ML14246A464

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E-mail from a C Settles, to P Longmire, Re Consult on Ea/Fonsi for Zionsolutions Exemption Request (LCO 3.1.1 Exemption Request Meeting: State Consult) Zion Nuclear Power Station ISFSI (Docket 72-1037)
ML14246A464
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 08/28/2014
From: Settles A
State of IL, Dept of Nuclear Safety
To: Foster K, Klinger J, Pamela Longmire
NRC/NMSS/SFST
Longmire P
References
Download: ML14246A464 (9)


Text

From:

Settles, Alwyn C.

To:

Longmire, Pamela Cc:

Foster, Kay; Klinger, Joe; Settles, Alwyn C.; Mischke, Stephen

Subject:

Consult on EA/FONSI for ZionSolutions exemption request Date:

Thursday, August 28, 2014 12:10:18 PM Attachments:

EA FONSI-state.pdf

Pamela, Thank you for the opportunity to comment on the License Amendment for ZionSolutions.

The additional Draft Safety Evaluation Report you provided was most helpful.

The only question that arose during our review was related to how ZionSolutions determines if a cask is less than 20 kW heat load. An IEMA Resident Inspector was at Zion Station this morning and was able to obtain a satisfactory explanation directly from ZionSolutions on the methodology for the heat load determinations. All questions have been answered.

In summary; IEMA has reviewed the referenced EA/FONSI for the ZionSolutions exemption request and has determined this amendment does not pose a significant hazard to the health and safety of the public.

IEMA recommends approval of this amendment.

Cecil

From: Foster, Kay Sent: Friday, August 22, 2014 2:06 PM To: Evans, Ken; Settles, Alwyn C.

Subject:

Fwd: Consult on EA/FONSI for ZionSolutions exemption request

Here is the attachment.

Sent from my iPhone Begin forwarded message:

From: "Klinger, Joe" <Joe.Klinger@illinois.gov>

Date: August 22, 2014 at 2:04:56 PM CDT To: "Foster, Kay" <Kay.Foster@illinois.gov>

Subject:

FW: Consult on EA/FONSI for ZionSolutions exemption request

Joseph G. Klinger

Assistant Director Illinois Emergency Management Agency 2200 S. Dirksen Parkway Springfield, IL 62703-4528 217 785-9868 Joe.Klinger@Illinois.gov

From: Longmire, Pamela [1]

Sent: Thursday, August 21, 2014 3:52 PM To: Klinger, Joe Cc: Lupold, Timothy

Subject:

Consult on EA/FONSI for ZionSolutions exemption request

Dear Mr. Klinger,

We have reviewed an exemption request for the Zion Nuclear Power Station (ZNPS). As part of our review process, we consult Federal and State agencies and persons affected by the licensing action. The consultation is typically done just prior to issuing the final environmental assessment (EA). The purpose of the consultation is to solicit comments on the environmental impact of the proposed action and any other comments pertaining to the proposed action.

Please note that we document in the Agencies and Persons Consulted of the federal register notice that the consultations occurred and summarize the comments received.

Please provide any comments on the attached draft EA and finding of no significant impact (FONSI) and provide comment back to me by August 28, 2014. Should you not be able to support this date please suggest an alternate due date you can meet.

I thank you in advance for both your time and consideration.

Best Regards,

Pamela Longmire, Ph.D.

NMSS/SFST/LB Project Manager Office: 3WFN 14-C79 (301) 287-0829 (Office): Tuesday & Wednesday (301) 415-7000 (remote location): Monday & Thursday

[7590-01-P]

NUCLEAR REGULATORY COMMISSION

[Docket Nos.: 50-295, 50-304 AND 72-1037]

ZION SOLUTIONS, LLC.

ZION NUCLEAR POWER STATION, UNITS 1 AND 2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION AGENCY: U.S. Nuclear Regulatory Commission.

ACTION: Issuance of Environmental Assessment and Finding of No Significant Impact.

FOR FURTHER INFORMATION CONTACT: Pamela Longmire, Ph.D., Project Manager, Division of Spent Fuel Storage and Transportation, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555. Telephone: (301) 287-0829; Fax number: (301) 287-9341; E-mail: pamela.longmire@nrc.gov.

SUPPLEMENTARY INFORMATION:

I.

INTRODUCTION The NRC is considering issuance of an exemption to Zion Solutions, LLC (hereafter, ZS or the applicant) pursuant to section 72.7 of Title 10 of the Code of Federal Regulations (10 CFR),

Specific exemptions, from specific portions of the requirements of 10 CFR 72.212 Conditions of general license issued under §72.210, specifically 10 CFR 72.212(a)(2), 72.212(b)(3),

72.212(b)(5)(i), 72.212(b)(11) and 10 CFR 72.214 List of approved spent fuel storage casks, for the Zion Nuclear Power Station (ZNPS) Independent Spent Fuel Storage Installation (ISFSI).

II.

ENVIRONMENTAL ASSESSMENT (EA)

Background:

The applicant is a general licensee under Title 10 of the Code of Federal Regulations (10 CFR) Part 72, for the storage of spent fuel in an ISFSI. The applicant is subject to 10 CFR 72.212, which provides in part that [t]he general license is limited to storage of spent fuel in casks approved under the provisions of 10 CFR Part 72. The general licensee must ensure that each cask used conforms to the terms, conditions, and specifications of a certificate of compliance (CoC), or an amended CoC, listed in section 72.214.

The applicant seeks approval to load casks in a different manner than permitted by its current CoC, but which the NRC has previously reviewed as a proposed amendment to that CoC.

NAC, the cask vendor, by application dated June 18, 2013 submitted an amendment request (ML13171A031), as supplemented September 6 (ML13261A278) and September 19 (ML13268A051) to change limiting condition operation (LCO) 3.1.1. The NRC technical review of the NAC CoC amendment request is documented in the safety evaluation report (ML14010A495). The NRC staff in the safety evaluation report concludes that the revised time limits of helium backfill and transportable storage canister (TSC) transfer time of technical specification (TS) LCO 3.1.1 are in compliance with 10 CFR Part 72. The evaluation of the thermal design provides reasonable assurance that the resulting values proposed will allow safe storage of the spent fuel. The applicants exemption request for modified transfer time when a canister's thermal output is less than or equal to twenty (20) kilowatts, 20kW, relies, as the basis for approval, on the NAC CoC amendment request review performed by the NRC staff.

Identification of Proposed Action: In a letter dated June 25, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14182A474), the applicant requests an exemption from certain requirements in 10 CFR 72.212(a)(2), 72.212(b)(3),

72.212(b)(5)(i), 72.212(b)(11) and 10 CFR 72.214. The proposed exemption request pertains to the requirements of technical specification (TS) LCO 3.1.1, TSC, Section 1, first table, regarding allowed transfer time from loading of a TSC inside the MAGNASTOR transfer cask (MTC) to placement into the vertical concrete cask (VCC) following the completion of helium backfill. The proposed exemption is to modify the allowable transfer time from eight (8) hours to six hundred (600) hours. The transfer time is for the movement of a TSC, with heat load 20 kW, from the decontamination pit to the VCC.

In the preparation of this Environmental Assessment, the staff used guidance in NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs (ADAMS Accession No. ML032450279)

Need for the Proposed Action: The applicant seeks relief from requirements of 72.212(a)(2),

72.212(b)(3), 72.212(b)(5)(i), 72.212(b)(11), and 10 CFR 72.214 and requests to use a limiting condition of operation submitted by the cask vendor, NAC, as Amendment 4 to NAC MAGNASTOR, CoC No. 1031. CoC No. 1031, Amendment 4 increases the transfer time for a canister with a heat load 20 kW from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, as required by LCO 3.1.1 under Amendment 3, to 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />. The applicant maintains that extending the period for the operator to complete the transfer provides the operator the opportunity to conclude the activity, provides flexibility in operations, minimizes equipment runtime and repair, and minimizes personnel dose.

Environmental Impacts of the Proposed Action: The NRC staff has determined that issuance of the proposed exemption will have no significant environmental impact.

The proposed action will not increase the probability or consequences of accidents. No changes are being made in the types or quantities of effluents that may be released offsite, and there is no significant increase in occupational or public radiation exposure. Therefore, there are no significant radiological environmental impacts associated with the proposed action. The proposed action does not affect non-radiological effluents and has no other environmental impacts. Thus, there are no significant non-radiological impacts associated with the proposed action. Therefore, the proposed action will not have a significant effect on the quality of the human environment. Based on these findings, the NRC concludes that there are no significant environmental impacts associated with the approval of the requested exemption.

Alternative to the Proposed Action: Because there are no significant environmental impacts associated with the proposed action, alternatives with equal or greater environmental impact have not been evaluated. The alternative to the proposed action would be to deny approval of the exemption. This alternative would have the same environmental impacts as the proposed action. In the event the NRC were to deny the requested exemption, ZS would continue to operate under the requirements of the current MAGNASTOR CoC, which has previously been determined to have no significant impacts. The potential environmental impact of using the MAGNASTOR system was initially analyzed in the environmental assessment for the final rule to add the MAGNASTOR system to the list of approved spent fuel storage casks in 10 CFR 72.214 (73 FR 70587; November 21, 2008). The environmental assessment for the November 21, 2008, final rule concluded that there would be no significant environmental impact for adding the MAGNASTOR system, and therefore, the NRC issued a finding of no significant impact.

Agencies and Persons Consulted: [Insert discussion of comments from the State here.] The NRC staff has determined that a consultation under Section 7 of the Endangered Species Act is not required because the proposed action will not affect listed species or critical habitat. The NRC staff has also determined that the proposed action is not a type of activity that has the potential to impact historic properties because the proposed action would occur within the established ZNPS site boundary. Therefore, no consultation is required under Section 106 of the National Historic Preservation Act.

III.

Finding of No Significant Impact The environmental impacts of the proposed action have been reviewed in accordance with the requirements set forth in 10 CFR Part 51. Based upon this environmental assessment, the NRC finds that the proposed action, issuance of an exemption from specific conditions of general license issued under section 72.210 requirements in 10 CFR 72.212, as further discussed in the safety evaluation, will not significantly impact the quality of the human environment. Accordingly, preparation of an environmental impact statement for the proposed exemption is not warranted, and a finding of no significant impact is appropriate.

IV.

Further Information In accordance with 10 CFR 2.390 of NRCs Agency Rules of Practice and Procedure, final NRC records and documents regarding this proposed action are publicly available in the records component of NRCs Agencywide Documents Access and Management System (ADAMS). The request for exemption dated June 25, 2014 (ADAMS Accession No. ML14182A474), was docketed under 10 CFR Part 50, Dockets 50-295 and 50-304. These documents may be inspected at NRCS Public Electronic Reading Room at http://www.nrc.gov/reading-rm/adams.html. These documents may also be viewed electronically on the public computers located at the NRCs Public Document Room (PDR), O1F21, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852. The PDR reproduction contractor will copy documents for a fee. Persons who do not have access to ADAMS, or who encounter problems in accessing the documents located in ADAMS, should contact the NRC PDR Reference staff by telephone at 1-800-397-4209, or (301) 415-4737, or by e-mail to pdr@nrc.gov.

Dated at Rockville, Maryland, this day of Month, 2014.

FOR THE NUCLEAR REGULATORY COMMISSION Timothy R. Lupold, Acting Chief Licensing Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards

ML14182A474), was docketed under 10 CFR Part 50, Dockets 50-295 and 50-304. These documents may be inspected at NRCS Public Electronic Reading Room at http://www.nrc.gov/reading-rm/adams.html. These documents may also be viewed electronically on the public computers located at the NRCs Public Document Room (PDR),

O1F21, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852. The PDR reproduction contractor will copy documents for a fee. Persons who do not have access to ADAMS, or who encounter problems in accessing the documents located in ADAMS, should contact the NRC PDR Reference staff by telephone at 1-800-397-4209, or (301) 415-4737, or by e-mail to pdr@nrc.gov.

Dated at Rockville, Maryland, this day of Month, 2014.

FOR THE NUCLEAR REGULATORY COMMISSION Timothy R. Lupold, Acting Chief Licensing Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguard TAC NO. L24750 File location: G:\\SFST\\ZionSolutions\\Exemption\\EA FONSI.docx ADAMS: ML