ZS-2017-0129, Request for Exemption from Certain Requirements of 10 CPR 72.212 and 72.214 for Dry Spent Fuel Storage Activities at the Zion Nuclear Power Station Independent Spent Fuel Storage Installation
| ML17311A148 | |
| Person / Time | |
|---|---|
| Site: | Zion, 07201031 File:ZionSolutions icon.png |
| Issue date: | 11/02/2017 |
| From: | Gerard van Noordennen ZionSolutions |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| ZS-2017-0129 | |
| Download: ML17311A148 (6) | |
Text
An EnergySo/utions Company November 2, 2017 ZS-2017-0129 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, 50-304 and 72-1037 7 'A- ID 31
Subject:
Request for Exemption from Certain Requirements of 10 CPR 72.212 and 72.214 for Dry Spent Fuel Storage Activities at the Zion Nuclear Power Station Independent Spent Fuel Storage Installation In accordance with 10 CPR 72. 7, Specific Exemption, ZionSolutions (ZS) is hereby requesting an exemption from certain requirements of 10 CPR 72.212(a)(2), 72.212(b)(5), 72.212(b)(l 1),
- and 72.214. These regulations require, in part, compliance with the terms and conditions of the NAC MAGNAS TOR Cask System Certificate of Compliance (Reference 1) for spent fuel storage in the ISFSI at the Zion Nuclear Power Station (ZNPS) site. The requested exemption would allow ZS to deviate from the requirements in *certificate of Compliance No. 1031, Amendment 6, Appendix A, Technical Specifications and Design Features for the MAGNASTOR System, Section 5.7, Training Program. The exemption would relieve ZS from the requirements to develop training modules under the Systematic Approach to Training (SAT) that include comprehensive instructions for the operation and maintenance of the ISFSI~ except for the MAGNASTOR Cask System.
ZS is not requesting any exemptions from the requirements to develop, under its SAT program, training modules for the NAC MAGNASTOR Cask System.
This exemption was previously approved by the NRC on August 21, 2015 (Reference 6) for Certificate of Compliance No. 1031, Amendment 3, Appendix A, Technical Specifications and Design Features for the MAGNASTOR System, Section 5.7, Training Program. This exemption request is being resubmitted due to the re-registration of the 61 NAC-MAGNASTOR spent fuel casks loaded at ZNPS from Certificate of Compliance No. 1031, Amendment 3 to Certificate of Compliance No. 1031, Amendment 6 (Reference 7). No substantial changes to Appendix A, Section 5.7, Training Program, occurred from Amendment 3 to Amendment 6.
BACKGROUND By a letter dated February 13, 1998, Commonwealth Edison (ComEd), a predecessor as licensee of ZNPS, certified to the NRC the permanent cessation of operation of ZNPS (Reference 4).
Subsequently, by separate letter dated March 9, 1998, ComEd certified to the NRC that all fuei assemblies had been permanently removed from both Zion Station reactor vessels and placed in the spent fuel pool. (Reference 5)
[VIVI sSD I 101 Shiloh Boulevard, Zion
- IL 60099 rJ fv{ s s 'Z-~
(224) 789-4016
- Fax: (224) 789-4008
- www.zionsolutionscompany.com f\)iVI SS
ZionSolutions, LLC ZS-2017-0129 Page 2of5 On September 1, 2010, the NRC issued License Amendment 185 for the ZNPS Unit 1 and License* Amendment 172 for the ZNPS, Unit 2 (Reference 2). These amendments implemented the May 4, 2009 NRC Order approving the License Transfer of the ZNPS from Exelon Generation Company, LLC (Exelon) to ZS (Reference 3).
With the docketing of these submittals, ZS is not authorized to operate the reactor or place fuel in the reactor vessel in accordance with 10 CPR 50.82. ZS built the ISFSI under the general license provision of 10 CPR 72, Subpart K. Subpart K grants a general license to holders of 10 CPR 50 licensees to construct and operate an ISFSI on a site licensed under 10 CPR 50. ZS has
. transferred all spent fuel from the spent fuel pool to the ISFSI at the ZNPS site.
DISCUSSION ZS requests an exemption from the requirements of Certificate of Compliance No. 1031, Amendment 6, Appendix A, Technical Specifications and Design Features for the MAGNASTOR System, Section 5.7, Training Program. Section 5.7 in Appendix A requires the following:
A training program for the MAGNASTOR system shall be developed under the general licensee's systematic approach to training (SAT). Training modules shall include comprehensive instructions for the operation and maintenance of the MAGNASTOR system and the independent spent fuel storage installation (ISFSI) as applicable to the status ofISFSI operations.
(Note: holding is provided to emphasize the issue under consideration for exemption)
The ZS training program for the NAC MAGNASTOR Cask System was developed using the SAT methods. The training modules included comprehensive instructions forthe operation and maintenance of the NAC MAGNASTOR Cask System. The NAC MAGNASTOR Cask System includes all of the important to safety Structures, Systems and Components (SSCs) for the ISFSI (including the concrete pad for the ISFSI). The remaining ISFSI SSCs are not important _to safety as defined in 10 CPR 72.3. SSCs thatare not important to safety include the heating and air conditioning systems, electrical distribution, lighting, fencing and barriers, intrusion detection and alarm systems. Application of a SAT for the training and qualification of personnel who operate systems that are not important to safety would result in additional expenses for task evaluation, lesson plan development, instruction and administration without a commensurate safety benefit. For activities associated with the operation and maintenance ofISFSI SSCs that are not important to safety, ZS will provide training/instructions in accordance with manufacturer's instructions and ZS approved procedures. .
In accordance with the provisions of 10 CPR 72.7, "[t]he C~mmission may, upon application by
. an interested person or upon its own initiative, grant such exemptions from the requirements of the regulation in this part as it determines are authorized by law and will not endanger life or property or common defense and security and otherwise in the public interest."
ZionSolutions, LLC ZS-2017-0129 Page 3of5 The requested exemption, relieving ZS from the requirements to develop training modules under the SAT that will include the SSCs not important to safety, is authorized by law and within the Commission's authority.
The requested exemption does not involve any additional risk to the public health and safety.
The requested exemption affects only Technical Specification administrative controls associated with training programs and training of ISFSI personnel in the operation and maintenance of SSCs not important to safety at the ISFSI.
The requested exemption does not affect any accident analysis in the NAC MAGNASTOR Cask System Final Safety Analysis Report (FSAR) or cause any release of radioactive material to the environment. The exemption request does not result in a decrease in ZS's ability to effectively safeguard the spent fuel stored at the ISFSI. Thus, this exemption would not endanger life or property or the common defense and security.
The requested exemption is in the public interest in that it will reduce cost associated with applying a more complex and labor intensive training process than required by regulation. The costs associated with these activities are paid from the decommissioning trust fund. Requiring implementation of this intensive.training process would impose an economic burden on ZS and an unnecessary increase in overall project costs.
ENVIRONMENTAL IMPACT The proposed action would grant an exemption from the requirements of 10 CPR 72.212(a)(2),
72.212(b)(5), 72.212(b)(l 1), and 72.214. The proposed action would not increase the probability or consequences of accidents. No changes are being made in the types or quantities of any radiological effluent that may be released offsite, and there is no significant increase in occupational or public radiation exposure. Therefore, there is no significant radiological environmental impact associated with the proposed action.
The proposed action does not affect non-radiological plant effluents and has no other environmental impacts. Therefore, there are no significant non-radiological impacts associated with the proposed action.
Based on the ab.ove assessment, the proposed action will not have a significant effect on the quality of the human environment.
ZionSolutions, LLC ZS-2017-0129 Page 4of5
SUMMARY
The information provided in this submittal gives the NRC sufficient basis for granting an exemption from the requirements of 10 CPR 72.212(a)(2), 72.212(b)(5), 72.212(b)(l 1), and 72.214. The requested exemption would allow ZS to deviate from the requirements in the Certificate of Compliance No. 1031, Amendment 6, Appendix A, Technical Specifications and Design Features for the MAGNASTOR System, Section 5.7, Training Program. The exemption would relieve ZS from the requirements to develop training modules under the Systematic Approach to Training (SAT) that include comprehensive instructions for the operation and maintenance of the ISFSI, except for the NAC MA GNAS TOR Cask System. ZS is not requesting an exemption from the requirements to develop, under its SAT program, modules for
- the NAC MAGNASTOR Cask System.
ZS requests the NRC approve this ex~ption request at your earliest convenience.
There are no regulatory commitments contained in this submittal.
If you have any question regarding this submittal, please contact Gerard van Noordennen at (860) 462-9707. .
Respectfully, .
G~~~
Gerard van N oordennen
- Vice President of regulatory Affairs cc: John Hickman, U.S. NRC Senior Project Manager Service List
References:
- 1) Certificate of Compliance No. 1031 for the NAC International, Inc., MAGNAST()R Cask System, Amendment No. 6," dated November 30, 2016
- 2) 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 1and2,"
dated September 1, 2010
- 3) John B. Hickman, U.S. Nuclear Regulatory Commission, Letter to John A. Christian, President, ZionSolutions, LLC, "Order Approving Transfer of Licenses and Conforming Amendments Relating to Zion Nuclear Power Station, Units 1 and 2," dated May 4, 2009
- 4) O.D. Kinsley, ComEd, Letter to U.S. Nuclear Regulatory Commission, "Certification of Permanent Cessation of Plant Operations," dated February 13, 1998
- 5) O.D. Kinsley, ComEd, Letter to U.S. Nuclear Regulatory Commission, "Certification of Permanent Removal of aU Fuel from the Reactor Vessels," dated March 9, 1998
ZionSolutions, LLC ZS-2017-0129 Page 5of5
- 6) Michele Sampson, U.S. Nuclear Regulatory Commission, Letter to John Sauger, ZionSolutions, LLC, "Response to Request for Exemption from Portions of Title 10 of the Code of Federal Regulations Sections 72.212(a)(2), 72.212(b)(5), 72.212(b)(l 1), and 72.214 Regarding MAGNASTOR System Training Requirements for ZionSolutions, LLC, for the Zion Nuclear Power Station Independent Spent Fuel Storage Installation,"
dated August 21, 2015
- 7) Gerard van Noordennen, ZionSolutions, LLC, Letter to U.S. Nuclear Regulatory Commission, "Re-Registration of Zion Nuclear Power Station Spent Fuel Storage Casks," dated April 17, 2017
Zion Nuclear Power Station, Unit 1and2 License Transfer Service List cc:
Ken Robuck Alwyn C. Settles Group President Disposal and Section Head, Nuclear Facility Inspection Decommissioning Bureau of Nuclear Facility Safety EnergySolutions Illinois Emergency Management Agency 299 South Main Stn:~et, Suite 1700 1011 North St., PO Box 250 Salt Lake City, UT 84111 Mazon, IL 60444 John Sauger Kelly F. Grahn Executive VP & General Manager Senior Health Physicist, Unit Supervisor ZionSolutions, LLC Bureau of Radiation Safety, Environmental 101 Shiloh Boulevard Management Zion, IL 60099 . Illinois Emergency Management Agency 245 W Roosevelt Road, Building 8,. Suite 55 Gerard van Noordennen West Chicago, IL 60185 VP Regulatory Affairs ZionSolutions, LLC Kent McKenzie 101 Shiloh Boulevard Emergency Management Coordinator Zion, IL 60099 Lake County Emergency Management Agency 1303 N. Milwaukee Avenue Jerry Houff 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 299 South Main Street, Suite 1700 1111 Pennsylvania A venue, NW Salt Lake City, UT 84111 Washington, DC 20004 Russ Workman General Counsel EnergySolutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111