ML17208A123

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
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Download: ML17208A123 (31)

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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 3-i 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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-ii 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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-i LIST OF ACRONYMS AND ABBREVIATIONS 1

ALARA As Low As Reasonably Achievable 2

ACM Asbestos Containing Material 3

CST Condensate Storage Tank 4

DSAR Defueled Safety Analysis Report 5

EPA Environmental Protection Agency 6

FOT Fuel Oil Tank 7

FRS Final Radiation Survey 8

FSS Final Status Survey 9

HVAC Heating Ventilation Air Conditioning 10 ISFSI Independent Spent Fuel Storage Installation 11 IRSF Interim Radioactive Waste Storage Facility 12 LTP License Termination Plan 13 MMTC Mechanical Maintenance Training Center 14 MARSAME Multi-Agency Radiation Survey and Assessment of Materials and Equipment 15 Manual 16 NESHAP National Emissions Standards for Hazardous Air Pollutants 17 NRC Nuclear Regulatory Commission 18 ODCM Dose Calculation Manual 19 PSDAR Post Shutdown Decommissioning Activity Report 20 PWST Primary Water Storage Tanks 21 RA Radiological Assessment 22 RCRA Resource Conservation and Recovery Act 23 RCS Reactor Coolant System 24 RWP Radiation Work Permit 25 SFP Spent Fuel Pool 26 S/G Steam Generator 27 TSCA Toxic Substances Control Act 28 TSD Technical Support Document 29 UFSAR Updated Final Safety Analysis Report 30 ZNPS Zion Nuclear Power Station 31 ZSRP Zion Station Restoration Project 32 33

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-1

3. IDENTIFICATION OF REMAINING SITE DISMANTLEMENT 37 ACTIVITIES 38 3.1.

Introduction 39 In accordance with 10CFR50.82 (a)(9)(ii)(B), the License Termination Plan (LTP) must identify 40 the remaining major dismantlement and decontamination activities for the decommissioning at 41 the time of submittal. The information includes those areas and equipment that need further 42 remediation and an assessment of the potential radiological conditions that may be encountered.

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

47 and do not depend upon LTP approval to proceed.

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

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

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

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

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-2 NRC. Activities conducted during decommissioning do not pose any greater radiological or 79 safety risk than those conducted during operations, especially those during major maintenance 80 and outage evolutions.

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

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

104 3.2.

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

109 Other completed Decommissioning activities include:

110

• Creation of large openings in each Containment Building (approximately 31 feet x 36 feet) 111 and installation of a Heavy Lift Rail system to enable transport of components and wastes out 112 of each Containment.

113

• Abatement, packaging and disposal of known and readily accessible lead and/or lead 114 containing material.

115

• Abatement, packaging and disposal of known and readily accessible Asbestos Containing 116 Material (ACM).

117

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-3

• Removal and shipment of the Unit 1 Reactor Coolant Pumps (3 out of 4), Reactor Coolant 118 Pump Motors (4 of 4), Loop Stop Isolation Valves (4 of 4), Steam Generator (S/G) steam 119 domes, the majority of the Reactor Coolant System (RCS) piping and the Reactor Head.

120

• Removal and shipment of the Unit 2 Reactor Coolant Pump Motors (4 of 4) and various RCS 121 piping.

122

• Installation of new temporary power feeds to each containment which will allow for a safer 123 commodity removal effort.

124

• Disconnection and termination of various plant systems.

125 3.2.2. Spent Fuel Island and ISFSI Activities 126 A priority task for ZionSolutions has been the construction of the ISFSI and the necessary 127 licensing, training and infrastructure modifications required to transfer spent fuel from the SFP to 128 the ISFSI. As part of this process, the Fuel Handling Building was upgraded with a new single-129 failure-proof crane. The ISFSI was constructed and became operational in late 2013. To date, 130 fifty (50) of the required sixty-one (61) dry cask storage canisters (1850 spent fuel assemblies) 131 have been successfully moved to the ISFSI. The completion of the movement of spent fuel into 132 dry cask storage and transfer to the ISFSI is scheduled for completion in early 2015.

133 3.2.3. Demolition and Dismantlement of Initial Structures 134 To date, the Interim Radioactive Waste Storage Facility (IRSF), the 135 Mechanical Maintenance Training Center (MMTC) & Warehouse 136 and the Fire Maze complex have been demolished and properly 137 dispositioned as radiologically-clean waste or potential clean hard 138 fill. The IRSF was built to temporarily store ZNPS generated 139 radioactive waste in the mid-1980s but was never utilized for that 140 purpose. It was a reinforced concrete structure that measured 141 134.5 feet long, 66 feet wide and 49 feet tall. The MMTC was a single story, steel framed, sheet 142 metal structure that measured approximately 40 feet by 77 feet. The structures in the Fire Maze 143 complex consisted of the Fire Maze, which was a single story steel framed building with sheet 144 metal siding that measured approximately 20 feet by 30 feet, the Fire Training Center, which was 145 a three story, steel framed building with sheet metal siding that measured approximately 25 feet 146 by 25 feet, the Fire Pit, which was a single story, steel framed building with sheet metal siding 147 that measured approximately 14 feet x 25 feet and the Temporary Radioactive Waste Liner 148 Building, which was a single story concrete building that measured approximately 36 feet by 149 39 feet.

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

154

• Identification of any operable systems that may have to be replaced or relocated. For these 155 initial structures, none were identified.

156

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-4

• Isolation of all electrical and mechanical systems servicing the structures.

157

• Issuance of a contract to a subcontractor designated as the 158 Demolition Contractor to complete demolition activities.

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

169

• Inspection of each structure for all universal, Resource Conservation and Recovery Act 170 (RCRA) or Toxic Substances Control Act (TSCA) wastes that would require removal prior to 171 demolition. These materials included mercury switches, light lamps, electrical ballasts and 172 ACM. For the initial test case structures, most of the wastes were directly removed and 173 dispositioned by ZionSolutions. The exceptions were mineral oil in a de-energized 174 transformer and the oil and brake shoes in the overhead crane in the IRSF. These wastes 175 were identified to the selected Demolition Contractor and subsequently abated as part of the 176 contracted work scope. ZionSolutions may elect to include any required waste abatement 177 activities as part of the Demolition Contractor work scope for future structural demolition.

178

• Completion of unconditional release surveys of each structure to ensure the structures can be 179 demolished and free-released. Surveys were performed in accordance with the site procedure 180 for the unconditional release of materials to verify that the material was free of plant-derived 181 radioactive material. Materials released for unconditional use were recycled or released for 182 disposal at a non-radiological landfill. No recycled materials remained on site.The survey 183 protocols described in NUREG-1575, Supplement 1, Multi-Agency Radiation Survey and 184 Assessment of Materials and Equipment Manual (MARSAME) (Reference 3-9) were used 185 to perform these surveys.

186

• Surveyed and verified concrete debris resulting from the building 187 demolition that was designated for reuse as clean hard fill as 188 radiologically clean. This concrete debris was then processed to 189 remove all exposed rebar and to ensure that individual debris pieces 190 were smaller than 10 inches in diameter. The processed concrete 191 debris was then transported to a designated storage area where it was 192 stockpiled for use as potential backfill material. These stockpile areas are isolated and 193 controlled to prevent the inadvertent introduction of potentially contaminated materials and 194 periodic surveillances are performed.

195

• All other construction demolition debris that was not stockpiled as 196 potential backfill material was packaged and transported to an 197 appropriate landfill for disposal or, to an off-site recycling center.

198

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-5 At the ZSRP, all bulk material, regardless of destination, passes through a radiological truck 199 monitor.

200 3.2.4. Dismantlement of East Yard Tanks 201 The next structures to be demolished were the set of 202 tanks located in the east yard of the Security-203 Restricted Area. These tanks included the Primary 204 Water Storage Tanks (PWST) and the Condensate 205 Storage Tanks (CST) for both units, the Fuel Oil Tank 206 (FOT), the De-Chlorination and Chlorination tanks for 207 both units and concrete pads and shacks constructed 208 to service and house tanks, systems and components.

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

• The tanks were located within the Security-Restricted Area and were considered to be 212 radiologically impacted. Removal of the tanks would allow for the initial use and assessment 213 of the plans, procedures and processes for open-air demolition on radiologically 214 contaminated structures and systems and allow the Demolition Contractor to become 215 acclimated to working in a radiologically controlled environment.

216

• The radiological contamination of the tanks required contamination mitigation and 217 engineering controls to be implemented as part of the work scope.

218

• The removal of the tanks provided needed space for the eventual planned demolition of the 219 Crib House and the Turbine Building.

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

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

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

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

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-6 and soil samples were taken of the soil surrounding the tanks. No soil was identified with 240 residual radioactivity in excess of the release criteria. The PWSTs and the CSTs for both units 241 were dismantled, properly packaged and dispositioned as low-level radioactive waste. All 242 radioactive waste was loaded and transported under the direction of ZionSolutions Waste 243 Department personnel to the licensed Energy Solutions radioactive waste disposal facility in 244 Clive, Utah. Sampling of surface and subsurface soil and groundwater in this area has been 245 performed. Preliminary results demonstrate that some soil will require remediation and disposal 246 off site due to the presence of polynuclear aromatic hydrocarbons above the Illinois EPA limits.

247 3.2.5. Demolition and Dismantlement of Crib House Structure 248 The next major structure demolition activity planned for 2014 249 involves the demolition of the Crib House. The Crib House contains 250 the Circulating Water pumps, the Service Water Pumps and the Fire 251 Protection pumps. In order to implement the Cold, Dark and Dry 252 approach in the Crib House, a number of design modifications are 253 required to replace the functioning systems in the Crib House that 254 are required for the operation of necessary systems, such as 255 component cooling and fire protection. These include:

256

• The retirement of the station fire pumps and the integration of a modified fire water ring 257 header that is connected to the city water system for the Town of Zion as a replacement.

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

261

• The retirement of the Service Water pumps required the installation of a new pump to supply 262 circulating water to certain systems. This new pump was installed in the Forebay in a 263 manner that would allow for the demolition of the Crib House to proceed. This pump system 264 provides dilution flow for liquid waste releases into the Forebay and also serves as a source 265 of emergency make up water to the SFP via a hose connection. The previous Heating 266 Ventilation Air Conditioning (HVAC) functions performed by Service Water were replaced 267 by temporary, local heating and cooling installations and the relocation of certain functions 268 (Hot and Cold Laboratories and Counting Room) to other areas.

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

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-7 also supply temporary power, lighting and all other support required for the survey performance.

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

290 3.2.6. Additional Activities 291 Additional activities that have been completed or are ongoing include, but are not limited to the 292 following:

293

• Continued assessment of the functional requirements for plant systems, structures, and 294 components.

295

• Identification of plant systems, structures, and components needed to support safe storage of 296 the spent fuel, support SFP cooling, and facilitate ongoing plant activities.

297

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

298

• Detailed planning and project scheduling.

299

• At the start of 2014, a management change by ZionSolutions at the ZSRP was instituted 300 which resulted in a partial site stand down to allow for the completion of a comprehensive 301 planning and scheduling effort. Upon completion, decommissioning activities resumed in 302 accordance with the revised project schedule.

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

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

311 3.3.

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

320

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-8 These license amendments will greatly enhance the ability to completely place the remaining 321 structures into a Cold, Dark and Dry state, to complete the processing of the remaining liquid 322 radioactive waste, to allow for the complete removal of all remaining commodities and to allow 323 for the enhanced ability to more freely move material and personnel around the site. The 324 complete dismantlement and decommissioning of the Turbine and Auxiliary Building is 325 contingent upon completion of these tasks. The plans for the decontamination, dismantlement 326 and anticipated end-state condition(s) for the remaining site structures are presented in the 327 following sections.

328 3.3.2. Turbine Building (Unit 1 and Unit 2) 329 Large component removal in the Turbine Building is scheduled 330 to commence in early 2015. Initial component removal will 331 include the dismantlement and removal of most of the large 332 components in Unit 1, including the turbines, generator, 333 moisture separator reheaters, feedwater heaters and coolers and, 334 several feedwater heaters and coolers in Unit 2. In parallel with 335 this

effort, the ZionSolutions Characterization/License 336 Termination personnel will perform surveys for the 337 unconditional release of materials, equipment and structural 338 surfaces throughout the building. In addition, inspections were completed to identify any 339 remaining waste streams. Surveys were performed in accordance with the National Emissions 340 Standards for Hazardous Air Pollutants (NESHAP) to identify any potential ACM and all 341 accessible friable ACM was removed. Any remaining identified potential ACM that was not 342 accessible at this time, including but not limited to gaskets in piping systems, caulking around 343 windows, floor and wall barrier seals, will be appropriately handled and abated by the 344 Demolition Contractor as part of the contracted work scope.

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

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

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-9 remaining buried and piping embedded in concrete will be surveyed for compliance with the 364 unrestricted release criteria prior to being isolated, abandoned in place and filled with grout or 365 fill as appropriate.

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

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

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

384 3.3.3. Auxiliary Building 385 Component and system removal is currently ongoing in the 386 Auxiliary Building. Radiological surveys performed to verify as-387 left contamination levels are below the criteria established as 388 suitable for open-air demolition are also being performed as a 389 parallel activity. Based upon the results of these surveys, the 390 remaining systems, components and structural surfaces that will be 391 required to be removed or decontaminated prior to permitting 392 open air demolition in accordance with TSD 10-002 are being 393 identified. Identified radiological commodities in excess of the 394 open-air demolition limits are currently being removed, or will be removed prior to structural 395 demolition. All radioactive waste will be loaded and transported under the direction of 396 ZionSolutions Waste Department personnel to the licensed Energy Solutions radioactive waste 397 disposal facility in Clive, Utah. All structural decontamination activities will be performed in 398 accordance with an approved Radiation Work Permit (RWP) and under the oversight of 399 ZionSolutions Radiation Protection personnel. The current Liquid Radioactive Waste system 400 will remain in place until all liquid radioactive waste has been successfully processed and 401 dispositioned. When this task is complete, the Liquid Radioactive Waste system will also be 402 dismantled and properly disposed of as radioactive waste.

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

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

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

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

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

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

437 3.3.4. Unit 1 and Unit 2 Containments 438 Component and system removal is currently ongoing in both Unit 1 439 and Unit 2 Containment Buildings. Surveys to verify as-left 440 contamination levels are below the criteria established for open-air 441 demolition are also being performed as a parallel activity. Based 442 upon the results of these surveys, the remaining systems, 443 components and structural surfaces that will be required to be 444 removed or decontaminated prior to permitting open air 445 demolition in accordance with TSD 10-002 are being identified.

446 Identified radiological commodities are currently being removed, or will be removed prior to 447

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-11 structural demolition. All radioactive waste will be loaded and transported under the direction of 448 ZionSolutions Waste Department personnel to the licensed Energy Solutions radioactive waste 449 disposal facility in Clive, Utah. All structural decontamination activities will be performed in 450 accordance with an approved RWP(s) and under the oversight of ZionSolutions Radiation 451 Protection personnel.

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

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

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-12 be stockpiled for use as potential backfill material. If the material is not used as clean hard fill, 492 then it will be packaged and transported to an appropriate landfill for disposal or, to an off-site 493 recycling center following final assessment for the presence of any residual radioactive 494 contamination by passing through a radiological truck monitor.

495 3.3.5. Fuel Handling Building 496 The dismantlement and decommissioning of the Fuel Handling 497 Building is contingent upon the placement of the spent nuclear fuel 498 located in the SFP into dry cask storage and transfer of the packaged 499 fuel to the ISFSI facility. After all the fuel has been removed from 500 the pool, the processing and discharge of the SFP water will 501 commence. Initially, approximately 350,000 gallons or half of the 502 water volume in the pool will be processed by the Liquid 503 Radioactive Waste system, sampled and, once the radioactive concentration in the water meets 504 the criteria for effluent release, discharged through the normal effluent release pathway into Lake 505 Michigan. The decontamination of the upper portions of the steel pool liner will occur in parallel 506 with the initial processing and discharge of the pool water. With the water level lowered, the 507 23 empty spent fuel storage racks will be removed from the pool. A cost benefit analysis will 508 determine if the fuel racks are processed for volume reduction on-site or off-site. The fuel racks 509 will be properly packaged and shipped for eventual disposal as radioactive waste. Once the fuel 510 racks have been removed, the remaining approximately 350,000 gallons of pool water will then 511 be processed by the Liquid Radioactive Waste system, sampled and, once the radioactive 512 concentration in the water meets the criteria for effluent release, discharged through the normal 513 effluent release pathway into Lake Michigan. The lower sections and bottom of the steel pool 514 liner will also be decontaminated as necessary while still wet.

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

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-13 Building may be left standing for some period of time to aid in the removal of low level waste 535 from the adjacent structures. When conditions become favorable, the Decommissioning 536 Contractor will demolish all of the remaining interior systems, structures, components and 537 concrete down to a depth of 3 feet below grade in accordance with the requirements of the Asset 538 Sale Agreement. All construction debris resultant from the demolition of the Fuel Handling 539 Building will be treated as low level radioactive waste and will be shipped to the licensed Energy 540 Solutions radioactive waste disposal facility in Clive, Utah by gondola railcar.

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

548 3.3.6. Waste Water Treatment Facility (WWTF) 549 The Wastewater Treatment Facility (WWTF) was designed to treat non-radioactive and low-550 level radioactive liquid from ZNPS sources including building roof run-off and the Turbine 551 Building Fire Sump, which received liquid waste from the Turbine Building Equipment and 552 Floor Drains, and the Fuel Pool Cooling Tower Blowdown. The WWTF was designed to 553 remove suspended solids and oil to ensure compliance with the facility National Pollutant 554 Discharge Elimination System (NPDES) permit. Since the wastewater discharge rates were 555 variable, an equalization tank was installed. The WWTF also includes other equipment such as 556 mixing tanks, mixers, oil skimmers, flocculators, oil coalescers, clarifiers, sludge drying beds 557 and filters. Discharge from the WWTF was by gravity to the Forebay. To prevent excessive 558 contamination of the WWTF, the Fire Sump discharge was monitored for radioactivity. During 559 ZNPS operations, liquid waste with detectable low-level radioactive contamination was 560 processed by the WWTF. Consequently, the internal surfaces of the WWTF systems are 561 considered as potentially contaminated.

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

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

576

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-14 3.3.7. Miscellaneous Structures 577 3.3.7.1.

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

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

600 3.3.7.2.

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

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

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

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-15 10 CFR 20.1402. As it is difficult to completely isolate the Forebay from Lake Michigan, safety 619 concerns will prevent personnel from physically entering the Forebay to perform this survey.

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

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

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

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

637 3.3.7.3.

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

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

658 3.3.7.4.

Laundry Building, North Security Restricted Area Gatehouse, South Security 659 Restricted Area Access, Restricted Area Fence and Vehicle Barrier System 660

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-16 These structures are located in the Security-Restricted Area and are 661 primarily security structures that will no longer be required once all the 662 spent nuclear fuel is moved to the ISFSI. The structures are a mix of 663 steel frame, slab on grade and reinforced concrete construction. The 664 structural surfaces and materials in each building and area will be 665 demonstrated as meeting the unrestricted releaseunconditional release 666 criteria using the approach presented in MARSAME. Surveys will be 667 performed in accordance with the site procedure for the unconditional release of materials to 668 verify that the material is free of plant-derived radioactive material. Materials released for 669 unconditional use can be recycled or released for disposal at a non-radiological landfill. No 670 recycled materials will remain on site. The structures will then made Cold, Dark and Dry and 671 turned over to a Demolition Contractor as non-radiologically controlled structures for demolition 672 as a contracted work scope. The concrete base slabs and wall foundations will be removed to a 673 depth of 3 feet below grade in accordance with the requirements of the Asset Sale Agreement 674 and all associated buried piping systems associated with these buildings are targeted for 675 complete removal and disposal as waste. All electrical services will be de-energized and 676 removed to a depth of 3 feet below grade. Any void created by the demolition of these structures 677 will be surveyed by the ZionSolutions Characterization/License Termination group and 678 documented as a RA. Upon completion of the RA and acceptance of the survey results, any 679 voids will be backfilled to the original site grade and contours.

680 3.3.7.5.

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

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

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

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-17 construction debris that is not appropriate for reuse as potential backfill material will be 704 packaged and transported to an appropriate landfill for disposal or, to an off-site recycling center 705 following final assessment for the presence of any residual radioactive contamination by passing 706 through a radiological truck monitor.

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

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

719 3.3.7.6.

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

734 3.3.7.7.

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-18 Characterization/License Termination group and documented as a RA. Upon completion of the 745 RA and acceptance of the survey results, any voids will be backfilled to the original site grade 746 and contours.

747 3.3.7.8.

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

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

760 3.4.

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

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

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

781

• No site-specific factors pertaining to the decommissioning of the ZNPS would alter the 782 conclusions presented in NUREG-0586 (see LTP Chapter 8).

783

• Radiation dose to the public will be minimal.

784

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-19

• Decommissioning is not an imminent health or safety concern and will generally have a 785 positive environmental impact.

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

791 3.4.1. Control Mechanisms to Mitigate the Recontamination of Remediated Areas 792 Due to the large scope of remaining structures and systems that will be decontaminated and 793 dismantled, Final Radiation Survey (FRS)FSS of areas may be performed in parallel with 794 decommissioning activities. Consequently, a systematic approach will be employed to ensure 795 that areas are adequately remediated prior to performing FRS FSS and ongoing decommissioning 796 activities do not impact the radiological condition of areas where compliance with the 797 unrestricted release criteria as specified in 10 CFR 20.1402 has been demonstrated. These 798 measures and mechanisms are described in Chapter 5, sections 5.6.3 and 5.12.

799 3.4.2. Occupational Exposure 800 Table 3-2 provides the cumulative site dose and estimates for the decommissioning of ZNPS.

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

809 3.4.3. Exposure to the Public 810 Continued application of ZionSolutions Radiation Protection, Radioactive Waste, Radiological 811 Effluent Technical Specification and Radiological Environmental Monitoring Programs assures 812 public protection in accordance with 10 CFR 20 and 10 CFR 50, Appendix I.

813 3.4.4. Radioactive Waste Projections 814 The Radioactive Waste Management Program is used to control the characterization, generation, 815 processing, handling, shipping, and disposal of radioactive waste during decommissioning.

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

819

• Contaminated water; 820

• Used disposable protective clothing; 821

• Expended abrasive and absorbent materials; 822

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-20

• Expended resins and filters; 823

• Contamination control materials (e.g., strippable coatings, plastic enclosures); and 824

• Contaminated equipment used in the decommissioning process.

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

833 3.5.

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

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

847 3-7 Letter from J.B. Hickman (U.S. Nuclear Regulatory Commission) to J. Christian 848 (ZionSolutions), Issuance of Conforming Amendments Relating to Transfer of Licenses 849 for Zion Nuclear Power Station, Units 1 and 2 - September 2010 850 3-8 Zion Nuclear Power Station, Units 1 and 2 Asset Sale Agreement - December 2007 851 3-9 ZionSolutions Technical Support Document 10-002, Technical Basis for Radiological 852 Limits for Structure/Building Open Air DemolitionU.S. Nuclear Regulatory 853 Commission NUREG-1575, Supplement 1, Multi-Agency Radiation Survey and 854 Assessment of Materials and Equipment Manual (MARSAME) - December 2006 855 3-10 ZionSolutions Technical Support Document 14-016, Description of Embedded Pipe, 856 Penetrations, and Buried Pipe to Remain in Zion End State 857 3-103-11 Exelon Nuclear Radiological Effluent Monitoring and Offsite Dose Calculation 858 Manual (ODCM) - January 2001ZionSolutions Technical Support Document 10-002, 859 Technical Basis for Radiological Limits for Structure/Building Open Air Demolition 860

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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-22 Table 3-1 Status of Major ZNPS Systems, Structures, and 868 Components as of December 2014 869 System or Component Required for SFP Status 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 Demineralizer System (SFPI systems)

Yes In place 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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-23 Table 3-1 (continued) 871 System or Component Required for SFP Status Instrument and Service Air System No Partially removed Gaseous Radioactive Waste System No Partially removed Solid Radioactive Waste System No Partially removed Liquid Radioactive Waste System No Partially removed; New system 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 Containment Building No Some equipment removed.

Decontamination activities are in progress.

Auxiliary Building No Some equipment removed. Interior 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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-24 Table 3-2 Radiation Exposure Projections for Decommissioning and after 873 1/1/2015 874 Fuel Storage Activities 875 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 Processing/Packaging 41 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

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-25 Table 3-3 Projected Waste Quantities 877 WASTE TYPE WASTE CLASS WASTE WEIGHT (lbs)

PACKING DENSITY (lbs/cubic feet)

WASTE VOLUME (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 (containerized)

A 1,450,000 59 24,700 Highly Radioactive B or C 305,000 80 3,800 Very Highly Radioactive

>C 71,600 112 640 Clean Concrete (on-site fill) 345,900,000 71 4,870,000 Clean Asbestos 1,008,000 8.3 121,400 Clean Debris (local landfill) 28,000,000 100 280,000 Clean Scrap Metal (recycler) 44,570,000 129 346,000 Totals 734,159,000 11,721,200 878 879

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 3-26 Table 3-4 General Project Milestones 880 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 Note; Circumstances can change during decommissioning. If ZionSolutions determines that the 881 decommissioning cannot be completed as outlined in this schedule, ZionSolutions will provide an updated 882 schedule to the NRC.

883 884