ZS-2013-0326, Revision to Previously Submitted License Amendment and Exemption Request for Independent Spent Fuel Storage Installation Physical Security Plan

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Revision to Previously Submitted License Amendment and Exemption Request for Independent Spent Fuel Storage Installation Physical Security Plan
ML13283A004
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 10/04/2013
From: Daly P
ZionSolutions
To:
Document Control Desk, NRC/FSME, Office of Nuclear Material Safety and Safeguards
References
ZS-2013-0326
Download: ML13283A004 (6)
v • d • e


Text

SAFEGUARDS INFORMATION ZIONSOLUTIONSLLC An EnergySoItons Company 10 CFR 73.4 October 4, 2013 ZS-2013-0326 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: a) a revision to the Zion Nuclear Power Station (ZNPS) Physical Security Plan (PSP) including a Transfer Plan; b) a new stand-alone ZNPS Independent Spent Fuel Storage Installation (ISFSI) Physical Security Plan; and; c) 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).

One June 5, 2013, ZionSolutions, LLC (ZS) submitted Reference 2) to supplement the ZNPS ISFSI PSP and associated exemption requests provided in Reference 1). 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 previously submitted therewith. To clarify certain sections of the ZNPS ISFSI PSP, implementing procedures have been provided with this submittal. No changes are made to the previously submitted revision to the previously NRC approved Defueled Physical Security Plan or its attached Fuel Transfer Plan, to the previously proposed revisions to License Condition 2.C (6) or requested exemptions.

The proposed amendment including-the revision herein reflects the intent of 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.

The new ZNPS ISFSI Physical Security Plan, Revision 2 is provided in Enclosure 2. 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- 11-268 issued on November 10, 2011 (Reference 3). The commitments to the additional security measures and F-1,41Z-O Ao S5(

SAFEGUARDS INFORMATION Document transmitted herewith contains SGI & OUO-SRI. When separated from enclosures, this document is DECONTROLLED.

101 Shiloh Boulevard, Zion, IL60099 (224) 789-4016

  • Fax: (224) 789-4008 - www.zionsolutionscompany.com

SAFEGUARDS INFORMATION ZionSolutions, LLC ZS-2013-0326 Page 2 of 3 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 4).

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 to the designated State Official.

Approval of the proposed amendment and exemptions is requested within a reasonable time period to support ZionSolutions' expected fuel transfer readiness date of October 31, 2013. Once approved, the amendment and exemptions will be implemented prior to the start of spent fuel transfer operations.

Enclosure 1, 2 and 3 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 CYR 2.390, a copy of Enclosure 4 and 5 contain Official Use Only - Security Related Information (OUO-SRI), when detached from Enclosure 1, 2 and 3, 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 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.
2) Patrick Daly, ZionSolutions, LLC, Letter to John Hickman, U.S. Nuclear Regulatory Commission, "Revision to Previously Submitted License Amendment and Exemption Request for Independent Spent Fuel Storage Installation Physical Security Plan," dated June 5, 2013.
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.

SAFEGUARDS INFORMATION Document transmitted herewith contains SGI & OUO-SRI. When separated from enclosures, this document is DECONTROLLED.

SAFEGUARDS INFORMATION ZionSolutions, LLC ZS-2013-0326 Page 3 of 3

4) 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:

Affidavits

Enclosures:

(1) Summary of Changes to the ZNPS ISFSI Physical Security Plan (SGI)

(2) ZNPS ISFSI Physical Security Plan (SGI)

(3) Zion Station Procedures: (SGI)

  • ZS-IS-905, CAS Responsibilities (SGI)

(4) Zion Station Procedures: (OUO-SRI)

  • ZS-IS-904, NRC Threat Advisory and Protective Measures System (OUO-SRI)

" ZS-IS-909, ISFSI Personnel Access Control (OUO-SRI)

" ZS-IS-910, ISFSI Vehicle Control (OUO-SRI)

(5) Lesson Plans (OUO-SRI)

" Patrol Officer 1.13 (OUO-SRI)

  • Patrol Officer 1.8 (OUO-SRI) 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.

STATE OF ILLINOIS )

) SS COUNTY OF LAKE )

Patrick T. Daly, being duly sworn according to law deposes and says:

I am Senior Vice President and General Manager of ZionSolutions, LLC, and as such, I am familiar with the contents of this correspondence and the enclosures thereto, concerning the Zion Nuclear Power Station, Units 1 and 2, and the matters set forth therein are true and correct to the best of my knowledge, information, and belief.

Subscribed and Sworn to before me this 4t da of October, 2013 Notary Public of Illinois I* LINDA CHOU  !

OFFICIAL SEAL

" Notary Public, Statr of Illinois My Commission Expires December 07, 2015

Affidavit Pursuant to 10 CFR 2.390 STATE OF ILLINOIS )

) SS COUNTY OF LAKE )

I, Patrick Daly, depose and say that I am the Senior Vice President and General Manager of ZionSolutions, LLC (ZS), duly authorized to execute this affidavit, and have reviewed or cause to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commission's regulations for withholding this information.

ZS is requesting information contained within relating to the Zion Independent Spent Fuel Storage Installation (ISFSI) Physical Security Plan be withheld from public disclosure as commercial information concerning ZS's physical protection pursuant to 10 CFR 2.390(d) and (e). The information for which proprietary treatment is sought is contained in the attached Enclosures.

. r-,j/

Subscribed and Sworn to before me This 4 th day of October, 2013 Notar*

Zion Nuclear Power Station, Unit 1 and 2 License Transfer Service List cc:

Patrick T, Daly Russ Workman Senior VP and General Manager General Counsel ZionSolutions, LLC EnergySolutions 101 Shiloh Boulevard 423 West 300 South, Ste. 200 Zion, IL 60099 Salt Lake City, UT 84101 Patrick Thurman, Esq. Illinois Department of Nuclear Safety VP Regulatory Affairs, Licensing & Office of Nuclear Facility Safety Document Control 1035 Outer Park Drive ZionSolutions, LLC Springfield, IL 62704 101 Shiloh Boulevard Zion, IL 60099 Kent McKenzie Emergency Management Coordinator Gary Bouchard Lake County Emergency Management Agency VP Engineering, Ops & Nuclear Security 1303 N. Milwaukee Avenue and Decommissioning Plant Manager Libertyville, IL 60048-1308 ZionSolutions, LLC 101 Shiloh Boulevard Regional Administrator Zion, IL 60099 U.S. NRC, Region III 2443 Warrenville Road Alan Parker Lisle, IL 60532-4352 President Projects Group EnergySolutions John E. Matthews 1009 Commerce Park Drive, Ste. 100 Morgan, Lewis & Bockius LLP Oak Ridge, TN 37830 1111 Pennsylvania Avenue, NW Washington, DC 20004 Dan Shrum Senior VP Regulatory Affairs EnergySolutions 423 West 300 South, Ste. 200 Salt Lake City, UT 84101

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