ZS-2018-0065, Submittal of Defueled Safety Analysis Report Update

Submittal of Defueled Safety Analysis Report Update

ML18291A915
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/01/2018
From:	Gerard van Noordennen ZionSolutions
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ZS-2018-0065
Download: ML18291A915 (7)

Text

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~~~~~~~~z10NS0Lur10NsL-LC~~~~~~~- An EnergySo/ut/ons Company 10 CFR 50.4(b)(6) 10 CFR 50.71(e) 10 CFR 50.59(d)(2) 10 CFR 72.48(d)(2)

October 1, 2018 ZS-2018-0065 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:

Submittal ofDefueled Safety Analysis Report Update 10 CFR 50.59 Report of Changes, Tests and Experiments 10 CFR 72.48 Report of Changes, Tests and Experiments

Reference:

(1) ZionSolutions, LLC letter, "Submittal ofDefueled Safety Analysis Report Update," dated October 1, 2016 (2) NRC Regulatory Issue Summary 2015-17, "Review and Submission of Updates to Final Safety Analysis Reports, Emergency Preparedness Documents, and Fire Protection Documents" In accordance with the requirements of 10 CFR 50.4, "Written Communications,"

paragraph (b)(6), ZionSolutions, LLC is submitting the July 2018 revision of the Defueled Safety Analysis Report (DSAR) for the Zion Nuclear Power Station (ZNPS). In accordance with 10 CFR 50.71(e)(4), the DSAR update is being submitted within 24 months of the previous ZNPS DSAR revision which was submitted in Reference (1).

This DSAR update is being provided as a DSAR total replacement on CD, satisfying the electronic submittal requirements of 10 CFR 50.4(b)(6) as discussed in Reference 2.

The changes to the DSAR reflect administrative changes (i.e., editorial and DSAR text changes) and plant design changes. The July 2018 DSAR revision includes changes made from October 2016 through July 2018.

Attachment 1 contains a summary of the DSAR changes. Attachment 2 contains the complete July 2018 update to the ZNPS DSAR in CD format. Attachment 3 contains a preflight status report identifying any noncompliance issues with the electronic submittal guidance that could not be resolved due to the source of the information being submitted. All submitted information is in legible format.

101 Shiloh Boulevard, Zion* IL 60099 Nfvf5SOI (224) 789-4016

• Fax: (224) 789-4008

• www.zionsolutionscompany.com

ZionSolutions, LLC ZS-2018-0065 Page 2 of2 In accordance with 10 CFR 50.59, "Changes, tests, and experiments," paragraph (d)(2), a report of changes, tests, and experiments, including a summary of the 10 CFR 50.59 evaluation of each change is required to be submitted at intervals not to exceed 24 months. In Reference (1), the previous ZNPS 10 CFR 50.59 report was submitted. Attachment 4 contains a summary of 10 CFR 50.59 evaluations performed during the time period from September 2016 through August 2018.

In accordance with 10 CFR 72.48, "Changes, tests, and experiments," paragraph (d)(2), a report of changes, tests, and experiments, including a summary of the 10 CFR 72.48 evaluation of each change is required to be submitted at intervals not to exceed 24 months. In Reference (1 ), the previous ZNPS 10 CFR 72.48 report was submitted. No 10 CFR 72.48 evaluations have been performed since the last report.

As Vice President of Regulatory Affairs, I certify that the information in this submittal accurately presents changes made since the previous submittals necessary to reflect information and analyses submitted to the NRC or prepared in accordance with NRC requirements.

Should you have any questions concerning this letter, please contact Jim Ashley at (224) 789-4017.

Respectfully, G~~~

Gerard van Noordennen Vice President Regulatory Affairs cc: John Hickman, U.S. NRC Senior Project Manager U.S. NRC, Region III Regional Administrator Service List (No attachment 2 - CD)

Attachments:

1. Summary of Changes

2. CD containing July 2018 ZNPS DSAR

3. Preflight Status Report

4. 10 CFR 50 .59 Summary Report

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

Ken Robuck Steven A. Reynolds President and CEO Manager, Nuclear Facility Inspection EnergySolutions Division of Nuclear Safety 299 South Main Street, Suite 1700 Illinois Emergency Management Agency Salt Lake City, UT 84111 245 W. Roosevelt Road, Units 55 & 56 West Chicago, Illinois 60185 John Sauger Executive VP & Chief Nuclear Officer Kelly F. Grahn ReactorD&D Decommissioning and Field Office Manager Bureau of Radiation Safety EnergySolutions Illinois Emergency Management Agency

• 121 W. Trade Street, Suite 2700

• 245 W Roosevelt Road, Building 8, Suite 55 Charlotte, NC 28202 West Chicago, IL 60185 Bruce Hinkley William P. Mazzeno General Manager Emergency Management Coordinator ZionSolutions, LLC Lake County Emergency Management Agency 2701 Deborah Avenue 1303 N. Milwaukee Avenue Zion, IL 60099 Libertyville, IL 60048-1308 Gerard van Noordennen John E. Matthews VP Regulatory Affairs Morgan, Lewis & Bockius LLP EnergySolutions 1111 Pennsylvania A venue, NW 121 W. Trade Street, Suite 2700 Washington, DC 20004 Charlotte, NC 28202 Jerry Houff Decommissioning Plant Manager ZionSolutions, LLC 2701 Deborah Avenue Zion, IL 60099 Russ Workman General Counsel EnergySolutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111

ZionSolutions, LLC

. ZS-2018-0065: Attachment 1 ATTACHMENT 1 Changes Made to the DSAR But Not Previously Submitted Revised Sections Description of Change Sections 2, 3, 4, and 5 DSAR Change 2016-04: The Auxiliary Building, Fuel Building, and Containment structures are being readied for internal demolition, followed by open-air demolition. All equipment and associated structural design functions described in the DSAR are no longer I applicable. The DSAR will be revised to remove discussion of those design functions.

Section 1, 2, 3, 4 and 6 DSAR Change 2017-01: Update the DSAR to reflect the progression of decommissioning activities. The miscellaneous changes document the current status of the site decommissioning activities.

Sections 1, 3, and 4 DSAR Change 2018-01: Revise DSAR to add discussion of decommissioning controls established to process groundwater intrusion and rainwater.

Section 1, 2, 3, 4 and 6 DSAR Change 2018-02: Revise DSAR to reflect the elimination of the Liquid Radwaste System and the plant side Fire Protection Program. The ISFSI Fire Protection Program remains in place.

ZionSolutions, LLC ZS-2018-0065: Attachment 2 ATTACHMENT 2 July 2018 ZNPS DSAR on CD

ZionSolutions, LLC ZS-2018-0065: Attachment 3 ATTACHMENT 3 DSAR Preflight Status Report The following file does not pass pre-flight criteria or does not meet NRC criteria, but text is word searchable with clarity/legibility of high quality.

Preflight File Name Reason Status Document contains scanned maps, images, and Error/

Zion DSAR July 2018.pdf scanned document (unembedded fonts),< 300 Failed ppi, clear and legible

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ZionSolutions, LLC ZS-2018-0065: Attachment 4 ATTACHMENT 4 ZION NUCLEAR POWER STATION 10 CFR 50.59

SUMMARY

REPORT Change Number and

Title:

2016-29, Revision O; Revise DSAR to Remove Discussion of Structures and Systems No Longer Applicable

Description:

The Auxiliary Building, Fuel Building, and Containment structures are being readied for internal demolition, followed by open-air demolition. All equipment and associated structural design functions described in the DSAR are no longer applicable. The DSAR will be revised to remove discussion of those design functions.

Summary: The DSAR is being revised to maintain the licensing basis of the plant. The design basis of the Auxiliary Building, Fuel Building, and Containment structures as described in the DASR is no longer applicable due to the progress of decommissioning. Therefore, this activity has no adverse impact on any DSAR described design functions or safety analyses and can be implemented without obtaining a license amendment.

Change Number and

Title:

2015-095, Revision 2; Modify Liquid Waste Systems

Description:

This activity installs a new liquid waste system and revises the DSAR discussion for processing liquid waste. The new liquid radioactive waste system will consist of a new processing system for processing the liquid to meet the applicable release limits and a new release system that will release the processed water to Lake Michigan.

Summary: The evaluation concluded that the new liquid waste system does not result in adverse affects on the capability to perform the design functions described in the DSAR. The effluent release concentrations of the release tanks are administratively limited to less than the regulatory release limits.