ZS-2014-0236, Withdrawal of the Original Request for Exemption as Applied to Transfer Times of Loaded Magnastor Canisters and a New Request for an Exemption as Applied to Transfer Times of Loaded Magnastor Canisters

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Withdrawal of the Original Request for Exemption as Applied to Transfer Times of Loaded Magnastor Canisters and a New Request for an Exemption as Applied to Transfer Times of Loaded Magnastor Canisters
ML14182A474
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 06/25/2014
From: Gerard van Noordennen
ZionSolutions
To:
Document Control Desk, NRC/FSME, Office of Nuclear Material Safety and Safeguards
References
ZS-2014-0236
Download: ML14182A474 (12)
v • d • e


Text

ZIONSOLUTIONSLLC An PnergySoafuonnCompany 10 CFR 72.7 10 CFR 72.212 10 CFR 72.214 June 25, 2014 ZS-2014-0236 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:

Withdrawal of the Original Request for Exemption as Applied to Transfer Times of Loaded MAGNASTOR Canisters and a New Request for an Exemption as Applied to Transfer Times of Loaded MAGNASTORO Canisters

References:

(1) Zion to NRC, Request for Exemption from Certain Requirements of 10 CFR Part 72.212(a)(2), 72.212(b)(3)(i), 72.212(b)(5)(i), 72.212(b)(1 1) and 72.214 as Applied to Transfer Times of Loaded MAGNASTOR Canisters dated July 2, 2013 (ZS-2013-0242)

(2) NRC Certificate of Compliance for Spent Fuel Storage Casks Issued to NAC International Inc. (NAC), Certificate No. 1031, MAGNASTORe, Amendment No. 3 (3) ED20130052, Submission of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for the NAC International MAGNASTOR Cask System, dated June 18, 2013 ML13268A050 & ML13268A049 (ADAMS Accession Nos. for Non-Proprietary Version)

(4) Application for Amendment to Materials Certificate of Compliance No. 1031, Docket No. 72-1031 - Supplemental Information Needed, U. S. Nuclear Regulatory Commission, August 8, 2013 (5) ED20130130, Submission of NAC's Response to the U.S. Nuclear Regulatory Commission's Request for Supplemental Information for NAC's Request to Amend the Certificate of Compliance No. 1031 for the NAC International MAGNASTOR Cask System, dated September 6, 2013 ML13261A278 (ADAMS Accession No. for Non-Proprietary Version)

(6) ED20130131, Submission of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for the NAC International MAGNASTOR Cask System, dated September 19, 2013 ML13171A031 (ADAMS Accession No. for Non-Proprietary Version)

(7) 78 FR 37927-37930, "List of Approved Spent Fuel Storage Casks:

MAGNASTOR System," June 25, 2013 101 Shiloh Boulevard, Zion - IL 60099 (224) 789-4016

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

ZionSolutions, LLC ZS-2014-0236 Page 2 of 4 This letter withdraws the Exemption Request submitted in Reference 1, dated July 2, 2013. The conditions requested in that exemption have changed in three ways. First, in Reference 6, NAC modified the request made in Reference 4 to provide specified durations on the affected transfer times in LCO 3.1.1, notably to change the allowed transfer time for a canister of< 20 kW from unlimited to 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />. ZionSolutions, LLC (ZS) concurs with that change. Second, this request no longer asks for an exemption to the transfer times for a cask with a heat load between 20 and 25 kW, as no casks of this heat load are expected in the fuel transfer campaign at Zion Station. Finally, the original request was prepared by ZS prior to the NRC issuance of Amendment 3 to Certificate of Compliance (CoC) No. 1031 (Reference 7). Accordingly, the request is modified to be an exemption to Amendment 3 to CoC No. 1031.

ZionSolutions, LLC hereby requests an exemption to change the allowed transfer time for a canister of < 20 kW from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> as currently required by LCO 3.1.1 of MAGNASTOR Certificate of Compliance Amendment 3 Technical Specifications to 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />. Prior to this ZS submittal, NAC International Inc. (NAC) submitted Reference 3 to request an amendment to NAC CoC No. # 1031 Amendment 2, to allow for longer transfer times associated with LCO 3.1.1 in Appendix A to the CoC. It is ZS's intent to rely on the technical evaluation NRC performed for that CoC amendment request, to allow approval for the ZS exemption request.

Since that submittal, NAC answered the NRC Request for Supplemental Information (Reference

4) with the responses contained in Reference 5. NRC has reviewed the NAC submittals and has published a schedule that identifies the CoC amendment review activity to be completed and then a direct final rule and proposed rule issuing Amendment 4 to the CoC to be published concurrently in the Federal Register on July 2, 2014 for a thirty day comment period. ZS has reviewed the draft CoC Amendment 4 and supports the comments already offered by NAC to the NRC.

Since the technical review of the NAC CoC Amendment Request has been completed, ZS would like to rely on the review already performed or in progress by NRC to provide the basis for approval of the ZS exemption request for modified transfer time when a canister's thermal output is < 20kW. The ZS fuel transfer campaign has begun and twenty four canisters have been transferred to the ISFSI Pad. The current schedule calls for all 61 canisters to be moved by late January, 2015, Waiting for the issuance of CoC Amendment 4 will preclude use of the extended transfer times for over one half of the canisters to be transferred. Although, the primary use of the exemption would be to provide flexibility in operations, likely positive outcomes when the exemption is approved and implemented include minimization of equipment run time and repair and minimizing dose to personnel. Accordingly, ZS requests an expedited review and approval of this exemption request, by August 1, 2014 to allow the NRC to publish the prerequisite Safety Evaluation supporting the NAC CoC Amendment Request.

ZionSolutions, LLC hereby requests approval of an exemption to certain requirements of 10 CFR Part 72.212(a)(2), 72.212(b)(3), 72.212(b)(5)(i), 72.212(b)(1 1) and 72.214 pursuant to 10 CFR 72.7. The regulations require, in part, compliance with the terms and conditions of the MAGNASTOR Certificate of Compliance No. 1031. Amendment 3 to Certificate of Compliance No. 1031 is currently issued (Reference 7).

ZionSolutions, LLC ZS-2014-0236 Page 3 of 4 The exemption pertains to the requirements of Technical Specification (TS) 3.1.1, Transportable Storage Canister (TSC), Section 1, first table, regarding allowed transfer time from loading of a TSC inside the MAGNASTOR Transfer Cask (MTC) to placement into the Vertical Concrete Cask (VCC) following the completion of helium backfill.

This letter, Attachments, and the NAC submittals identified, provide the information necessary for the NRC to issue an approval to the exemption Request. Although the MAGNASTOR CoC Amendment 3 package has been issued by NRC, none of the changes requested in this enclosed exemption package depends on CoC Amendment 3 since the technical basis for LCO 3.1.1 is unchanged between CoC Amendment 2 and Amendment 3 (similarly for FSAR Revision 4 and Revision 5). Therefore, to remain consistent with the basis of the NAC CoC Amendment Request, the NAC technical information supporting this exemption package is based on MAGNASTOR FSAR Revision 4 and CoC Amendment 2. ZS believes the exemption is technically justified, results in no reduction in safety, results in less dose to the operators during transfer operations and will reduce unnecessary time pressure demands placed on the operators to meet the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> transfer time currently required.

Currently, the MAGNASTOR CoC Amendment 3 package has been approved (Reference 7) and is the certificate used to load the MAGNASTOR casks loaded to date. The changes requested by NAC's CoC amendment package in References 3, 5 and 6 depend on content available in CoC Amendment 2. However the subject references are unchanged in the CoC Amendment 3 and FSAR Revision 5. Therefore, the references provided by NAC for this exemption package is based on MAGNASTOR FSAR Revision 4 and CoC Amendment 2 and is referred to by NAC as CoC Amendment 4 in Reference 3, 5 and 6.

NRC approval of the aforementioned CoC amendment would obviate the need for this exemption. However, since it is not anticipated that the CoC amendment will be approved and effective prior to September 15, 2014, this exemption is necessary. The exemption would apply to all MAGNASTOR casks loaded under Certificate of Compliance 1031, Amendment No. 3 following its issuance and on-site implementation. However, following NRC approval and subsequent implementation at ZS of CoC Amendment No. 4, the exemption would not be required for future cask loadings.

References 3, 5 and 6 (proprietary version) contain the technical information submitted by NAC that ZS is relying on for the NRC to review in order to develop an approval for this exemption.

The reference list contains the non-proprietary version with the NRC Adams Ascension number.

Reference 3 contains the update to the MAGNASTOR FSAR and proposed changes to Appendix A that reflect the original request for unlimited transfer time and associated technical bases. The MAGNASTOR FSAR and Technical Specification Appendix A submittal contained in Reference 6 reflects the transfer time of 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />. All other information in References 3, 5 and 6 is applicable to this exemption request. NAC has submitted these analyses and calculations in References 3, 5 and 6 as proprietary documents and NRC has made a proprietary determination.

Those documents provide the technical basis for NRC review and are available internally to the NRC as part of the NRC review of CoC No. 1031 Amendment 4 Request.

ZionSolutions, LLC ZS-2014-0236 Page 4 of 4 There are no regulatory commitments made in this submittal.

If you have any questions or require additional information, please contact Mr. Jack Bailey at (224) 789-4138.

Respectfully, Gerard van Noordennen Vice President Regulatory Affairs ZionSolutions, LLC cc: Pamela Longmire, Ph.D. USNRC Project Manager John Hickman, U.S. NRC Senior Project Manager A. L. Patko, Director, Licensing Engineering NAC International, Inc.

3930 East Jones Bridge Road, Suite 200 Norcross, GA 30092 Service List Attachments:

1. Request for Exemption from Certain Requirements of Title 10 of Code of Federal Regulations Part 72.212(a)(2), 72.212(b)(3), 72.212(b)(5)(i), 72.212(b)(1 1) and 72.214
2. Proposed Changes to MAGNASTOR Certificate of Compliance Appendix A, Technical Specifications

ZionSolutions, LLC ZS-2014-0236: Attachment 1 Page 1 of 6 Request for Exemption from Certain Requirements of Title 10 of Code of Federal Regulations Part 72.212(a)(2), 72.212(b)(3), 72.212(b)(5)(i), 72.212(b)(11) and 72.214

1. Request for Exemption ZionSolutions, LLC (ZS) hereby requests an exemption from certain requirements of 10 CFR Part 72.212(a)(2), 72.212(b)(3), 72.212(b)(5)(i), 72.212(b)(1 1) and 72.214 which, in part, require compliance with the terms and conditions of the MAGNASTOR Certificate of Compliance (CoC) (Reference 1) (Note: "References" in this Attachment are tabulated in Section 7). This exemption, if approved, would apply to all casks loaded by ZS under Certificate of Compliance 1031, Amendment No. 3, following receipt and implementation of required changes to assure compliance. However, the exemption would not be required for cask loadings following NRC approval and subsequent implementation at Zion Nuclear Power Station, Units 1 and 2 of the CoC amendment proposed by NAC International (NAC) (References 2, 3 and 4), referred to as Amendment 4.
2. Background This exemption request consists of one exemption.,

The Certificate of Compliance conditions require the general licensee to meet the requirements of the Technical Specifications (TS) for the MAGNASTOR System (Appendix A to the Certificate of Compliance).

TS 3.1.1, issued as part of CoC 1031 Amendment 2 (and CoC Amendment 3), "Transportable Storage Canister (TSC)," LCO 3.1.1, first table, requires the TSC transfer be limited to a maximum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for all cases of the canister contents heat load. In lieu of this requirement, ZS is requesting to modify the first table of LCO 3.1.1 as shown in Attachment 2, which is consistent with the proposed NAC CoC Amendment Request (References 2, 3 and 4) which provides bases for extending the transfer time allowed, based on the maximum heat load of the canister.

As shown in the supplemental information in Reference 2, 3 and 4, LCO 3.1.1 may be modified for those transfer times associated with TSCs with heat loads of< 20kW and < 25kW. All canisters being transferred by ZS as part of its decommissioning activities are < 20kW. As a result, ZS is requesting only the transfer time be extended for those canisters with thermal output

< 20kW and Attachment 2 is marked up accordingly.

Calculations have been performed by NAC using the same codes used to develop the original transfer times given in CoC Amendment 2, but utilizing 20 kW and 25 kW inputs to develop revised transfer times. Accordingly, the performance of transfer operations in accordance with the revised table, as requested by this exemption, introduces no undue risk to the health and safety of the public because the maximum allowed fuel clad temperature of 706'F is not exceeded.

ZionSolutions, LLC ZS-2014-0236: Attachment 1 Page 2 of 6 Two potential risks are averted by adoption of the revised transfer times as proposed:

The first case involves imposition of the shorter time limit of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (existing LCO 3.1.1 first table). If the eight-hour transfer time is chosen, then the operator may be unable to conclude the activity within the eight hours due to operational delays or complications. To complete required action, which is to return the MAGNASTOR Transfer Cask (MTC) to Annulus Cooling Water System (ACWS) cooling within the transfer time, the transfer time available to the operator becomes limited to approximately six hours. The recovery action from being unable to complete the transfer in the allowed eight hours (in a practical sense only six hours is available to the operator) is to re-instate the ACWS flow. Performing the ACWS reconnection unnecessarily increases dose to the operators, is not ALARA and is shown to be unnecessary by the NAC analyses.

The second case is for the management to decide to avoid use of the 8-hour transfer time limitation by planning on the 48-hour limit (LCO 3.1.1 second table) which is achieved by remaining on ACWS for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to attempting the transfer following the completion of helium backfill. This additional time is likely to avoid operational delays or complications. This additional 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> of operating time, per individual cask loading, increases dose to personnel as part of maintaining equipment operations, increases equipment wear and increases the risk of equipment failure during extended operation. Additional maintenance will likely also need to be scheduled. Performing the additional maintenance and increasing system running time with concomitant operator involvement unnecessarily increases dose to the operators, is not ALARA and is shown to be unnecessary by the NAC analyses. The resulting system's lack of availability will also impact operations. The additional operational period is specifically a concern for the ZS fuel loading campaign, which involves 61 casks, because up to 43 days will be added to the transfer duration if the additional 17 hour1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> soak (24 total hours) is adopted as required in CoC TS 3.1.1 Table B "PWR with Maximum TSC Backfill" for all 61 casks.

3. Justification for Granting the Exemption The specific requirements for granting exemptions to 10 CFR Part 72 licensing requirements are set forth in 10 CFR 72.7, "Specific Exemptions," which states: "The Commission may, upon application by any interested person or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest." The following factors are relevant to this exemption request:

A. The ISFSI regulations cited in this exemption request, 10 CFR 72.212(a)(2),

72.212(b)(3), 72.212(b)(5)(i), 72.212(b)(1 1) and 72.214, are contained within 10 CFR Part 72 of the Commission's regulations. The Commission has the legal authority to issue exemptions for the ZS ISFSI as provided in §72.7.

B. The evaluation of heat loads for a loaded transfer cask at 20k W and 25 kW has been analyzed using the PWR Transfer cask. The results for 20 kW, with no additional cooling, show no increase over the previously calculated maximum value

ZionSolutions, LLC ZS-2014-0236: Attachment 1 Page 3 of 6 for fuel clad temperature even though the transfer time moves from a limit of eight hours to a period of 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> with no additional cooling needed. ZS has not included a request for utilization of the extended transfer time for the < 25kW case, since no canister in the Zion transfer will exceed 20 kW. The following description of the calculation contains references to the <25 kW case, since ZS is relying on the analyses and conclusions of the NAC analyses submitted in Reference 2, 3 and 4 although ZS is not requesting relief for that case.

Required TSC cooling times, prior to performing the operation of transferring the helium-backfilled TSC into the concrete cask, are less for reduced heat loads.

Regardless of the heat load, the TSC in the transfer cask is still subjected to four separate operational boundary conditions.

" The water phase when the lid is being welded to the TSC. The annulus circulating water cooling (ACWS) is active during this phase.

" The drying phase during which helium is present while vacuum drying to remove moisture from the TSC. For the 20 kW heat load, the vacuum time is unlimited. The ACWS is active during this phase.

  • The helium-backfilled phase is minimized so that for 20 kW, there is no additional cooling time. It is during this time that the TSC port covers are welded and the transfer cask ACWS is operating.

" Transferring the helium-backfilled TSC into the concrete cask with the transfer cask ACWS system drained.

To determine the cool time limits, the PWR TSC/transfer cask model is used. Due to the minimum 20 kW heat load, the transfer cask model with air in the annulus was solved as a steady state problem. For this solution, there was no additional time with the TSC backfilled with helium with ACWS operating.

Using the PWR TSC/transfer cask model, a transient evaluation is performed using an initial cooling period of 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. During this 7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> period the ACWS is operated to reduce the fuel clad temperature prior to the transfer condition. After the 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> of cooling, the water in the annulus between the TSC and the transfer cask is replaced with air. During the transfer phase of the TSC into the concrete cask, air is allowed to flow up through the annulus. The transient is continued until the fuel clad temperatures reaches 730'F.

For the 20 kW case, which has no additional cooling, the resulting maximum clad temperature was 653°F at steady state, which has a larger margin to the allowable fuel clad temperature (752°F) than for the 25 kW case. Therefore, there is no additional cooling required for the < 20 kW PWR fuel heat load. Additionally, the time for transferring the < 20 kW helium backfilled TSC into the concrete cask is unlimited. The change to Table A of LCO Section 3.1.1 however, requests a change to 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />.

ZionSolutions, LLC ZS-2014-0236: Attachment 1 Page 4 of 6 C. The requested exemption items are consistent with providing for the common defense and security. The changes identified do not affect the ISFSI security plans so the ZS ISFSI will continue to be physically protected under ZS's ISFSI Physical Security Plan to the same level of safety. The changes do not affect the confinement barriers of the canisters and are shown not to affect the integrity of the spent nuclear fuel and therefore approval of the request does not affect the confinement of the spent fuel stored at the ISFSI facility.

D. ZS seeks the exemption from the Commission's rules cited to allow the ability to transfer the loaded TSC in an MTC to a vertical concrete cask (VCC) in the Fuel Handling Building. This change in handling duration will allow operations to proceed at a rate without requiring the operator to meet arbitrary intermediate goals to ensure, not exceeding the time limit of the current LCO due to operational delays or equipment problems and forcing a return to ACWS. Performing the ACWS reconnection unnecessarily increases dose to the operators, is not ALARA and is shown to be unnecessary by the NAC analyses. The alternative is to utilize the second table (Table B. PWR with Maximum TSC Transfer) and perform a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Helium Backfill soak to obtain the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> transfer time. This course of action leads to additional maintenance, increasing support systems run time and could increase the fuel transfer schedule up to 43 days considering loading of 61 casks.

The associated operator involvement during this period unnecessarily increases dose to the operators, is not ALARA and is shown to be unnecessary by the NAC analyses.

4. Conclusion ZS concludes that the requested exemption in part from the requirements of 10 CFR Part 72.212(a)(2), 72.212(b)(3), 72.212(b)(5)(i), 72.212(b)(1 1) and 72.214, allowing the use of the adjusted transfer times of the proposed amendment to the provisions of TS 3.1.1 to Certificate of Compliance No. 1031, are justified. Such an exemption meets the specific exemption requirements of 10 CFR 72.7. The requested exemption item is authorized by law, will not endanger life or property, and is consistent with the common defense and security. Furthermore, granting the exemption is in the public interest in that the time constraints during transfer operations on operators is lessened and there is an avoidance of potential additional radiological exposure to workers during upcoming cask loading campaign.
5. Environmental Consideration Pursuant to the provisions of 10CFR 72.7, ZS is requesting an exemption from certain requirements under the 10 CFR Part 72.212(a)(2),72.212(b)(3), 72.212(b)(5)(i), 72.212(b)(1 1) and 72.214. ZionSolutions has evaluated the proposed changes against the criteria for identification of licensing and regulatory actions requiring environmental assessment and provided a summary of its environmental considerations below.

ZionSolutions, LLC ZS-2014-0236: Attachment 1 Page 5 of 6 Introduction The proposed exemption is to modify the allowable transfer time for movement of a TSC, with heat load < 20 kW from the decontamination pit to the VCC from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />. The technical evaluation, performed using the FSAR analysis methods, demonstrates that during the extended period proposed for this movement, the fuel temperature identified in the MAGNASTOR FSAR is not exceeded.

The Need for the Proposed Action Extending the period for the operator to complete the transfer provides the operator the opportunity to conclude the activity, should there be the occurrence of operational delays or complications. The ability to complete the transfer may not be possible under some circumstances with the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> transfer period. The required action if the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit cannot be met is to return the MTC, containing the TSC, to ACWS cooling within the allowable transfer time. Being able to perform the ACWS reconnection within the allowable transfer time further limits the transfer time available to the operator and the action of restoring ACWS System operation unnecessarily increases dose to the operators, and is not ALARA. The alternative of extending the time period for transfer allows the operator to respond to the occurrence of operational delays or complications, with less likelihood of the need to unnecessarily reconnect the ACWS System with the associated exposure during the process. The need to perform the reconnection within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is shown to be unnecessary by the technical analyses.

Environmental Impacts of the Proposed Action The proposed exemption will not significantly increase public radiation exposure. The canister being transferred is welded shut and has limited surface contamination, which is not affected by this action, thus the public is not affected. The transfer occurs in a seismic structure and there is no radiation dose to the public from this transfer operation. As a result, the proposed exemption does not affect the type of radioactive effluents or the quantity or type of non-radioactive effluents entering the environment. In addition, the proposed exemption does not increase occupational radiation exposure, and rather, under the circumstances discussed previously, will reduce such exposure.

Environmental Impacts of the Alternatives to the Proposed Action The principle alternative to the proposed action would be to deny the requested exemption. If the exemption were denied the environmental effect would be to potentially increase dose to the operators. This increase in dose would be caused because the operators would need to perform reconnection of the ACWS System and receive occupational exposure, which could, in many cases, be avoided if the exemption were to be approved. Denial of the exemption request would result in continuing the existing levels of operator exposure.

Concerning alternative use of resources, granting the requested exemption will not involve the use of resources not previously considered in the Environmental Statement for initial approval of

ZionSolutions, LLC ZS-2014-0236: Attachment 1 Page 6 of 6 CoC 1031. The proposed action (i.e., granting the exemption) will not increase the probability or consequences of accidents, no changes are being made in the types or quantities of effluents that may be released offsite, and there is no significant increase in occupational or public radiation exposure. Therefore, there are no significant radiological environmental impacts associated with the proposed action.

The proposed action does not affect non-radiological plant effluents and has no other environmental impact. Therefore, there are no significant non-radiological impacts associated with the proposed action. Based on the assessment above, the proposed action will not have a significant effect on the quality of the human environment. Therefore, there is no significant environmental effect associated with the proposed exemption.

6. Precedent The exemption request is based on using a previously approved licensing method (Reference 5) with inputs defining the specific conditions to be considered. Accordingly, acceptance of the results should not pose the need for new regulatory analysis by the NRC; rather acceptance would be an expansion of the results of the approved analyses. The exemption is being requested to provide relief for the initial stage of the loading campaign until the CoC amendment request filed by NAC (Reference 2, 3 and 4) is approved.
7. References
1. NRC Certificate of Compliance for Spent Fuel Storage Casks Issued to NAC International Inc. (NAC), Certificate No. 1031, MAGNASTOR, Amendment No. 3.
2. ED 20130052, NAC International letter dated June 18, 2013, Submission of a Request to Amend the U. S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for the NAC International MAGNASTOR Cask System, NRC Docket No. 72-1031
3. ED20130130, Submission of NAC's Response to the U.S. Nuclear Regulatory Commission's Request for Supplemental Information for NAC's Request to Amend the Certificate of Compliance No. 1031 for the NAC International MAGNASTOR Cask System, dated September 6, 2013
4. ED20130131, Submission of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No.1 031 for the NAC International MAGNASTOR Cask System, dated September 19, 2013
5. MAGNASTOR Final Safety Analysis Report, Revision 0

ZionSolutions, LLC ZS-2014-0236: Attachment 2 Page 1 of 1 Proposed Changes to MAGNASTOR Certificate of Compliance Appendix A Technical Specifications The following revision will be made to Table A of LCO Section 3.1.1.:

1. Table title revised from "PWR Drying with 8 Hours TSC Transfer" to "PWR TSC Transfer with Reduced Helium Backfill Time"
2. Row 1, 4th column, revised from "8" to "600" PWR TSC Transfer with Reduced Helium Backfill Time Helium Heat Load Vacuum Time Backfill Time TSC Transfer (kW) Limit (hours) (hours) Time (hours)

< 20 No limit 0 600

< 25 50 0 8

<30 19 7 8

<_35.5 15 7 8 (note-ZS has no canisters planned for greater than 20 kW so no change has been made to row 2 for the purposes of this exemption.)

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

Alan Parker Russ Workman President Projects Group General Counsel EnergySolutions 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 Senior 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 Zion, IL 60099 Agency 1303 N. Milwaukee Avenue Anthony Orawiec Libertyville, IL 60048-1308 Decommissioning Plant Manager ZionSolutions, LLC Regional Administrator 101 Shiloh Boulevard U.S. NRC, Region III Zion, IL 60099 2443 Warrenville Road Lisle, IL 60532-4352 Dan Shrum Senior VP Regulatory Affairs John E. Matthews EnergySolutions Morgan, Lewis & Bockius LLP 423 West 300 South, Ste. 200 1111 Pennsylvania Avenue, NW Salt Lake City, UT 84101 Washington, DC 20004

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