ML16153A293

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Ltr to J. Sauger Request for Additional Information Related to the Proposed Revision to the Defueled Station Emergency Plan for Zion Nuclear Power Station
ML16153A293
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 06/03/2016
From: John Hickman
Division of Decommissioning, Uranium Recovery and Waste Programs
To: Sauger J
ZionSolutions
John Hickman 415-3017
References
TAC L53114, TAC L53115
Download: ML16153A293 (6)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 3, 2016 Mr. John Sauger General Manager Zion Restoration Project ZionSolutions LLC 101 Shiloh Blvd.

Zion, IL 60099-2797

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PROPOSED REVISION TO THE DEFUELED STATION EMERGENCY PLAN FOR ZION NUCLEAR POWER STATION, UNITS 1 AND 2 (TAC NOS. L53114 AND L53115)

Dear Mr. Sauger:

By letter dated January 7, 2016, you submitted a request for approval of the Zion Nuclear Power Station (ZNPS) Defueled Station Emergency Plan (DSEP). We have reviewed your request and have some additional information that will be needed to complete our review. The additional information requested is enclosed.

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 Web site at http://www.nrc.gov/reading-rm/adams.html.

Should you have any questions regarding this action please contact me at 301-415-3017 or John.Hickman@nrc.gov.

Sincerely,

/RA/

John B. Hickman, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos. 50-295 and 50-304 License Nos. DPR-39 and DPR-48

Enclosure:

Request for Additional Information cc: w/enclosure Zion Service List

June 3, 2016 Mr. John Sauger General Manager Zion Restoration Project ZionSolutions LLC 101 Shiloh Blvd.

Zion, IL 60099-2797

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PROPOSED REVISION TO THE DEFUELED STATION EMERGENCY PLAN FOR ZION NUCLEAR POWER STATION, UNITS 1 AND 2 (TAC NOS. L53114 AND L53115)

Dear Mr. Sauger:

By letter dated January 7, 2016, you submitted a request for approval of the Zion Nuclear Power Station (ZNPS) Defueled Station Emergency Plan (DSEP). We have reviewed your request and have some additional information that will be needed to complete our review. The additional information requested is enclosed.

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 Web site at http://www.nrc.gov/reading-rm/adams.html.

Should you have any questions regarding this action please contact me at 301-415-3017 or John.Hickman@nrc.gov.

Sincerely,

/RA/

John B. Hickman, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-295 and 50-304 License Nos.: DPR-39 and DPR-48

Enclosure:

Request for Additional Information cc: w/enclosure Zion Service List DISTRIBUTION:

ML16153A293 OFFICE NMSS NMSS NMSS NMSS NAME JHickman CHolston BWatson JHickman DATE 6/2/16 6/2/16 6/3/16 6/3/16 OFFICIAL RECORD COPY

Zion Nuclear Power Station, Units 1 and 2 Service List cc:

John Christian President of Logistics, Processing and Disposal Group EnergySolutions 1750 Tysons Boulevard, Suite 1500 McLean, VA 22102 Mr. John Sauger Senior VQ & General Manager ZionSolutions LLC 101 Shiloh Blvd.

Zion, IL 60099-2797 Gerard van Noordennen VP Regulatory Affairs ZionSolutions, LLC 101 Shiloh Blvd.

Zion, IL 60099-2797 Anthony Orawiec Decommissioning Plant Manager ZionSolutions, LLC 101 Shiloh Blvd.

Zion, IL 60099 Dan Shrum Senior VP Regulatory Affairs EnergySolutions 423 West 300 South, Ste. 200 Salt Lake City, UT 84101 Russ Workman General Counsel EnergySolutions 423 West 300 South, Suite 200 Salt Lake City, UT 84101 Alwyn C. Settles Section Head, Nuclear Facilities Inspection Bureau of Nuclear Facility Safety Illinois Emergency Management Agency 1303 N. Milwaukee Avenue Libertyville, IL 60048-1308 Mr. Kent McKenzie Emergency Management Coordinator Lake County Emergency Management Agency 1303 N. Milwaukee Avenue Libertyville, IL 60048-1308 Regional Administrator U.S. NRC, Region III 2443 Warrenville Road Lisle, IL 60532-4352 John E. Matthews Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mayor of Zion Zion, IL 60099 Matias F. Travieso-Diaz Pillsbury Winthrop Shaw Pittman LLP 2300 N St., NW Washington, DC 20037 Tom Rielly, Executive Principal Vista 360 649 Innsbruck Libertyville, IL 60048 Director Spent Fuel & Decommissioning Strategy Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 J. Bradley Fewell Associate General Counsel Exelon Corporation, LLC 4300 Winfield Rd.

Warrenville, IL 60555 Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 6055

Enclosure REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST EMERGENCY PLAN CHANGE ZION NUCLEAR POWER STATION UNITS 1 AND 2 DOCKET NOS. 50-295, 50-304 AND 72-1037 By letter dated January 7, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML16008B080), ZionSolutions, LLC (ZS), is requesting an amendment to Facility Operating Licenses DPR-39 and DPR-48 for the Zion Nuclear Power Station (ZNPS) Units 1 and 2, respectively. ZS proposes to revise the ZNPS Defueled Station Emergency Plan (DSEP) to an Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan. The proposed major changes include the removal of non-ISFSI related emergency event types; transfer of responsibility for include implementing the Emergency Plan to ISFSI Management, and a revised emergency plan organization.

The staff reviewed the following documents as part of the evaluation of proposed changes: NRC safety evaluation reports dated May 14, 2015 (ADAMS Accession No. ML15092A423), and July 20, 2015 (ADAMS Accession No. ML15140A563); Revision 16 to the ZNPS DSEP dated October 16, 2014 (ADAMS Accession No. ML14314A071), which is the last ZNPS DSEP revision approved by the NRC, and Revision 18 to the ZNPS DSEP dated September 15, 2015 (ADAMS Accession No. ML15292A420).

The requests for additional information (RAIs) listed below are needed to support NRC staffs continued technical review of the proposed Emergency Plan change.

RAI-ZS-1 (Zion Station ISFSI Emergency Plan, Revision 0 DRAFT), Section 5.4, Radiological Assessment, states: The ISS [ISFSI Shift Supervisor] will ensure an assessment of ISFSI dose rates is performed after any natural phenomena event or accident condition.

Please describe the process used to determine if the EAL threshold values for E-HU1 are reached, including: (1) a description of how the surveys are to be conducted; (2) the type and availability of survey instrument(s) to be used, and (3) how the ISS is prompted to initiate the surveys.

RAI-ZS-2

, Section 5.5.2, Decontamination Capabilities, states in part, contamination of individuals at the ISFSI, injured or not, is not a credible event. However,Section IV.E.3, Emergency Facilities and Equipment, to Appendix E of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, requires the following, in part:

Adequate provisions shall be made and described for emergency facilities and equipment, including:

3. Facilities and supplies at the site for decontamination of onsite individuals; Please describe how the Zion Station ISFSI Emergency Plan meets the regulatory requirement cited above. [Note: Staff consideration for the elimination of this requirement would require the licensees submittal of an exemption request under 10 CFR 501.12 seeking specific relief from the cited Appendix E requirement.]

RAI-ZS-3 Section IV.E6 to Appendix E of 10 CFR) Part 50 requires the following, in part:

Adequate provisions shall be made and described for emergency facilities and equipment, including:

6. Arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary;

, Section 5.6, First Aid and Medical, states: Both the Vista Medical Center and the City of Zion Fire and Rescue Department have personnel trained in radiation protection measures. Please clarify the extent of training for the City of Zion Fire and Rescue Department as to whether: (1) training for the City of Zion Fire and Rescue Department covers the transportation of contaminated injured individuals from the site to the Vista Medical Center, and (2) training for the Vista Medical Center addresses the treatment of radiologically contaminated injuries.

RAI-ZS-4

, Section 5.3, Emergency Response Organization Actions, lists separate bullets for: ED [Emergency Director] deactivates Augmented ERO [emergency response organization],

and ED deactivates ERO. Please clarify if these are intended to be separate actions or unintentional duplication.

RAI-ZS-5 ZNPS DSEP (Revision 18), Section 7.2.2, Augmented DERO [Defueled Emergency Response Organization], states: The Radiation Protection Director is the only member of the Augmented DERO that is on call. The remainder of the Augmented DERO will be developed by the ED using guidance and contact information provided in EPIP EO-03, Emergency Preparedness Administration.

, Section 7.2.2, Augmented ERO, states: For an Emergency Classification of ALERT involving radiological consequences or at the discretion of ED, On-call support personnel can be activated.

Please describe, in the event that a declaration is made under initiating condition (IC) E-HU-1, at what time would health physics expertise be available on site to perform the follow up radiological surveys to determine the magnitude of the release and radiological conditions due to the event.

RAI-ZS-6 (Zion ISFSI Emergency Action Level Basis Document, Revision 0 DRAFT),

IC E-HU1 states, in part: The technical specification multiple of 2 times, which is also used in Recognition Category A, IC AU1, is used here to distinguish between non-emergency and emergency conditions. However, Recognition Category A, IC AU1, is not included in the proposed emergency action level (EAL) scheme. Please remove this statement or explain how it is applicable.

RAI-ZS-7

, IC PD-HU1, lists Emergency Action Level Threshold Values: (1 or 2 or 3).

However, there are only 2 threshold values listed, neither of which are numbered. Please revise accordingly to address inconsistency.

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 3, 2016 Mr. John Sauger General Manager Zion Restoration Project ZionSolutions LLC 101 Shiloh Blvd.

Zion, IL 60099-2797

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PROPOSED REVISION TO THE DEFUELED STATION EMERGENCY PLAN FOR ZION NUCLEAR POWER STATION, UNITS 1 AND 2 (TAC NOS. L53114 AND L53115)

Dear Mr. Sauger:

By letter dated January 7, 2016, you submitted a request for approval of the Zion Nuclear Power Station (ZNPS) Defueled Station Emergency Plan (DSEP). We have reviewed your request and have some additional information that will be needed to complete our review. The additional information requested is enclosed.

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 Web site at http://www.nrc.gov/reading-rm/adams.html.

Should you have any questions regarding this action please contact me at 301-415-3017 or John.Hickman@nrc.gov.

Sincerely,

/RA/

John B. Hickman, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos. 50-295 and 50-304 License Nos. DPR-39 and DPR-48

Enclosure:

Request for Additional Information cc: w/enclosure Zion Service List

June 3, 2016 Mr. John Sauger General Manager Zion Restoration Project ZionSolutions LLC 101 Shiloh Blvd.

Zion, IL 60099-2797

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PROPOSED REVISION TO THE DEFUELED STATION EMERGENCY PLAN FOR ZION NUCLEAR POWER STATION, UNITS 1 AND 2 (TAC NOS. L53114 AND L53115)

Dear Mr. Sauger:

By letter dated January 7, 2016, you submitted a request for approval of the Zion Nuclear Power Station (ZNPS) Defueled Station Emergency Plan (DSEP). We have reviewed your request and have some additional information that will be needed to complete our review. The additional information requested is enclosed.

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 Web site at http://www.nrc.gov/reading-rm/adams.html.

Should you have any questions regarding this action please contact me at 301-415-3017 or John.Hickman@nrc.gov.

Sincerely,

/RA/

John B. Hickman, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-295 and 50-304 License Nos.: DPR-39 and DPR-48

Enclosure:

Request for Additional Information cc: w/enclosure Zion Service List DISTRIBUTION:

ML16153A293 OFFICE NMSS NMSS NMSS NMSS NAME JHickman CHolston BWatson JHickman DATE 6/2/16 6/2/16 6/3/16 6/3/16 OFFICIAL RECORD COPY

Zion Nuclear Power Station, Units 1 and 2 Service List cc:

John Christian President of Logistics, Processing and Disposal Group EnergySolutions 1750 Tysons Boulevard, Suite 1500 McLean, VA 22102 Mr. John Sauger Senior VQ & General Manager ZionSolutions LLC 101 Shiloh Blvd.

Zion, IL 60099-2797 Gerard van Noordennen VP Regulatory Affairs ZionSolutions, LLC 101 Shiloh Blvd.

Zion, IL 60099-2797 Anthony Orawiec Decommissioning Plant Manager ZionSolutions, LLC 101 Shiloh Blvd.

Zion, IL 60099 Dan Shrum Senior VP Regulatory Affairs EnergySolutions 423 West 300 South, Ste. 200 Salt Lake City, UT 84101 Russ Workman General Counsel EnergySolutions 423 West 300 South, Suite 200 Salt Lake City, UT 84101 Alwyn C. Settles Section Head, Nuclear Facilities Inspection Bureau of Nuclear Facility Safety Illinois Emergency Management Agency 1303 N. Milwaukee Avenue Libertyville, IL 60048-1308 Mr. Kent McKenzie Emergency Management Coordinator Lake County Emergency Management Agency 1303 N. Milwaukee Avenue Libertyville, IL 60048-1308 Regional Administrator U.S. NRC, Region III 2443 Warrenville Road Lisle, IL 60532-4352 John E. Matthews Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mayor of Zion Zion, IL 60099 Matias F. Travieso-Diaz Pillsbury Winthrop Shaw Pittman LLP 2300 N St., NW Washington, DC 20037 Tom Rielly, Executive Principal Vista 360 649 Innsbruck Libertyville, IL 60048 Director Spent Fuel & Decommissioning Strategy Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 J. Bradley Fewell Associate General Counsel Exelon Corporation, LLC 4300 Winfield Rd.

Warrenville, IL 60555 Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 6055

Enclosure REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST EMERGENCY PLAN CHANGE ZION NUCLEAR POWER STATION UNITS 1 AND 2 DOCKET NOS. 50-295, 50-304 AND 72-1037 By letter dated January 7, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML16008B080), ZionSolutions, LLC (ZS), is requesting an amendment to Facility Operating Licenses DPR-39 and DPR-48 for the Zion Nuclear Power Station (ZNPS) Units 1 and 2, respectively. ZS proposes to revise the ZNPS Defueled Station Emergency Plan (DSEP) to an Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan. The proposed major changes include the removal of non-ISFSI related emergency event types; transfer of responsibility for include implementing the Emergency Plan to ISFSI Management, and a revised emergency plan organization.

The staff reviewed the following documents as part of the evaluation of proposed changes: NRC safety evaluation reports dated May 14, 2015 (ADAMS Accession No. ML15092A423), and July 20, 2015 (ADAMS Accession No. ML15140A563); Revision 16 to the ZNPS DSEP dated October 16, 2014 (ADAMS Accession No. ML14314A071), which is the last ZNPS DSEP revision approved by the NRC, and Revision 18 to the ZNPS DSEP dated September 15, 2015 (ADAMS Accession No. ML15292A420).

The requests for additional information (RAIs) listed below are needed to support NRC staffs continued technical review of the proposed Emergency Plan change.

RAI-ZS-1 (Zion Station ISFSI Emergency Plan, Revision 0 DRAFT), Section 5.4, Radiological Assessment, states: The ISS [ISFSI Shift Supervisor] will ensure an assessment of ISFSI dose rates is performed after any natural phenomena event or accident condition.

Please describe the process used to determine if the EAL threshold values for E-HU1 are reached, including: (1) a description of how the surveys are to be conducted; (2) the type and availability of survey instrument(s) to be used, and (3) how the ISS is prompted to initiate the surveys.

RAI-ZS-2

, Section 5.5.2, Decontamination Capabilities, states in part, contamination of individuals at the ISFSI, injured or not, is not a credible event. However,Section IV.E.3, Emergency Facilities and Equipment, to Appendix E of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, requires the following, in part:

Adequate provisions shall be made and described for emergency facilities and equipment, including:

3. Facilities and supplies at the site for decontamination of onsite individuals; Please describe how the Zion Station ISFSI Emergency Plan meets the regulatory requirement cited above. [Note: Staff consideration for the elimination of this requirement would require the licensees submittal of an exemption request under 10 CFR 501.12 seeking specific relief from the cited Appendix E requirement.]

RAI-ZS-3 Section IV.E6 to Appendix E of 10 CFR) Part 50 requires the following, in part:

Adequate provisions shall be made and described for emergency facilities and equipment, including:

6. Arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary;

, Section 5.6, First Aid and Medical, states: Both the Vista Medical Center and the City of Zion Fire and Rescue Department have personnel trained in radiation protection measures. Please clarify the extent of training for the City of Zion Fire and Rescue Department as to whether: (1) training for the City of Zion Fire and Rescue Department covers the transportation of contaminated injured individuals from the site to the Vista Medical Center, and (2) training for the Vista Medical Center addresses the treatment of radiologically contaminated injuries.

RAI-ZS-4

, Section 5.3, Emergency Response Organization Actions, lists separate bullets for: ED [Emergency Director] deactivates Augmented ERO [emergency response organization],

and ED deactivates ERO. Please clarify if these are intended to be separate actions or unintentional duplication.

RAI-ZS-5 ZNPS DSEP (Revision 18), Section 7.2.2, Augmented DERO [Defueled Emergency Response Organization], states: The Radiation Protection Director is the only member of the Augmented DERO that is on call. The remainder of the Augmented DERO will be developed by the ED using guidance and contact information provided in EPIP EO-03, Emergency Preparedness Administration.

, Section 7.2.2, Augmented ERO, states: For an Emergency Classification of ALERT involving radiological consequences or at the discretion of ED, On-call support personnel can be activated.

Please describe, in the event that a declaration is made under initiating condition (IC) E-HU-1, at what time would health physics expertise be available on site to perform the follow up radiological surveys to determine the magnitude of the release and radiological conditions due to the event.

RAI-ZS-6 (Zion ISFSI Emergency Action Level Basis Document, Revision 0 DRAFT),

IC E-HU1 states, in part: The technical specification multiple of 2 times, which is also used in Recognition Category A, IC AU1, is used here to distinguish between non-emergency and emergency conditions. However, Recognition Category A, IC AU1, is not included in the proposed emergency action level (EAL) scheme. Please remove this statement or explain how it is applicable.

RAI-ZS-7

, IC PD-HU1, lists Emergency Action Level Threshold Values: (1 or 2 or 3).

However, there are only 2 threshold values listed, neither of which are numbered. Please revise accordingly to address inconsistency.

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