ZS-2013-0204, Revision to Previously Submitted License Amendment and Exemption Request for Independent Spent Fuel Storage Installation Physical Security Plan
| ML13157A308 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 06/05/2013 |
| From: | Daly P ZionSolutions |
| To: | Document Control Desk, NRC/FSME |
| References | |
| ZS-2013-0204 | |
| Download: ML13157A308 (3) | |
Text
SAFEGUARDS INFORMATION ZIONSOLUTIONSLC An EnergySolutions Company 10 CFR 73.4 June 5, 2013 ZS-2013-0204 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Zion Nuclear Power Station (ZNPS), Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295, 50-304 and 72-1037
Subject:
Revision to Previously Submitted License Amendment and Exemption Request for Independent Spent Fuel Storage Installation Physical Security Plan Reference 1) requested an amendment to the ZNPS licenses to approve: 1) a revision to the Zion Nuclear Power Station (ZNPS) Physical Security Plan (PSP) including a Transfer Plan; 2) a new stand-alone ZNPS Independent Spent Fuel Storage Installation (ISFSI) Physical Security Plan; and; 3) a revision to License Condition 2.C (6) of licenses DPR-39 and DPR-48 to incorporate the ISFSI PSP. Reference 1 also identified the existing NRC approved exemptions to various provisions of 10 CFR 73.55 that would be applied to the ISFSI PSP (and several that would not).
This submittal supplements the request previously proposed by Reference 1) and supersedes the version of the ZNPS Independent Spent Fuel Storage Installation (ISFSI) Physical Security Plan and associated exemption requests previously submitted therewith. No changes are made to the previously submitted revision to the existing Defueled Physical Security Plan or its attached Fuel Transfer Plan or to the previously proposed revisions to License Condition 2.C (6).
The proposed amendment reflects the intent of ZionSolutions, LLC (ZS) to transfer all spent nuclear fuel from wet storage that is in the spent fuel pool to dry storage casks located at an on-site ISFSI. Greater than Class C (GTCC) low level radioactive waste will also be transferred to the ISFSI from the Containment Buildings.
Pursuant to 10 CFR 73.5, "Specific Exemptions," ZS is requesting NRC approval of exemptions from certain requirements of 10 CFR 73.55, "Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage." Specific exemption requests have been provided in Enclosure 1 to affirm the application of the relevant, existing exemptions to ISFSI security operations and to request several new exemptions that are appropriate for the stand-alone ISFSI.
SAFEGUARDS INFORMATION Document transmitted herewith contains SGI & OUO-SRI. When separated from enclosures, this document is DECONTROLLED.
101 Shiloh Boulevard, Zion
- IL 60099 (224) 789-4016 - Fax: (224) 789-4008
- www.zionsolutionscompany.com
SAFEGUARDS INFORMATION ZionSolutions, LLC ZS-2013-0204 Page 2 of 3 The evaluation of the proposed ZNPS ISFSI Physical Security Plan and associated exemption requests is provided in Enclosure 2. The evaluation shows that the new ISFSI Physical Security Plan supplements the existing security plan commitments.
The new ZNPS ISFSI Physical Security Plan is provided in Enclosure 3. The ZNPS ISFSI Physical Security Plan meets the additional security measures for physical protection and access authorization requirements for ISFSIs as provided to ZS in NRC Order EA-1 1-268 issued on November 10, 2011 (Reference 3). The commitments to the additional security measures and access authorization requirements are included in the plan and a response to the order was provided on January 9, 2012 (Reference 5).
In accordance with 10 CFR 50.91, ZS is notifying the State of Illinois of this license amendment request by transmitting a copy of this letter and enclosures 1 and 2 to the designated State Official.
Approval of the proposed amendment and exemptions is requested by August 1, 2013 in order to support the decommissioning and spent fuel transfer schedule for the ZNPS. Once approved, the amendment and exemption will be implemented prior to the start of spent fuel transfer operations. to this cover letter contains Safeguards Information (SGI) of a type specified in 10 CFR 73.22(a)(1) and 10 CFR 73.22(a)(4) is being withheld from public disclosure. In accordance with 10 CFR 2.3 90, a copy of Enclosures 1, 2 and 3 contain Official Use Only -
Security Related Information (OUO-SRI), when detached from Enclosure 4, do not contain Safeguards Information.
If you have any questions regarding this submittal, please contact Mr. Patrick Thurman of my staff at (224) 789-4041.
- Patrick Daly z
Senior Vice President and Ge ral Manager ZionSolutions, LLC
References:
- 1) Patrick Thurman, ZionSolutions. LLC, Letter to John Hickman, U.S. Nuclear Regulatory Commission, "License Amendment and Exemption Request for Independent Fuel Storage Installation Physical Security Plan," dated June 18, 2012.
SAFEGUARDS INFORMATION Document transmitted herewith contains SGI & OUO-SRI. When separated from enclosures, this document is DECONTROLLED.
SAFEGUARDS INFORMATION ZionSolutions, LLC ZS-2013-0204 Page 3 of 3
- 2) Dino C. Scaletti, U.S. Nuclear Regulatory Commission, Letter to Oliver D. Kingsley, President, Commonwealth Edison Company, "Zion Nuclear Power Station, Units I and 2 -
Exemption From Certain Requirements of 10 CFR 73," dated October 18, 1999.
- 3) John B. Hickman, U.S. Nuclear Regulatory Commission, Letter to John A. Christian, ZionSolutions, LLC, "Zion Nuclear Power Station, Units 1 and 2 - Issuance of Exemption From Security Requirements of 10 CFR Part 50 and 10 CFR Part 73," dated November 10, 2011.
- 4) Daniel H. Dorman, U.S. Nuclear Regulatory Commission, Letter to John A. Christian, ZionSolutions, LLC, "Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Zion Nuclear Power Station Independent Spent Fuel Storage Installation," Order EA-1 1-268, dated December 20, 2011.
- 5) Patrick S. Thurman, ZionSolutions, LLC, Letter to Director, Division of Spent Fuel Storage and Transportation, U.S. Nuclear Regulatory Commission, "Response to NRC Order EA-1 1-268, Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Zion Nuclear Power Station Independent Spent Fuel Storage Installation," dated January 9, 2012.
Attachment:
Enclosures:
(1) Existing Exemption Applicability to the ISFSI and New Exemption Request (OUO-SRI)
(2) Evaluation of Proposed Amendment (OUO-SRI)
(3) Summary of Changes to the ZNPS ISFSI Physical Security Plan (OUO-SRI)
(4) ZNPS ISFSI Physical Security Plan (SGI) cc: John Hickman, U.S. NRC Senior Project Manager (with Enclosures)
Doug Gardner, U.S. NRC Office of Nuclear Security and Incident Response (with Enclosures)
Service List (w/o Enclosures)
SAFEGUARDS INFORMATION Document transmitted herewith contains SGI & OUO-SRI. When separated from enclosures, this document is DECONTROLLED.