ML17208A120

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LTP Ch 1 Rev 1 020717 L
ML17208A120
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 02/27/2017
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EnergySolutions, ZionSolutions
To:
Division of Decommissioning, Uranium Recovery and Waste Programs
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Download: ML17208A120 (17)


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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN CHAPTER 1 GENERAL INFORMATION

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-i TABLE OF CONTENTS 1

GENERAL INFORMATION................................................................................................. 1 1.1 Purpose............................................................................................................................. 1 1.2 Decommissioning Objective............................................................................................ 1 1.3 Facility.............................................................................................................................. 2 1.3.1 Site Description......................................................................................................... 2 1.3.2 Current/Future Land Use.......................................................................................... 2 1.3.3 Meteorology and Climatology.................................................................................. 3 1.3.4 Geology and Seismology.......................................................................................... 3 1.3.5 Surface Water Hydrology......................................................................................... 4 1.3.6 Ground Water Hydrology......................................................................................... 5 1.3.7 Environs and Natural Resources............................................................................... 5 1.4 Operational Background.................................................................................................. 6 1.5 Plan Summary.................................................................................................................. 6 1.5.1 General Information.................................................................................................. 6 1.5.2 Site Characterization................................................................................................. 6 1.5.3 Identification of Remaining Site Dismantlement Activities..................................... 6 1.5.4 Remediation Plans.................................................................................................... 7 1.5.5 Final Radiation Survey Plan..................................................................................... 7 1.5.6 Compliance with the Radiological Criteria for License Termination....................... 8 1.5.7 Update of the Site-Specific Decommissioning Costs............................................... 8 1.5.8 Supplement to the Environmental Report................................................................. 8 1.6 Regulatory Notifications of Changes............................................................................... 9 1.7 References...................................................................................................................... 10 LIST OF FIGURES Figure 1-1 Zion Nuclear Power Station Geographical Location.............................................. 12 Figure 1-2 Zion Nuclear Power Station Owner Controlled Area............................................. 13 Figure 1-3 Zion Nuclear Power Station Topographical Map................................................... 14

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-ii LIST OF ACRONYMS AND ABBREVIATIONS 1

AEC Atomic Energy Commission 2

AMSL Above Mean Sea Level 3

ALARA As Low As Reasonably Achievable 4

AMCG Average Member of the Critical Group 5

ComEd Commonwealth Edison 6

DQO Data Quality Objectives 7

DCGL Derived Concentration Guideline Level 8

DSAR Defueled Safety Analysis Report 9

DUST-MS Disposal Unit Source Term - Multiple Species 10 FRS Final Radiation Survey 11 FSS Final Status Survey 12 FSAR Final Safety Analysis Report 13 HSA Historical Site Assessment 14 ICMP Illinois Coastal Management Program 15 ISFSI Independent Spent Fuel Storage Installation 16 LTP License Termination Plan 17 MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual 18 NRC Nuclear Regulatory Commission 19 ODCM Off-Site Dose Calculation Manual 20 QAPP Quality Assurance Project Plan for Characterization and FSS 21 PWR Pressurized Water Reactors 22 RESRAD RESidual RADioactive materials 23 SFP Spent Fuel Pool 24 STS Source Term Survey 25 ZNPS Zion Nuclear Power Station 26

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-1 1

GENERAL INFORMATION 27 The Zion Nuclear Power Station (ZNPS) consists of two (Units 1 and 2) Pressurized Water 28 Reactors (PWR). The station is located near the city of Zion in northeast Illinois on the west 29 shore of Lake Michigan. The site is approximately 40 miles north of Chicago, Illinois and 30 42 miles south of Milwaukee, Wisconsin.

31 ZNPS was previously operated by Commonwealth Edison (ComEd) until it was permanently 32 shut down on February 13, 1998. In 2000, the license was transferred from ComEd to Exelon 33 Nuclear Generation, LLC (Exelon). On January 25, 2008, Exelon and ZionSolutions, LLC 34 submitted an Application for License Transfers and Conforming Administrative License 35 Amendments (Reference 1-1) to the Nuclear Regulatory Commission (NRC) requesting that the 36 NRC consent to the transfer of Exelons Facility Operating Licenses for ZNPS to ZionSolutions.

37 On September 1, 2010, the licenses were transferred from Exelon to ZionSolutions.

38 ZionSolutions is now the current licensee and the submitter of this License Termination Plan 39 (LTP) (Issuance of Conforming Amendments Relating to Transfer of Licenses for Zion Nuclear 40 Power Station, Units 1 and 2 [Reference 1-2]).

41 The following provides the licensee name, address, license numbers and docket numbers for 42 ZNPS:

43 ZionSolutions, LLC 44 Zion Station 45 101 Shiloh Boulevard 46 Zion, IL 60099 47 License No. DPR-39 & DPR-48 48 Docket No. 50-295 & 50-304 and 72-1037 49 As an end-state for the decommissioning of ZNPS, all of the spent nuclear fuel will be stored in 50 the Independent Spent Fuel Storage Installation (ISFSI) which will be maintained under 51 amended Part 50 Licenses.

52 1.1 Purpose 53 The objective of decommissioning the ZNPS is to reduce the level of residual radioactivity to 54 levels that permit the release of the site for unrestricted use and allow for the termination of the 55 10 CFR Part 50 licenses, excluding the ISFSI area. This LTP satisfies the requirement of 56 10 CFR 50.82(a)(9). This LTP was written following the guidance in Regulatory Guide 1.179, 57 Standard Format and Contents for License Termination Plans for Nuclear Power Reactors 58 (Reference 1-3) and in NUREG-1700, Standard Review Plan for Evaluating Nuclear Power 59 Reactor License Termination Plans (Reference 1-4). This LTP is accompanied by a proposed 60 license amendment that establishes the criteria for when changes to the LTP require NRC 61 approval.

62 1.2 Decommissioning Objective 63 The decommissioning objective is to conduct remediation and survey operations such that 64 ZionSolutions can submit a request to the NRC for the unrestricted release of the site (other than 65

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-2 the remaining licensed ISFSI facility) in accordance with Subpart E of 10 CFR Part 20 and 66 meeting the unrestricted release requirements of 10 CFR 20.1402, Radiological Criteria for 67 Unrestricted Use. The LTP documents the process that will be used to demonstrate that the 68 dose from residual radioactivity that is distinguishable from background radiation does not 69 exceed 25 mrem/yr to the Average Member of the Critical Group (AMCG) from all appropriate 70 pathways over a 1,000 yr period and, to also demonstrate that the residual radioactivity has been 71 reduced to levels that are As Low As Reasonably Achievable (ALARA).

72 1.3 Facility 73 1.3.1 Site Description 74 The ZNPS site is located in Northeast Illinois on the west shore of Lake Michigan. Figure 1-1 75 shows the geographical location of the plant relative to nearby towns, cities, river and the lake.

76 The site is approximately 40 miles north of Chicago, Illinois, and 42 miles south of Milwaukee, 77 Wisconsin. The site is in the extreme eastern portion of the city of Zion, in Lake County, 78 Illinois, on the west shore of Lake Michigan approximately 6 miles NNE of the center of the city 79 of Waukegan, Illinois and 8 miles south of the center of the city of Kenosha, Wisconsin. The US 80 Census Bureau listed the estimated 2011 population of Zion as 24,508.

81 The site is located at longitude 87 degrees 48.1 minutes west and latitude 42 degrees 82 26.8 minutes north. The site occupies portions of Sections 22, 23, 26, and 27 in Township 46 83 North, Range 23 East.

84 The owner-controlled site is approximately 331 acres and within the owner-controlled area is an 85 approximate 87 acre, fence-enclosed nuclear facility. The Zion Station Defueled Safety 86 Analysis Report (DSAR) (Reference 1-5) states that the licensee maintains exclusion-area 87 control over approximately 250 acres. However during site characterization (see Chapter 2 of 88 this LTP), the total acreage surveyed as impacted and non-impacted open land survey units 89 totaled 331 acres. No other major changes to the site boundary have been made. Figure 1-2 90 shows the main plant structures and the boundaries of the owner-controlled property.

91 The topography of the site and its immediate environs is relatively flat; elevations vary from the 92 Lake Michigan shoreline (low water level is 577.4 feet Above Mean Sea Level [AMSL]) to 93 approximately 20 feet above the level of the lake. The elevation of the developed portion of the 94 site is 591 feet. A series of low, parallel beach ridges separated by marshy depressions crosses 95 the site. This topography represents recessional beach lines deposited along the Lake Michigan 96 shoreline subsequent to the most recent period of glaciations. The beach ridges are composed 97 primarily of sand. Figure 1-3 provides a topographical map of the site and the surrounding area.

98 1.3.2 Current/Future Land Use 99 The 87 acre, fence-enclosed nuclear facility is within an area zoned for industrial use in 100 accordance with The City of Zion, Illinois, Comprehensive Plan 2010 (Reference 1-6). This 101 industrially developed area, which currently includes the major buildings (Containment 102 Buildings, Turbine Building, Spent Fuel Building, Auxiliary Building), the switchyard, parking 103 areas, rail lines, haul paths and the ISFSI, will continue as an industrial-zoned property 104 throughout the decommissioning and for future use. The ISFSI as well as the Commonwealth 105

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-3 Edison switchyard to the west of the plant will remain after the decommissioning of ZNPS is 106 completed. Most of the overall site that lies to the west of the 87 acre developed plant site is 107 designated as wetland according to Chapter 9 of the Lake County Illinois, Regional Framework 108 Plan (Reference 1-7) and the site property is also identified as an environmentally sensitive 109 area to be protected from development in the City of Zion Comprehensive Plan 2010. None of 110 the land within approximately 4 miles of the Zion property is zoned as agricultural.

111 The site is bounded by park areas, including the City of Zions Park District, Hosah Park as well 112 as the Illinois State Beach Park to the north, and another Illinois State Beach Park parcel to the 113 south. These park areas, which are adjacent to Lake Michigan to the east, include various 114 boardwalks, paved walking trails, picnic and camping areas. The parks promote recreational use, 115 including boating, fishing, camping and bird watching. The Illinois Coastal Management 116 Program, Issue Paper - Illinois Beach State Park and North Point Marina Including the Dead 117 River and Kellogg Creek Watersheds (Reference 1-8) concluded that the presence of the 118 surrounding recreational property has limited residential, commercial or agricultural land use in 119 the land surrounding ZNPS.

120 Upon license termination, ZionSolutions will be returning ownership and management of the 121 property back to Exelon, which will make the ultimate determination about future use of the 122 property after the completion of the decommissioning activities described in this LTP.

123 1.3.3 Meteorology and Climatology 124 Zions climate is continental with cold winters, warm summers, and frequent short fluctuations 125 in temperature, humidity, cloudiness, and wind direction. The average temperature in the 126 summer is 72oF and the average temperature in the winter is 24oF. Because the eastern edge of 127 Zion is bounded by Lake Michigan, inland lake breezes can cool the air along the lake shore by 128 10oF to 15oF in the summer and can warm the air by as much as 20oF in the winter. The average 129 annual rainfall is 32.0 inches and the average annual snowfall is 41.0 inches.

130 1.3.4 Geology and Seismology 131 As stated in the Commonwealth Edison Company, Zion Nuclear Power Station Final Safety 132 Analysis Report (FSAR) (Reference 1-9), and Environmental Report, Zion Nuclear Power 133 Station (Reference 1-10), the near-surface geology of northeastern Illinois is comprised of 134 unconsolidated deposits which range from 90 to 150 feet in thickness. The surface deposits are 135 comprised mostly of unconsolidated glacial deposits which rest on a series of sedimentary rock 136 layers that were deposited in the Paleozoic Era. The thickness of the Paleozoic sedimentary 137 rocks in northeastern Illinois is approximately 4,000 feet. These sedimentary bedrock layers dip 138 gently toward the east at the rate of about 10 feet per mile and rest on Precambrian basement 139 rock.

140 The upper portion of surface deposits in the vicinity of the ZNPS is comprised of unconsolidated 141 sand, silt and peat derived from Lake Michigan shore deposits. This is overlaid on a mixture of 142 unconsolidated material ranging from sand, clay to boulders deposited as glacial till, outwash, 143 loess and lake sediments.

144 As stated in the Conestoga-Rovers and Associates, Hydrogeologic Investigation Report, 145 Fleetwide Assessment, Zion Station, Revision 1 (Reference 1-11), the surface deposits in the 146

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-4 vicinity of the ZNPS structures are comprised of three layers, or units, of irregular thickness.

147 The uppermost layer is identified as the upper sand unit and ranges from about 30 to 35 feet in 148 thickness. Immediately below the upper sand unit lies a layer comprised predominantly of silt 149 and clay. This layer, identified as the silt-clay unit, ranges from about 20 to 40 feet in thickness.

150 The lower unconsolidated layer, which rests on the upper bedrock layer, is a mixture of sand and 151 glacial deposits. This unit, called the lower sand layer ranges from about 30 to 50 feet in 152 thickness.

153 The upper bedrock layer is the Niagara Dolomite, a consolidated layer of carbonaceous marine 154 sediments laid down in the Silurian Period. It is about 200 feet thick in the vicinity of the ZNPS 155 site.

156 There is no indication of faulting beneath the site. The area within 100 miles of the site is 157 considered to be one of minor seismic activity. Few events of moderate significance have 158 occurred in the region in the last 150 to 200 years.

159 Near Des Plaines, approximately 25 miles southwest of the site, a highly complex faulted zone 160 exists which appears to bear no relationship to the regional structure. The zone is roughly 161 circular and covers an area of 25 square miles. Within the faulted zone, the bedrock generally 162 has been up-thrown. Some faulting also exists in southern Wisconsin and the closest known 163 fault in Southern Wisconsin is approximately 45 miles from the site and has a northeast 164 orientation.

165 Recent minor earthquakes which occurred near the site include a small 2.4-magnitude earthquake 166 on January 30, 2010 which occurred 2 miles east of McHenry and approximately 30 miles West 167 of the Zion plant and a previous earthquake of 3.8 magnitude which occurred about 2 miles 168 northwest of Lily Lake, approximately 70 miles from ZNPS.

169 1.3.5 Surface Water Hydrology 170 ZNPS is located on the shores of Lake Michigan. The lake is 307 miles long from north to south 171 and has an average width of 70 miles. In the general vicinity of the site, the 30-foot depth 172 contour of the lake is 1.2 miles, and the 60-foot depth contour is 2.0 miles from the shore.

173 Lake Michigan is used by recreational boaters. The nearest marina/public boat launch to ZNPS 174 is located approximately 2.5 miles north of the site. There are also several fishing charter 175 services that are located approximately 3 miles north of the site. Lake Michigan is also used for 176 commercial barge and ship traffic, however these activities typically do not ordinarily operate 177 within 5 miles of the site.

178 Water from Lake Michigan is used for municipal and domestic water supplies. There are 179 multiple potable water intakes located in Lake Michigan in the vicinity of ZNPS. The nearest 180 lake source water supply is located approximately 1 mile north of the site with the intake located 181 approximately 3,000 feet out in the lake.

182 Other surface water features near the site include Kellogg Creek (1.25 mile north), Dead River 183 (3 miles south), and Bull Creek (0.2 mile south). Kellogg Creek is a perennial stream that drains 184 to the north property of the Illinois Beach State Park through a bluff/ravine system that is 185 moderately to severely eroded. The creek has a reduced natural function as it has been 186 channelized since early industrial development. Bull Creek is also a perennial stream that drains 187

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-5 to the south property of the Illinois Beach State Park. Similar to Kellogg Creek, the bluff/ravine 188 system for Bull Creek is severely eroded along most of the length. Bull Creek becomes Dead 189 River once it begins to cross the sand plain. The Dead River is an unaltered natural tributary to 190 Lake Michigan that flows through an extensive high quality coastal wetland complex, which is a 191 rare habitat type in the Illinois Lake Michigan watershed.

192 1.3.6 Ground Water Hydrology 193 The groundwater table in the area is close to the ground surface and has a flat gradient to the east 194 and south. Shallow groundwater movement in the area is to the east towards Lake Michigan.

195 The upper sand unit is a high permeability unit that is directly connected to Lake Michigan, 196 which is a regional discharge feature and which generally allows unrestricted lateral groundwater 197 flow. Vertical groundwater flow is limited by the underlying silt-clay unit which has a low 198 permeability and is approximately 30 feet thick.

199 1.3.7 Environs and Natural Resources 200 Of the 331 acre ZNPS site, about 87 acres is enclosed within the perimeter security fence. This 201 is called the Radiological-Restricted Area. The remainder, which lies mostly to the west of the 202 ComEd Switchyard, is an open marshy area. This area is undeveloped except for overhead 203 transmission lines and dirt roads maintained by ComEd.

204 The land area immediately west of the site up to the rail track owned by Chicago &

205 Northwestern is zoned light industrial by the City of Zion. This area is about five blocks long, 206 extending from 29th Street on the south to Shiloh Boulevard on the north and is about four blocks 207 wide in the east-west direction centered on Deborah Avenue. It is currently occupied by several 208 warehouses and associated truck shipping operations, an industrial cleaning-service company, 209 several auto service garages, a salvage yard, a former manufacturing facility and a number of 210 vacant lots.

211 The center of the community of Zion is approximately 1.6 miles from the plant location on the 212 site. There are no schools or hospitals within one mile of the site and there are no residences 213 within 2,000 feet of any ZNPS structures.

214 There are no potable wells on or near the site. Water service is provided through the City of 215 Zion municipal water supply which draws water from Lake Michigan via a water intake about 216 one mile north of the site.

217 A significant factor which affects land use in the near vicinity of ZNPS is the Illinois Beach State 218 Park. The park has been expanded since the construction of ZNPS. The present day north and 219 south Illinois Beach State Park properties are part of a state-owned costal management area 220 which extends from Winthrop Harbor about 3 miles north of the ZNPS site to about 3 miles 221 south of the ZNPS site. The area from Winthrop Harbor Marina on the north to the southern end 222 of the Illinois Beach State Park has been incorporated into the Illinois Coastal Management 223 Program (ICMP). The ICMP has identified this area as a unique public resource requiring 224 special attention for preservation, protection and restoration of areas impacted by shoreline 225 erosion, invasive species and damage caused by previous industrial activities.

226

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-6 1.4 Operational Background 227 Key station milestones are presented in Table 2-1 of Chapter 2 of this LTP. Several key 228 significant milestones are reproduced below:

229

  • ComEd dockets application for construction: July 1967 230
  • Operating license issued: April 6, 1973 for Unit 1 and November 14, 1973 for Unit 2 231
  • Commercial operations achieved: December 1973 for Unit 1 and September 1974 for Unit 2 232
  • Final reactor operation: February 21, 1997 for Unit 1; September 19, 1996 for Unit 2 233
  • Cessation of operations: February 13, 1998 234
  • All fuel removed from the reactor and placed in the Spent Fuel Pool (SFP): April 27, 1997 235 for Unit 1 and February 25, 1998 for Unit 2 236
  • Decommissioning operations begin: October 1, 2010 237
  • Spent fuel and Greater Than Class C (GTCC) waste transferred to ISFSI: 2015 238 1.5 Plan Summary 239 1.5.1 General Information 240 The LTP describes the process used to meet the requirements for terminating the 10 CFR Part 50 241 license and to release the site for unrestricted use. The LTP has been prepared in accordance 242 with the requirements in 10 CFR 50.82(a)(9) and is submitted as a supplement to the DSAR.

243 The LTP submittal is accompanied by a proposed license amendment that establishes the criteria 244 for when changes to the LTP require prior NRC approval. The subsections below provide a brief 245 summary of the other seven chapters of the LTP.

246 1.5.2 Site Characterization 247 LTP Chapter 2 discusses the site characterization that has been conducted to determine the extent 248 and range of radioactive contamination on site prior to remediation, including structures that will 249 remain at the time of license termination, soils, and ground water. Based on the results of the 250 site characterization, ZionSolutions will plan remediation and Final Status Surveys (FSS) in 251 areas determined to be impacted by the operation of ZNPS.

252 The Zion Historical Site Assessment (HSA) (Reference 1-12) provided the initial foundation 253 for further site characterization and the basis for dividing the site into survey units. The survey 254 units were evaluated against the criteria specified in NUREG-1575, Multi-Agency Radiation 255 Survey and Site Investigation Manual (MARSSIM) (Reference 1-13) for classification. Data 256 from subsequent characterization may be used to change the original classification of an area, 257 within the requirements of this LTP, up to the time of Final Status Survey (FSS), as long as the 258 classification reflects the level of residual activity existing prior to any remediation in the area.

259 1.5.3 Identification of Remaining Site Dismantlement Activities 260 LTP Chapter 3 identifies the remaining site dismantlement and decontamination activities. The 261 information provided in Chapter 3 includes:

262

  • A description of the areas and equipment that need further remediation, 263
  • A summary of radiological conditions that may be encountered, 264

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-7

  • Estimates of associated occupational radiation dose, 265
  • An estimate of the types and quantities of radioactive material generated for release and 266 disposal, and, 267
  • Descriptions of proposed control mechanisms to ensure areas are not re-contaminated.

268 ZionSolutions is decommissioning ZNPS in accordance with the DECON alternative described 269 in NUREG-0586 Generic Environmental Impact Statement on Decommissioning of Nuclear 270 Facilities, Supplement 1, Volume 1 (Reference 1-14). The decommissioning activities will be 271 conducted in accordance with the ZionSolutions Health and Safety Program, Radiation 272 Protection Program, Radioactive Waste Program, Off-Site Dose Calculation Manual (ODCM),

273 and plant administrative, work control and decommissioning implementation procedures. These 274 are established programs that are routinely inspected by the NRC.

275 Activities conducted during decommissioning do not pose any greater radiological or safety risk 276 than those conducted during plant operations. The radiological risk associated with 277 decommissioning activities is bounded by previously analyzed radiological risk for former 278 operating activities that occurred during major maintenance and outage activities.

279 The information provided in Chapter 3 supports the assessment of impacts considered in other 280 sections of the LTP and provides sufficient detail to identify resources needed during the 281 remaining dismantlement activities.

282 1.5.4 Remediation Plans 283 LTP Chapter 4 discusses the various remediation techniques that may be used during 284 decommissioning to reduce residual contamination to levels that comply with the release criteria 285 in 10 CFR 20.1402. This chapter also discusses the ALARA evaluation and the impact of 286 remediation activities on the Radiation Protection Program.

287 The selected remediation methods used are dependent upon the contaminated material and extent 288 of contamination. The principal materials that may be subject to remediation are structural 289 surfaces. Very limited soil contamination is expected and no groundwater or surface water 290 contamination has been identified to date. Remediation techniques that may be used for 291 structural surfaces include scabbling and shaving, chipping, sponge and abrasive blasting, 292 standard and pressure washing, wiping, grit blasting, mechanical fracturing and cutting, and 293 other methods. Surface and subsurface soil with activity levels in excess of the appropriate 294 Derived Concentration Guideline Level (DCGL) will be removed and disposed as radioactive 295 waste. Soil remediation equipment will include, but not be limited to, back and track hoe 296 excavators. Remediation of soils will include the use of established excavation safety and 297 environmental control procedures as well as appropriate work package instructions to ensure 298 adequate erosion, sediment and air emission controls during soil remediation.

299 1.5.5 Final Radiation Survey Plan 300 LTP Chapter 5 presents the Final StatusRadiation Survey (FSSFRS) Plan which will be used to 301 develop the site procedures, survey packages and instructions to perform the FSS of the Zion 302 Station site. The FRS Plan is comprised of FSS for open land areas and a Source Term Survey 303 (STS) for remaining building basements. The FSSFRS Plan describes the final survey process 304 used to demonstrate that the ZNPS facility and site comply with radiological criteria for 305

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-8 unrestricted use specified in 10 CFR 20.1402 (e.g. annual dose limit of 25 mrem to AMCG plus 306 ALARA for all dose pathways).

307 The FSSFRS Plan describes the development of the survey plan, survey design and Data Quality 308 Objectives (DQO), survey method and instrumentation, data collection and processing, data 309 assessment and compliance, and the ZionSolutions ZS-LT-01, Quality Assurance Project Plan 310 (for Characterization and FSS) (QAPP) (Reference 1-15). The FSSFRS Plan addresses only 311 ZNPS structures and land areas that are identified as impacted. The adjacent areas that were 312 classified as non-impacted and the ISFSI, which will still remain a licensed area, will not be 313 subject to FSS.

314 1.5.6 Compliance with the Radiological Criteria for License Termination 315 LTP Chapter 6 presents the radiological information and methods used to demonstrate 316 compliance with the radiological criteria for license termination and release of the site for 317 unrestricted use. Chapter 6 discusses the site-specific inventory of radionuclide, future land use 318 scenarios, exposure pathways, computational models used for dose modeling, sensitivity 319 analysis, DCGLs, the derivation of area factors, the basis for the selected exposure compliance 320 scenario and evaluation of alternative exposure scenarios.

321 LTP Chapter 6 utilizes radiological information from Chapter 2 and establishes the allowable 322 contamination and radioactivity concentration levels that Chapter 4 remediation methods will 323 work towards and be verified by the FSS or STS discussed in Chapter 5. ZionSolutions applied 324 the Disposal Unit Source Term - Multiple Species (DUST-MS) model and the RESidual 325 RADioactive materials (RESRAD) v7.0 model to determine the radiological release criteria for 326 remaining structures and soils to enable license termination.

327 1.5.7 Update of the Site-Specific Decommissioning Costs 328 LTP Chapter 7 provides an updated estimate of the remaining decommissioning costs for 329 releasing the site for unrestricted use. This chapter also compares the estimated remaining cost 330 with the funds currently available in the decommissioning trust fund.

331 1.5.8 Supplement to the Environmental Report 332 LTP Chapter 8 updates the environmental report for ZNPS with new information and any 333 significant environmental impacts associated with the sites decommissioning and license 334 termination activities. This section of the LTP is prepared pursuant to 10 CFR 51.53(d) and 335 10 CFR 50.82(a)(9)(ii)(G). In accordance with 10 CFR 51.53(d), ZionSolutions considers 336 Chapter 8 as a supplement to the Environmental Report addressing the actual or potential 337 environmental impacts associated with the execution of the described decommissioning 338 activities.

339 LTP Chapter 8 compares the described decommissioning attributes to those identified in 340 NUREG-0586, which provides a generic environmental assessment for the decommissioning of a 341 reference nuclear facility. The environmental assessment performed by ZionSolutions 342 determined that the environmental effects for decommissioning ZNPS are minimal and there are 343 no adverse effects outside the bounds of NUREG-0586. Additionally, the conclusions contained 344 in the United States Atomic Energy Commission (AEC) Final Environmental Statement related 345

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-9 to operation of Zion Nuclear Power Station Units 1 and 2, - December 1972 (AEC 346 Environmental Statement) (Reference 1-16), used as the original basis for the decommissioning 347 environmental assessment of radiological and non-radiological effects of decommissioning, are 348 still valid.

349 1.6 Regulatory Notifications of Changes 350 ZionSolutions is submitting the LTP as a supplement to the DSAR. Accordingly, ZionSolutions 351 will update the LTP in accordance with 10 CFR 50.71(e). Once approved, ZionSolutions may 352 make changes to the LTP, without prior NRC approval, in accordance with the criteria in 353 10 CFR 50.59, 10 CFR 50.82(a)(6), and 10 CFR 50.82(a)(7).

354 ZionSolutions is also submitting a proposed amendment to the ZNPS licenses that adds a license 355 condition that establishes the criteria for determining when changes to the LTP require prior 356 NRC approval. Changes to the LTP require prior NRC approval when the change:

357

358

  • Result in significant environmental impacts not previously reviewed.

359

  • Detract or negate the reasonable assurance that adequate funds will be available for 360 decommissioning 361
  • Decrease a survey unit area classification (i.e., impacted to not impacted, Class 1 to Class 2; 362 Class 2 to Class 3; or Class 1 to Class 3 without providing NRC a minimum 14 day 363 notification prior to implementing the change in classification.

364

  • Increase the derived concentration guideline levels (or corresponding source term inventory 365 limits in the Basement Fill Model)and related minimum detectable concentrations (for both 366 scan and fixed measurement methods).

367

  • Increase the radioactivity level, relative to the applicable derived concentration guideline 368 level, at which an investigation occurs.

369

  • Change the statistical test applied to one other than the Sign test or Wilcoxon Rank Sum test.

370

  • Increase the Type I decision error 371 The LTP will also be updated every two years. The contact for LTP information, including any 372 submitted changes and updates, is:

373 Gerard P. van Noordennen 374 Vice President, Regulatory Affairs 375 ZionSolutions, LLC 376 101 Shiloh Blvd.

377 Zion, IL 60099 378 (224) 789-4025 379 gpvannoordennen@energysolutions.com 380 381

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-10 1.7 References 382 1-1 Letter from T.S. ONeill (Exelon Generation Company) and J. Christian (ZionSolutions) 383 to NRC, Application for License Transfers and Conforming Administrative License 384 Amendments - January 2008 385 1-2 Letter from J.B. Hickman (U.S. Nuclear Regulatory Commission) to J. Christian 386 (ZionSolutions), Issuance of Conforming Amendments Relating to Transfer of Licenses 387 for Zion Nuclear Power Station, Units 1 and 2 - September 2010 388 1-3 U.S. Nuclear Regulatory Commission Regulatory Guide 1.179, Standard Format and 389 Content of License Termination Plans for Nuclear Power Reactors - January 1999 390 1-4 U.S. Nuclear Regulatory Commission NUREG-1700, Revision 1, Standard Review Plan 391 for Evaluating Nuclear Power Reactor License Termination Plans - April 2003 392 1-5 Zion Station, Defueled Safety Analysis Report (DSAR) - September 2014 393 1-6 The City of Zion, Illinois, Comprehensive Plan 2010 - January 1992 394 1-7 Lake County Illinois, Regional Framework Plan, Chapter 9, Land Use - February 13, 395 2007 396 1-8 Illinois Coastal Management Program, Illinois Beach State Park and North Point Marina 397 Including the Dead River and Kellogg Creek Watersheds - 2011 398 1-9 Commonwealth Edison Company, Zion Nuclear Power Station - Final Safety Analysis 399 Report (FSAR) - November 1970 400 1-10 Commonwealth Edison Company, Environmental Report - Zion Nuclear Power Station 401

- May 1971, Supplement 1 - November 1971, Supplement II - December 1971, 402 Supplement III - February 1972, Supplement IV - April 1972, Supplement V -

403 May 1972 404 1-11 Conestoga-Rovers and Associates, Hydrogeologic Investigation Report, Fleetwide 405 Assessment, Zion Station, Zion Illinois, Revision 1 - September 2006 406 1-12 Zion Station Historical Site Assessment (HSA) - September 2006 407 1-13 U.S. Nuclear Regulatory Commission NUREG-1575, Revision 1, Multi-Agency 408 Radiation Survey and Site Investigation Manual (MARSSIM) - August 2000 409 1-14 U.S. Nuclear Regulatory Commission NUREG-0586, Generic Environmental Impact 410 Statement on Decommissioning of Nuclear Facilities, Supplement 1, Volume 1 -

411 November 2002 412 413

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-11 1-15 ZionSolutions ZS-LT-01, Quality Assurance Project Plan (for Characterization and 414 FSS) (QAPP) 415 1-16 United States Atomic Energy Commission, Directorate of Licensing, Final 416 Environmental Statement related to the Operation of Zion Nuclear Power Station Units 1 417 and 2, Docket Nos. 50-295 and 50-304 - December 1972 418

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-12 Figure 1-1 Zion Nuclear Power Station Geographical Location 419 420

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-13 Figure 1-2 Zion Nuclear Power Station Owner Controlled Area 421 422

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 1-14 Figure 1-3 Zion Nuclear Power Station Topographical Map 423 424