Text

Ltp Ch 3 Rev 1 021317 L
	ML17208A123
Person / Time
Site:	Zion File:ZionSolutions icon.png
Issue date:	02/27/2017
From:	; EnergySolutions, ZionSolutions
To:	; Division of Decommissioning, Uranium Recovery and Waste Programs
Shared Package
ML17208A121	List: ML17208A019; ML17208A113; ML17208A114; ML17208A115; ML17208A116; ML17208A117; ML17208A119; ML17208A120; ML17208A122; ML17208A123; ML17208A125; ML17208A126; ML17208A127; ML17208A130; ML17208A131; ML17208A139; ML17208A140; ML17208A141; ML17208A142; ML17208A143; ML17208A144; ML17208A145; ML17208A146; ML17208A147; ML17208A148; ML17208A149; ML17208A150; ML17208A151; ML17208A152; ML17208A153; ML17208A154; ML17208A155; ML17208A156; ML17208A167; ML17208A168; ML17208A170; ML17208A171; ML17208A172; ML17208A173; ML17208A174; ML17208A175; ML17208A176; ML17208A177; ML17208A179; ML17208A181; ML17208A183; ML17208A184; ML17208A253; ML17208A254; ML17208A255; ... further results
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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN CHAPTER 3, REVISION 1 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES

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

3. IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES ............ 3-1 3.1. Introduction ..................................................................................................... 3-1 3.2. Completed and Ongoing Decommissioning Activities and Tasks .................. 3-2 3.2.1. Overview ......................................................................................................... 3-2 3.2.2. Spent Fuel Island and ISFSI Activities ........................................................... 3-3 3.2.3. Demolition and Dismantlement of Initial Structures ...................................... 3-3 3.2.4. Dismantlement of East Yard Tanks................................................................. 3-5 3.2.5. Demolition and Dismantlement of Crib House Structure ............................... 3-6 3.2.6. Additional Activities ....................................................................................... 3-7 3.3. Future Decommissioning Activities and Tasks ............................................... 3-7 3.3.1. Overview ......................................................................................................... 3-7 3.3.2. Turbine Building (Unit 1 and Unit 2) .............................................................. 3-8 3.3.3. Auxiliary Building ........................................................................................... 3-9 3.3.4. Unit 1 and Unit 2 Containments .................................................................... 3-10 3.3.5. Fuel Handling Building ................................................................................. 3-12 3.3.6. Waste Water Treatment Facility (WWTF) .................................................... 3-13 3.3.7. Miscellaneous Structures ............................................................................... 3-14 3.3.7.1. East and West Service Buildings ................................................................... 3-14 3.3.7.2. Forebay, Forebay Valve Houses and Intake and Outflow Structures located in Lake Michigan .............................................................................. 3-14 3.3.7.3. NGET, ENC, South Warehouse, North Security Access Gatehouse ............. 3-15 3.3.7.4. Laundry Building, North Security Restricted Area Gatehouse, South Security Restricted Area Access, Restricted Area Fence and Vehicle Barrier System ........................................................................... 3-15 3.3.7.5. Steam Tunnels and Waste Handling Area ..................................................... 3-16 3.3.7.6. Old Sewage Treatment Facility and Meteorological Tower .......................... 3-17 3.3.7.7. Storm Drain System, Manholes and Fire Protection Buried Piping .............. 3-17 3.3.7.8. Surface Soils, Subsurface Soil and Groundwater .......................................... 3-18 3.4. Radiological Impacts of Decommissioning Activities .................................. 3-18 3.4.1. Control Mechanisms to Mitigate the Recontamination of Remediated Areas.......................................................................................... 3-19 3.4.2. Occupational Exposure.................................................................................. 3-19 3.4.3. Exposure to the Public................................................................................... 3-19 3.4.4. Radioactive Waste Projections ...................................................................... 3-19 3.5. References ..................................................................................................... 3-20 3-i

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 LIST OF TABLES Table 3-1 Status of Major ZNPS Systems, Structures, and Components as of December 2014.............................................................................................. 3-22 Table 3-2 Radiation Exposure Projections for Decommissioning after 1/1/2015 ......... 3-24 Table 3-3 Projected Waste Quantities ........................................................................... 3-25 Table 3-4 General Project Milestones ........................................................................... 3-26 3-ii

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1 LIST OF ACRONYMS AND ABBREVIATIONS 2 ALARA As Low As Reasonably Achievable 3 ACM Asbestos Containing Material 4 CST Condensate Storage Tank 5 DSAR Defueled Safety Analysis Report 6 EPA Environmental Protection Agency 7 FOT Fuel Oil Tank 8 FRS Final Radiation Survey 9 FSS Final Status Survey 10 HVAC Heating Ventilation Air Conditioning 11 ISFSI Independent Spent Fuel Storage Installation 12 IRSF Interim Radioactive Waste Storage Facility 13 LTP License Termination Plan 14 MMTC Mechanical Maintenance Training Center 15 MARSAME Multi-Agency Radiation Survey and Assessment of Materials and Equipment 16 Manual 17 NESHAP National Emissions Standards for Hazardous Air Pollutants 18 NRC Nuclear Regulatory Commission 19 ODCM Dose Calculation Manual 20 PSDAR Post Shutdown Decommissioning Activity Report 21 PWST Primary Water Storage Tanks 22 RA Radiological Assessment 23 RCRA Resource Conservation and Recovery Act 24 RCS Reactor Coolant System 25 RWP Radiation Work Permit 26 SFP Spent Fuel Pool 27 S/G Steam Generator 28 TSCA Toxic Substances Control Act 29 TSD Technical Support Document 30 UFSAR Updated Final Safety Analysis Report 31 ZNPS Zion Nuclear Power Station 32 ZSRP Zion Station Restoration Project 33 3-i

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 34 35 Page Intentionally Left Blank 36 3-ii

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 37 3. IDENTIFICATION OF REMAINING SITE DISMANTLEMENT 38 ACTIVITIES 39 3.1. Introduction 40 In accordance with 10CFR50.82 (a)(9)(ii)(B), the License Termination Plan (LTP) must identify 41 the remaining major dismantlement and decontamination activities for the decommissioning at 42 the time of submittal. The information includes those areas and equipment that need further 43 remediation and an assessment of the potential radiological conditions that may be encountered.

44 Estimates of the occupational radiation dose for completion of the scheduled task and the 45 projected volumes of radioactive waste that will be generated are also included. These activities 46 will be undertaken pursuant to the current 10 CFR 50 license, are consistent with the Zion 47 Nuclear Station Post Shutdown Decommissioning Activity Report (PSDAR) (Reference 3-1),

48 and do not depend upon LTP approval to proceed.

49 ZionSolutions primary goals are to decommission the Zion Nuclear Power Station (ZNPS) safely 50 and to maintain the continued safe storage of spent fuel. ZionSolutions will decontaminate and 51 dismantle the ZNPS in accordance with the DECON alternative, as described in NUREG-0586 52 Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, 53 Supplement 1, Volume 1 (Reference 3-2). Completion of the DECON option is contingent upon 54 continued access to one or more low level waste disposal sites. Currently, ZionSolutions has 55 access to low-level waste disposal facilities located in Barnwell, South Carolina, Andrews, Texas 56 and in Clive, Utah.

57 ZionSolutions is currently conducting active decontamination and dismantlement activities at 58 ZNPS in accordance with the PSDAR. Decommissioning activities are being coordinated with 59 the applicable Federal and State regulatory agencies in accordance with plant administrative 60 procedures. Applicable Federal agencies include the U.S. Nuclear Regulatory Commission 61 (NRC) and the U.S. Environmental Protection Agency (EPA). Coordination with applicable 62 State and local regulatory agencies are addressed in section 8.7.2 of Chapter 8. In order to 63 minimize the impact of ongoing decommissioning activities, a Spent Fuel Pool (SFP) Island has 64 been established to separate spent fuel storage functions from other plant functions and other 65 decommissioning activities.

66 Decommissioning activities at the Zion Station Restoration Project (ZSRP) will be conducted in 67 accordance with the Zion Station Defueled Safety Analysis Report (DSAR) (Reference 3-3),

68 the NRC Docket Number 50-295, Facility Operating License Number DPR-39 (for 69 Unit One) (Reference 3-4), NRC Docket Number 50-304, Facility Operating License Number 70 DPR-48 (for Unit Two) (Reference 3-5), all associated Technical Specifications and, the 71 requirements of 10 CFR 50.82(a)(6) and (a)(7). At the time of LTP submittal, the remaining 72 activities do not involve any un-reviewed safety questions or changes in the Technical 73 Specifications for ZNPS. If an activity requires prior NRC approval under 10 CFR 50.59(c)(2),

74 or a change to the technical specifications or license, a submittal will be made to the NRC for 75 review and approval before implementing the activity in question. Decommissioning activities 76 are conducted under the scrutiny of the existing ZionSolutions Radiation Protection Program, 77 Industrial Safety Program, and Waste Management Program. Such activities will be conducted 78 in accordance with these programs, which are well established and frequently inspected by the 3-1

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 79 NRC. Activities conducted during decommissioning do not pose any greater radiological or 80 safety risk than those conducted during operations, especially those during major maintenance 81 and outage evolutions.

82 The remaining decontamination and dismantlement activities that will be performed are 83 described in section 3.3. The specific system considerations that will be taken into account are 84 discussed in sections 3.3.2 through 3.3.7. These sections provide an overview and describe the 85 major remaining components of contaminated plant systems and, as appropriate, a description of 86 specific equipment remediation considerations. Table 3-1 contains a list of major systems and 87 components that have been or are to be removed.

88 On January 25, 2008, Exelon and ZionSolutions submitted an Application for License Transfers 89 and Conforming Administrative License Amendments (Reference 3-6) requesting that the NRC 90 approve the transfer of Exelon Corporations Facility Operating Licenses for ZNPS to 91 ZionSolutions. On September 1, 2010, the licenses were transferred from Exelon to 92 ZionSolutions (Issuance of Conforming Amendments Relating to Transfer of Licenses for Zion 93 Nuclear Power Station, Units 1 and 2 [Reference 3-7]). Integral to the transfer of the licenses, 94 ZionSolutions entered into an agreement with Exelon Corporation titled Zion Nuclear Power 95 Station, Units 1 and 2 Asset Sale Agreement (Reference 3-8). This document presents the terms 96 and conditions under which ZionSolutions would decommission ZNPS, construct an Independent 97 Spent Fuel Storage Installation (ISFSI), place the spent nuclear fuel in dry cask storage and 98 transfer the loaded fuel casks to the ISFSI, and remediate the site to the unrestricted release 99 criteria as specified in 10 CFR 20.1402. Once the balance of the site is remediated and the as-100 left radiological conditions are demonstrated to be below the unrestricted release criteria, the 101 10 CFR Part 50 license will be reduced to the area around the ISFSI and the site will be 102 transferred back to Exelon under the 10 CFR Part 50 license. ZionSolutions commenced the 103 active decommissioning of ZNPS on October 13, 2010. Spent fuel and decommissioning 104 activities completed to date are provided in section 3.2.

105 3.2. Completed and Ongoing Decommissioning Activities and Tasks 106 3.2.1. Overview 107 ZionSolutions and its subcontractor, Siempelkamp, have completed the segmentation of the 108 reactor vessel internals in both units, which will be followed by the segmentation of both reactor 109 vessels.

110 Other completed Decommissioning activities include:

111

Creation of large openings in each Containment Building (approximately 31 feet x 36 feet) 112 and installation of a Heavy Lift Rail system to enable transport of components and wastes out 113 of each Containment.

114

Abatement, packaging and disposal of known and readily accessible lead and/or lead 115 containing material.

116

Abatement, packaging and disposal of known and readily accessible Asbestos Containing 117 Material (ACM).

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 118

Removal and shipment of the Unit 1 Reactor Coolant Pumps (3 out of 4), Reactor Coolant 119 Pump Motors (4 of 4), Loop Stop Isolation Valves (4 of 4), Steam Generator (S/G) steam 120 domes, the majority of the Reactor Coolant System (RCS) piping and the Reactor Head.

121

Removal and shipment of the Unit 2 Reactor Coolant Pump Motors (4 of 4) and various RCS 122 piping.

123

Installation of new temporary power feeds to each containment which will allow for a safer 124 commodity removal effort.

125

Disconnection and termination of various plant systems.

126 3.2.2. Spent Fuel Island and ISFSI Activities 127 A priority task for ZionSolutions has been the construction of the ISFSI and the necessary 128 licensing, training and infrastructure modifications required to transfer spent fuel from the SFP to 129 the ISFSI. As part of this process, the Fuel Handling Building was upgraded with a new single-130 failure-proof crane. The ISFSI was constructed and became operational in late 2013. To date, 131 fifty (50) of the required sixty-one (61) dry cask storage canisters (1850 spent fuel assemblies) 132 have been successfully moved to the ISFSI. The completion of the movement of spent fuel into 133 dry cask storage and transfer to the ISFSI is scheduled for completion in early 2015.

134 3.2.3. Demolition and Dismantlement of Initial Structures 135 To date, the Interim Radioactive Waste Storage Facility (IRSF), the 136 Mechanical Maintenance Training Center (MMTC) & Warehouse 137 and the Fire Maze complex have been demolished and properly 138 dispositioned as radiologically-clean waste or potential clean hard 139 fill. The IRSF was built to temporarily store ZNPS generated 140 radioactive waste in the mid-1980s but was never utilized for that 141 purpose. It was a reinforced concrete structure that measured 142 134.5 feet long, 66 feet wide and 49 feet tall. The MMTC was a single story, steel framed, sheet 143 metal structure that measured approximately 40 feet by 77 feet. The structures in the Fire Maze 144 complex consisted of the Fire Maze, which was a single story steel framed building with sheet 145 metal siding that measured approximately 20 feet by 30 feet, the Fire Training Center, which was 146 a three story, steel framed building with sheet metal siding that measured approximately 25 feet 147 by 25 feet, the Fire Pit, which was a single story, steel framed building with sheet metal siding 148 that measured approximately 14 feet x 25 feet and the Temporary Radioactive Waste Liner 149 Building, which was a single story concrete building that measured approximately 36 feet by 150 39 feet.

151 These structures were selected as initial test cases to demonstrate that the plans, programs and 152 procedures put in place by ZionSolutions for the demolition of buildings and structures on the 153 site were ready for implementation. ZionSolutions instituted a Cold, Dark and Dry 154 methodology that consisted of the following basic activities:

155

Identification of any operable systems that may have to be replaced or relocated. For these 156 initial structures, none were identified.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 157

Isolation of all electrical and mechanical systems servicing the structures.

158

Issuance of a contract to a subcontractor designated as the 159 Demolition Contractor to complete demolition activities.

160 For the test case buildings and structures, contracted 161 demolition activities included the installation of any 162 required environmental controls and the demolition and 163 removal of all above grade structures, systems and 164 components. All foundations were either completely 165 removed or demolished and removed to a depth of 3 feet below grade. None of the initial 166 test case structures had sub-grade basements. All buried piping (service air, service water 167 and sewer lines) were removed with the structures. Electrical services (conduits and cables) 168 were removed to a depth of 3 feet below grade. The remaining excavation void was 169 radiologically surveyed and then backfilled using clean fill to the existing grade.

170

Inspection of each structure for all universal, Resource Conservation and Recovery Act 171 (RCRA) or Toxic Substances Control Act (TSCA) wastes that would require removal prior to 172 demolition. These materials included mercury switches, light lamps, electrical ballasts and 173 ACM. For the initial test case structures, most of the wastes were directly removed and 174 dispositioned by ZionSolutions. The exceptions were mineral oil in a de-energized 175 transformer and the oil and brake shoes in the overhead crane in the IRSF. These wastes 176 were identified to the selected Demolition Contractor and subsequently abated as part of the 177 contracted work scope. ZionSolutions may elect to include any required waste abatement 178 activities as part of the Demolition Contractor work scope for future structural demolition.

179

Completion of unconditional release surveys of each structure to ensure the structures can be 180 demolished and free-released. Surveys were performed in accordance with the site procedure 181 for the unconditional release of materials to verify that the material was free of plant-derived 182 radioactive material. Materials released for unconditional use were recycled or released for 183 disposal at a non-radiological landfill. No recycled materials remained on site.The survey 184 protocols described in NUREG-1575, Supplement 1, Multi-Agency Radiation Survey and 185 Assessment of Materials and Equipment Manual (MARSAME) (Reference 3-9) were used 186 to perform these surveys.

187

Surveyed and verified concrete debris resulting from the building 188 demolition that was designated for reuse as clean hard fill as 189 radiologically clean. This concrete debris was then processed to 190 remove all exposed rebar and to ensure that individual debris pieces 191 were smaller than 10 inches in diameter. The processed concrete 192 debris was then transported to a designated storage area where it was 193 stockpiled for use as potential backfill material. These stockpile areas are isolated and 194 controlled to prevent the inadvertent introduction of potentially contaminated materials and 195 periodic surveillances are performed.

196

All other construction demolition debris that was not stockpiled as 197 potential backfill material was packaged and transported to an 198 appropriate landfill for disposal or, to an off-site recycling center.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 199 At the ZSRP, all bulk material, regardless of destination, passes through a radiological truck 200 monitor.

201 3.2.4. Dismantlement of East Yard Tanks 202 The next structures to be demolished were the set of 203 tanks located in the east yard of the Security-204 Restricted Area. These tanks included the Primary 205 Water Storage Tanks (PWST) and the Condensate 206 Storage Tanks (CST) for both units, the Fuel Oil Tank 207 (FOT), the De-Chlorination and Chlorination tanks for 208 both units and concrete pads and shacks constructed 209 to service and house tanks, systems and components.

210 The logic for the removal of the tanks as the next 211 structures in the demolition sequence included; 212

The tanks were located within the Security-Restricted Area and were considered to be 213 radiologically impacted. Removal of the tanks would allow for the initial use and assessment 214 of the plans, procedures and processes for open-air demolition on radiologically 215 contaminated structures and systems and allow the Demolition Contractor to become 216 acclimated to working in a radiologically controlled environment.

217

The radiological contamination of the tanks required contamination mitigation and 218 engineering controls to be implemented as part of the work scope.

219

The removal of the tanks provided needed space for the eventual planned demolition of the 220 Crib House and the Turbine Building.

221 Prior to commencing the dismantlement and demolition of the yard tanks, the tanks and systems 222 were prepared in accordance with the Cold, Dark and Dry approach implemented at ZSRP. In 223 order to retire the CSTs as part of this process, it was necessary to design and install a new 224 Demineralized Water Processing system.

225 The interior and exterior of both PWSTs and CSTs were radiologically surveyed prior to 226 commencing physical dismantlement activities. The survey results indicated that the interiors of 227 the tanks were radiologically contaminated. As a contamination control measure, a fixative was 228 applied to the interior surfaces of the tanks. Following the application of the fixative, a survey 229 was performed to verify that the radiological conditions of the structures met the criteria for 230 open-air demolition as presented in Technical Support Document (TSD)10-002, Technical 231 Basis for Radiological Limits for Structure/Building Open Air Demolition (Reference 3-109).

232 Compliance with this criterion minimized the implementation of additional contamination 233 controls that would be required for open-air demolition and allows for the use of heavy 234 equipment to perform the demolition. The intent is to perform this type of survey to verify the 235 radiological conditions in all radiologically-impacted structures, components and systems prior 236 to demolition.

237 The soils surrounding the tanks were radiologically surveyed as part of the site characterization.

238 No soils were identified during the characterization that would necessitate excavation and 239 removal as radioactive waste. During the course of the tank dismantlement, additional surveys 3-5

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 240 and soil samples were taken of the soil surrounding the tanks. No soil was identified with 241 residual radioactivity in excess of the release criteria. The PWSTs and the CSTs for both units 242 were dismantled, properly packaged and dispositioned as low-level radioactive waste. All 243 radioactive waste was loaded and transported under the direction of ZionSolutions Waste 244 Department personnel to the licensed Energy Solutions radioactive waste disposal facility in 245 Clive, Utah. Sampling of surface and subsurface soil and groundwater in this area has been 246 performed. Preliminary results demonstrate that some soil will require remediation and disposal 247 off site due to the presence of polynuclear aromatic hydrocarbons above the Illinois EPA limits.

248 3.2.5. Demolition and Dismantlement of Crib House Structure 249 The next major structure demolition activity planned for 2014 250 involves the demolition of the Crib House. The Crib House contains 251 the Circulating Water pumps, the Service Water Pumps and the Fire 252 Protection pumps. In order to implement the Cold, Dark and Dry 253 approach in the Crib House, a number of design modifications are 254 required to replace the functioning systems in the Crib House that 255 are required for the operation of necessary systems, such as 256 component cooling and fire protection. These include:

257

The retirement of the station fire pumps and the integration of a modified fire water ring 258 header that is connected to the city water system for the Town of Zion as a replacement.

259 This modification also resulted in changing the pressurized fire suppression system at ZNPS 260 to a dry system that would be supplied from a new exterior connection for the Town of Zion 261 Fire Department.

262

The retirement of the Service Water pumps required the installation of a new pump to supply 263 circulating water to certain systems. This new pump was installed in the Forebay in a 264 manner that would allow for the demolition of the Crib House to proceed. This pump system 265 provides dilution flow for liquid waste releases into the Forebay and also serves as a source 266 of emergency make up water to the SFP via a hose connection. The previous Heating 267 Ventilation Air Conditioning (HVAC) functions performed by Service Water were replaced 268 by temporary, local heating and cooling installations and the relocation of certain functions 269 (Hot and Cold Laboratories and Counting Room) to other areas.

270 Once the system modifications are in place and the Crib House has been successfully made 271 Cold and Dark, the Crib House will be surveyed for unrestricted unconditional release using 272 the approach presented in MARSAMErelease. Surveys will be performed in accordance with the 273 site procedure for the unconditional release of materials to verify that the material is free of 274 plant-derived radioactive material. Materials released for unconditional use can be recycled or 275 released for disposal at a non-radiological landfill. No recycled materials will remain on site. In 276 addition, all electrical and mechanical systems will be isolated and removed as commodities.

277 Once the structure has been successfully surveyed and system removal is complete, the above 278 grade portions can then be readily demolished by the Demolition Contractor. In order to perform 279 system removal and perform unrestricted release surveys of the deep pump well areas, stop logs 280 and dewatering pumps must be installed to isolate the sub-grade areas from the Forebay and 281 Lake Michigan. These measures will be implemented by the Demolition Contractor, who will 3-6

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 282 also supply temporary power, lighting and all other support required for the survey performance.

283 Due to the depth of the Circulating Water (centerline elevation 33 feet below grade) and Service 284 Water (centerline elevation 12 feet below grade) headers, they will be sealed off at the west wall 285 of the Crib House. These pipe headers will also be surveyed for compliance with the 286 unrestricted release criteria prior to being isolated, abandoned in place and filled with grout or 287 fill as appropriate. All concrete structures will be removed to a depth of 3 feet below grade in 288 accordance with the requirements of the Asset Sale Agreement. All remaining structures below 289 3 feet below grade will be surveyed to demonstrate compliance with the unrestricted release 290 criteria as specified in 10 CFR 20.1402.

291 3.2.6. Additional Activities 292 Additional activities that have been completed or are ongoing include, but are not limited to the 293 following:

294

Continued assessment of the functional requirements for plant systems, structures, and 295 components.

296

Identification of plant systems, structures, and components needed to support safe storage of 297 the spent fuel, support SFP cooling, and facilitate ongoing plant activities.

298

Design, installation and operation of a new Liquid Radioactive Waste Processing system.

299

Detailed planning and project scheduling.

300

At the start of 2014, a management change by ZionSolutions at the ZSRP was instituted 301 which resulted in a partial site stand down to allow for the completion of a comprehensive 302 planning and scheduling effort. Upon completion, decommissioning activities resumed in 303 accordance with the revised project schedule.

304 The Liquid Radioactive Waste system at ZNPS had become degraded since the shutdown of the 305 units and was not capable of successfully processing liquid radwaste for effluent discharge.

306 Consequently, ZionSolutions elected to design and install a new Liquid Radioactive Waste 307 Processing system. This system is used to process liquid radwaste at ZNPS and, process the 308 water from each of the reactor cavities (approximately 500,000 gallons each) and the SFP 309 (approximately 700,000 gallons including the transfer canal) once all spent fuel has been moved 310 to the ISFSI. The Turbine Building and Auxiliary Building cannot be completely placed in a 311 Cold, Dark and Dry status until this liquid waste processing is completed in 2015.

312 3.3. Future Decommissioning Activities and Tasks 313 3.3.1. Overview 314 The priority task at ZSRP is the movement of the spent fuel into dry cask storage and transfer to 315 the ISFSI facility. Spent fuel movement to the ISFSI is currently scheduled to be complete in 316 early 2015. Once the movement of the spent fuel is complete, then other significant 317 dismantlement and decommissioning tasks will take precedent. The removal of the spent fuel 318 from the Fuel Handling Building will allow ZionSolutions to implement a license amendment to 319 the 10 CFR 50 license for each unit to remove operational requirements and technical 320 specifications specifically required for the maintenance of spent nuclear fuel in wet pool storage.

3-7

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 321 These license amendments will greatly enhance the ability to completely place the remaining 322 structures into a Cold, Dark and Dry state, to complete the processing of the remaining liquid 323 radioactive waste, to allow for the complete removal of all remaining commodities and to allow 324 for the enhanced ability to more freely move material and personnel around the site. The 325 complete dismantlement and decommissioning of the Turbine and Auxiliary Building is 326 contingent upon completion of these tasks. The plans for the decontamination, dismantlement 327 and anticipated end-state condition(s) for the remaining site structures are presented in the 328 following sections.

329 3.3.2. Turbine Building (Unit 1 and Unit 2) 330 Large component removal in the Turbine Building is scheduled 331 to commence in early 2015. Initial component removal will 332 include the dismantlement and removal of most of the large 333 components in Unit 1, including the turbines, generator, 334 moisture separator reheaters, feedwater heaters and coolers and, 335 several feedwater heaters and coolers in Unit 2. In parallel with 336 this effort, the ZionSolutions Characterization/License 337 Termination personnel will perform surveys for the 338 unconditional release of materials, equipment and structural 339 surfaces throughout the building. In addition, inspections were completed to identify any 340 remaining waste streams. Surveys were performed in accordance with the National Emissions 341 Standards for Hazardous Air Pollutants (NESHAP) to identify any potential ACM and all 342 accessible friable ACM was removed. Any remaining identified potential ACM that was not 343 accessible at this time, including but not limited to gaskets in piping systems, caulking around 344 windows, floor and wall barrier seals, will be appropriately handled and abated by the 345 Demolition Contractor as part of the contracted work scope.

346 All systems and materials that are or will be identified by radiological survey as contaminated 347 with detectable plant-derived radioactive material will be removed by ZionSolutions personnel 348 and dispositioned and properly disposed of as radioactive waste. The remaining structure and 349 materials in the Turbine Building will be demonstrated as meeting the unconditional release 350 criteria using the approach presented in MARSAME. Surveys will be performed in accordance 351 with the site procedure for the unconditional release of materials to verify that the material is free 352 of plant-derived radioactive material. Materials released for unconditional use can be recycled or 353 released for disposal at a non-radiological landfill. No recycled materials will remain on site.

354 The remaining structure will then be made Cold, Dark and Dry and turned over to a 355 Demolition Contractor as a non-radiologcally controlled structure for demolition as a contracted 356 work scope.

357 The selected Demolition Contractor will remove and disposition all remaining commodities and 358 demolish the structure to a depth of 3 feet below grade in accordance with the requirements of 359 the Asset Sale Agreement. All remaining structures below 3 feet below grade will undergo a 360 survey to demonstrate compliance with the unrestricted release criteria as specified in 361 10 CFR 20.1402. All equipment and components will be removed from the structure with the 362 exception of the underground circulating water headers, discharge tunnels and buried service 363 water piping running between the Crib House location and the Auxiliary Building. All 3-8

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 364 remaining buried and piping embedded in concrete will be surveyed for compliance with the 365 unrestricted release criteria prior to being isolated, abandoned in place and filled with grout or 366 fill as appropriate.

367 Concrete debris resulting from the building demolition that iswill be designated for beneficial 368 reuse as clean hard fill. Only concrete that meets the non-radiological definition of clean 369 concrete demolition debris and where Final Status Survey (FSS) demonstrates that the concrete 370 is free of plant derived radionuclides above background will be used. will be surveyed in 371 accordance with MARSAME and verified to be free of detectable radiation above background.

372 This concrete debris will then be processed to remove all exposed rebar and to ensure that 373 individual debris pieces were smaller than 10 inches in diameter. The processed concrete debris 374 will then be transported to a designated on-site storage area where it will be stockpiled for use as 375 potential backfill material. All other construction demolition debris that is not appropriate for 376 reuse as potential backfill material will be packaged and transported to an appropriate landfill for 377 disposal or, to an off-site recycling center following final assessment for the presence of any 378 residual radioactive contamination by passing through a radiological truck monitor.

379 Once the remaining concrete structure located below 3 feet below grade (588 foot elevation) has 380 been satisfactorily surveyed and compliance with the unrestricted release criteria has been 381 demonstrated and, contingent upon the completion of confirmatory surveys and regulatory 382 approval, the Turbine Building void will be backfilled using concrete debris suitable for reuse as 383 clean hard fill and/or clean fill to the original site grade and contours. The top 3 feet of fill will 384 be soil only (i.e. concrete clean hard fill will only be utilized as fill up to the 588 foot elevation).

385 3.3.3. Auxiliary Building 386 Component and system removal is currently ongoing in the 387 Auxiliary Building. Radiological surveys performed to verify as-388 left contamination levels are below the criteria established as 389 suitable for open-air demolition are also being performed as a 390 parallel activity. Based upon the results of these surveys, the 391 remaining systems, components and structural surfaces that will be 392 required to be removed or decontaminated prior to permitting 393 open air demolition in accordance with TSD 10-002 are being 394 identified. Identified radiological commodities in excess of the 395 open-air demolition limits are currently being removed, or will be removed prior to structural 396 demolition. All radioactive waste will be loaded and transported under the direction of 397 ZionSolutions Waste Department personnel to the licensed Energy Solutions radioactive waste 398 disposal facility in Clive, Utah. All structural decontamination activities will be performed in 399 accordance with an approved Radiation Work Permit (RWP) and under the oversight of 400 ZionSolutions Radiation Protection personnel. The current Liquid Radioactive Waste system 401 will remain in place until all liquid radioactive waste has been successfully processed and 402 dispositioned. When this task is complete, the Liquid Radioactive Waste system will also be 403 dismantled and properly disposed of as radioactive waste.

404 When commodity removal is complete and all structural surfaces have been decontaminated to 405 the open-air demolition limits in accordance with TSD 10-002, the Auxiliary Building will be 3-9

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 406 placed in a Cold, Dark and Dry configuration and it will be turned over to a subcontracted 407 Decommissioning Contractor. The selected Decommissioning Contractor will demolish the 408 structure to a depth of 3 feet below grade in accordance with the requirements of the Asset Sale 409 Agreement. All below grade interior floors (560 and 579 foot elevations) and walls will be 410 removed. Contamination control methods (vaccuming, wiping, etc) will be used to mitigate 411 loose surface contamination on the remaining exposed structural surfaces. All construction 412 debris resultant from the demolition of the Auxiliary Building structure will be treated as low 413 level radioactive waste and will be shipped to the licensed Energy Solutions radioactive waste 414 disposal facility in Clive, Utah by gondola railcar. All remaining structures below 3 feet below 415 grade will be surveyed to demonstrate compliance with the unrestricted release criteria as 416 specified in 10 CFR 20.1402.

417 Five 24 inch diameter sleeves that are buried in soil between each of the two containments and 418 the Auxiliary Building 542 foot elevation will be surveyed for compliance with the unrestricted 419 release criteria prior to being isolated, abandoned in place and filled with grout or fill as 420 appropriate. Two of the five sleeves have been capped and were never used. The remaining 421 three sleeves housed 20 inch diameter Recirculating Sump Suction lines which will be removed 422 prior to surveying and abandoning the sleeves in place.

423 Several other sections of piping systems associated with the Auxiliary Building may also remain.

424 The list of buried piping, penetrations and embedded piping to remain is provided in 425 ZionSolutions Technical Support Document (TSD)14-016, Description of Embedded Pipe, 426 Penetrations, and Buried Pipe to Remain in Zion End State (Reference 3-10). The decision to 427 remove or abandon in place will be made based on the results of a cost-benefit analysis that will 428 be performed once access to the pipe sections become possible. In all cases, any buried or 429 embedded piping that will remain will be surveyed for compliance with the unrestricted release 430 criteria prior to being isolated, abandoned in place and filled with grout or fill as appropriate.

431 Once the remaining concrete structure located 3 feet below grade (extending between the 432 542 foot and 588 foot elevation) has been satisfactorily surveyed and compliance with the 433 unrestricted release criteria has been demonstrated and, contingent upon the completion of 434 confirmatory surveys and regulatory approval, the Auxiliary Building void will be backfilled 435 using concrete debris suitable for reuse as clean hard fill and/or clean fill to the original site 436 grade and contours. The top 3 feet of fill will be soil only (i.e. concrete clean hard fill will only 437 be utilized as fill up to 588 foot elevation).

438 3.3.4. Unit 1 and Unit 2 Containments 439 Component and system removal is currently ongoing in both Unit 1 440 and Unit 2 Containment Buildings. Surveys to verify as-left 441 contamination levels are below the criteria established for open-air 442 demolition are also being performed as a parallel activity. Based 443 upon the results of these surveys, the remaining systems, 444 components and structural surfaces that will be required to be 445 removed or decontaminated prior to permitting open air 446 demolition in accordance with TSD 10-002 are being identified.

447 Identified radiological commodities are currently being removed, or will be removed prior to 3-10

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 448 structural demolition. All radioactive waste will be loaded and transported under the direction of 449 ZionSolutions Waste Department personnel to the licensed Energy Solutions radioactive waste 450 disposal facility in Clive, Utah. All structural decontamination activities will be performed in 451 accordance with an approved RWP(s) and under the oversight of ZionSolutions Radiation 452 Protection personnel.

453 When commodity removal is complete and all structural surfaces have been decontaminated to 454 the open-air demolition limits in accordance with TSD 10-002, the Containment Buildings will 455 be placed in a Cold, Dark and Dry configuration and they will be turned over to a 456 Decommissioning Contractor. In both Containment basements, all concrete will be removed 457 from the interior side of the steel liner above the 565 foot elevation, leaving only the remaining 458 exposed liner below the 588 foot elevation, the concrete in the In-core Instrument Shaft leading 459 to and including the area under vessel (or Under-Vessel area), and the structural concrete outside 460 of the liner.The Decommissioning Contractor will demolish all of the remaining interior systems, 461 structures, components and concrete down to the containment liners. Contamination control 462 methods (vaccuming, wiping, etc) will be used to mitigate loose surface contamination on the 463 remaining exposed structural surfaces. All construction debris resultant from the demolition of 464 each of the Containment Building structures will be treated as low level radioactive waste and 465 will be shipped to the licensed EnergySolutions radioactive waste disposal facility in Clive, Utah 466 by gondola railcar. Once all commodities and interior concrete have been removed from the 467 Containment shells, the exposed steel liner below the 588 foot elevation and Under-Vessel 468 concrete will be surveyed for compliance with the unrestricted release criteria as specified in 469 10 CFR 20.1402. In addition, at this point, any confirmatory surveys required by the regulator 470 will also be accomplished. Once the Containment structural surfaces located 3 feet below grade 471 (588 foot elevation) have been satisfactorily surveyed and compliance with the unrestricted 472 release criteria has been demonstrated and, contingent upon the completion of confirmatory 473 surveys and regulatory approval, the Containment Building basements will be filled to above the 474 588 foot elevation using clean fill or concrete debris suitable for reuse as clean hard fill. The top 475 3 feet of fill will be soil only. An additional one foot of clean soil may be placed as sacrificial 476 soil to minimize the potential for contaminating the clean fill.

477 After packing each Containment basement with clean fill, both Containment shells will be 478 demolished to a depth of 3 feet below grade in accordance with the requirements of the Asset 479 Sale Agreement. Demolition will include the removal of the pre-stressing tendons and the 480 gradual demolition of the containment shells from grade, using ram-hoes to chip away the 481 concrete along the bottom circumference of the shell and allowing the weight of the remaining 482 structure to slowly demolish the structure to grade. This is the same or similar approach that was 483 used to demolish the Containment structure during the decommissioning of the Connecticut 484 Yankee Atomic Power Companys Haddam Neck Nuclear Power Plant. The process will also 485 allow for the removal of all exposed rebar and to ensure that individual debris pieces are smaller 486 than 10 inches in diameter. Concrete debris resulting from the building demolition that ismay be 487 designated for beneficial reuse as clean hard fill will be surveyed. Only concrete that meets the 488 non-radiological definition of clean concrete demolition debris and where FSS demonstrates that 489 the concrete is free of plant derived radionuclides above background will be used. in 490 accordance with MARSAME and verified to be free of detectable radiation above background.

491 The processed concrete debris will then be transported to a designated storage area where it will 3-11

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 492 be stockpiled for use as potential backfill material. If the material is not used as clean hard fill, 493 then it will be packaged and transported to an appropriate landfill for disposal or, to an off-site 494 recycling center following final assessment for the presence of any residual radioactive 495 contamination by passing through a radiological truck monitor.

496 3.3.5. Fuel Handling Building 497 The dismantlement and decommissioning of the Fuel Handling 498 Building is contingent upon the placement of the spent nuclear fuel 499 located in the SFP into dry cask storage and transfer of the packaged 500 fuel to the ISFSI facility. After all the fuel has been removed from 501 the pool, the processing and discharge of the SFP water will 502 commence. Initially, approximately 350,000 gallons or half of the 503 water volume in the pool will be processed by the Liquid 504 Radioactive Waste system, sampled and, once the radioactive concentration in the water meets 505 the criteria for effluent release, discharged through the normal effluent release pathway into Lake 506 Michigan. The decontamination of the upper portions of the steel pool liner will occur in parallel 507 with the initial processing and discharge of the pool water. With the water level lowered, the 508 23 empty spent fuel storage racks will be removed from the pool. A cost benefit analysis will 509 determine if the fuel racks are processed for volume reduction on-site or off-site. The fuel racks 510 will be properly packaged and shipped for eventual disposal as radioactive waste. Once the fuel 511 racks have been removed, the remaining approximately 350,000 gallons of pool water will then 512 be processed by the Liquid Radioactive Waste system, sampled and, once the radioactive 513 concentration in the water meets the criteria for effluent release, discharged through the normal 514 effluent release pathway into Lake Michigan. The lower sections and bottom of the steel pool 515 liner will also be decontaminated as necessary while still wet.

516 When the pool is completely empty and dry, all known radioactively contaminated systems and 517 components will be removed by either ZionSolutions personnel or a subcontracted Demolition 518 Contractor and properly disposed of as radioactive waste. This will include the steel liner of the 519 SFP. In parallel, ZionSolutions Radiation Protection personnel will perform surveys to verify as-520 left contamination levels are below those established for open-air demolition of the interior 521 surfaces and remaining commodities in the Fuel Handling Building, including the exposed 522 concrete of the SFP foundation once the liner is removed. Based upon the results of these 523 surveys, the remaining systems, components and structural surfaces that will be required to be 524 removed or decontaminated prior to permitting open air demolition in accordance with 525 TSD 10-002 will be removed or successfully decontaminated prior to structural demolition. All 526 radioactive waste will be loaded and transported under the direction of ZionSolutions Waste 527 Department personnel to the licensed EnergySolutions radioactive waste disposal facility in 528 Clive, Utah. All structural decontamination activities will be performed in accordance with an 529 approved RWP(s) and under the oversight of ZionSolutions Radiation Protection personnel.

530 When the commodity removal by ZionSolutions personnel is complete and all structural surfaces 531 and remaining commodities have been decontaminated to the open-air demolition limits in 532 accordance with TSD 10-002, the Fuel Handling Building will be turned over to a subcontracted 533 Decommissioning Contractor. Due to its strategic locations adjacent to the Containment 534 Buildings, the Auxiliary Building and the existing rail line, the shell of the Fuel Handling 3-12

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 535 Building may be left standing for some period of time to aid in the removal of low level waste 536 from the adjacent structures. When conditions become favorable, the Decommissioning 537 Contractor will demolish all of the remaining interior systems, structures, components and 538 concrete down to a depth of 3 feet below grade in accordance with the requirements of the Asset 539 Sale Agreement. All construction debris resultant from the demolition of the Fuel Handling 540 Building will be treated as low level radioactive waste and will be shipped to the licensed Energy 541 Solutions radioactive waste disposal facility in Clive, Utah by gondola railcar.

542 Once any remaining concrete structures, which could include the concrete sub-slab for the SFP, 543 located below 3 feet below grade has been satisfactorily surveyed and demonstrated to be in 544 compliance with the unrestricted release criteria as specified in 10 CFR 20.1402 and, contingent 545 upon the completion of confirmatory surveys and regulatory approval, the void where the Fuel 546 Handling Building once stood will be backfilled using concrete debris suitable for reuse as clean 547 hard fill and/or clean fill to the original site grade and contours. The top 3 feet of fill will be soil 548 only (i.e. concrete clean hard fill will only be utilized as fill up to 588 foot elevation).

549 3.3.6. Waste Water Treatment Facility (WWTF) 550 The Wastewater Treatment Facility (WWTF) was designed to treat non-radioactive and low-551 level radioactive liquid from ZNPS sources including building roof run-off and the Turbine 552 Building Fire Sump, which received liquid waste from the Turbine Building Equipment and 553 Floor Drains, and the Fuel Pool Cooling Tower Blowdown. The WWTF was designed to 554 remove suspended solids and oil to ensure compliance with the facility National Pollutant 555 Discharge Elimination System (NPDES) permit. Since the wastewater discharge rates were 556 variable, an equalization tank was installed. The WWTF also includes other equipment such as 557 mixing tanks, mixers, oil skimmers, flocculators, oil coalescers, clarifiers, sludge drying beds 558 and filters. Discharge from the WWTF was by gravity to the Forebay. To prevent excessive 559 contamination of the WWTF, the Fire Sump discharge was monitored for radioactivity. During 560 ZNPS operations, liquid waste with detectable low-level radioactive contamination was 561 processed by the WWTF. Consequently, the internal surfaces of the WWTF systems are 562 considered as potentially contaminated.

563 All systems, component and materials associated with the WWTF that are or will be identified 564 by radiological survey as contaminated with detectable plant-derived radioactive material will be 565 removed by ZionSolutions personnel and dispositioned and properly disposed of as radioactive 566 waste. The remaining structure will then be made Cold, Dark and Dry. Once this is complete, 567 all remaining commodities and all structural surfaces will be demolished to a depth of 3 feet 568 below grade in accordance with the requirements of the Asset Sale Agreement. All remaining 569 structural surfaces from the WWTF below 3 feet below grade will undergo a survey to 570 demonstrate compliance with the unrestricted release criteria as specified in 10 CFR 20.1402.

571 Once the remaining concrete structure located below 3 feet below grade (588 foot elevation) has 572 been satisfactorily surveyed and compliance with the unrestricted release criteria has been 573 demonstrated and, contingent upon the completion of confirmatory surveys and regulatory 574 approval, the WWTF void will be backfilled using concrete debris suitable for reuse as clean 575 hard fill and/or clean fill to the original site grade and contours. The top 3 feet of fill will be soil 576 only (i.e. concrete clean hard fill will only be utilized as fill up to the 588 foot elevation).

3-13

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 577 3.3.7. Miscellaneous Structures 578 3.3.7.1. East and West Service Buildings 579 These two structures are located to the south of the Unit 1 580 Turbine Building and have been utilized primarily as office 581 space and a machine shop. Both are steel framed structures 582 that have no sub-grade basement. The remaining structure 583 and materials in the East and West Service Buildings will 584 be demonstrated as meeting the unrestricted 585 releaseunconditional release criteria using the approach 586 presented in MARSAME. Surveys will be performed in 587 accordance with the site procedure for the unconditional 588 release of materials to verify that the material is free of plant-derived radioactive material.

589 Materials released for unconditional use can be recycled or released for disposal at a non-590 radiological landfill. No recycled materials will remain on site. The remaining structure will 591 then be made Cold, Dark and Dry and turned over to a Demolition Contractor as a non-592 radiologically controlled structure for demolition as a contracted work scope. Both buildings are 593 scheduled for demolition at essentially the same period as the Turbine Building. The concrete 594 base slabs and edge beams will be removed to a depth of 3 feet below grade in accordance with 595 the requirements of the Asset Sale Agreement and all associated buried piping systems 596 associated with these buildings are targeted for complete removal and disposal as waste. Any 597 void created by the demolition of these structures will be surveyed by the ZionSolutions 598 Characterization/License Termination group and documented as a Radiological Assessment 599 (RA). Upon completion of the RA and acceptance of the survey results, any voids will be 600 backfilled to the original site grade and contours.

601 3.3.7.2. Forebay, Forebay Valve Houses and Intake and Outflow Structures located in 602 Lake Michigan 603 The Circulating Water Intake Piping and Discharge Tunnels located at the bottom of Lake 604 Michigan will remain and be abandoned in place. These structures will be surveyed in place to 605 demonstrate compliance with the unrestricted release criteria as specified in 10 CFR 20.1402.

606 The accessible Forebay surfaces above the 588 foot elevation and 607 the Valve Houses will be radiologically surveyed to demonstrate 608 that the structural surfaces and materials meet the unrestricted 609 unconditional release criteria using the approach presented in 610 MARSAME. Surveys will be performed in accordance with the 611 site procedure for the unconditional release of materials to verify 612 that the material is free of plant-derived radioactive material.

613 Materials released for unconditional use can be recycled or 614 released for disposal at a non-radiological landfill. No recycled materials will remain on site.

615 The Valve Houses and the Forebay will then be made Cold, Dark and Dry and turned over to a 616 Demolition Contractor as a non-radiologically controlled structure for demolition as a contracted 617 work scope. The structural surfaces of the Forebay located below the 588 foot elevation will be 618 surveyed to demonstrate compliance with the unrestricted release criteria as specified in 3-14

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 619 10 CFR 20.1402. As it is difficult to completely isolate the Forebay from Lake Michigan, safety 620 concerns will prevent personnel from physically entering the Forebay to perform this survey.

621 Consequently, it is anticipated that this survey will be performed remotely using detectors 622 deployed by extended booms or long-handled tools.

623 Once the compliance survey is complete, and contingent upon the completion of confirmatory 624 surveys and regulatory approval, the selected Demolition Contractor will remove and disposition 625 all remaining commodities and completely demolish the Valve Houses and demolish the Forebay 626 structure to a depth of 3 feet below grade in accordance with the requirements of the Asset Sale 627 Agreement. All other construction demolition debris that is not appropriate for beneficial reuse 628 as potential backfill material will be packaged and transported to an appropriate landfill for 629 disposal or, to an off-site recycling center following final assessment for the presence of any 630 residual radioactive contamination by passing through a radiological truck monitor.

631 Once the remaining concrete structure located below 3 feet below grade (588 foot elevation) has 632 been satisfactorily surveyed and demonstrated to be in compliance with the unrestricted release 633 criteria as specified in 10 CFR 20.1402, the Forebay void will be backfilled using clean fill or 634 concrete debris suitable for reuse as clean hard fill to the original site grade and contours. Large 635 blocks of concrete will be placed in the Forebay at the mouth of the intake prior to the actual 636 backfill to minimize any long term erosion concerns. The top 3 feet of fill will be soil only (i.e.

637 concrete clean hard fill will only be utilized as fill up to 588 foot elevation).

638 3.3.7.3. NGET, ENC, South Warehouse, North Security Access Gatehouse 639 These structures are located in the Radiologically-Restricted Area and have been utilized 640 primarily as office and storage space. All are steel framed structures that have no sub-grade 641 basement. The structural surfaces and materials in each of these buildings will be demonstrated 642 as meeting the unrestricted releaseunconditional release criteria using the approach presented in 643 MARSAME. Surveys will be performed in accordance with the site procedure for the 644 unconditional release of materials to verify that the material is free of plant-derived radioactive 645 material. Materials released for unconditional use can be recycled or released for disposal at a 646 non-radiological landfill. No recycled materials will remain on site. The structures will then 647 made Cold, Dark and Dry and turned over to a Demolition Contractor as non-radiologically 648 controlled structures for demolition as a contracted work scope.

649 The concrete base slabs and wall foundations will be removed to a 650 depth of 3 feet below grade in accordance with the requirements 651 of the Asset Sale Agreement and all associated buried piping 652 systems associated with these buildings are targeted for complete 653 removal and disposal as waste. All electrical services will be de-654 energized and removed to a depth of 3 feet below grade. Any 655 void created by the demolition of these structures will be surveyed 656 by the ZionSolutions Characterization/License Termination group 657 and documented as a RA. Upon completion of the RA and acceptance of the survey results, any 658 voids will be backfilled to the original site grade and contours.

659 3.3.7.4. Laundry Building, North Security Restricted Area Gatehouse, South Security 660 Restricted Area Access, Restricted Area Fence and Vehicle Barrier System 3-15

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 661 These structures are located in the Security-Restricted Area and are 662 primarily security structures that will no longer be required once all the 663 spent nuclear fuel is moved to the ISFSI. The structures are a mix of 664 steel frame, slab on grade and reinforced concrete construction. The 665 structural surfaces and materials in each building and area will be 666 demonstrated as meeting the unrestricted releaseunconditional release 667 criteria using the approach presented in MARSAME. Surveys will be 668 performed in accordance with the site procedure for the unconditional release of materials to 669 verify that the material is free of plant-derived radioactive material. Materials released for 670 unconditional use can be recycled or released for disposal at a non-radiological landfill. No 671 recycled materials will remain on site. The structures will then made Cold, Dark and Dry and 672 turned over to a Demolition Contractor as non-radiologically controlled structures for demolition 673 as a contracted work scope. The concrete base slabs and wall foundations will be removed to a 674 depth of 3 feet below grade in accordance with the requirements of the Asset Sale Agreement 675 and all associated buried piping systems associated with these buildings are targeted for 676 complete removal and disposal as waste. All electrical services will be de-energized and 677 removed to a depth of 3 feet below grade. Any void created by the demolition of these structures 678 will be surveyed by the ZionSolutions Characterization/License Termination group and 679 documented as a RA. Upon completion of the RA and acceptance of the survey results, any 680 voids will be backfilled to the original site grade and contours.

681 3.3.7.5. Steam Tunnels and Waste Handling Area 682 The Steam Tunnels are buried structures that connect the Unit 1 and Unit 2 Containment 683 Building with the Turbine Building at the 570 foot elevation. They are constructed of reinforced 684 concrete. The Waste Handling Area is a steel frame building built on an on-grade concrete slab.

685 Both of these structures will undergo radiological surveys to verify that as-left contamination 686 levels are below those established for open-air demolition prior to commencing 687 decommissioning. Based upon the results of these surveys, the remaining systems, components 688 and structural surfaces that will be required to be removed or decontaminated prior to permitting 689 open air demolition in accordance with TSD 10-002 will be removed or successfully 690 decontaminated prior to structural demolition. All radioactive waste will be loaded and 691 transported under the direction of ZionSolutions Waste Department personnel to the licensed 692 EnergySolutions radioactive waste disposal facility in Clive, Utah.

693 Once all identified radioactive systems have been removed and any structural surfaces that 694 require remediation have been decontaminated, the structures will then be made Cold, Dark and 695 Dry and turned over to a Decommissioning Contractor for demolition as a contracted work 696 scope. The Waste Handling Building will be completely removed, including the concrete slab.

697 The roof of the Steam Tunnels will be exposed by excavation. The concrete roof slabs will be 698 demolished and removed and all remaining materials in the Steam Tunnels will be removed 699 through the created opening. Concrete debris resulting from the building demolition may be 700 designated for beneficial reuse as clean hard fill. Only concrete that meets the non-radiological 701 definition of clean concrete demolition debris and where FSS demonstrates that the concrete is 702 free of plant derived radionuclides above background will be used. The demolition debris will 703 be surveyed for unrestricted release using the approach presented in MARSAME. All clean 3-16

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 704 construction debris that is not appropriate for reuse as potential backfill material will be 705 packaged and transported to an appropriate landfill for disposal or, to an off-site recycling center 706 following final assessment for the presence of any residual radioactive contamination by passing 707 through a radiological truck monitor.

708 The remaining structural surfaces of the Steam Tunnels located below the 588 foot elevation will 709 be surveyed to demonstrate compliance with the unrestricted release criteria as specified in 710 10 CFR 20.1402. Once the compliance survey is complete, and contingent upon the completion 711 of confirmatory surveys and regulatory approval, the selected Decommissioning Contractor shall 712 demolish the Steam Tunnel structures to a depth of 3 feet below grade in accordance with the 713 requirements of the Asset Sale Agreement.

714 Once the remaining concrete structure located below 3 feet below grade (588 foot elevation) has 715 been satisfactorily surveyed and compliance with the unrestricted release criteria has been 716 demonstrated, the Steam Tunnels voids will be backfilled using concrete debris suitable for 717 reuse as clean hard fill and/or clean fill to the original site grade and contours. The top 3 feet of 718 fill will be soil only (i.e. concrete clean hard fill will only be utilized as fill up to 588 foot 719 elevation).

720 3.3.7.6. Old Sewage Treatment Facility and Meteorological Tower 721 The Old Sewage Treatment Facility and the Meteorological Tower will be demonstrated as 722 meeting the unconditional releaseunconditional release criteria using the approach presented in 723 MARSAME. Surveys will be performed in accordance with the site procedure for the 724 unconditional release of materials to verify that the material is free of plant-derived radioactive 725 material. Materials released for unconditional use can be recycled or released for disposal at a 726 non-radiological landfill. No recycled materials will remain on site. The structures will then be 727 made Cold, Dark and Dry and turned over to a Decommissioning Contractor as non-728 radiologically controlled structures for demolition as a contracted work scope. The structures, 729 concrete slabs all associated buried piping systems associated with these buildings will be 730 completely removed and disposed of as waste. All electrical services will be de-energized and 731 removed to a depth of 3 feet below grade. Any void created by the demolition of these structures 732 will be surveyed by the ZionSolutions Characterization/License Termination group and 733 documented as a RA. Upon completion of the RA and acceptance of the survey results, any 734 voids will be backfilled to the original site grade and contours.

735 3.3.7.7. Storm Drain System, Manholes and Fire Protection Buried Piping 736 It is anticipated that once fire suppression is provided by temporary or local systems and physical 737 conditions support the retirement of the on-site fire suppression system, the existing fire 738 protection piping (including hydrants and valves) and the storm drain system (including the oil 739 separators) will be removed and disposed of as clean waste. If a situation occurs where difficulty 740 is encountered with ground water, some of the piping and/or catch basins located greater than a 741 depth of 5 feet below grade may be abandoned in place. In these cases, any piping or catch 742 basins that remain will be surveyed for compliance with the unrestricted release criteria as 743 specified in 10 CFR 20.1402 prior to being isolated and abandoned in place. Any voids created 744 by excavation to support the removal of these systems will be surveyed by the ZionSolutions 3-17

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 745 Characterization/License Termination group and documented as a RA. Upon completion of the 746 RA and acceptance of the survey results, any voids will be backfilled to the original site grade 747 and contours.

748 3.3.7.8. Surface Soils, Subsurface Soil and Groundwater 749 Characterization survey results and historical survey data indicate that there is minimal residual 750 radioactivity in soil and no groundwater contamination identified to date. As needed, additional 751 investigations will be performed to ensure that any changing soil radiological contamination 752 profile during decommissioning is adequately identified and addressed. Chapter 5 discusses soil 753 sampling and survey methods.

754 The release criteria that will be used to demonstrate compliance with the 25 mrem/yr dose 755 criterion are provided in Tables 5-4 and 5-5 of Chapter 5. Throughout the course of the 756 decommissioning and through site closure, ZSRP will continue to survey and characterize soils 757 as they are exposed by excavation during building demolition or made accessible by the removal 758 of structures or components. If residual radioactivity is discovered in surface or subsurface soils, 759 ZSRP will excavate, package and dispose of any soil contaminated with residual radioactivity at 760 concentrations greater that the unrestricted release criteria.

761 3.4. Radiological Impacts of Decommissioning Activities 762 The decommissioning activities described are and will be conducted under the provisions of the 763 ZionSolutions Radiation Protection Program and Radioactive Waste Management Program.

764 These programs are and will continue to be implemented as described in the DSAR. The 765 ZionSolutions Radiation Protection Program and written site procedures are intended to provide 766 sufficient information to demonstrate that decommissioning activities will be performed in 767 accordance with 10 CFR 19, Notices, Instructions And Reports To Workers, 10 CFR 20, 768 Standards For Protection Against Radiation and to maintain radiation exposures As Low As 769 Reasonably Achievable (ALARA). The ZionSolutions Radioactive Waste Management Program 770 controls the generation, characterization, processing, handling, shipping, and disposal of 771 radioactive waste in accordance with the approved ZionSolutions Radiation Protection Program, 772 Process Control Program, and written plant procedures.

773 The current Radiation Protection Program, Waste Management Program, and Radiological 774 Effluent Monitoring and Offsite Dose Calculation Manual (ODCM) (Reference 3-1111) will be 775 used to protect the workers and the public during the various decontamination and 776 decommissioning activities. These well-established programs are routinely inspected by the 777 NRC to ensure that workers, the public, and the environment are protected during facility 778 decommissioning activities. It is also important to note that decommissioning activities involve 779 the same radiation protection and waste management considerations as those encountered during 780 plant operations, maintenance and outages. As described in the PSDAR, the decommissioning 781 will be accomplished with no significant adverse environmental impacts in that:

782

No site-specific factors pertaining to the decommissioning of the ZNPS would alter the 783 conclusions presented in NUREG-0586 (see LTP Chapter 8).

784

Radiation dose to the public will be minimal.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 785

Decommissioning is not an imminent health or safety concern and will generally have a 786 positive environmental impact.

787 Continued application of the current and future Radiation Protection and Radiological Effluent 788 Monitoring Programs at ZNPS ensures public protection in accordance with 10 CFR 20 and 789 10 CFR 50, Appendix I. ODCM reports for ZNPS to date conclude that the public exposure as a 790 result of decommissioning activities is bounded by the evaluation in NUREG-0586, which 791 concludes the impact is minimal.

792 3.4.1. Control Mechanisms to Mitigate the Recontamination of Remediated Areas 793 Due to the large scope of remaining structures and systems that will be decontaminated and 794 dismantled, Final Radiation Survey (FRS)FSS of areas may be performed in parallel with 795 decommissioning activities. Consequently, a systematic approach will be employed to ensure 796 that areas are adequately remediated prior to performing FRS FSS and ongoing decommissioning 797 activities do not impact the radiological condition of areas where compliance with the 798 unrestricted release criteria as specified in 10 CFR 20.1402 has been demonstrated. These 799 measures and mechanisms are described in Chapter 5, sections 5.6.3 and 5.12.

800 3.4.2. Occupational Exposure 801 Table 3-2 provides the cumulative site dose and estimates for the decommissioning of ZNPS.

802 These estimates were developed to provide site management ALARA goals. The goals are 803 verified by summation of actual site dose, as determined by appropriate dosimetry. ALARA 804 estimates are a compilation of RWP estimates for the period. This information is in addition to 805 information gathered for reporting of yearly site dose. The annual report of occupational dose 806 meets the guidance of NRC Regulatory Guide 1.16, Reporting of Operating Information, 807 Appendix A, Technical Specifications (Reference 3-1212). The total radiation exposure impact 808 for decommissioning and spent fuel management is estimated to be approximately 935 person-809 rem.

810 3.4.3. Exposure to the Public 811 Continued application of ZionSolutions Radiation Protection, Radioactive Waste, Radiological 812 Effluent Technical Specification and Radiological Environmental Monitoring Programs assures 813 public protection in accordance with 10 CFR 20 and 10 CFR 50, Appendix I.

814 3.4.4. Radioactive Waste Projections 815 The Radioactive Waste Management Program is used to control the characterization, generation, 816 processing, handling, shipping, and disposal of radioactive waste during decommissioning.

817 Activated and contaminated systems, structures, and components represent the largest volume of 818 low level radioactive waste expected to be generated during decommissioning. Other forms of 819 waste generated during decommissioning include:

820

Contaminated water; 821

Used disposable protective clothing; 822

Expended abrasive and absorbent materials; 3-19

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 823

Expended resins and filters; 824

Contamination control materials (e.g., strippable coatings, plastic enclosures); and 825

Contaminated equipment used in the decommissioning process.

826 Table 3-3 provides projections of waste classifications and quantities that will be generated by 827 the decommissioning of ZNPS. These waste quantities are consistent with the waste quantities 828 projected in the PSDAR. As ZionSolutions has elected to institute an approach commonly 829 referred to as rip & ship verses performing significant on-site decontamination activities, the 830 total volume of low-level radioactive waste for disposal has been estimated at approximately 831 6,000,000 cubic feet. Actual waste volumes and classifications may vary. The vast majority of 832 this waste will be shipped to the licensed EnergySolutions radioactive waste disposal facility in 833 Clive, Utah by gondola railcar.

834 3.5. References 835 3-1 Zion Nuclear Power Station, Post Shutdown Decommissioning Activity Report 836 (PSDAR), - March 2008 837 3-2 U.S. Nuclear Regulatory Commission NUREG-0586 Generic Environmental Impact 838 Statement on Decommissioning of Nuclear Facilities, Supplement 1, Volume 1 -

839 November 2002 840 3-3 Zion Station, Defueled Safety Analysis Report (DSAR) - September 2014 841 3-4 U.S. Nuclear Regulatory Commission Docket Number 50-295, Facility Operating 842 License Number DPR-39 (for Unit One) 843 3-5 U.S. Nuclear Regulatory Commission Docket Number 50-304, Facility Operating 844 License Number DPR-48 (for Unit Two) 845 3-6 Letter from ZionSolutions to the U.S. Nuclear Regulatory Commission, Notification of 846 Amended Post-Shutdown Decommissioning Activities Report (PSDAR) for Zion 847 Nuclear Power Station, Units 1 and 2 - March 18, 2008.

848 3-7 Letter from J.B. Hickman (U.S. Nuclear Regulatory Commission) to J. Christian 849 (ZionSolutions), Issuance of Conforming Amendments Relating to Transfer of Licenses 850 for Zion Nuclear Power Station, Units 1 and 2 - September 2010 851 3-8 Zion Nuclear Power Station, Units 1 and 2 Asset Sale Agreement - December 2007 852 3-9 ZionSolutions Technical Support Document 10-002, Technical Basis for Radiological 853 Limits for Structure/Building Open Air DemolitionU.S. Nuclear Regulatory 854 Commission NUREG-1575, Supplement 1, Multi-Agency Radiation Survey and 855 Assessment of Materials and Equipment Manual (MARSAME) - December 2006 856 3-10 ZionSolutions Technical Support Document 14-016, Description of Embedded Pipe, 857 Penetrations, and Buried Pipe to Remain in Zion End State 858 3-103-11 Exelon Nuclear Radiological Effluent Monitoring and Offsite Dose Calculation 859 Manual (ODCM) - January 2001ZionSolutions Technical Support Document 10-002, 860 Technical Basis for Radiological Limits for Structure/Building Open Air Demolition 3-20

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 861 3-113-12 U.S. Nuclear Regulatory Commission Regulatory Guide 1.16, Reporting of 862 Operating Information, Appendix A, Technical Specifications - August 1975Exelon 863 Nuclear Radiological Effluent Monitoring and Offsite Dose Calculation Manual 864 (ODCM) - January 2001 865 3-12 U.S. Nuclear Regulatory Commission Regulatory Guide 1.16, Reporting of Operating 866 Information, Appendix A, Technical Specifications - August 1975 867 3-21

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 868 Table 3-1 Status of Major ZNPS Systems, Structures, and 869 Components as of December 2014 Required for System or Component Status SFP Reactor Coolant System No Partially Removed Reactor Vessel Internals No Segmentation completed Reactor Vessels No Segmentation underway Steam Generators No Removal preparations underway Reactor Coolant Pumps No Removed from site Pressurizer No Removal preparations underway Chemical & Volume Control System No Partially removed Safety Injection System No Partially removed Residual Heat Removal System No Partially removed Containment Spray System No Partially removed Component Cooling Water System No Partially removed Service Water System No Partially removed.

Spent Fuel Pool Yes In place Fuel Handling Equipment No In place Spent Fuel Pool Cooling and Yes In place Demineralizer System (SFPI systems)

Condensate System No Partially removed Feedwater System No Partially removed Steam Generator Blowdown System No Partially removed Primary Makeup Water System No Partially removed Refueling Water Storage Tank No In place Plant Effluent Monitoring System No In place Containment Ventilation System No In place Fuel Building Ventilation System Yes In place Aux Building Ventilation System No In place Auxiliary Boiler No In place 870 3-22

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 871 Table 3-1 (continued)

Required for System or Component Status SFP Instrument and Service Air System No Partially removed Gaseous Radioactive Waste System No Partially removed Solid Radioactive Waste System No Partially removed Partially removed; New system Liquid Radioactive Waste System No operational.

Makeup Water Systems Yes In place Radioactive Monitoring System Yes In place Process Sampling System No Partially removed Fire Protection System Yes Partially removed Electrical Systems Yes Partially removed Some equipment removed.

Containment Building No Decontamination activities are in progress.

Some equipment removed. Interior Auxiliary Building No dismantlement and decontamination activities are in progress.

Fuel Handling Building Yes In place Turbine Building No Some equipment removed.

Service Buildings No Some equipment removed.

872 3-23

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 873 Table 3-2 Radiation Exposure Projections for Decommissioning and after 874 1/1/2015 875 Fuel Storage Activities Activity Exposure (person-rem)

Dismantlement Activities RCS Decon. 32 Asbestos Abatement (includes scaffolding) 1362 Steam Generators and Pressurizer 8831 Reactor Vessel Internals 90 Reactor Vessel & Head Prep (CRDM/ICI Structure) 72 Main Reactor Coolant System 1732 Plant Systems 248180 Structures 7450 Miscellaneous 72136 Waste Processing (includes shipping and prep) 12 Subtotal Dismantlement Activities 841431 Operational ActivitiesTransportation and Waste 41 Processing/Packaging 1996 Operations--post certifications 1 1997 Operations 17 Spent Fuel Pool Isolation Modifications 10 Spent Fuel Storage 24 Fuel Transfer/Cask Loading 42 Subtotal Operational Activities 94 Total for Decommissioning and Fuel Storage Activities 935472 Transportation (occupational and to general public) 72 876 3-24

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 877 Table 3-3 Projected Waste Quantities WASTE PACKING WASTE WASTE WASTE TYPE WEIGHT DENSITY VOLUME CLASS (lbs) (lbs/cubic feet) (cubic feet)

Bulk Concrete A 223,263,000 66 3,370,000 Soils A 4,500,900 100 45,009 Metal Debris A 66,890,000 25 - 47 2,590,000 Large Components A 18,200,000 68 - 388 69,700 HazMat A 1,450,000 59 24,700 (containerized)

Highly Radioactive B or C 305,000 80 3,800 Very Highly

>C 71,600 112 640 Radioactive Clean Concrete (on-

- 345,900,000 71 4,870,000 site fill)

Clean Asbestos - 1,008,000 8.3 121,400 Clean Debris (local

- 28,000,000 100 280,000 landfill)

Clean Scrap Metal

- 44,570,000 129 346,000 (recycler)

Totals - 734,159,000 11,721,200 878 879 3-25

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 880 Table 3-4 General Project Milestones Date Milestone Q3/2014 Unit 2 Reactor Internals Segmentation Complete Q4/2014 Unit 1 Reactor Internals Segmentation Complete Q4/2014 License Termination Plan Submittal to NRC Q1/2015 Complete Transfer of Spent Nuclear Fuel to ISFSI Q1/2015 Cold and Dark Complete (Electrical)

Q2/2015 Complete Demolition of Crib House Q2/2015 Unit 2 Reactor Vessel Segmentation Complete Q3/2015 Complete Demolition of Service Building (East/West)

Q4/2015 Complete Demolition of Turbine Building Q4/2015 Unit 1 Reactor Vessel Segmentation Complete Q4/2016 Complete Interior Dismantlement of Auxiliary Building Q1/2017 Complete Interior Dismantlement of Unit 2 Containment Q4/2017 Complete Interior Dismantlement of Unit 1 Containment Q4/2018 Complete All Major Demolition Q4/2018 Complete Final Radiation Survey (FRS)FSS and Site Restoration Q4/2018 Complete Zion Station Restoration Project 881 Note; Circumstances can change during decommissioning. If ZionSolutions determines that the 882 decommissioning cannot be completed as outlined in this schedule, ZionSolutions will provide an updated 883 schedule to the NRC.

884 3-26

ML17208A123

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