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Category:Letter
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November 8, 2023 Mr. John T. Sauger, General Manager Zion Restoration Project ZionSolutions, LLC 101 Shiloh Boulevard Zion, IL 60099-2797
SUBJECT:
PARTIAL SITE RELEASE, ZION NUCLEAR POWER STATION, UNIT NOS. 1 and 2 (EPID L-2020-DSR-0000)
Dear Mr. Sauger:
On June 5, 2020 (Agencywide Document Access and Management System (ADAMS)
Accession No. ML20164A096), as supplemented on March 3, 2023 (ML23068A012)
ZionSolutions, LLC (ZS) submitted a request for partial site release (PSR) of the Zion Nuclear Power Station, Unit Nos. 1 and 2 (ZNPS or Zion) Facility Operation License Nos.
DPR-39 and DPR-48. ZS states in its request that ZS intends to remove an area consisting of seven basement survey units, 116 open land survey units (including three below grade excavation survey units), and five buried pipe survey units from the licenses consistent with the approved License Termination Plan (LTP) (ML18164A223 Pkg). The proposed action would effectively terminate the Zion Facility Operating Licenses outside the footprint for the remaining on-site Independent Spent Fuel Storage Installation (ISFSI), which encompasses approximately 5 acres.
The NRC staff has completed its review of the Zion Final Status Survey Reports (FSSRs) and other documentation associated with removing all remaining survey units from the Zion Facility Operating Licenses outside the on-site ISFSI boundary: the area consisting of seven basement survey units, 116 open land survey units (including three below grade excavation survey units), and five buried pipe survey units from the licenses. The NRC staffs review considered if the FSSR for these survey units meets the criteria in 10 CFR 50.82(a)(11):
whether the remediation of these survey units is in accordance with the approved LTP and whether these survey units meet the criteria for unrestricted release in Subpart E, Radiological Criteria for License Termination, of 10 CFR Part 20, Standards for Protection Against Radiation. The radiological dose contributions associated with the 128 Zion survey units were evaluated in aggregate with the 214-acre parcel of land sub-divided into 11 survey units previously released to ensure that the site, as a whole (with the exception of the area inside the ISFSI boundary), meets the criteria for unrestricted release.
The NRC concluded that: (i) the remaining dismantlement has been performed in accordance with the approved LTP, (ii) the FSSs and associated documentation, including an assessment of dose contributions associated with parts released for use before approval of the LTP, demonstrate that the entire site, with the exception of the ISFSI which will remain under the License Nos. DPR-39 and DPR-48, have met the criteria for decommissioning in 10 CFR part 20, Subpart E, and (iii) ZS has met the 10 CFR Parts 30, Rules of General Applicability to Domestic Licensing of Byproduct Material, 10 CFR 40 Domestic Licensing of Source Material, and 10 CFR Part 70, Domestic Licensing of Special Nuclear Material, requirements for forwarding of specific records to NRC prior to
J. Sauger 2 PSR. The NRC concludes that ZS satisfied the requirements for termination of the Zion site outside the boundary of the on-site ISFSI, as stated in 10 CFR 50.82(a)(11).
Therefore, the NRC staff finds the release of the 121 survey units to be acceptable and releases these survey units from the Zion Facility Operation Licenses, No. DPR-38 and DRP-49. This PSR supports the Direct License Transfer Order issued November 26, 2019 (ML19228A130) and the two Indirect License Transfer Orders issued on November 16, 2021 (ML21277A192) and May 2, 2022 (ML22076A008 Pkg), respectively, involving the Zion Licenses.
The enclosure to this letter contains the NRC staffs safety evaluation and analysis of the portions of the Zion FSSR associated with the remaining survey units and supports the determination that these 121 survey units may be released from the Zion Facility Operating Licenses under 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. This evaluation also includes other license termination verification activities that were completed to support removal of this portion of the site from the ZNPS licenses.
The NRC now considers the Zion Facility Operating Licenses, No. DPR-38 and No. DPR-49 to be terminated outside the boundary of the on-site ISFSI. Following their removal from the licenses, in the unlikely event the released areas were to become radiologically contaminated because of later decommissioning activities at the on-site ISFSI, the contamination would be considered an offsite release, and subject to 10 CFR Part 20.
The NRC staff also reviewed the residual radioactivity values in the Zion FSSRs and compared them to the trigger values in the 2002 Memorandum of Understanding (MOU) between the NRC and the U.S. Environmental Protection Agency (EPA) entitled Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites. Based on this review, the residual radioactivity in soil and groundwater at the site do not exceed the trigger values in the MOU and, as such, Level 2 consultation with EPA in accordance with the MOU is not required.
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 Website at http://www.nrc.gov/reading-rm/adams.html.
J. Sauger 3 If you have any questions concerning this evaluation, please contact Amy Snyder, the Zion Project Manager, at (301) 4156822 or via email at Amy.Snyder@NRC.gov.
Sincerely, Signed by Marshall, Jane on 11/08/23 Jane E. Marshall, Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-295, License No. DPR-39 Docket No. 50-304, License No. DPR-48 Docket No. 72-1037
Enclosure:
- 1. Safety Evaluation Related to the Partial Site Release, Facility Operating License Nos.DPR-39 AND DPR-48 cc: ZION List Serv A. Hazelhoff, EnergySolutions J. Wheat, EnergySolutions
ML23286A304; Ltr ML23286A309 OGC/GCHA OFFICE NMSS/DUWP/RDB NMSS/DUWP/RTAB NMSS/DFM/STLB
/AGCNRP/NLO NAME ASnyder AS CMcKenney CM YDiaz-Sanabria YD KRoach KR DATE Oct 16, 2023 Oct 23, 2023 Nov 7, 2023 Nov 7, 2023 OFFICE NMSS/DUWP/RDB NMSS/DUWP/RDB NMSS/DUWP NAME SAnderson SA ASnyder AS JMarshall JM DATE Nov 7, 2023 Nov 7, 2023 Nov 8, 2023