ZS-2014-0058, License Amendment Change Request Related to the Unloaded Spent Fuel Pool

License Amendment Change Request Related to the Unloaded Spent Fuel Pool

ML14078A049
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/17/2014
From:	Gerard van Noordennen ZionSolutions
To:	Document Control Desk, NRC/FSME
References
ZS-2014-0058
Download: ML14078A049 (49)

Text

ZIONSOLUTIONSLLC March 17, 2014 ZS-2014-0058 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304

Subject:

License Amendment Change Request Related to the Unloaded Spent Fuel Pool

References:

1) John B. Hickman (U.S. Nuclear Regulatory Commission) Letter to John A. Christian, President, ZionSolutions, LLC, "Issuance of Conforming Amendments Relating to the Transfer of Licenses for Zion Nuclear Power Station, Units 1 and 2", dated September 1, 2010

2) NRC Administrative Letter 95-06, Relocation of Technical Specification Administrative Controls Related To Quality Assurance, dated December 12, 1995 The Zion Nuclear Power Station (ZNPS) is owned by ZionSolutions, LLC (ZionSolutions). The U.S. NRC transferred Facility Operating License Numbers DPR-39 and DPR-48 on September 1, 2010 from Exelon Generation Company, LLC (Exelon) to ZionSolutions. In February and March 1998, Commonwealth Edison Company (now Exelon) certified to the NRC, the permanent cessation of operation of Zion Station Units 1 and 2 and transfer of all fuel assemblies to the spent fuel pool. ZionSolutions is authorized by the NRC to store spent fuel in the spent fuel pool at the ZNPS site by Facility Operating Licenses Nos. DPR-39 and DPR-48 (Docket Nos. 50-295 and 50-304) consistent with the provisions of 10 CFR 50. The spent fuel is currently being moved from the spent fuel pool to the Independent Spent Fuel Storage Installation (ISFSI).

Spent fuel transfer is projected to be complete in December 2014.

Pursuant to 10 CFR 50.90, ZionSolutions proposes to amend its licenses, DPR-39 and DPR-48, and revise the ZNPS Technical Specifications to reflect the removal of all the spent fuel from the ZNPS spent fuel pool. The proposed changes will result in Technical Specifications that will be applicable to the ZNPS once the last spent fuel assembly has been removed from the spent fuel pool and placed at the ISFSI.

The proposed changes to both Facility Operating Licenses modify Section 2.C.(6) to specify the ZNPS Independent Spent Fuel Storage Installation Physical Security Plan, eliminate Section 2.C.(7) Spent Fuel Pool Modification, and eliminate Section 2.C.(16), related to the single-failure proof fuel building crane.

The proposed changes to the Technical Specifications eliminate provisions of the specifications applicable to spent fuel stored in the spent fuel pool and relocate the remaining Technical 101 Shiloh Boulevard, Zion IL 60099 (224) 789-4016

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ZionSolutions, LLC ZS-2014-0058 Page 2 of 3 Specification administrative requirements to the Quality Assurance Project Plan (QAPP). These changes are proposed pursuant to the criteria contained in 10 CFR 50.36 and in accordance with recommendations contained in Administrative Letter 95-06. provides a discussion of the proposed changes, technical analysis, regulatory analysis, and environmental consideration. Attachment 2 provides the amended ZNPS Technical Specifications. Attachment 3 provides the proposed related changes to the Quality Assurance Project Plan. Attachment 4 provides the change pages for the Unit 1 Facility Operating License, License No. DPR-39. Attachment 5 provides the change pages for the Unit 2 Facility Operating License No. DRP-48.

The proposed changes do not impact the public health and safety and do not involve a Significant Hazards Consideration (SHC) pursuant to the provisions of 10 CFR 50.92 (see SHC provided in Section 4.1 of Attachment 1).

The Station Review Committee reviewed the proposed changes and concurred with the determinations.

ZionSolttions requests approval of the proposed changes prior to completion of transfer of spent fuel assemblies to the ISFSI. We request NRC approval by November 1, 2014 to permit implementation of the approved amendment as soon as possible after transfer of the last spent fuel assembly from the spent fuel pool to the ISFSI. Transfer of spent fuel assemblies is expected to be complete by December 2014. ZionSolutions will notify the NRC when the last fuel loaded Vertical Concrete Cask (VCC) is transferred to the ISFSI.

In accordance with 10 CFR 50.91 (b), a copy of this license amendment request is being provided to the State of Illinois.

If you should have any questions regarding this submittal, please contact me at (860) 462-9707.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on March 17, 2014.

Respectfully, Gerard van Noordennen Vice President of Regulatory Affairs ZionSolhtions, LLC Attachments

1) Attachment 1, Zion Nuclear Power Station License Amendment Change Request

2) Attachment 2, Zion Nuclear Power Station Proposed Technical Specifications

ZionSolutions, LLC ZS-20 14-0058 Page 3 of 3

3) Attachment 3, Zion Nuclear Power Station Proposed Quality Assurance Project Plan, ZS-QA- 10 Affected Pages

4) Attachment 4, Zion Nuclear Power Station, Unit 1, Proposed Amendment to Facility Operating License No. DPR-39 Docket No. 50-295 Affected Pages

5) Attachment 5, Zion Nuclear Power Station, Unit 2, Proposed Amendment to Facility Operating License No. DPR-48 Docket No. 50-304 Affected Pages cc: John Hickman, U.S. NRC Senior Project Manager Service List

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

Alan Parker Russ Workman President Projects Group General Counsel EnergySohltions EnergySolutions 1009 Commerce Park Drive, Ste. 100 423 West 300 South, Ste. 200 Oak Ridge, TN 37830' Salt Lake City, UT 84101 John Sauger Alwyn C. Settles Sr. VP & General Manager Section Head, Nuclear Facility Inspection ZionSolutions, LLC Bureau of Nuclear Facility Safety 101 Shiloh Boulevard Illinois Emergency Management Agency Zion, IL 60099 1011 North St., PO Box 250 Mazon, IL 60444 Gerard van Noordennen VP Regulatory Affairs Kent McKenzie ZionSolutions, LLC Emergency Management Coordinator 101 Shiloh Boulevard Lake County Emergency Management Agency Zion, IL 60099 1303 N. Milwaukee Avenue Libertyville, IL 60048-1308 Gary Bouchard VP Ops & Engineering and Regional Administrator Decommissioning Plant Manager U.S. NRC, Region III ZionSolutions, LLC 2443 Warrenville Road 101 Shiloh Boulevard Lisle, IL 60532-4352 Zion, IL 60099 John E. Matthews Dan Shrum Morgan, Lewis & Bockius LLP Sr. VP Regulatory Affairs 1111 Pennsylvania Avenue, NW EnergySolutions Washington, DC 20004 423 West 300 South, Ste. 200 Salt Lake City, UT 84101

ZionSolutions, LLC ZS-2014-0058: Attachment 1 Zion Nuclear Power Station License Amendment Change Request

ZionSolutions, LLC ZS-2014-0058: Attachment 1 Zion Nuclear Power Station License Amendment Change Request Changes Related to the Unloaded Spent Fuel Pool Discussion of Changes, Technical and Regulatory Analysis Including Significant Hazards Consideration Discussion

1.0 INTRODUCTION

In September 1996, the Zion Nuclear Power Station (ZNPS) Unit 2 was permanently shutdown after approximately 23 years of operation. In February 1997, the ZNPS Unit 1 was permanently shutdown after approximately 24 years of operation. In February 1998, in accordance with 10 CFR 50.82(a)(1 )(i) and (ii), Exelon Generating Company LLC (Exelon) notified the Nuclear Regulatory Commission (NRC) of the permanent cessation of operations at the ZNPS and the permanent removal of all spent fuel assemblies from the reactor vessels and transfer to the spent fuel pool.

Following the cessation of operation, Exelon began planning to decommission the ZNPS. On February 14, 2000, Exelon submitted a Post-Shutdown Decommissioning Report (PSDAR) for the Zion units, pursuant to 10 CFR 50.82(a)(4)(i), which was amended on March 18, 2008.

In support of the decommissioning process currently underway at the ZNPS, the spent fuel is being transferred from the spent fuel pool to an Independent Spent Fuel Storage Installation (ISFSI) at the ZNPS using casks certified for use under a general 10 CFR 72 license. Completion of decommissioning requires the eventual dismantlement of the spent fuel pool. Pursuant to 10 CFR 50.90, ZionSolutions proposes to amend its Facility Operating Licenses Nos. DPR-39 and DPR- 48 (Docket Nos. 50-295 and 50-304) and revise the ZNPS Permanently Defueled Technical Specifications to reflect the removal of all spent fuel from the ZNPS spent fuel pool.

The proposed changes will result in the Technical Specifications that will be applicable to the ZNPS once the last spent fuel assembly has been removed from the spent fuel pool and placed at the ISFSI at the ZNPS.

The proposed changes to the Technical Specifications would simplify the Technical Specifications by relocating administrative requirements to the ZionSolutions Quality Assurance Project Plan (QAPP) and subsequently controlling them in accordance with 10 CFR 50.54(a).

This relocation is being proposed pursuant to the criteria contained in 10 CFR 50.36 and in accordance with recommendations contained in NRC Administrative Letter 95-06. Additionally, ZionSolutions proposes to eliminate Technical Specifications (operational requirements and certain design requirements involving spent fuel) that will no longer be applicable following the transfer of the last spent fuel assembly from the spent fuel pool to the ISFSI.

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ZionSolutions, LLC ZS-2014-0058: Attachment 1

2.0 DESCRIPTION

OF PROPOSED CHANGES In anticipation of transferring all of the ZNPS spent fuel to dry cask storage at the ISFSI, ZionSolutions proposes the following Technical Specification Changes.

2.1 Deletion and Relocation of Technical Specifications 2.1 A Section 1.0, Use and Application The ZNPS Technical Specifications currently provide definitions for the following terms: Actions, Logical Connectors, Completion Times, and Frequency related to Limiting Conditions for Operation (LCOs) and Surveillance Requirements (SRs) that are applicable to spent fuel related systems, structures, components, and activities.

ZionSolutions proposes to delete these definitions from Technical Specification Section 1.0. As discussed later in this Attachment, with the complete transfer of spent fuel from the spent fuel pool to the ISFSI, there will no longer be any LCOs or SRs. As such, the definitions of Actions, Logical Connectors, Completion Times, and Frequency will no longer be applicable. Therefore, deleting these definitions from the ZNPS Technical Specifications effective after the last fuel transfer from the Defueled Plant is acceptable.

2.1 B Section 2.0, Safety limits This section is not applicable to defueled facilities and had previously been deleted (Amendment Nos. 180 and 167).

2.1 C Section 3.0, Limiting Condition for Operation (LCO) Applicability and Surveillance Requirement (SR) Applicability Technical Specification Sections LCO 3.0.1 and LCO 3.0.2, provide the general requirements applicable to LCOs. Technical Specification Sections SR 3.0.1, SR 3.0.2, and SR 3.0.3 specify the conditions when surveillances are required, the required frequency for surveillances and what constitutes noncompliance with LCO operability requirements.

ZionSohitions proposes to delete Sections LCO 3.0.1, LCO 3.0.2, SR 3.0.1, SR 3.0.2, and SR 3.0.3. As discussed later in this Attachment, after all of the spent fuel has been transferred from the spent fuel pool to the ISFSI, the Section 3.0 LCO and SR requirements concerning management and protection of spent fuel are no longer required. This eliminates the need for Sections LCO 3.0.1, LCO 3.0.2, SR 3.0.1, SR 3.0.2, and SR 3.0.3.

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ZionSohltions, LLC ZS-2014-0058: Attachment 1 2.1 D Section 3.1, Defueled Plant Systems Technical Specification Section 3.1.1, Spent Fuel Pool Water Level, provides the LCO, Applicability, Action, and Surveillance Requirements for spent fuel pool water level. This Section requires that at least 23 feet of water be maintained over the top of fuel assemblies seated in the spent fuel pool racks. This Section also specifies the frequency that the spent fuel pool water level is to be verified. ZionSolutions proposes to delete Section 3.1.1. After all of the spent fuel has been transferred from the spent fuel pool to the ISFSI, since the need to maintain or monitor a specified water level will no longer exists. Therefore, the proposed deletion is acceptable.

Technical Specification Section 3.1.2, Spent Fuel Pool Boron Concentration, provides the LCO, Applicability, Action, and Surveillance Requirements for spent fuel pool boron concentration level. This Section requires that at least 500 ppm be maintained in the spent fuel pool during movement of spent fuel or when fuel is stored in Region 2 and a verification has not been performed since the last movement of fuel. This Section also specifies the frequency that the spent fuel pool boron concentration is to be verified. ZionSohltions proposes to delete Section 3.1.2. After all of the spent fuel has been transferred from the spent fuel pool to the ISFSI, the need to maintain or monitor a specified boron concentration no longer exists. Therefore, the proposed deletion is acceptable.

Technical Specification Section 3.1.3, Spent Fuel Assembly Storage, provides the LCO, Applicability, Action, and Surveillance Requirements for spent fuel assemblies stored in the spent fuel pool racks. This Section requires that the combination of initial enrichment and discharge fuel burnup of each spent fuel assembly stored in Region 2 shall be within the Acceptable Burnup Domain of Figure 3.1.3-1. This Section also specifies the frequency that this SR is to be performed. ZionSolutions proposes to delete Section 3.1.3 and Figure 3.1.3-1. After all of the spent fuel has been transferred from the spent fuel pool to the ISFSI, the need to maintain or monitor spent fuel assembly storage locations no longer exists. Therefore, the proposed deletion is acceptable.

2.1 E Section 4.2, Fuel Storage Section 4.2 currently provides a description of the spent fuel storage design including criticality control, drainage potential, and storage capacity. ZionSolutions proposes to delete Section 4.2. After all of the spent fuel has been transferred to the ISFSI in dry cask storage, there is no need to maintain the content of this section. Therefore, the proposed deletion is acceptable.

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ZionSolutions, LLC ZS-2014-0058: Attachment 1 Specification 4.2.1, Criticality, provides the limitation to ensure that the reactivity of fuel assemblies introduced into the spent fuel pool racks, with no credit taken for soluble boron in the spent fuel pool, will remain < 0.95 Kff at all times. ZionSolutions proposes to delete Section 4.2.1. After all of the spent fuel has been transferred from the spent fuel pool to the ISFSI, there is no need to maintain the limitation on the reactivity in the spent fuel pool. Therefore, the proposed deletion is acceptable.

Specification 4.2.2, Drainage, states that the design of the spent fuel pool precludes draining below the elevation of 598 feet. ZionSolutions proposes to delete Section 4.2.2. After all of the spent fuel has been transferred from the spent fuel pool to the ISFSI, there is no need for this design criteria. Therefore, the proposed deletion is acceptable.

Specification 4.2.3, Capacity, states that the spent fuel pool is designed and shall be maintained with a storage capacity limited to no more than 3012 fuel assemblies. ZionSolutions proposes to delete Section 4.2.3.

After all of the spent fuel has been transferred from the spent fuel pool to the ISFSI, there is no need for this design criteria. Therefore, the proposed deletion is acceptable.

2.1 F Section 5.0, Administrative Controls ZionSolutions proposes to delete Administrative Controls Sections 5.1.2,

'responsibility for Shift Supervisor; 5.2.1 .d, the portion related to individuals who train the Certified Fuel Handlers and 5.2.2, Facility Staff; the portion of 5.3.1 related to the Decommissioning Operations Manager; 5.4, Training; 5.5.1 .a Procedures applicable to safe storage of nuclear fuel recommended in Regulatory Guide 1.33; and 5.6.4, Technical Specification (TS) Bases Control Program.

The remaining Administrative Controls Sections of 5.1, Responsibility; 5.2, Organization; 5.3 Facility Staff Qualifications; 5.5, Procedures; 5.6, Programs and Manuals; 5.7, Reporting Requirements; 5.8, High Radiation Area; and 5.9, Reviews will be deleted from the Technical Specifications and relocated to the QAPP for ongoing implementation.

NRC Administrative Letter 95-06 provides a discussion concerning the relocation of Technical Specification administrative controls to a quality assurance program. The NRC considers relocating these requirements to the quality assurance program acceptable because of the controls imposed by 10 CFR 50, Appendix B, the existence of an NRC approved quality assurance program, and the quality assurance program change control process in 10 CFR 50.54(a). With the transfer of the spent fuel to the ISFSI, the administrative controls pertaining to the safe storage of spent fuel within the spent fuel pool are no longer needed or applicable.

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ZionSolutions, LLC ZS-2014-0058: Attachment 1 Section 5.1, Responsibility, currently provides a general description of the responsibilities of the Decommissioning Plant Manager and the Shift Supervisor with respect to spent fuel management duties. ZionSolutions is proposing to delete the Shift Supervisor requirements in Section 5.1.2 and relocate the remaining section 5.1.1 to the QAPP. With removal of all of the spent fuel from the spent fuel pool, a need for the Shift Supervisor for spent fuel management no longer exists. Therefore, Section 5.1.2 which provides a description of responsibility of the Shift Supervisor will be deleted from the Technical Specifications. The remaining section 5.1.1 will be deleted from the Technical Specifications and relocated to the QAPP to provide the responsibilities for the Decommissioning Plant Manager. Providing this description in the QAPP is consistent with NRC Administrative Letter 95-06. Therefore, the proposed deletion of Section 5.1 is acceptable.

Section 5.2. 1, General Organizational Requirements, provides a general discussion of the unit organization established for safe facility operations so that nuclear safety is assured. Section 5.2.1 .d provides requirements for independence of the Certified Fuel Handler trainers and the Health Physics and Quality Assurance personnel. ZionSolutions proposes to delete the portion of Section 5.2.1 .d pertaining to Certified Fuel Handler trainers.

The remainder of section 5.2.1 will be deleted from the Technical Specifications and relocated to the QAPP to provide an equivalent description of the requirements for independence of the Health Physics and Quality Assurance personnel. Providing unit organization description in the QAPP is consistent with NRC Administrative Letter 95-06.

Therefore, the proposed deletion and relocation are acceptable.

Section 5.2.2, Facility Staff, provides requirements for staff. ZionSolutions proposes to delete Section 5.2.2. With the completion of the transfer of all the spent fuel to the ISFSI, these requirements are no longer applicable.

Therefore, the deletion of the staff composition and staffing requirements is acceptable.

Section 5.3, Facility Staff Qualification, currently specifies the minimum qualifications that each member of the facility staff, the Radiation Protection Manager and the Decommissioning Operations Manager must meet. ZionSolutions proposes to delete this requirement from the Technical Specifications and relocate it to the QAPP except for the Decommissioning Operations Manager which will no longer exist once all the spent fuel is transferred to the ISFSI. The relocated requirement will be maintained in accordance with 10 CFR 50.54(a). Since this administrative requirement will be maintained in the QAPP, the proposed relocation of the requirement is consistent with NRC Administrative Letter 95-06. Therefore, the proposed deletion and relocation are acceptable.

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ZionSolutions, LLC ZS-2014-0058: Attachment 1 Section 5.4, Training, currently specifies the training requirement for the Certified Fuel Handlers. ZionSolutions proposes to delete this requirement.

With the completion of the transfer of all the spent fuel to the ISFSI, there will no longer be a need for the Certified Fuel Handlers or for the associated training. Therefore, the proposed deletion of Section 5.4 is acceptable.

Section 5.5, Procedures, currently specifies requirement for procedures.

Section 5.5.1 .a provides guidance for procedures applicable to the safe storage of nuclear fuel. ZionSolutions proposes to delete this section from the Technical Specification. The remaining section of 5.5 will be deleted from the Technical Specifications and relocated it to the QAPP. It will be maintained in accordance with 10 CFR 50.54(a). Since this administrative requirement will be maintained in the QAPP, the proposed relocation of the requirement is consistent with NRC Administrative Letter 95-06.

Therefore, the proposed deletion and relocation are acceptable.

Section 5.6, Programs and Manuals, provides specific requirements for certain programs. ZionSolutions proposes to delete the requirements contained in Section 5.6.4, Technical Specification (TS) Bases Control Program since the bases are all spent fuel pool related. In addition, the remaining programs contained in Section 5.6.1, Offsite Dose Calculation Manual (ODCM); Section 5.6.2, Radioactive Effluent Controls Program; and Section 5.6.3, Outdoor Storage Tank Radioactivity Monitoring Program will be deleted from the Technical Specifications and relocated to the QAPP. Since this administrative requirement will be maintained in the QAPP, the proposed relocation of the requirement is consistent with NRC Administrative Letter 95-06. Therefore, the proposed deletion and relocation are acceptable.

Section 5.6.1, Offsite Dose Calculation Manual (ODCM), currently specifies how to document, review, and approve changes to the ODCM.

ZionSolutions proposes to delete this requirement from the Technical Specifications and relocate it to the QAPP. This requirement will be maintained in accordance with 10 CFR 50.54(a). Since the intent of this section is to ensure that the ODCM continues to meet the requirements of 40 CFR 190, 10 CFR 20, 10 CFR 50.36(a), and 10 CFR 50, Appendix I, and since this requirement will be maintained in the QAPP, the proposed relocation of the requirement is consistent with NRC Administrative Letter 95-06. Therefore, the proposed deletion and relocation of the requirement are acceptable.

Section 5.6.2, Radioactive Effluent Controls Program, currently conforms to 10 CFR 50.36(a) and specifies requirements for the control of radioactive effluents and for maintaining doses to the public from effluents ALARA. ZionSolutions proposes to delete this requirement from the Technical Specifications and relocate it to the QAPP, except for the last sentence "The provisions of SR 3.0.2 are applicable to Radioactive Page 6 of 16

ZionSolutions, LLC ZS-2014-0058: Attachment I Effluent Controls Program surveillance frequencies.". This sentence will be deleted from the Technical Specifications and not relocated to the QAPP. The equivalent surveillance requirement currently exists in the ODCM, Chapter 12, Radiological Effluent Technical Standards. The requirement will be maintained in accordance with 10 CFR 50.54(a).

Since the intent of this section is to ensure that the Radioactive Effluent Controls Program continues to meet the requirements of 10 CFR 20, 10 CFR 50, Appendix I, and 40 CFR 190, and since this requirement will be maintained in the QAPP, the proposed relocation of the requirement is consistent with NRC Administrative Letter 95-06. Therefore, the proposed deletion and relocation of the requirement are acceptable.

Section 5.6.3, Outdoor Storage Tank Radioactive Monitoring Program, currently provides controls for the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. ZionSolutions proposes to delete these requirements from the Technical Specifications and relocate them to the QAPP, except for the last sentence "The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Outdoor Storage Tank Radioactivity Program surveillance frequencies.". This sentence will be deleted from the Technical Specifications and will not be relocated to the QAPP. A surveillance requirement equivalent to SR 3.0.2 currently exists in the ODCM, Chapter 12, Radiological Effluent Technical Standards. SR 3.0.3 will not be relocated to the QAPP. The ODCM requires a more conservative response in the event that a surveillance is not performed.

The requirement will be maintained in accordance with 10 CFR 50.54(a).

The proposed relocation of the requirement is consistent with NRC Administrative Letter 95-06. Therefore, the proposed deletion and relocation of the requirement are acceptable.

Section 5.6.4, Technical Specification (TS) Bases Control Program, provides means for processing changes to the Bases of the Technical Specifications. ZionSolutions proposes to delete this requirement from the Technical Specifications. Deletion of the Technical Specification Bases Control Program is acceptable because with the transfer of all the spent fuel assemblies from the spent fuel pool to the ISFSI, there will no longer be any LCOs or SRs. Therefore, statements of bases for Technical Specifications will no longer be required, and the proposed deletion is acceptable.

Section 5.7, Reporting Requirements, currently provides requirements for reports submitted in accordance with 10 CFR 50.4. Section 5.7.2 and Section 5.7.3 specify the content and submission requirements for the Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report, respectively. ZionSolutions proposes to delete these requirements from the Technical Specifications and relocate them to the QAPP. The requirements will be maintained in accordance with 10 CFR 50.54(a). The proposed relocation of these requirements is consistent with NRC Administrative Letter 95-06. Therefore, the proposed deletion Page 7 of 16

ZionSolutions, LLC ZS-2014-0058: Attachment 1 and relocation of these requirements are acceptable. Section 5.7.1 was previously deleted in Amendments 184 and 171 for Units 1 and 2, respectively.

Section 5.8, High Radiation Area, currently specifies the posting and access control requirements for high radiation areas pursuant to 10 CFR 20.1601(c). ZionSolutions proposes to delete the requirements and relocate them to the QAPP. The requirements will be maintained in accordance with 10 CFR 50.54(a). The requirements of 10 CFR 20 would continue to mandate appropriate personnel protection and the proposed relocation is consistent with NRC Administrative Letter 95-06. Therefore, the proposed deletion and relocation of these requirements are acceptable.

Section 5.9, Reviews, provides requirements for Qualified Technical Reviewers and the Station Review Committee (SRC). ZionSolutions proposes to delete these requirements from the Technical Specifications and relocate them to the QAPP. The requirements will be maintained in accordance with 10 CFR 50.54(a). The proposed relocation of these requirements is consistent with NRC Administrative Letter 95-06.

Therefore, the proposed deletion and relocation of these requirements are acceptable.

2.2 Deletion of Permanently Defueled Technical Specification Bases The current Permanently Defueled Technical Specification Bases provides bases and reasons for current LCOs and SRs. ZionSolutions proposes to delete the bases sections for the Technical Specification Sections B 3.0 and B 3.1. After all of the spent fuel has been transferred to the ISFSI, Specifications B 3.0 and B 3.1 are no longer needed and are being deleted from the ZNPS Technical Specifications. Therefore, the statements for the Technical Specification Bases will not be required. Therefore, the proposed deletion is acceptable.

2.3 Appendix B Environmental Technical Specification for Zion Station Units 1 and 2 No changes are proposed for Appendix B.

2.4 Facility Operating Licenses for Units 1 and 2 ZionSohltions proposes the following changes to both Facility Operating Licenses Nos. DPR-39 and DPR- 48 (Docket Nos. 50-295 and 50-304).

A. Section 2.C.(6)

Unit I Facility Operating License The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Zion Nuclear Power Station Independent Spent Fuel Page 8 of 16

ZionSohltions, LLC ZS-2014-0058: Attachment I Storage Installation Physical Security Plan. This plan contains Safeguards Information protected under 10 CFR 73.21. (revised 1-15-81; Am. 61; revised 10-11-88; Am. 102: revised 12-13-13; Am. 187, revised mm-dd-yy, AM. xxx).

Unit 2 Facility Operating License The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Zion Nuclear Power Station Independent Spent Fuel Storage Installation Physical Security Plan. This plan contains Safeguards Information protected under 10 CFR 73.21. (revised 1-15-81; Am. 61; revised 10-11-88; Am. 102: revised 12-13-13; Am. 174, revised mm-dd-yy, AM. xxx).

B. Section 2.C.(7) Spent Fuel Pool Modification Because the spent fuel pool will no longer be required for storage of spent fuel assemblies, ZionSolutions proposes to delete this section for both units.

C. Section 2.C.(16) (Related to the single-failure proof fuel building crane)

Because a single-failure proof crane is no longer required ZionSolutions proposes to delete this section for both units.

3.0 TECHNICAL ANALYSIS

3.1 Deletion and Relocation of Technical Specifications Currently, ZionSolutions is in the process of decommissioning the ZNPS. In support of decommissioning, the spent fuel is being transferred from the spent fuel pool to the ISFSI. The proposed changes to the ZNPS Technical Specifications reflect the removal of all the spent fuel from the spent fuel pool.

With no spent fuel in the spent fuel pool, the purpose of the design bases for spent fuel storage and the design basis accident for fuel handling are no longer applicable. The ZNPS Defueled Safety Analysis Report (DSAR), Chapter 5, Safety Analysis, addresses the design basis accidents related to the spent fuel pool.

These postulated accidents are predicated on spent fuel being stored in the spent fuel pool. With removal of the spent fuel from the spent fuel pool, there are no remaining spent fuel assemblies to be monitored and there are no credible fuel related accidents that require actions of a Certified Fuel Handler, Shift Supervisor, or a Non-certified Operator to prevent occurrence or mitigate the consequences.

In addition, the ZNPS DSAR Chapter 5 also provides a discussion of other radiological events postulated to occur as a result of decommissioning with the bounding consequences resulting from the failure of a High Integrity Container (HIC) containing dewatered radioactive demineralizer resin. The proposed changes do not have an adverse impact on the remaining decommissioning activities or any of their postulated consequences.

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ZionSolutions, LLC ZS-2014-0058: Attachment 1 With no spent fuel in the spent fuel pool, there is no need to maintain spent fuel water level, verification of boron concentration, spent fuel pool cooling, and safe load paths over the spent fuel pool are no longer necessary.

The proposed amendment request relocates Administrative Requirements contained in Sections of 5.1, Responsibility; 5.2, Organization; 5.3 Facility Staff Qualifications; 5.5, Procedures; 5.6, Programs and Manuals; 5.7, Reporting Requirements; 5.8, High Radiation Area; and 5.9, Reviews to the QAPP. Since the relocated requirements will be maintained in the QAPP in accordance with 10 CFR 50.54(a) and the proposed relocation of the requirements are consistent with NRC Administrative Letter 95-06, the proposed relocation is acceptable.

Consequently, by removing the spent fuel from the spent fuel pool, the probability and consequences of the design events associated with spent fuel have been removed. There is no possibility for a new or different type of fuel related accident. The margin of safety associated with the spent fuel design basis accident is no longer applicable.

3.2 Deletion of Permanently Defueled Technical Specification Bases The current Permanently Defueled Technical Specification Bases provides bases and reasons for current LCOs and SRs. ZionSolutions proposes to delete the bases sections for the Technical Specification Sections B 3.0 and B 3.1. After all of the spent fuel has been transferred to the ISFSI, Specifications B 3.0 and B 3.1 are no longer needed and are being deleted from the ZNPS Technical Specifications. Therefore, the statements for the Technical Specification Bases are no longer applicable.

3.3 Changes to the Facility Operating Licenses The current Facility Operating Licenses allow for the licensee to implement and maintain both the Zion Nuclear Power Station Security Plan and the Zion Nuclear Power Station Independent Spent Fuel Storage Installation Physical Security Plan in Section 2.C.(6). In addition, the current Facility Operating Licenses provide for Section 2.C.(7) related to spent fuel pool modification and Section 2.C.(1 6) related to the single-failure proof fuel building crane. After all of the spent fuel has been transferred to the ISFSI, ZionSolutions proposes to modify Section 2.C.(6) to specify only the Zion Nuclear Power Station Independent Spent Fuel Storage Installation Physical Security Plan and delete Section 2.C.(7) and 2.C.(1 6) which will no longer needed.

4.0 REGULATORY ANALYSIS

4.1 No Significant Hazards Consideration In accordance with 10 CFR 50.92, ZionSolutions has reviewed the proposed changes and concluded that the proposed changes do not involve a Significant Page 10 of 16

ZionSolutions, LLC ZS-2014-0058: Attachment I Hazard Consideration (SHC). The following is provided in support of this conclusion.

4.1.1 Deletion and Relocation of Technical Specifications and Deletion of the Permanently Defueled Technical Specifications Bases and Changes to the Facility Operating Licenses The proposed changes do not involve an SHC because the changes would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes (deletion of operational requirements and certain design requirements) reflect the complete transfer of the spent fuel from the spent fuel pool to the ISFSI. Design basis accidents related to the spent fuel pool are discussed in the ZNPS DSAR Chapter 5. These postulated accidents are predicated on spent fuel being stored in the spent fuel pool. With the removal of the spent fuel from the spent fuel pool, there are no remaining spent fuel assemblies to be monitored and there are no credible accidents that require the actions of a Certified Fuel Handler, Shift Supervisor, or a Non-certified Operator to prevent occurrence or mitigate the consequences of an accident.

In addition, the ZNPS DSAR Chapter 5 also provides analyses of accidents as result of decommissioning with the bounding consequences resulting from the failure of a High Integrity Container (HIC) containing dewatered radioactive demineralizer resin.

The proposed changes do not have an adverse impact on the remaining decommissioning activities or any decommissioning related postulated accident consequences.

The proposed changes related to the relocation of certain administrative requirements do not affect operating procedures or administrative controls that have the function of preventing or mitigating any remaining decommissioning design basis accidents.

In addition, these proposed changes are consistent with the guidance of NRC Administrative Letter 95-06.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of any accident previously evaluated.

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ZionSolutions, LLC ZS-2014-0058: Attachment 1

2. Create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes eliminate the operational requirements and certain design requirements associated with the storage of the spent fuel in the spent fuel pool, and relocate certain administrative controls to the QAPP.

With the complete removal of the spent fuel from the spent fuel pool and transfer to the ISFSI, there are no spent fuel assemblies that remain at the plant and the potential for fuel related accidents is removed. The proposed changes do not introduce any new failure modes. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any previously evaluated.

3. Involve a significant reduction in a margin of safety.

The design basis and accident assumptions within the ZNPS DSAR and the Technical Specifications relating to spent fuel are no longer applicable. The proposed changes do not affect remaining plant operations, systems, or components supporting decommissioning activities. In addition, the proposed changes do not result in a change in initial conditions, system response time, or in any other parameter affecting the course of the remaining decommissioning activity accident analysis. Therefore, the proposed changes. do not involve a significant reduction in a margin of safety.

4.2 Applicable Regulatory Requirements/Criteria 4.2.2 Deletion and Relocation of Technical Specifications and Changes to the Facility Operating Licenses Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include Technical Specifications as part of the application. The Commission's regulatory requirements related to the content of Technical Specifications are set forth in 10 CFR 50.36. In 10 CFR 50.36, the emphasis is placed on matters related to the prevention of accidents, mitigation of accident consequences, and items directly related to maintaining the integrity of the physical barriers designed to contain radioactivity. That regulation requires that Technical Specifications include items in five specific categories: (1) safety limits, limiting safety systems settings and limiting control settings (10 CFR 50.36(c)(1)); (2) Limiting Conditions for Operation (LCO) (10 CFR 50.36(c)(2)); (3) surveillance requirements (10 CFR 50.36(c)(3)); (4) design features (10 CFR 50.36(c)(4)); and (5) administrative controls (10 CFR 50.36(c)(5)). The regulation, however, does not specify particular Page 12 of 16

ZionSolutions, LLC ZS-2014-0058: Attachment 1 items to be included in Technical Specifications. As described above, ZionSolutions proposes to delete the Definitions, the LCOs, Surveillance Requirements and associated Bases, design features related to spent fuel storage, and delete/relocate certain Administrative Controls.

10 CFR 50.36(c)(1), Safety Limits, limiting safety settings, and limiting control settings This section is no longer applicable and is not part of the current ZNPS Technical Specifications.

10 CFR 50.36(c)(2), Limiting conditions for operation On July 22, 1993 (58FR39132) the Commission published a "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (Final Policy Statement) which discussed the criteria to determine which items are required to be included in the Technical Specifications as LCOs. The criteria were subsequently incorporated into the regulations by an amendment to 10 CFR 50.36 (60FR36953). Specifically 10 CFR 50.36(c)(2)(ii) requires that a technical specification limiting condition for operation of a nuclear reactor be established for each item meeting one or more of the following criteria:

Criterion 1 - Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion2 - A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion3 - A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion4 - A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The five LCOs, in Section 3.0, Section 3.1.1, Section 3.1.2, and Section 3.1.3, currently in the ZNPS Technical Specifications, are directly related to the storage of spent nuclear fuel in the spent fuel pool. After all the spent nuclear fuel has been transferred to the ISFSI, none of the four criteria listed above would apply and the LCOs would no longer be applicable. Therefore, it is acceptable to delete these LCOs from the Technical Specifications.

10 CFR 50.36(c)(3), Surveillance requirements Surveillance requirements relate to verification and inspection to assure that the necessary quality of systems and components is maintained and that the limiting conditions for operation will be met.

As discussed above, following transfer of all the spent nuclear fuel to the ISFSI, the LCOs are no longer applicable. Deleting the LCOs eliminates the need for surveillance requirements in the Page 13 of 16

ZionSolutions, LLC ZS-2014-0058: Attachment 1 Technical Specifications. Therefore, the proposed deletion of the surveillance requirements is acceptable.

10 CFR 50.36(c)(4), Design features Design features are those features of the facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety and are not covered in categories described in 10 CFR 50.36 subparagraphs (c)(1), (2), and (3).

Technical Specification 4.2 currently addresses spent fuel design characteristics, storage capacity, and criticality control. The proposed amendment deletes the text of this section. With no spent fuel being stored in the spent fuel pool, there is no longer a concern regarding criticality, drainage or capacity since these design features are no longer applicable. Therefore, the proposed deletion is acceptable.

10 CFR 50.36(c)(5), Administrative controls Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. The particular administrative controls to be included in the Technical Specifications are the provisions that the Commission deems essential for the safe operation of the facility that are not covered by other regulations. Therefore, it is appropriate that administrative control requirements that are not specifically required under 10 CFR 50.36(c)(5), and that are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an.

immediate threat to the public health and safety, be relocated to more appropriate documents (e.g., Quality Assurance Program, Security Plan, or Emergency Plan) which are subject to regulatory controls.

The QAPP is a logical candidate for the relocation of administrative controls because the controls imposed by 10 CFR 50 Appendix B, the existence of an NRC approved quality assurance program, and the established quality assurance program change control process in 10 CFR 50.54(a) are maintained.

NRC Administrative Letter (AL) 95-06 "Relocation of Technical Specification Administrative Controls Related to Quality Assurance" provides guidance to licensees requesting amendments that relocate administrative controls to NRC approved quality assurance programs where changes are controlled in accordance with 10 CFR 50.54(a).

Certain administrative controls pertained to the safe storage of the spent fuel within the spent fuel pool. With the transfer of all the spent fuel to the ISFSI, these administrative controls are no longer applicable. Therefore the proposed deletion is acceptable. As discussed above, relocation of the administrative controls proposed in the amendment is consistent with the guidance in NRC Administrative Letter 95-06 and is therefore acceptable.

Lastly, 10 CFR 50.36(c)(6) "Decommissioning" states that for nuclear power reactor facilities that have submitted the certifications required by §50.82(a)(1), Technical Specifications involving limiting conditions for operation; surveillance requirements; design features; and administrative controls will be developed on a case-by-case basis.

Page 14 of 16

ZionSolutions, LLC ZS-2014-0058: Attachment I Based on the discussion above, ZionSolutions believes that the proposed amendment is completely consistent with the content of NRC Administrative Letter 95-06 as well as the justification provided above and that the health and safety of the public will not be endangered by operation of the facility in the proposed manner.

5.0 ENVIRONMENTAL CONSIDERATION

ZionSolutions has evaluated the proposed changes against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.22. ZionSolutions has determined that the proposed changes meet the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)( 10)) and as such, has determined that no irreversible consequences exist in accordance with 10 CFR 50.92(b). The following is provided in support of the conclusion.

5.1 Deletion and Relocation of Technical Specifications and Changes to the Facility Operating Licenses (i) The proposed changes involve no significant hazards consideration.

As demonstrated in Section 4.1.1 of this attachment, the proposed changes do not involve an SHC and the action to remove fuel from the defueled plant reduces the inherent hazard.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released off site.

The proposed changes remove operational and administrative requirements for systems that are no longer functionally required to support the safe storage of the spent fuel within the spent fuel pool and which will eventually be demolished. In addition Technical Specification administrative controls are being relocated to the QAPP. These changes are administrative in nature and do not affect any systems such that there may be an increase or change in the type of effluents discharged offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The elimination of non-applicable operational and administrative requirements from the Technical Specifications will not result in a significant increase in individual or cumulative occupational radiation exposure.

Page 15 of 16

ZionSolutions, LLC ZS-2014-0058: Attachment 1 6.0 Precedent It is noted that similar Technical Specification changes were reviewed and approved by the NRC for Maine Yankee Atomic Power Company (Docket No. 50-309, Amendment No. 171, dated May 5, 2004), Yankee Atomic Electric Company (Docket No. 50-29, Amendment No. 157, dated April 18, 2003), Rancho Seco Plant (Docket No. 50-312, Amendment No. 130, dated February 5, 2002), and Connecticut Yankee Atomic Power (Docket No. 50-213, Amendment No.

201, dated December 20, 2004).

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ZionSolutions, LLC ZS-2014-0058: Attaclunent 2 Zion Nuclear Power Station Proposed Technical Specifications

ZION NUCLEAR POWER STATION TECHNICAL SPECIFICATIONS

TABLE OF CONTENTS SPECIFICATIONS TABLE OF CONTENTS 1.0 USE AND APPLICATION 2.0 SAFETY LIMITS 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 4.0 DESIGN FEATURES 4.1 Site 5.0 ADMINISTRATIVE CONTROLS Zion Station Amendment Nos.

Definitions 1.0 1.0 USE AND APPLICATION This section is no longer applicable.

Zion Station 1-0 Amendment Nos.

Safety Limits 2.0 2.0 SAFETY LIMITS This section is no longer applicable.

Zion Station 2-0 Amendment Nos.

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY This section is no longer applicable.

Zion Station 3-0 Amendment Nos.

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site 4.1.1 Site Location Zion Units 1 and 2 are located at the Zion Station which consists of a tract of land of approximately 250 acres located in the extreme eastern portion of the city of Zion, Lake County, Illinois, on the west shore of Lake Michigan approximately 6 miles NNE of the center of the city of Waukegan, Illinois, and 8 miles south of the center of the city of Kenosha, Wisconsin. It is located at longitude 870 48.1' W and latitude 420 26.8' N.

Zion Station 4-0 Amendment Nos.

Responsibility 5.0 5.0 ADMINISTRATIVE CONTROLS This section relocated to the QAPP.

Zion Station 5-0 Amendment Nos.

ZionSolutions, LLC ZS-2014-0058: Attachment 3 Zion Nuclear Power Station Proposed Quality Assurance Project Plan ZS-QA-10 Affected Pages

ZS-QA-10 Revision 5 Information Use TABLE OF CONTENTS Pae

1.0 INTRODUCTION

5 1.1 Project Quality Assurance Program 5 1.2 Scope 7 2.0 QUALITY RESPONSIBILITIES 8 2.1 Responsibility 8 2.2 Organization 8 2.3 Senior Vice President & General Manager 9 2.4 President 9 2.5 Management Team 9 2.6 Vice President of Regulatory Affairs 10 2.7 Quality Assurance Manager 10 2.8 Training Manager 10 2.9 ZionSolutions Project Review and Advisory Board 10 2.10 Quality Assurance Personnel 11 2.11 Support Personnel 11 2.12 Supplier/Subcontractor Project Managers 11 2.13 Supplier/Subcontractor Quality Assurance Managers 11 3.0 CLASSIFICATION OF PROJECT TASKS 11 Table 3.1 - ZionSolutions Quality Classification Category Descriptions 13 4.0 QUALITY ASSURANCE REQUIREMENTS 14 4.1 Organization 14 4.2 QA Program 15 4.3 Design Control 18 4.4 Procurement Document Control 23 4.5 Instructions, Procedures and Drawings 24 4.6 Document Control 25 4.7 Control of Purchased Material, Equipment and Services 25 4.8 Identification and Control of Materials, Parts and Components 29 4.9 Control of Special Processes 30 4.10 Inspection 31 4.11 Test Control 33 4.12 Control of Measuring and Test Equipment 34 4.13 Handling, Storage and Shipping 35 4.14 Inspection, Test, and Operating Status 36 4.15 Nonconforming Materials, Parts or Components 37 3

ZS-QA-1 0 Revision 5 Information Use TABLE OF CONTENTS Page 4.16 Corrective Action 38 4.17 Quality Assurance Records 39 4.18 Audits 43 5.0 QUALITY MONITORING 46 6.0 ZIONSOLUTIONS QUALITY COUNCIL 46

7.0 REFERENCES

47 FIGURES Figure 1 ZionSolutions Restoration and DSC Organization Chart 48 APPENDICES Appendix A List of Acronyms 49 Appendix B Administrative Requirements (moved from Technical 50 Specifications) 4

ZS-QA-10 Revision 5 Information Use 2.0 QUALITY RESPONSIBILITIES This section defines the responsibilities of key project members accountable for implementation of the QAPP. Functions and actions can be delegated; however, the responsibility remains with the designated individual. Implementation and management oversight of the QAPP is the responsibility of the following key individuals:

Note: Minor variations may occur between the titles contained herein and those used in practice. Specific position descriptions may be contained in other approved company documents. Certain functions may be named differently within the EnergySolutions and ZionSolutions organizations.

2.1 Responsibility 2.1.1 The Decommissioning Plant Manager shall be responsible for overall plant operations and shall delegate in writing the succession to this responsibility during his absence. The Decommissioning Plant Manager or his designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect the safe storage of nuclear fuel.

2.2 Organization 2.2.1 General Organizational Requirements - Onsite and offsite organizations shall be established for station and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safe storage of nuclear fuel.

a. Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the Quality Assurance Manual or a site specific quality assurance program description incorporated directly or by reference in the DSAR.

b. The Decommissioning Plant Manager shall be responsible for overall plant safety and shall have control over those on site activities necessary for safe storage of nuclear fuel.

c. The President, Zion Solutions, shall have corporate responsibility for the safe storage of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure the safe storage of nuclear fuel.

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ZS-QA-10 Revision 5 Information Use

d. The individuals who carry out health physics and quality assurance functions may report to an appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

2.3 Senior Vice President & General Manager (GM)

This project executive provides direct oversight of the project, and other selected tasks, to ensure the project is properly planned, staffed and executed. The GM has overall authority and responsibility for the establishment and effective implementation of the ZionSolutions quality assurance program. The GM has periodic meetings with the management team to review plans and progress and to address stakeholder, quality, and project management issues. The GM delegates to the Management Team the day-to-day responsibilities for the DCS project, plant operation and decommissioning such as, but not limited to, safe conduct of work, procedure reviews, test and experiment reviews, personnel qualification, and other selected tasks.

2.4 President The President, Zion Solutions, shall have corporate responsibility for the safe handling and storage of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure the safe handling and storage of nuclear fuel.

2.5 Management Team The Management Team consist of those VP's, Directors and Managers who are the senior person in each department/functional area. They report directly to the GM on all DCS project, plant operations and decommissioning activities and are responsible for the implementation of the QAPP for the duration of the project and other site activities as designated by the GM. Management Team members have full authority and accountability for successful project planning and execution, including effective implementation of this QAPP. They are responsible for assuring that project personnel are properly indoctrinated, trained, and qualified to all applicable project quality and technical requirements. They also are responsible for satisfactory resolution of nonconforming conditions and effective implementation of corrective action commitments. They are responsible for contract management and development of contract deliverables in accordance with quality requirements defined in this QAPP. They are also responsible for ensuring that applicable project quality and technical requirements are transmitted to, addressed by, and acceptably implemented by the project's Subcontractors.

9

ZS-QA-10 Revision 5 Information Use 4.0 QUALITY ASSURANCE REQUIREMENTS Quality procedures, instructions, processes, and systems will be utilized to manage, supervise and perform work for the duration of the Zion Restoration and DCS project.

The approach to achieving effective quality assurance and control throughout the project involves the effective execution of this QAPP, the DFSS Designer, the Design Authority, and other supplier/subcontractor quality programs and associated procedures, instructions, processes, and systems. A Design Authority (DA) is a selected Architect-Engineering firm, crane designer, or the selected Dry Cask Storage System (DCSS) Designer for the DCS project. Each is the Design Authority within its assigned scope of responsibility.

The Administrative Controls previously contained in Section 5.0 of the ZNPS Permanently Defueled Technical Specifications are now contained in this QAPP as Appendix B. The Administrative Controls will be implemented for applicable decommissioning, spent fuel, and ISFSI activities as indicated in Appendix B.

Note:

Some of the requirements of QAPP Appendix B are only required to support defueled plant decommissioning activities and will be deleted as decommissioning progresses. The remaining Administrative Controls will continue to be applicable to the ISFSI and other applicable licensed activities.

4.1 Organization The Zion Restoration and DCS Project organization, authority, duties, responsibilities, and interface requirements are addressed in QAPP Section 2.0, Quality Responsibilities. These activities include performing activities affecting the functions of structures, systems, and components which are important to safety, those associated with attaining quality objectives, and the QA functions. The primary Zion Restoration and DCS Project organizations are ZionSolutions, EnergySolutions, DFSS Designer, DFSS Prime Fabricator(s), and Design Authorities.

The QAM position shall be responsible for verifying the proper establishment and effective execution of the QAPP and shall have no assigned responsibilities that would preclude appropriate attention to Quality Assurance matters.

Quality Assurance staff shall have sufficient independence from cost and schedule considerations and shall have the access to work areas and organizational freedom to effectively identify quality problems, initiate, recommend or provide solution to quality problems through designated channels, verify implementation of solutions; and assure that further processing, delivery, installation, and use are controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.

The QAM has the authority to stop work when significant conditions adverse to quality warrant such action.

14

Appendix B 5.0 ADMINISTRATIVE CONTROLS (moved from Technical Specifications -

Technical Specification numbering preserved to facilitate comparison) 5.3 Facility Staff Qualifications 5.3.1 Staff Qualifications - Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1, "Selection and Training of Nuclear Power Plant Personnel," dated March 8, 1971, with the following exceptions:

a. Either the Manager of the Health Physics Department or the Lead Health Physicist shall meet or exceed the qualifications of "Radiation Protection Manager" of Regulatory Guide 1.8, September 1975.

5.5 Procedures 5.5.1 Procedures - Written procedures shall be established, implemented, and maintained covering the following activities:

b. Fire Protection Program implementation; and

c. All programs specified in 5.6 (below).

5.6 Programs and Manuals The following programs shall be established, implemented and maintained.

5.6.1 Offsite Dose Calculation Manual (ODCM)

a. The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program;

b. The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release Reports required by 5.7.2 and 5.7.3 (see page 53);

c. Licensee initiated changes to the ODCM:

1. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:

I. Sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and II . A determination that the change(s) will maintain the levels of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50. Appendix I, and do 50

not adversely impact the accuracy or reliability of effluent, dose or setpoint calculations:

2. Shall become effective after the approval of the Decommissioning Plant Manager or designee; and

3. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made effective. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.6.2 Radioactive Effluent Controls Program - This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

a. Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM;

b. Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas, conforming to ten times the concentration values in 10 CFR 20, Appendix B, Table 2, Column 2;

c. Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM;

d. Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released for each unit to unrestricted areas, conforming to 10 CFR 50, Appendix I;

e. Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days;

f. Limitations on the functional capability and use of the liquid and gaseous effluent treatment systems to ensure that appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31 day period would 51

exceed 2 percent of the guidelines for the annual dose or dose commitment, conforming to Appendix I to 10 CFR 50;

g. Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas beyond the site boundary conforming to the following:

1. For noble gases: less than or equal to a dose rate of 500 mrem/yr to the whole body and less than or equal to a dose rate of 3000 mrem/yr to the skin; and

2. For tritium and for all radionuclides in particulate form with half-lives greater than 8 days: less than or equal to a dose rate of 1500 mrem/yr to any organ;

h. Limitations on the annual and 'quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the site boundary, conforming to Appendix I to 10 CFR 50; I. Limitations on the annual and quarterly doses to a member of the public from tritium and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from each unit to areas beyond the site boundary, conforming to Appendix I to 10 CFR 50; and j- Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.

5.6.3 Outdoor Storage Tank Radioactivity Monitoring Program - This program provides controls for the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. This program is required if radioactive liquid is contained in unprotected (as defined below) outdoor storage tanks. The liquid radwaste quantities shall be determined in accordance with the ODCM.

The program shall include a surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by iners, dikes, or walls, capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system is less than the amount that would result in concentrations less than the limits of 10 CFR 20, Appendix S, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

5.7 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4 (note that a single submittal may be made for a multiple unit station):

52

5.7.2 Annual Radiological Environmental Operating Report - The Annual Radiological Environmental Operating Report covering unit activities during the previous calendar year shall be submitted before May 15 of each year. The report shall include summaries, interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in (1) the ODCM and (2)

Sections IV.B.2, IV.B.3, and IV.C of Appendix I of 10 CFR Part 50. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.7.3 Radioactive Effluent Release Report - The submittal should combine sections common to all units at the station. The Radioactive Effluent Release Report covering unit activities shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be (1) consistent with the objectives outlined in the ODCM and Process Control Program and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I t to 10 CFR Part 50.

5.8 High Radiation Area 5.8.1 Pursuant to 10 CFR 20, paragraph 20.1601(c), in lieu of the "control device" or "alarm signal" required by 10 CFR 20.1601, each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is equal 'to or less than 1000 mrem/hr at 30 cm (12 in) from the radiation source or from any surface which the radiation penetrates, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates equal to or less than 1000 mrem/hr, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area; or

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received . Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been 53

established and personnel have been made knowledgeable of them: or

c. An individual qualified in radiation protection procedures with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified in the Radiation Work Permit.

5.8.2 In addition to the requirements of 5.8.1 above, areas accessible to personnel with radiation levels greater than 1000 mrem/hr at 30 cm (12 in) from the radiation source or from any surface which the radiation penetrates shall require the following:

a. Locked doors to prevent unauthorized entry. The keys shall be maintained under the administrative control of the operating shift supervision on duty and/or health physics supervision.

b. Personnel access and exposure control over activities being performed within these areas shall be specified by an approved RWP. During emergency situations which involve personnel injury or actions taken to prevent major equipment damage, continuous surveillance and radiation monitoring of the work area by an individual qualified in radiation protection procedures may be substituted for the routine RWP procedure.

c. Each person entering the area shall be provided with an alarming radiation monitoring device which continuously integrates the radiation dose rate (such as an electronic dosimeter). Continuous coverage by a radiation technician may be substituted for alarming dosimetry.

5.8.3 For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mrem/hr at 30cm (12 in.), that are located within large areas (With the exception of 5.8 .4), including the containment outside the missile barrier, where no enclosure exists for purposes of locking, and where no enclosure can be reasonably constructed around the individual area. that individual area shall be barricaded (by a more substantial obstacle than a rope), conspicuously posted, and a flashing light shall be activated as a warning device.

5.8.4 For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mrem/hr at 30 cm (12 in.), that are located within the containment inside the missile barrier, where no enclosure exists for purposes of locking the individual area, the access control shall be per the following:

a. The missile barrier ingress/egress points shall be barricaded, locked and conspicuously posted to prevent access; or 54

b.

1. The missile barrier ingress/egress points shall be conspicuously posted and have direct or electronic surveillance that is capable of preventing unauthorized entry; and

2. Additional localized postings shall be provided in areas with normal personnel access inside the missile barrier to inform personnel of dose rates greater than 1000 mrem/hr at 30 cm (12 in).

5.9 Reviews 5.9.1 Qualified Technical Review - Thorough reviews of the documents specified below shall be conducted by a Qualified Technical Reviewer.

Persons performing these reviews shall be knowledgeable in the subject area being reviewed. Qualified Technical Reviews must be completed prior to implementation of proposed activities.

a. Qualified Technical Reviewers shall be individuals without direct responsibility for the document under review; these reviewers may be from the same functionally cognizant organization as the individual or group performing the original work.

b. Qualified Technical Reviewers shall have at least 5 years of professional experience and either a Bachelor's degree in Engineering or the Physical Sciences or shall have equivalent qualifications evaluated on a case by case basis and approved by the Decommissioning Plant Manager. The Decommissioning Plant Manager shall document the appointment of Qualified Technical Reviewers.

c. The following subjects shall be independently reviewed by a Qualified Technical Reviewer:

1. 10 CFR 50.59 evaluations for changes in the facility as described in the DSAR, changes in procedures as described in the DSAR, and tests or experiments not described in the DSAR to verify that such actions do not involve a change to the Technical Specifications or will not require NRC approval pursuant to 10 CFR 50.59;

2. Proposed changes to the programs required by section 5.6 above, and to verify that such changes do not involve a change to the Technical Specifications and will not require NRC approval pursuant to 10 CFR 50.59; and

3. Proposed changes to the license or Technical Specifications.

.5.9.2 Station Review Committee (SRC) - The SRC is responsible for reviewing and advising the Decommissioning Plant Manager on matters related to the safe storage of nuclear fuel. The review function is independent of line organization responsibilities.

55

a. The SRC shall include a minimum of five members. Alternates may be substituted for regular members. The licensee shall designate in writing the chairman, the members, and alternates for the SRC.

b. The SRC shall collectively have experience and knowledge in the following functional areas:

1. Fuel storage

2. Chemistry and radiochemistry

3. Engineering

4. Radiation protection, and

5. Regulatory assurance.

c. The SRC shall hold at least one meeting per quarter.

d. A quorum shall consist of three regular members or their duly appointed alternates. Those members representing the line organizations responsible for the operation and maintenance of the facility shall not constitute a majority of the quorum. At least one member of the quorum shall be the chairman or the chairman's designated alternate.

e. As a minimum, the SRC shall perform the following functions:

1. Advise the Decommissioning Plant Manager on all matters related to safe storage of nuclear fuel; and

2. Notify the responsible President, ZionSolutions, of any safety significant disagreement between the SRC and the Decommissioning Plant Manager within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

f. The SRC shall be responsible for reviewing:

1. The evaluations for new documents or changes to documents completed under the provisions of 10 CFR 50.59 to verify that such actions do not require NRC approval pursuant to 10 CFR 50.59. This review may be completed after implementation of the affected procedure;

2. Changes to structures, systems, or components important to the safe storage of nuclear fuel to verify that such changes do not require NRC approval pursuant to 10 CFR 50.59. This review may be completed after implementation of the change;

3. Tests or experiments involving the safe storage of nuclear fuel to verify that such tests or experiments do not require NRC approval pursuant to 10 CFR 50.59. This review may be completed after performance of the test or experiment;

4. Proposed changes to the license or Technical Specifications.

56

5. Violations of codes, regulations, orders, license requirements, or internal procedures/instructions having nuclear safety significance;

6. Indications of unanticipated deficiencies in any aspect of design or operation of structures, systems, or components that could affect safe storage of nuclear fuel;

7. Significant accidental, unplanned, or uncontrolled radioactive releases, including corrective action(s) to prevent recurrence;

8. Significant operating abnormalities or deviations from normal and expected performance of equipment that affect safe storage of nuclear fuel;

9. Internal and external experience information related to the safe storage of nuclear fuel that may indicate areas for improving facility safety; and

10. Reportable Events.

Reports or records of these reviews shall be forwarded to the Decommissioning Plant Manager within 30 days after completion of the review.

5.9.3 Records - Written records of reviews shall be maintained. As a minimum, these records shall include:

a. Results of the activities conducted under the provisions of sections 5.9.1 and 5.9.2 above; and

b. Determination of whether each item considered under sections 5.9.2.f.1 through 5.9.2.f.3 above requires NRC approval pursuant to 10 CFR 50.59.

57

ZionSolutions, LLC ZS-2014-0058: Attachment 4 Zion Nuclear Power Station, Unit 1 Proposed Amendment to Facility Operating License No. DPR-39 Docket No. 50-295 Affected Pages

C. This amended license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50 and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below.

(1) Deleted.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 187, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Deleted.

(4) Deleted.

(5) Deleted.

(6) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Zion Nuclear Power Station Independent Spent Fuel Storage Installation Physical Security Plan. This plan contains Safeguards Information protected under 10 CFR 73.21. (revised 1-15-81; Am. 61; revised 10-11-88; Am. 113: revised 12-13-13; Am. 187; revised mm-dd-yy, Am.xxx).

(7) Deleted.

Amendment No. 21, 61, 77, 82, 139, 142, 148,1!80,1!S7

(e) The appropriate section of the decommissioning trust agreement shall state that the trustee, investment advisor, or anyone else directing the investments made in the trust shall adhere to a "prudent investor" standard, as specified in 18 CFR 35.32(a)(3) of the Federal Energy Regulatory Commission's regulations.

(15) ZS shall take all necessary steps to ensure that the decommissioning trust is maintained in accordance with the application for approval of the transfer of the Zion, Unit 1, license and the requirements of the Order approving the transfer, and consistent with the safety evaluation supporting the Order.

(16) Deleted.

3. This amended license is issued without prejudice to subsequent licensing action which may be taken by the Commission.

4. This license is effective as of the date of issuance and shall expire at midnight on April 6, 2013.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by Roger S. Boyd A. Giambusso, Deputy Director For Reactor Projects Directorate of Licensing Date of Issuance: October 19, 1973 Amendment No. 486

ZionSolutions, LLC ZS-2014-0058: Attachment 5 Zion Nuclear Power Station, Unit 2 Proposed Amendment to Facility Operating License No. DPR-48 Docket No. 50-304 Affected Pages

C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

(1) Deleted.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 174, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Deleted 3-11-83; Am. 72.

(4) Deleted.

(5) Deleted.

(6) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Zion Nuclear Power Station Independent Spent Fuel Storage Installation Physical Security Plan. This plan contains Safeguards Information protected under 10 CFR 73.21. (revised 10-11-88; Am. 102: revised 12-13-13; Am. 174, revised mm-dd-yy; AM.xxx).

(7) Deleted.

Amendment No. 51, 59, 72, 102, 129, 136, 167, 174

(c) The decommissioning trust agreement for Zion, Unit 2, must provide that no disbursements or payments from the trust shall be made by the trustee unless the trustee has first given the Director of the Office of Nuclear Reactor Regulation 30 days prior written notice of payment. The decommissioning trust agreement shall further contain a provision that no disbursements or payments from the trust shall be made ifthe trustee receives prior written notice of objection from the NRC.

(d) The decommissioning trust agreement must provide that the agreement cannot be amended in any material respect without 30 days prior written notification to the Director of the Office of Nuclear Reactor Regulation.

(e) The appropriate section of the decommissioning trust agreement shall state that the trustee, investment advisor, or anyone else directing the investments made in the trust shall adhere to a "prudent investor" standard, as specified in 18 CFR 35.32(a)(3) of the Federal Energy Regulatory Commission's regulations.

(15) ZS shall take all necessary steps to ensure that the decommissioning trust is maintained in accordance with the application for approval of the transfer of the Zion, Unit 1, license and the requirements of the Order approving the transfer, and consistent with the safety evaluation supporting the Order.

(16) Deleted.

3. This amended license is issued without prejudice to subsequent licensing action which may be taken by the Commission.

4. This license is effective as of the date of issuance and shall expire at midnight on November 14, 2013.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by Roger S. Boyd A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Date of Issuance: November 14, 1973 Amendment No. 4-3