specification (TS), or until termination of the license if not otherwise specified.
The partial exemption from recordkeeping requirements of 10 CFR Part 50, Appendix B, Criterion XVII; 10 CFR 50.59(d)(3); and 10 CFR 50.71(c) for CCEC was issued only to the extent necessary to allow CEG to advance the schedule to remove records associated with systems, structures, and components (SSCs) removed from the decommissioning licensing basis documents by appropriate change mechanisms (e.g., 10 CFR 50.48(f), 10 CFR 50.59, 10 CFR 50.90, 10 CFR 50.54(a),
10 CFR 50.54(p), or 10 CFR 50.54(q)). Records required by 10 CFR 50.75, Reporting and recordkeeping for decommissioning planning, or any other requirements of 10 CFR Part 50 applicable to decommissioning and dismantlement, as well as recordkeeping related to storage of spent fuel at the Independent Spent Fuel Storage Installation (ISFSI), were not subject to the partial exemption. Records associated with residual radiological activity and with programmatic 1 At that time, CEG was named Exelon Generation Company, LLC. See Reference 3, Page 2, Footnote 1.
May 29, 2025 U.S. Nuclear Regulatory Commission Page 2 controls necessary to support decommissioning, such as security and quality assurance, will continue to be retained as decommissioning records until termination of the license.
During the shutdown period, records have been retained in accordance with Appendix E, Section E.2 of the Decommissioning Quality Assurance Program (DQAP) (Reference 5), including those records related to SSCs removed from the decommissioning licensing basis documents by appropriate change mechanisms for which the allowable disposition schedule was advanced upon approval of the partial exemption. The records retention requirements implemented by the DQAP were previously required by CCEC Technical Specification (TS) 6.10. Relocation of the record retention requirements from the TS to the DQAP consistent with NRC Administrative Letter 95-06 was approved by the NRC in Reference 6.
CEG will continue to implement the records retention requirements detailed in the DQAP and Restoration Quality Assurance Program (Reference 5) for activities in support of the potential resumption of power operations until returning to the ORLB as approved by the NRC, at which time CCEC will transition to the CEG fleet Quality Assurance Topical Report.
There are no new or revised regulatory commitments contained in this submittal.
For questions regarding this submittal, please contact Hannah Pell, Regulatory Specialist, Crane Clean Energy Center, at hannah.pell@constellation.com.
Respectfully, Dennis M. Moore Senior Manager, Licensing Constellation Energy Generation, LLC cc:
NRC Regional Administrator - Region I NRC Director, NRR - DORL NRC Deputy Director, NRR - DORL NRC Project Manager, NRR-DORL - Crane Clean Energy Center Director, Bureau of Radiation Protection - Pennsylvania Dept of Environmental Protection Chairman, Board of County Commissioners of Dauphin County Chairman, Board of Supervisors of Londonderry Township
References:
- 1. Letter RS-24-121 from Constellation Energy Generation to U.S. Nuclear Regulatory Commission, Regulatory Path to Reauthorize Power Operations, dated November 4, 2024 (ML24310A104)
- 2. Letter from U.S. Nuclear Regulatory Commission to Exelon Generation Company, Three Mile Island Nuclear Station, Unit 1 - Partial Exemption from Certain Record Retention Requirements (EPID L-2019-LLE-0018), dated May 19, 2020 (Cover: ML20107J648; Partial Exemption: ML20107J698)
- 3. Letter RS-24-124 from Constellation Energy Generation to U.S. Nuclear Regulatory Commission, Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82, dated November 19, 2024 (ML24324A048)
Moore, Dennis M Digitally signed by Moore, Dennis M Date: 2025.05.29 09:46:25 -04'00'
May 29, 2025 U.S. Nuclear Regulatory Commission Page 3
- 4. Letter TM-19-068 from Exelon Generation Company to U.S. Nuclear Regulatory Commission, Three Mile Island Nuclear Station, Unit 1 - Request for Exemption from Record Retention Requirements, dated July 12, 2019 (ML19193A005)
- 5. Letter TMI-24-009/RS-24-130 from Constellation Energy Generation to U.S. Nuclear Regulatory Commission, Constellation Energy Generation, LLC, Decommissioning Quality Assurance Program, dated December 6, 2024 (Cover: ML24341A195; DQAP, Rev. 2:
ML24341A196; RQAP, Rev. 0: ML24341A197)
- 6. Letter from U.S. Nuclear Regulatory Commission to Constellation Energy Generation, Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendment No. 304 to the Renewed Facility Operating License No. DPR-50 to Revise the License Conditions and the Permanently Defueled Technical Specifications to Align to the Requirements for Permanent Removal of Spent Fuel from the Spent Fuel Pool, dated April 19, 2022 (ML22081A229)