Energysolutions, LLC; Renewal Letter Dtd October 12, 2018, of NRC

~ ENERGYSOLUTIONS

October 12, 2018 DD-RR-2018-001

Licensing Assistance Team Division of Nuclear Materials Safety U.S. Nuclear Regulatory Commission, Region 1 2100 Renaissance Boulevard, Suite 100 King of Prussia, Pennsylvania 19406-2713

RE: Renewal ofNRC Materials License 39-35044-01

Dear Sirs,

EnergySolutions, LLC (ES) holds U.S. NRC Materials License 39-35044-01 (Docket# 030- 39013) for use at temporary job sites to support a variety of possible work scope activities at those sites. The Authorized Uses, listed in Section 9 of the license, are wide ranging and describe the variety of services involving radioactive material that ES is qualified to perform.

This license has been held for many years, based at various ES office/administrative locations. This license was most recently re-issued to support some administrative changes on December 28, 2016. This license is noted to expire on November 30, 2021.

This license is historically utilized on several occasions each year at a variety of temporary job sites, for periods that range from a single day to many months. ES does not maintain any site or facility at which radioactive material is possessed under this license. Upon each use of this license, all radioactive material is either shipped to another licensed facility and/or returned to the possession of the holder of a permanent license for the site/facility. These actions are completed before demobilizing from the temporary ES location and terminating that temporary license use.

Each use of this license since 2016 has happened to occur in an Agreement State, under the reciprocity process specified by that given state. Since that time, no uses of this license have occurred in states with NRC jurisdiction for activities involving handling of radioactive material.

During a routine inspection oflicense records in August of this year, an NRC inspector noted that despite continuing, periodic use of the license under reciprocity in Agreement States, the ES mobile license had not been used in an NRC jurisdiction since mid-2016. The inspector stated that this situation would be considered to meet the condition stated in item (3) on Page 3 of RIS 2015-19, Rev 1 ("no principal activities under the license have been conducted for a period of 24 months").

250 Berryhill Road, Suite 400 Columbia, South Carolina 29210 803-256-0450 • www.energysolutions.com October 12, 2018 DD-RR-2018-001 Page 2 of2

The inspector also advised that, given the usage history summarized above, ES should either terminate the license or obtain a license extension to keep the license active past January 1, 2019. The inspector stated that the use of the NRC Materials License to obtain reciprocity in Agreement States does not constitute "a principal activity" as defined in the regulations.

While we disagree with this interpretation of the regulations, in order to support the continuing business need for this Material License, ES has completed the attached NRC Form 313 for renewal oflicense 39-35044-01. No programmatic changes to the license program and procedures are associated with this renewal.

Please advise how to proceed with this renewal request. Thank you for your assistance in this matter.

Sincerely,

for Gerard P. Van N oordennen Vice President, Reactor D&D Projects N~C FORM 313 U.S, NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0120 EXPIRES: 06/30/2019 (10-2017) Estimated burden per response to comply with this mandatory collection request: 4.3 hours. Submittal of the 10 CFR 30, 32, application is necessary to determine that the applicant is qualified and that adequate procedures exist to protect the 33, 34, 35, 36, public health and safety. Send comments regarding burden estimate to the Information Services Branch (T-2 F43), 37, 39, and 40 APPLICATION FOR U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to [email protected], MATERIALS LICENSE and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0120), Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection does not display a currently valid 0MB control number, the NRG may not conduct or sponsor, and a person is not required to respond to, the information collection

INSTRUCTIONS: SEE THE CURRENT VOLUMES OF THE NUREG-1556 TECHNICAL REPORT SERIES ("CONSOLIDATED GUIDANCE ABOUT MATERIALS LICENSES") FOR DETAILED INSTRUCTIONS FOR COMPLETING THIS FORM: l!ltp://www,nrc.go'l/ru.!lln.9.,n11J_g_9i;_,i;_Q.l!l'-Ct!Q1li;/!11JLQ.Qfill;t<1ffl~I-~- SEND TWO COPIES OF THE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW.

APPLICATION FOR DISTRIBUTION OF EXEMPT PRODUCTS FILE APPLICATIONS WITH: IF YOU ARE LOCATED IN:

MATERIALS SAFETY LICENSING BRANCH ILLINOIS, INDIANA, IOWA, MICHIGAN, MINNESOTA, MISSOURI, OHIO, OR WISCONSIN, SEND DIVISION OF MATERIAL SAFETY, STATE, TRIBAL AND RULEMAKING PROGRAMS APPLICATIONS TO: OFFICE OF NUCLEAR MATERIALS SAFETY AND SAFEGUARDS U.S. NUCLEAR REGULA TORY COMMISSION MATERIALS LICENSING BRANCH WASHINGTON, DC 20555-0001 U.S. NUCLEAR REGULATORY COMMISSION, REGION Ill 2443 WARRENVILLE ROAD, SUITE 210 All OTHER PERSONS FILE APPLICATIONS AS FOLLOWS: LISLE, IL 60532-4352

IF YOU ARE LOCATED IN: IF YOU ARE LOCATED IN:

ALABAMA, CONNECTICUT, DELAWARE, DISTRICT OF COLUMBIA, FLORIDA, ALASKA, ARIZONA, ARKANSAS, CALIFORNIA, COLORADO, HAWAII, IDAHO, KANSAS, GEORGIA, KENTUCKY, MAINE, MARYLAND, MASSACHUSETIS, NEW HAMPSHIRE, LOUISIANA, MISSISSIPPI, MONTANA, NEBRASKA, NEVADA, NEW MEXICO, NORTH NEW JERSEY, NEW YORK, NORTH CAROLINA, PENNSYLVANIA, PUERTO RICO, DAKOTA, OKLAHOMA, OREGON, PACIFIC TRUST TERRITORIES, SOUTH DAKOTA, TEXAS, RHODE ISLAND, SOUTH CAROLINA, TENNESSEE, VERMONT, VIRGINIA, VIRGIN UTAH, WASHINGTON, OR WYOMING, ISLANDS, OR WEST VIRGINIA,

SEND APPLICATIONS TO: SEND APPLICATIONS TO: LICENSING ASSISTANCE TEAM NUCLEAR MATERIALS LICENSING BRANCH DIVISION OF NUCLEAR MATERIALS SAFETY U.S. NUCLEAR REGULATORY COMMISSION, REGION IV U.S. NUCLEAR REGULATORY COMMISSION, REGION I 1600 E. LAMAR BOULEVARD 2100 RENAISSANCE BOULEVARD, SUITE 100 ARLINGTON, TX 76011-4511 KING OF PRUSSIA, PA 19406-2713

PERSONS LOCATED IN AGREEMENT STATES SEND APPLICATIONS TO THE U,S, NUCLEAR REGULATORY COMMISSION ONLY IF THEY WISH TO POSSESS AND USE LICENSED MATERIAL IN STATES SUBJECT TO U,S, NUCLEAR REGULATORY COMMISSION JURISDICTIONS, 1. TH IS IS AN APPLICATION FOR (Check appropriate item) 2. NAME AND MAILING ADDRESS OF APPLICANT (Include zip code) D A. NEW LICENSE Jon R. Newman, RSO EnergySolutions, Inc. D B AMENDMENT TO LICENSE NUMBER 250 Berryhill Road, Suite 400 [Z] C. RENEWAL OF LICENSE NUMBER 39-35044-14 Columbia, South Carolina 29210

3. ADDRESS WHERE LICENSED MATERIALS WILL BE USED OR POSSESSED 4. NAME OF PERSON TO BE CONTACTED ABOUT THIS APPLICATION Gerard P. Van Noordennen

Various temporary locations as necessary to support BUSINESS TELEPHONE NUMBER BUSINESS CELLULAR TELEPHONE NUMBER Gerard P. Van Noordennen 224-789-4025 scope of contracted projects and work activities. BUSINESS E-MAIL ADDRESS [email protected]

SUBMIT ITEMS 5 THROUGH 11 ON 8-1/2 X 11" PAPER. THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED IS DESCRIBED IN THE LICENSE APPLICATION GUIDE. 5. RADIOACTIVE MATERIAL 6. PURPOSE(S) FOR WHICH LICENSED MATERIAL WILL BE USED. a. Element and mass number; b. chemical and/or physical form; and c. maximum amount 7. INDIVIDUAL(S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING AND which will be possessed at any one time. EXPERIENCE. 8. TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS. 9. FACILITIES AND EQUIPMENT. 10. RADIATION SAFETY PROGRAM. 11. WASTE MANAGEMENT. 12. LICENSE FEES (Fees required only for new applications, with few exceptions*) I CA~~~RY AMOUNT (See 10 CFR 170 and Section 170.31) IENCLOSED $1 "'Amendments/Renewals that increase the scope of the existing license to a new or higher fee category will require a fee.

PER THE DEBT COLLECTION IMPROVEMENT ACT OF 1996 (PUBLIC LAW 104-134), YOU ARE REQUIRED TO PROVIDE YOUR TAXPAYER IDENTIFICATION NUMBER. PROVIDE THIS INFORMATION BY COMPLETING NRC FORM 531: tlll!)~;l/www.nrc,g9y/reading-n11/\Jqc_-~9Jle~tj9n~/{Qrm~/n.r~~ni.nf9,htrnJ.

13. CERTIFICATION. (Must be completed by applicant) THE APPLICANT UNDERSTANDS THAT ALL STATEMENTS AND REPRESENTATIONS MADE IN THIS APPL/CATION ARE BINDING UPON THE APPLICANT.

THE APPLICANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPLICANT, NAMED IN ITEM 2, CERTIFY THAT THIS APPLICATION IS PREPARED IN CONFORMITY WITH TITLE 10, CODE OF FEDERAL REGULATIONS, PARTS 30, 32, 33, 34, 35, 36, 37, 39, AND 40, AND THAT ALL INFORMATION CONTAINED HEREIN IS TRUE AND CORRECT TO THE BEST OF THEIR KNOWLEDGE AND BELIEF. WARNING: 18 U.S.C. SECTION 1001 ACT OF JUNE 25, 1948 62 STAT. 749 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT OR REPRESENTATION TO ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATIER WITHIN ITS JURISDICTION.

CERTIFYING OFFICER -- TYPED/PRINTED NAME AND TITLE DATE SIGNATU~ ~--' Gerard P. Van Noordennen, V.P., Reactor D&D Projects ~ for Gerry van Noordennen 10/12/2018

NRG FORM 313 (10-2017) ,NOC FORM 313 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO_ 3150-0120 EXPIRES: 06/30/2019 110-2017) Esnmated burden per response to comply w:th this mandatory coi1ect1on req:Jest 4 3 hours S·Jbm1tta1 of the 10 CFR 30, 32, appi1cat1on 1s necessary :a determine !hat the appt1cam 1s qua:ified and :ha; adequate procedures exist to pro\ect tne 33. 34, 35. 36, public hea!m and safety Send comments regarding burden es:1mate to the lntorma-c;on Services Branch 1T.2 F43j 37, 39, and 40 APPLICATION FOR U.S Nucear Regulatory Comm1ss1on. Washington. DC 20555-000t or by e-ma11 :o lnfoco11ects Resource@nrc gov MATERIALS LICENSE and to the Desk Officer Office of Information and Regu1arory Affairs. NEOB-10202. (3150-0120), Office of Managemen'. and 8Jdge: Washing:on DC 20503 if a means used to impose an information co1,ect10n does no~ d1spay a va11d 0MB contra· num:}er tile NRC may no: conduct or soonsor and a person 1s not required :o respond '.O. :he co::ect1or.

APPLICATION FOR DISTRIBUTION OF EXEMPT PRODUCTS FILE APPLICATIONS WITH: IF YOU ARE LOCATED IN:

MATERIALS SAFETY LICENSING BRANCH ILLINOIS, INDIANA, IOWA, MICHIGAN, MINNESOTA, MISSOURI, OHIO, OR WISCONSIN, SEND DIVISION OF MATERIAL SAFETY. STATE. TRIBAL AND RULEMAKING PROGRAMS APPLICATIONS TO: OFFICE OF NUCcEAR MATERIALS SAFETY AND SAFEGUARDS U.S NUCLEAR REGULATORY COMMISSION MATER'AcS c!C;ENSING BRANCH WASHINGTON, DC 20555-0001 US. NUCcE/IR REGULATORY COMMISSION, REG10N ,II 2443 WARRENVILLE ROAD. SUITE 210 ALL OTHER PERSONS FILE APPLICATIONS AS FOLLOWS: LISLE. :L 60532-4352

IF YOU ARE LOCATED IN: IF YOU ARE LOCATED IN:

ALABAMA, CONNECTICUT. DELAWARE, DISTRICT OF COLUMBIA, FLORIDA, ALASKA, ARIZONA, ARKANSAS, CALIFORNIA, COLORADO, HAWAII, IDAHO, KANSAS, GEORGIA, KENTUCKY, MAINE, MARYLAND, MASSACHUSETIS, NEW HAMPSHIRE, LOUISIANA, MISSISSIPPI, MONTANA, NEBRASKA, NEVADA, NEW MEXICO, NORTH NEW JERSEY, NEW YORK, NORTH CAROLINA, PENNSYLVANIA, PUERTO RICO, DAKOTA, OKLAHOMA, OREGON, PACIFIC TRUST TERRITORIES, SOUTH DAKOTA, TEXAS, RHODE ISLAND, SOUTH CAROLINA. TENNESSEE, VERMOITT, VIRGINIA, VIRGIN UTAH, WASHINGTON, OR WYOMING, ISLANDS, OR WEST VIRGINIA,

SEND APPLICATIONS TO; SEND APPLICATIONS TO: LICENSING ASSISTANCE TEAM NUCLEAR MATERIALS LICENSING BRANCH DIVISION OF NUCLEAR MATERIALS SAFETY U.S. NUCLEAR REGULATORY COMMISSION. REGION iV U.S. NUCLEAR REGULATORY COMMISSION, REGION: 1600 E. LAMAR BOULEVARD 2100 RENAISSANCE BOULEVARD. SUITE 100 ARLINGTON, TX 76011-4511 KING OF PRUSSIA, PA 19406-2713

PERSONS LOCATED IN AGREEMENT STATES SEND APPLICATIONS TO THE U.S. NUCLEAR REGULATORY COMMISSION ONLY IF THEY WISH TO POSSESS AND USE LICENSED MATERIAL IN STATES SUBJECT TO U.S. NUCLEAR REGULATORY COMMISSION JURISDICTIONS. 1. THIS IS AN APPLICATION FOR (Check appropnate 1tem) 2. NAME AND MAILING ADDRESS OF APPLICANT (Include zip code) D A. NEW LICENSE Jon R Newman, RSO EnergySolutions, Inc. D B AMENDMENT TO LICENSE NUMBER 250 Berryhill Road, Suite 400 0 C. RENEWAL OF LICENSE NUMBER 39-35044-14 Columbia, South Carolina 29210 3. ADDRESS WHERE LICENSED MATERIALS WILL BE USED OR POSSESSED 4. NAME OF PERSON TO BE CONTACTED ABOUT THIS APPLICATION Gerard P. Van Noordennen

BUS,NESS TELEPHO,~E NUMBER BUS,NESS CE"LULAR TELEPrlONE NUMBER Various temporary locations as necessary to support Gerard P. Van Noordennen 224-789-4025 scope of contracted projects and work activities. BUSINESS E-MAIL ADDRESS [email protected]

SUBMIT ITEMS 5 THROUGH 11 ON 8-112 X 11" PAPER. THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED 1S DESCRIBED IN THE LICENSE APPLICATION GUIDE. 5. RADIOACTIVE MATERIAL 6 PURPOSE(S) FOR WHICH LICENSED MATERIAL WILL BE USED. a. Element and rrass number: b. chemical and/or physical form; and c. maximum amount 7. INDIVIDUAL($) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING AND which will be possessed at any one time. EXPERIENCE. 8. TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS. 9. FACILITIES AND EQUIPMENT. 10 RADIATION SAFETY PROGRAM. 11 WASTE MANAGEMENT 12. LICENSE FEES (Fees required only for new applications, with few excepbons·) I AMOUNT (See 10 CFR 170 and Section 170.31) CA:E~RY IENCLOSED $1 "Amendments/Renewals that increase the scope of the existing license to a new or higher fee category will require a fee.

PER THE DEBT COLLECTION IMPROVEMENT ACT OF 1996 (PUBLIC LAW 104-134), YOU ARE REQUIRED TO PROVIDE YOUR TAXPAYER IDENTIFICATION NUMBER PROVIDE THIS INFORMATION BY COMPLETING NRC FORM 531: ht1Ps:/1www,.nrc,gov/r~a1Hng-rm/l1oc-cQllecliQrl$/f9rms/nrcS31 info.html

13. CERTIFICATION. (Must be completed by app/Jcam) THE APPLICANT UNDERSTANDS THAT ALL STATEMENTS AND REPRESENTATIONS MADE IN THIS APPLICATION ARE BINDING UPON THE APPLICANT.

THE APPLICANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPLICANT, NAMED IN ITEM 2, CERTIFY THAT THIS APPLICATION IS PREPARED IN CONFORMITY WITH TITLE 10, CODE OF FEDERAL REGULATIONS, PARTS 30, 32, 33, 34, 35, 36, 37, 39, AND 40, AND THAT ALL INFORMATION CONTAINED HEREIN IS TRUE AND CORRECT TO THE BEST OF THEIR KNOWLEDGE AND BELIEF. WARNING 18 U.S.C. SECTION 1001 ACT OF JUNE 25, 1948 62 STAT. 749 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT OR REPRESENTATION TO ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATIER WITHIN ITS JURISDICTION.

DATE CERTIFYING OFFICER - TYPED/PRINTED NAME AND TITLE SIGNA TUR:-A ~ __I Gerard P. Van Noordennen, V.P., Reactor D&D Projects ~ for Gerry van Noordennen 10/12/2018

NRC FORM 313 (10-2017)