ML17208A131

Ltp Ch 8 Rev 1 021517 L

ML17208A131
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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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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN CHAPTER 8, REVISION 1 SUPPLEMENT TO THE ENVIRONMENTAL REPORT

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

8. SUPPLEMENT TO THE ENVIRONMENTAL REPORT................................................. 8-1 8.1. Introduction ..................................................................................................... 8-1 8.1.1. Purpose ............................................................................................................ 8-1 8.1.2. Background ..................................................................................................... 8-1 8.2. Site Location and Description ......................................................................... 8-2 8.2.1. Site Description After Unrestricted Release ................................................... 8-2 8.3. Remaining Dismantlement and Decommissioning Activities......................... 8-4 8.4. Impacts to the Post-Shutdown Decommissioning Activities Report (PSDAR).............................................................................................. 8-4 8.5. Zion Station Environment Description............................................................ 8-5 8.5.1. Geography and Demography........................................................................... 8-5 8.5.2. Climate ............................................................................................................ 8-6 8.5.3. Geology and Seismology................................................................................. 8-6 8.5.4. Hydrology and Hydrogeology ......................................................................... 8-7 8.6. Environmental Effects of Decommissioning .................................................. 8-8 8.6.1. Summary ......................................................................................................... 8-8 8.6.2. Radiological Effects of Decommissioning ...................................................... 8-9 8.6.3. Non-radiological Effects of Decommissioning ............................................. 8-12 8.7. Overview of Regulatory Governing Decommissioning Activities and Site Release............................................................................................. 8-22 8.7.1. Federal Requirements .................................................................................... 8-22 8.7.2. State and Local Requirements ....................................................................... 8-23 8.8. Conclusion ..................................................................................................... 8-24 8.9. References ..................................................................................................... 8-24 8-i

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 LIST OF TABLES Table 8-1 Summary of the Environmental Impacts from Decommissioning Nuclear Power Facilities ............................................................................... 8-26 LIST OF FIGURES Figure 8-1 Zion Nuclear Power Station Geographical Location ........................................... 8-29 Figure 8-2 Zion Nuclear Power Station Owner Controlled Area .......................................... 8-30 Figure 8-3 Zion Nuclear Power Station Topographical Map ................................................ 8-31 8-ii

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1 LIST OF ACRONYMS AND ABBREVIATIONS 2 ACS American Community Survey 3 AEC Atomic Energy Commission 4 ALARA As Low As Reasonably Achievable 5 AMSL Above Mean Sea Level 6 BMP Best Management Practices 7 ComEd Commonwealth Edison 8 CCDD Clean Construction Demolition Debris 9 DOE Department of Energy 10 DOT Department of Transportation 11 DSAR Defueled Safety Analysis Report 12 EPA Environmental Protection Agency 13 ES Environmental Statement 14 FSAR Final Safety Analysis Report 15 GEIS Generic Environmental Impact Statement 16 GTCC Greater-Than- Class- C 17 HASP Health and Safety Plan 18 HSA Historical Site Assessment 19 ICMP Illinois Coastal Management Program 20 IDNR Department of Natural Resources 21 IEPA Illinois Environmental Protection Agency 22 IRSF Interim Radioactive Storage Facility 23 ISFSI Independent Spent Fuel Storage Installation 24 LTP License Termination Plan 25 NOI Notice of Intent 26 NPDES National Pollutant Discharge Elimination System 27 NRC Nuclear Regulatory Commission 28 NSSD North Shore Sanitary District 29 ODCM Off-site Dose Calculation Manual 30 OSHA Occupational Health and Safety Administration 31 PCB Polychlorinated Biphenyls 32 PDSAR Post Shutdown Decommissioning Activity Report 33 PWR Pressurized Water Reactors 34 RCRA Resource Conservation and Recovery Act 35 REMP Radiological Environmental Monitoring Program 36 RGPP Radiological Groundwater Protection Program 37 SMC Storm Water Management Commission 8-i

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 38 SWPPP Storm Water Pollution Prevention Plan 39 TEDE Total Effective Dose Equivalent 40 VCC Vertical Concrete Cask 41 WCS Waste Control Specialist 42 WDO Watershed Development Ordinance 43 WWTF Waste Water Treatment Facility 44 ZNPS Zion Nuclear Power Station 45 ZSRP Zion Station Restoration Project 46 8-ii

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 47 8. SUPPLEMENT TO THE ENVIRONMENTAL REPORT 48 8.1. Introduction 49 In accordance with the requirements of 10 CFR 50.82 (a)(9)(ii)(A) and the guidance of 50 Regulatory Guide 1.179, Standard Format and Contents for License Termination Plans for 51 Nuclear Power Reactors (Reference 8-1), this chapter provides a supplement to the 52 environmental report describing any new information or significant environmental change 53 associated with the site-specific decommissioning and site closure activities performed at the 54 Zion Nuclear Power Station (ZNPS) site.

55 8.1.1. Purpose 56 This chapter supplements the Commonwealth Edison Company, Environmental Report - Zion 57 Nuclear Power Station as supplemented (Reference 8-2), describing any new information or 58 significant environmental changes associated with the site-specific decommissioning and license 59 termination activities presented in this License Termination Plan (LTP). The supplement 60 includes a detailed description of the remaining decommissioning and site closure activities, the 61 interaction between those activities and the environment, and the likely environmental impact of 62 those activities. The supplement discusses whether the activities and their impacts are bounded 63 by the impacts predicted by the United States Atomic Energy Commission (AEC) Final 64 Environmental Statement related to operation of Zion Nuclear Power Station Units 1 and 2, -

65 December 1972 (AEC Environmental Statement) (Reference 8-3) issued in December 1972; 66 NUREG-0586, Supplement 1, Volume 1 Generic Environmental Impact Statement on 67 Decommissioning of Nuclear Facilities (Reference 8-4); and the Zion Nuclear Power Station, 68 Post Shutdown Decommissioning Activity Report (PSDAR) (Reference 8-5). This chapter 69 discusses decommissioning activities, with a focus on those activities to be performed from time 70 of submittal of this LTP until the license transfer back to Exelon.

71 8.1.2. Background 72 ZNPS is comprised of two 1,100-Mwe Pressurized Water Reactors (PWR), Units 1 and Unit 2, 73 with supporting facilities, which was owned and operated by Commonwealth Edison Company 74 (now Exelon) from 1973 to 1998.

75 The station was granted a construction permit by the AEC in December 1968 for both Units.

76 Commercial operation was achieved in 1973 for Unit 1 and 1974 for Unit 2. Due to a variety of 77 factors, including economic analysis associated with proposed steam generator replacements, 78 Commonwealth Edison made the decision to shut down ZNPS. Permanent cessation of 79 operations at ZNPS occurred on February 13, 1998. Certification of Permanent Defueled Status 80 for both Units was achieved in March 09, 1998.

81 In accordance with the requirements of 10 CFR 50.82, Commonwealth Edison Company (now 82 Exelon) submitted the initial revision of the PSDAR to the Nuclear Regulatory Commission 83 (NRC) on February 14, 2000. The reactors at ZNPS remained in a SAFSTOR condition until 84 September of 2010. At this point, the license for the facility was transferred from Exelon (the 85 licensee at that time) to ZionSolutions LLC. This was accomplished to allow ZionSolutions to 86 begin the process of the physical decommissioning of the ZNPS. Integral to the license transfer, 8-1

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 87 the PSDAR was amended on March 18, 2008 to address the acceleration of decommissioning 88 activities, changes to the decommissioning schedule and cost milestones. The amended PSDAR 89 established the DECON method as the current decommissioning approach and described the 90 accelerated decommissioning schedule with a lower revised cost estimate to reflect current 91 knowledge and waste disposal options.

92 The environmental impacts of decommissioning operations at ZNPS were previously assessed in 93 both revision of the PSDAR. The assessments included the evaluation of impacts against those 94 noted in the AEC Environment Statement and NUREG-0586. The reference facility in NUREG-95 0586 is a 1,175-MWe PWR owned by Portland General Electric and designed by Westinghouse.

96 As the Zion PWRs are similar in size and also designed by Westinghouse, the two ZNPS units 97 fall within the envelope of the generic environmental assessment.

98 The amended PSDAR concluded that the decommissioning of the ZNPS would be accomplished 99 with no significant adverse environmental impacts and that the environmental impacts associated 100 with the site-specific decommissioning activities for ZNPS would be bounded by previously 101 issued environmental impact statements.

102 8.2. Site Location and Description 103 ZNPS is located in northeastern Illinois on the west shore of Lake Michigan, about 40 miles 104 north of Chicago, Illinois and about 42 miles south of Milwaukee, Wisconsin. The site is located 105 in the eastern portion of the City of Zion in Lake County, Illinois, about 3.2 miles south of the 106 Illinois-Wisconsin State line. See Figure 8-1 for a map showing the site location, including 107 nearby prominent features such as highways, rivers and lakes. The map coordinates for ZNPS 108 are longitude 87 degrees, 48.1 minutes West and latitude 42 degrees, 26.8 minutes North.

109 The site comprises approximately 331 acres which is owned and controlled by ZionSolutions, 110 LLC under a lease agreement with Exelon Generation, Inc. integral to the Zion Nuclear Power 111 Station, Units 1 and 2 Asset Sale Agreement (Reference 8-6). The site is accessed by Shiloh 112 Boulevard which enters the site on the north side. The site is bordered on the west by an 113 industrial area located immediately east of the Chicago and Northwestern railway. The site is 114 bordered on the north by the City of Zion Hosah Park, and further north as well as south by the 115 Illinois State Beach Park along the Lake Michigan shoreline. Figure 8-2 is an aerial view of the 116 local area showing the site boundaries. Figure 8-3 presents a topographic map of the site with 117 contour intervals; the site grade is at 591 feet Above Mean Sea Level (AMSL).

118 8.2.1. Site Description After Unrestricted Release 119 This section provides a summary of the final condition of the site at the conclusion of 120 decommissioning and site closure activities. The End State is defined as the configuration of 121 the remaining below ground buildings, structures, piping and open land areas at the time of 122 license termination.

123 Section 8.5 of Exhibit C, Lease Agreement, titled Removal of Improvements; Site Restoration 124 integral to the Asset Sale Agreement requires the demolition and removal of all on-site buildings, 125 structures, and components to a depth of at least three feet below grade (designated as an 126 elevation of 588 foot AMSL. All systems, components, piping, buildings and structures above 127 588 foot elevation will be removed during decommissioning and disposed of as waste. The 8-2

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 128 demolition debris will be segregated for recycling, reuse, or disposal. The decommissioning 129 approach also calls for the beneficial reuse of concrete from building demolition as clean fill.

130 Only concrete that meets the definition of Clean Construction and Demolition Debris (CCDD) 131 and, where radiological surveys demonstrate that the concrete is free of plant derived 132 radionuclides above background will be considered for use as fill.

133 In both Containment basements (Unit 1 and Unit 2), all concrete will be removed from the inside 134 of the steel liner, leaving only the remaining exposed liner below the 588 foot elevation and the 135 structural concrete outside of the liner. In the Auxiliary and Turbine building basements, all 136 internal walls and floors will be removed, leaving only the reinforced concrete floors and outer 137 walls of the building structures. For the Fuel Handling Building, the only portion of the structure 138 that will remain is the lower 12 feet of the fuel pool below the 588 foot elevation and the 139 concrete structure of the Fuel Transfer Canals after the steel liner has been removed. There are 140 four additional below ground structures that will remain including the lower concrete portions of 141 the Waste Water Treatment Facility (WWTF), Main Steam Tunnels, Circulating Water Inlet 142 Piping and Circulating Water Discharge Tunnels.

143 An evaluation was performed regarding the disposition of the Intake/Discharge structures. The 144 alternative to leave in place was determined to be the least disruptive to the environment and was 145 recommended. The impact of leaving the intake and discharge piping in place is discussed in an 146 AMEC, Inc. report titled Final Environmental Analysis of Alternatives Regarding 147 Intake/Discharge Structure Disposition at the Former Zion Nuclear Generating Station, Zion, 148 Illinois (Reference 8-7).

149 Remaining below grade structures such as basement foundations will be filled with clean 150 concrete debris, soil, sand or other suitable media. The end-state will also include a range of 151 buried, embedded piping and penetrations. All buried piping that is abandoned in place will be 152 capped and/or filled with grout. The restored areas on the site will be back-filled, graded and 153 returned to natural contours. Several structures will remain at license transfer as requested by 154 Exelon. These structures are as follows; 155

• North Access Control Security Gate 156

• Owner Controlled Fence Line 157

• Commonwealth Edison Electrical Switchyard (note: the Switchyard will remain in active use 158 after decommissioning in support of the existing Commonwealth Edison offsite electrical 159 transmission and distribution system) including the microwave tower 160

• Sanitary sewage system Lift Station (note: the Lift Station is required to remain to support 161 the Independent Spent Fuel Storage Installation [ISFSI] Monitoring Building).

162

• Paved roadways and rail lines, including the lines and rail spur constructed in 2011, allowing 163 for rail service at the site via connection to the nearby Union Pacific railway 164 After all demolition and remediation activities are compete, ZionSolutions will use the final 165 survey process described in Chapter 5 of this LTP to demonstrate that the ZNPS and surrounding 166 open land areas, with the exception of the ISFSI facility, comply with radiological criteria for 167 unrestricted use specified in 10 CFR 20.1402. As part of the decommissioning process, all 168 reactor fuel and greater than Class C waste will be loaded into casks and transferred to the ISFSI.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 169 It is expected that the fuel will remain on-site in dry storage within the ISFSI until it is 170 transferred to the Department of Energy (DOE). The ISFSI, which occupies approximately 171 5 acres, has been constructed in the southwest corner of the ZNPS site, immediately south of the 172 Switchyard.

173 Following the conclusion of radiological remediation activities and prior to initiating final 174 survey, isolation and control measures will be implemented. The control measures will be 175 implemented to ensure the final radiological condition is not compromised by the potential for 176 re-contamination as result of access by personnel or equipment. Open land areas, access roads 177 and boundaries will be posted with signs restricting access. Isolation and control measures will 178 be implemented through approved plant procedures and will remain in force throughout final 179 survey activities and until there is no risk of recontamination from decommissioning or the 180 survey area has been released from the license.

181 Several services, such as the City of Zion water and sanitary sewer services and Commonwealth 182 Edison electrical service will remain in operation to support the ISFSI monitoring and security 183 operations. There are no potable wells on site. Water service will be provide through the City of 184 Zion municipal water supply which draws water from Lake Michigan via a water intake about 185 one mile north of the site.

186 8.3. Remaining Dismantlement and Decommissioning Activities 187 Key dismantlement and decommissioning activities that have been completed include: activities 188 associated with the removal of system piping and components; the segmentation and packaging 189 of the internals from both Unit 1 and Unit 2 reactors; the on-going transfer of spent nuclear fuel 190 from the Fuel Handling Building to the ISFSI and the demolition and disposal of several 191 ancillary structures, including the Interim Radioactive Storage Facility (IRSF) and the storage 192 tank farms located east of the Turbine Building.

193 Chapter 3 of this LTP provides details on the dismantlement, demolition and remediation 194 activities currently performed and remaining activities to be executed to achieve the End State 195 condition.

196 8.4. Impacts to the Post-Shutdown Decommissioning Activities Report (PSDAR) 197 The PSDAR, amended in March 2008, described the planned decommissioning operations at the 198 site and concluded that the potential environmental impacts associated with decommissioning the 199 site have already been postulated in, and will be bounded by the previously issued environmental 200 impact statements, specifically:

201

• Final Environmental Statement, 202

• NUREG-0586, 203

• NUREG-1496 Generic Environmental Impact Statement in Support of Rulemaking on 204 Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities 205 (Reference 8-8), dated July 1997.

206 Chapter 3 of this LTP identified the dismantlement and decontamination activities that are 207 scheduled to be completed prior to unrestricted release of the site (excluding the ISFSI footprint) 8-4

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 208 and the transfer of the license back to Exelon. These identified activities are not significantly 209 different than what was proposed in the PSDAR. Although additional details regarding major 210 decommissioning activities will be defined during ongoing decommissioning planning efforts, no 211 significant impacts beyond those identified in the PSDAR have been identified. Subsequent 212 sections in this chapter provide additional evaluation and information regarding the 213 environmental effects of decommissioning.

214 8.5. Zion Station Environment Description 215 8.5.1. Geography and Demography 216 8.5.1.1. Site Location and Description 217 The site location and description were previously discussed in Section 8.2. In addition, the site 218 occupies portions of Sections 22, 23, 26, and 27 in Township 46 North, Range 23 East. The site 219 is located on a narrow strip of lake deposits which borders the Lake Michigan shoreline. A 220 series of low, parallel beach ridges, oriented north-south, separated by marshy depressions, cross 221 the site. The topography at the site ranges from approximately 580 feet to 605 feet AMSL and 222 represents recessional beach lines deposited along the Lake Michigan shoreline subsequent to the 223 most recent period of glaciations. The beach ridges are composed primarily of sand.

224 8.5.1.2. Population 225 The U.S. Census Bureau American Community Survey (ACS) latest 5-year report 226 (Reference 8-9) provides the most reliable census data for the City of Zion, nearby cities, and 227 Lake County. The estimated total population in 2012 was: 24,400 for the City of Zion; 6,752 for 228 Winthrop Harbor, located 3 miles to the north of Zion; 88,982 for Waukegan, located 7 miles 229 south of Zion; and 701,282 for Lake County.

230 8.5.1.3. Site Access, Land, and Water Use 231 The ZNPS property is located in the extreme eastern portion of the City of Zion in Lake County, 232 Illinois on the west shore of Lake Michigan. Although the site encompasses approximately 233 331 acres, it is relatively isolated as the property is bordered to the north and south by Illinois 234 Beach State Park, a small industrial area followed by railroad tracks to the west and Lake 235 Michigan to the east. The center of the community of Zion is approximately 1.6 miles from the 236 plant location on the site. There are no schools or hospitals within one mile of the site and there 237 are no residences within 2,000 feet of any ZNPS structures (Zion Historical Site Assessment 238 (HSA) [Reference 8-10]).

239 The area of Lake Michigan adjacent to ZNPS is used by recreational boaters. The nearest 240 marina/public boat launch is located approximately 2.5 miles north of the site. There are also 241 several fishing charter services in Winthrop Harbor that are located approximately 3 miles north 242 of the site. Lake Michigan is also used for commercial barge and ship traffic, however this 243 traffic does not ordinarily operate within 5 miles of the site.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 244 8.5.2. Climate 245 Zions climate is continental with cold winters, warm summers, and frequent short fluctuations 246 in temperature, humidity, cloudiness, and wind direction. The average temperature in the 247 summer is 72 degrees F and the average temperature in the winter is 24 degrees F. Because the 248 eastern edge of Zion is bounded by Lake Michigan, inland lake breezes can cool the air along the 249 lake shore by 10 to 15 degrees F in the summer and can warm the air by as much as 20 degrees F 250 in the winter (Conestoga-Rovers and Associates, Hydrogeologic Investigation Report, 251 Fleetwide Assessment, Zion Station, Revision 1 [Reference 8-11]).

252 The average annual rainfall is 32.0 inches and the average annual snowfall is 41.0 inches (Illinois 253 Department of Commerce and Economic Opportunity, Zion Illinois, General Information, 254 Climate [Reference 8-12]). Winter storms, with snowfalls exceeding 6 inches, occur about 255 once every 2 years in the northeastern part of Illinois (Illinois State Water Survey (1971-2000) 256 [Reference 8-13]).

257 Wind speeds in the northeastern portion of Illinois, encompassing Zion, typically average 8 to 258 10 mph (Illinois Climate Network, 1991-2000 Data Set [Reference 8-14]). High winds (on the 259 order of 70 mph) can be expected once in 50 years from storms (Commonwealth Edison 260 Company, Zion Station Defueled Safety Analysis Report [DSAR] [Reference 8-15]). The Zion 261 area has rarely experienced tornados. On September 28, 1972, a category F4 tornado 5.8 miles 262 away from the Zion city center injured 20 people and caused between $500,000 and $5,000,000 263 in damages. On April 21, 1967, a category F4 tornado 20.9 miles away from the city center 264 killed one person and injured 100 people and caused between $500,000 and $5,000,000 in 265 damages (City of Zion Illinois Data [Reference 8-16]).

266 8.5.3. Geology and Seismology 267 The near-surface geology of northeastern Illinois is comprised of unconsolidated glacial deposits 268 which range from 90 to 150 feet in thickness. The surface deposits overlay a series of 269 sedimentary rock layers deposited in the Paleozoic Era. The thickness of the Paleozoic 270 sedimentary rocks in northeastern Illinois is approximately 4,000 feet. These sedimentary 271 bedrock layers dip gently toward the east at an incline of approximately 10 feet per mile and 272 overlay on the Precambrian basement rock (Commonwealth Edison Company Zion Nuclear 273 Power Station Final Safety Analysis Report (FSAR) [Reference 8-17]).

274 At ZNPS, in the vicinity of the major buildings, the surface deposits are comprised of three 275 layers, or units, of irregular thickness. In descending order, the following overburden 276 stratigraphic units have been identified and characterized during the various site investigations, 277 ZionSolutions TSD 14-003, Conestoga Rovers & Associates (CRA) Report, Zion 278 Hydrogeologic Investigation Report (Reference 8-18):

279

• Upper sand unit (also known as the Shallow Aquifer): Dense to very dense granular soils 280 which range in gradation from very fine sand to fine to coarse sand, and which contains some 281 gravel and occasional cobbles and boulders (i.e. shallow granular lake deposits). This unit 282 includes both native and fill sand. Depth ranges from the ground surface to an elevation of 283 approximately 555 feet AMSL.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 284

• Upper silty clay unit: Hard silt, silty clay, clayey silt, and sandy silt which contain some sand 285 and gravel and occasional cobbles and boulders. Depth ranges from approximately 525 feet 286 to 555 feet AMSL.

287

• Lower sand unit: Dense to very dense sands and silty sands which contain some gravel, 288 occasional cobbles and boulders, and layers of hard silty clay, clayey silt, and sandy silt.

289 Depth ranges from approximately 480 feet to 525 feet AMSL. This unit is discontinuous.

290 The lower unconsolidated sand unit layer overlies an upper bedrock layer. This upper bedrock 291 layer is the Niagara Dolomite, a consolidated layer of carbonaceous marine sediments laid down 292 in the Silurian Period. It is about 200 feet thick in the vicinity of ZNPS.

293 There is no indication of faulting beneath the site. The area within 100 miles of the site is 294 considered to be one of minor seismic activity. Few events of moderate significance have 295 occurred in the region in the last 150 to 200 years.

296 Information on recent earthquakes near Lake County was obtained from the Illinois State 297 Geological Survey (Reference 8-19). This review indicated a small 2.4-magnitude earthquake on 298 January 30, 2012 at an epicenter of 42.340 latitude and -88.243 longitude, 2 miles east of 299 McHenry and approximately 30 miles west of ZNPS. A previous earthquake of 3.8 magnitude 300 occurred on February 10, 2010; this seismic event was located about 2 miles northwest of Lily 301 Lake in Kane County, southwest of Zion, approximately 70 miles from ZNPS.

302 8.5.4. Hydrology and Hydrogeology 303 Hydrology and hydrogeology information was primarily obtained from two Conestoga Rovers &

304 Associates reports (References 8-11 and 8-18). Groundwater is encountered at a depth less than 305 20 feet below ground surface in the shallow granular lake deposits identified above as the Upper 306 Sand Unit This shallow water-bearing zone is isolated from the underlying regional bedrock 307 aquifers by a significant thickness (~30 to 50 feet) of glacial silts and clays that act as an 308 aquitard.

309 Lake Michigan it the major regional discharge zone for groundwater. The groundwater flow in 310 the region is generally towards the lake. Based on borehole observations and the 311 hydrogeological setting, groundwater flow at ZNPS proceeds predominantly easterly to 312 southeasterly toward Lake Michigan, with a more complex localized flow around deep 313 foundations, utilities and the retaining wall that was installed during construction.

314 The Upper Sand Unit is a high permeability unit that is in hydraulic communication with Lake 315 Michigan, the regional discharge feature, and which generally allows unrestricted lateral 316 groundwater flow, with the exception of the areas around plant structures and the cutoff wall:

317 these deep structures local alters the local flow patterns, however ultimate discharge of 318 groundwater is to the Lake. Vertical groundwater flow is limited by the underlying Silt-Clay 319 Unit which has a low permeability and is approximately 30 feet thick (Dames and Moore 320 Foundation Investigation, Proposed Nuclear Power Plant, Zion, Illinois [Reference 8-20]).

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 321 8.6. Environmental Effects of Decommissioning 322 8.6.1. Summary 323 The evaluation of the environmental effects (or impacts) of the decommissioning of ZNPS 324 follows the approach outlined in NUREG-0586. The methodology is described in NUREG-325 0586, Supplement 1. This approach includes identification of environmental issues as either 326 generic or site-specific. If the issue is considered to be generic, it is assigned a significance level 327 of either Small, Moderate, or Large. If identified as generic, the environmental impact is 328 considered to be bounded by the evaluation in the GEIS which concludes that the impact 329 significance is Small. In this event, site specific evaluation by licensees is generally not 330 required.

331 For those environmental issues or decommissioning activities that require site-specific 332 evaluation, a standard approach is followed. It is summarized as follows:

333 1) The issue or activity is summarized including a summary of the impacts as reported in the 334 original Environmental Statement (ES) and PSDAR. Note that many decommissioning 335 activities are not identified in these documents.

336 2) Applicable regulations, permits, limits or other regulatory requirements are identified.

337 3) Potential impacts from decommissioning activities relating to the environmental issue are 338 described.

339 4) An evaluation is performed. This includes analysis and professional judgment to estimate or 340 determine whether the activity is likely to make a noticeable impact on the environment 341 considering the available information. If an impact is likely, existing and additional 342 mitigation measures that can be taken are evaluated. If an impact cannot be avoided, a 343 determination is made as to whether the impact is likely to seriously damage the resource or 344 attribute.

345 5) A conclusion is reached.

346 A conclusion is derived from the evaluation steps summarized above. The conclusion identifies 347 the level of significance of the impacts. Site-specific issues are not bounded by the GEIS 348 evaluation.

349 Table 8-1 was used as the basis for the site specific environmental impact assessment for ZNPS.

350 It is excerpted from Table 6.1 of NUREG-0586, Supplement 1. The first step in this process is to 351 screen the issues to identify site-specific issues. Decommissioning activities specific to ZNPS 352 are then reviewed and the activities that may require site-specific evaluation are identified. The 353 screening identified the following; 354

• Offsite land use activities: changes in demographics and zoning that have occurred in the past 355 40 years.

356

• Aquatic ecology affected by activities beyond the operational area; changes in designation of 357 sensitive areas (local wetlands and expansion of Illinois State Beach).

358

• Terrestrial Ecology affected by activities beyond the operational area: changes in designation 359 of sensitive areas (local wetlands and expansion of Illinois State Beach).

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 360

• Threatened and endangered species: changes in local flora and fauna and designation of 361 threatened and endangered species that have occurred in the past 40 years.

362

• Environmental Justice: changes in demographics and socioeconomic status in the past 363 40 years.

364

• Cultural and Historic Resource impacts beyond the operational areas: changes in local 365 historic landmark designations and other cultural resources.

366 The following decommissioning activities were identified which required evaluation of impacts 367 across several environmental attributes or issues.

368

• ISFSI construction: land use impacts (onsite).

369

• Vertical Concrete Cask (VCC) construction for the ISFSI: land use impacts (onsite).

370

• Rail line upgrade and extension (onsite and offsite).

371

• Circulating Water inlet and outlet piping disposition: aquatic ecology (within and beyond the 372 operational area).

373

• Placement of clean construction demolition debris (CCDD) and sand mix in major building 374 basements: terrestrial ecology and transportation.

375 8.6.2. Radiological Effects of Decommissioning 376 8.6.2.1. Occupational Radiation Exposure 377 During decommissioning, ZionSolutions has and will continue to implement a Radiation 378 Protection Program in accordance with the license specifications and the requirements of 10 CFR 379 Part 20. The objectives of the Radiation Protection Program are to control radiation hazards, 380 avoid accidental radiation exposures, maintain occupational worker exposures to less than the 381 administrative limit of less than 2,000 mrem/yr Total Effective Dose Equivalent (TEDE) and, to 382 maintain doses to workers and the public As Low As Reasonably Achievable (ALARA).

383 On March 9, 1998, Commonwealth Edison (ComEd), the licensee at the time, placed both units 384 at ZNPS in a SAFSTOR condition (a period of safe storage of the stabilized and defueled 385 facility). The reactors at Zion remained in a SAFSTOR condition until September of 2010, when 386 active decommissioning activities commenced. This period of time allowed for the decay of 387 most short-lived radionuclides which subsequently, reduced radiation levels at the facility. This 388 fact, combined with the effective implementation of the Radiation Protection Program and 389 ALARA measures minimizes the projected and actual occupational radiation dose exposure 390 during the decommissioning of ZNPS. It is anticipated that the most significant contributors to 391 occupational dose from remaining dismantlement activities is the segmenting, packaging and 392 shipping of the reactor vessel internals and the reactor vessel.

393 The GEIS estimates that 1,115 Rem will be needed to decommission a PWR similar in size to the 394 Zion units. Current occupational dose expended and dose expected to complete 395 decommissioning for both units is less than 1,000 Rem. This is well below the GEIS estimate of 396 2,230 Rem for two units.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 397 As the occupational dose for the decommissioning will meet the regulatory standards of 398 10 CFR 20, it is therefore bounded by the criteria in the GEIS and the impact is considered as 399 Small.

400 8.6.2.2. Offsite Radiation Exposure and Monitoring 401 ZionSolutions implements a regulatory compliant Radiological Environmental Monitoring 402 Program (REMP) at ZNPS, which provides annual reports with an accurate assessment of the 403 radiological environment in and around the environs of the site. The REMP program provides 404 assurance that the radioactive gaseous and liquid effluent releases during plant operations do not 405 exceed the concentration limits of 10 CFR 20, the dose limits of 10 CFR 50, Appendix I, or the 406 fuel cycle dose limits of 40 CFR 190. ZionSolutions will continue to adhere to these limits 407 throughout the course of the decommissioning. Consequently, the public dose from 408 decommissioning is bounded by the criteria in the GEIS and the impact is considered as Small.

409 At ZNPS, the Circulating Water Discharge Tunnels are the main authorized effluent release 410 pathway for the discharge of treated and filtered radioactive liquid waste to Lake Michigan.

411 Liquid effluents are monitored and sampled prior to release from onsite storage tanks.

412 The gaseous pathway analysis is subject to the meteorological conditions during the time of the 413 release. Due to plant shutdown and cessation of noble gas and other radionuclide generation, 414 gaseous effluents do not present a significant release or exposure pathway. Routine grab air 415 sampling is performed to determine the dose due to radioactive gaseous releases.

416 The direct radiation exposure is measured continuously with the use of passive monitoring 417 devices. The dose is integrated over three months to accumulate a statistically significant 418 exposure.

419 The design basis for the ISFSI precludes airborne radioactive releases during spent fuel storage 420 and provides adequate shielding to minimize exposure. Radiation monitoring for the ISFSI is 421 performed in accordance with the Radiation Protection Program implemented at ZNPS. In 422 accordance with the worst case scenario in the design basis, the projected doses at the site 423 boundary are substantially below the limits established in 10 CFR 72.106(b) where there is total 424 loss of the confinement barrier. Exposure from the ISFSI to the nearest permanent resident will 425 not exceed 25 mrem/year as specified in 10 CFR 72.104 and 40 CFR Part 190.

426 8.6.2.3. Environmental Effects of Accidents and Decommissioning Events 427 Decommissioning accident analysis is integral to the licensing design basis for ZNPS. While 428 decommissioning radioactively contaminated structures, systems and components at ZNPS, it is 429 necessary to assure the safety of the public in the surrounding area and workers. Worker safety 430 is addressed in the Radiation Protection and Safety programs for the Zion Station Restoration 431 Project (ZSRP) which rely on ALARA principles and the ZionSolutions ZS-SA-01, Zion 432 Restoration Project Health and Safety Plan (HASP) (Reference 8-21). The safety of the public 433 is principally related to potential hazards associated with an airborne release of radioactive 434 materials during decommissioning operations.

435 During decommissioning, ZSRP will perform decontamination and dismantlement of structures, 436 systems, and components in addition to maintenance, waste management, and surveillance. The 8-10

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 437 accidents discussed in NUREG-0586, Supplement 1 associated with immediate dismantling 438 would also be applicable during the decommissioning of ZNPS. However, the potential 439 consequences associated with those accidents would be less at ZNPS due to the reduction of the 440 total radionuclide inventory at ZNPS due to:

441

• Decontamination efforts made before decommissioning, 442

• Prior radioactive waste shipments, and 443

• Radioactive decay.

444 Consequently, the potential decommissioning accidents at ZNPS are bounded by the accident 445 evaluation presented in NUREG-0586, Supplement 1.

446 Operational accidents during decommissioning could result from equipment failure, human error, 447 and service conditions. With the spent nuclear fuel removed from the reactors, operational 448 accidents during decommissioning can be categorized as follows:

449

• Radioactive waste transportation accidents, 450

• Explosions and/or fires associated with explosive and/or combustible materials, 451

• Loss of contamination control, 452

• Natural phenomena, and 453

• Human caused events external to ZNPS.

454 These potential operational accidents during decommissioning are addressed in NUREG-0586, 455 Supplement 1 for immediate dismantlement and consequently, are bounding for the 456 decommissioning of ZNPS.

457 8.6.2.4. Storage and Disposal of Low-level Radioactive Waste 458 The decommissioning of ZNPS has, and will continue to require the disposal of large volumes of 459 low level radioactive waste, including contaminated equipment, tools, clothing and bulk debris 460 materials such as concrete, metal, and asphalt. Materials that cannot be free released are, and 461 will continue to be dispositioned as low-level radioactive waste. Through the proper 462 implementation of the Waste Management Program, Process Control Program and associated 463 procedures, ZionSolutions ensures the appropriate segregation, classification, processing, 464 packaging, shipment and control of solid, liquid and gaseous radioactive wastes.

465 The majority of the Class A low-level radioactive waste from ZNPS will be shipped to the 466 EnergySolutions disposal site in Clive, Utah. The radioactive materials are typically packaged in 467 SuperSacs and then placed into EnergySolutions owned 100 ton, high-capacity SuperGondola 468 railcars for transport on Union Pacific rail lines to the disposal site. Oversized or overweight 469 components, such as the Reactor Vessel Head, are shipped using multiple axle tractor/trailer rigs 470 or special rail cars. Rail and truck shipments are made in accordance with Department of 471 Transportation (DOT) regulations. Class B and C low-level radioactive waste from ZNPS will 472 be shipped to the Waste Control Specialists disposal site in Andrews, Texas.

473 ZionSolutions completed the construction of the ISFSI in August 2013 and started spent nuclear 474 fuel cask loading in December 2013. ZionSolutions anticipates completing the transfer of all its 8-11

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 475 spent nuclear fuel, in sixty-one (61) VCC to the ISFSI by early 2015. The multi-purpose fuel 476 canisters within the casks are seal-welded and leak tight; therefore no leakage is expected during 477 normal operation, off-normal conditions, or design basis accidents. The storage of the fuel at the 478 ISFSI does not generate any gaseous, liquid, or solid radioactive waste. The spent nuclear fuel 479 will remain in storage at the ISFSI under the Part 50 license until the fuel is transferred to a 480 permanent repository. Greater-Than-Class C low-level radioactive waste will be stored in four 481 seal-welded leak tight canisters within storage casks co-located at the ISFSI with the spent fuel.

482 8.6.2.5. Radiological Criteria for License Termination 483 Following the completion of decontamination, dismantlement and remediation activities, 484 radiological surveys will be performed to demonstrate that the dose from any residual 485 radioactivity remaining in as-left structure basements and soils at ZNPS (excluding the ISFSI) to 486 the unrestricted release criteria as specified in 10 CFR 20.1402. Once the balance of the site is 487 remediated and the as-left radiological conditions are demonstrated to be below the unrestricted 488 release criteria, the 10 CFR Part 50 license will be reduced to the area around the ISFSI and the 489 site will be transferred back to Exelon under the 10 CFR Part 50 license. LTP Chapter 5 and 490 Chapter 6 provide the methodology for demonstrating compliance with the unrestricted release 491 criteria.

492 8.6.3. Non-radiological Effects of Decommissioning 493 8.6.3.1. Onsite Land Use 494 The environmental impact associated with onsite land uses have been determined by the NRC, 495 within section 4.3.1 of NUREG-0586, Supplement 1 to be generically considered as a Small 496 impact.

497 The decommissioning project is located and executed within the boundary of the existing ZNPS 498 property previously used for power generation; all work will be conducted in previously 499 developed footprint. Some onsite roads have been refurbished and a reinforced heavy haul path 500 was constructed to support the transfer of VCCs to the ISFSI. No barge slips are being 501 constructed. The rail was originally installed during the construction of the station and was part 502 of the operation of the facility. The onsite rail line was modified and refurbished to support 503 decommissioning activities. Containers will be unloaded and loaded onsite. Onsite land 504 activities such as vehicle parking and equipment/container laydown, storage, staging and waste 505 loading are and continue to occur in a manner similar to when the facility was operational.

506 Several structures such as the Switchyard, the ISFSI, the ISFSI warehouse, the microwave tower, 507 and the Sewage Lift Station, as well as all roadways and rail lines, will remain at license 508 termination as requested by Exelon.

509 Section 8.5 of Exhibit C, Lease Agreement, titled Removal of Improvements; Site Restoration 510 integral to the Asset Sale Agreement requires the demolition and removal of all on-site buildings, 511 structures, and components to a depth of at least three feet below grade. The major structures 512 that will remain at license termination are the basements of the Unit 1 Containment Building, 513 Unit 2 Containment Building, Auxiliary Building, Turbine Building, WWTF, the lower portion 514 of the Spent Fuel Pool, Crib House and Forebay, Unit 1 and Unit 2 Steam Tunnels and the 515 Circulating Water Intake and Discharge Tunnels below the 588 foot elevation. All systems, 8-12

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 516 components as well as all structures above the 588 foot elevation (with the exception of the 517 structures previously noted) will be removed during the decommissioning process and disposed 518 of as a waste stream. In both Containment basements, all concrete will be removed from the 519 interior side of the steel liner, leaving only the remaining exposed liner below the 588 foot 520 elevation and the structural concrete outside of the liner. In the Auxiliary Building, all interior 521 walls and floors will be removed, leaving only the exterior walls and basement floor. In the 522 Turbine Building basement, the remaining structures will consist of reinforced concrete floors 523 and exterior foundation walls and the sub-grade portions of the pedestals below the 588 foot 524 elevation. For the Fuel Handling Building, the only portion of the structure that will remain is 525 the lower 12 feet of the Spent Fuel Pool below 588 foot elevation and the concrete structure of 526 the Fuel Transfer Canals once the steel liner has been removed. Other below ground structures 527 that will remain are the lower concrete portions of the WWTF, Main Steam Tunnels, and 528 Circulating Water Inlet Piping and Discharge Tunnels.

529 The decommissioning approach for ZSRP also calls for the beneficial reuse of concrete from 530 building demolition as clean fill. Uncontaminated concrete that meets the definition of CCDD 531 and where radiological surveys demonstrate that the concrete is free of plant derived 532 radionuclides above background will be used. Demolition debris found to be contaminated or 533 potentially contaminated based on process knowledge will be disposed of as low-level 534 radioactive waste. Consequently, the burial of demolition debris contaminated with residual 535 radioactivity will not have the potential to affect land use and ground or surface water quality.

536 Similarly, painted concrete will only be used if the chemical analysis demonstrates that the 537 chemical constituents are below USEPA and IEPA regulatory criteria.

538 As during the operation of the facility, decommissioning activities have not been conducted in 539 wetlands. The wetlands around the plant have been protected in accordance with environmental 540 regulations and permits.

541 There is no information pertaining to any significant environmental changes associated with the 542 site-specific decommissioning activities. Site closure will comply with applicable USEPA and 543 IEPA regulatory requirements.

544 In accordance with the guidance presented in the GEIS, the potential impacts to land use onsite 545 are considered as Small.

546 8.6.3.2. Offsite Land Use (in the Vicinity) 547 Only areas within the existing site boundary will be used to support decommissioning and 548 license termination activities (such as temporary storage and staging areas). Appropriate 549 isolation and control measures will be instituted to prevent the spread of contamination. These 550 measures will also be monitored to ensure their effectiveness. Thus, no environmental impacts 551 associated with the use of offsite lands are anticipated from the decommissioning activities at 552 ZNPS.

553 Of the 331 acre site, about 87 acres are located within the fence-enclosed Radiologically-554 Restricted Area. The remainder, which lies mostly to the west of the station switchyard, which 555 belongs to ComEd, is an open marshy area. This area is undeveloped except for overhead 556 transmission lines and corridors maintained by ComEd.

8-13

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 557 The land area immediately west of the site, located between the site and the railway is zoned 558 light industrial by the City of Zion (The City of Zion, Illinois, Comprehensive Plan 2010 559 [Reference 8-22]). This area is about five blocks long, extending from 29th Street on the south to 560 Shiloh Boulevard on the north and is about four blocks wide in the east-west direction centered 561 on Deborah Avenue. It is currently occupied by several warehouses and associated truck 562 shipping operations, an industrial cleaning-service company, several auto service garages, a 563 salvage yard, a former manufacturing facility and a number of vacant lots.

564 A significant factor which affects land use in the near vicinity of ZNPS is the Illinois Beach State 565 Park. The Illinois Beach State Park has been expanded since the construction of ZNPS, at which 566 time it only comprised an area located south of the site along the Lake Michigan shoreline. The 567 present day Illinois Beach State Park is comprised of a section north and a section south of 568 ZNPS. The Park is part of a state-owned coastal management area, which extends from 569 Winthrop Harbor (about three miles north of the ZNPS site) to about three miles south of the 570 ZNPS site. The area from Winthrop Harbor Marina on the north to the southern end of the 571 Illinois Beach State Park has been incorporated into the Illinois Coastal Management Program 572 (ICMP). The ICMP has identified this area as a unique public resource requiring special 573 attention for preservation, protection and restoration of areas impacted by shoreline erosion, 574 invasive species and damage caused by previous industrial activities (Illinois Coastal 575 Management Program, Illinois Beach State Park and North Point Marina, Including the Dead 576 River and Kellogg Creek Watersheds, 2011 [Reference 8-23]).

577 The ZNPS site and the surrounding land on all sides are identified as environmentally sensitive 578 in the Zion City planning document. The Lake County Regional Framework Plan identifies the 579 western portion of the ZNPS site and adjacent land, as wetlands and areas with environmental 580 limitations. In the Lake County Plan, this area is also assigned a high priority for open space.

581 This includes the strip of land between the Chicago and Northwestern Railway on the west and 582 the Illinois Beach State Park on the east, bisected by the Deborah Avenue light industrial area 583 and the ZNPS site.

584 Decommissioning activities are not being performed in areas defined as environmentally 585 sensitive within the site boundary, nor in land which adjoins similar offsite land areas, City of 586 Zion industries, or the State beach park areas. Consequently, the offsite land areas are not 587 affected by the decommissioning activities and the potential impacts to land use offsite are 588 considered Small.

589 8.6.3.3. Water Use 590 In accordance with section 4.3.2 of NUREG-0586, Supplement 1, the environmental impact 591 associated with water use has been determined to be generally applicable with a Small impact.

592 ZNPS is located on the shores of Lake Michigan. The lake is 307 miles long from north to south 593 and has an average width of 70 miles. The predominant water usage during the operation of 594 ZNPS was the use of water from Lake Michigan as secondary cooling water for the reactor 595 systems. With the plant shutdown and fuel removed from the reactor, the cooling water system 596 is currently used for the cooling of the Spent Fuel Pool, building environmental systems such as 597 air conditioning and heating, and fire suppression. The use of water from Lake Michigan during 598 decommissioning activities is significantly less than the usage during operations.

8-14

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 599 Water from Lake Michigan is also extensively used for municipal and domestic water supplies.

600 There is multiple potable water intakes located in Lake Michigan in the vicinity of ZNPS. The 601 nearest intake is located about 1 mile north of the ZNPS site and approximately 3,000 feet out 602 into the lake. The City of Zion provides potable water services to support ZNPS. The sewage 603 system is connected to the North Shore Sanitary District (NSSD). Potable water use during 604 decommissioning operations is not expected to be greater than the potable water use experience 605 during operations. Water will continue to be processed in accordance with the site National 606 Pollutant Discharge Elimination System permit (NPDES). Consequently, in accordance with the 607 GEIS, the potential impacts to water use are considered Small.

608 8.6.3.4. Water Quality 609 This section evaluates potential project effects on those portions of the natural environment 610 related to surface water and groundwater. Surface water generally refers to streams, rivers, 611 ponds, reservoirs and lakes. At ZNPS, the nearby bodies of water are Lake Michigan and 612 surface streams near the site, including Kellogg Creek (1.25 miles north), Dead River (3 miles 613 south), and Bull Creek (0.2 mile south) and surrounding wetlands.

614 The environmental impact evaluation associated with surface and groundwater quality in 615 section 4.3.3 of NUREG-0586, Supplement 1 has been determined to be generally applicable to 616 ZNPS with a Small impact.

617 At ZNPS, all non-radiological water discharges to Lake Michigan are controlled under an 618 NPDES permit which is issued by the Illinois Environmental Protection Agency (IEPA).

619 ZionSolutions has filed a Notice of Intent (NOI) with the IEPA, implemented a Storm Water 620 Pollution Prevention Plan (SWPPP) and obtained a Watershed Development Ordinance (WDO) 621 permit from the Lake County Stormwater Management Commission (SMC) for the demolition of 622 the site structures. In addition, impacts to the lake and nearby creeks will be greatly reduced 623 through implementation of appropriate Best Management Practices (BMP) for soil erosion and 624 sedimentation control.

625 Radiological impacts are minimized through adherence to Off-site Dose Calculation Manual 626 (ODCM) limits and assessed through the Radiological Environmental Monitoring Program 627 (REMP) and the Radiological Groundwater Protection Program (RGPP). Potential groundwater 628 impacts are monitored by the routine sampling of eleven (11) permanent onsite RGPP wells at 629 ZNPS.

630 As the water from Lake Michigan is no longer used to cool operating reactor systems at ZNPS, 631 the thermal impact to Lake Michigan has been reduced.

632 No adverse impacts on surface water and groundwater are expected from the implementation of 633 decommissioning activities. Consequently, the potential impacts to surface and groundwater 634 quality are bounded by the GEIS and considered Small.

635 8.6.3.5. Air Quality 636 The environmental impact evaluation associated with air quality in section 4.3.4 of NUREG-637 0586, Supplement 1 has been determined to be generally applicable to ZNPS with a Small 638 impact.

8-15

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 639 ZNPS complies with all applicable Federal and State air quality regulations, including the 640 requirements of the IEPA, Bureau of Air, and will implement BMP to minimize fugitive dust 641 during demolition and decommissioning activities. Air emission sources such as the diesel 642 generators are no longer in service and the auxiliary boiler has been removed. A minor emission 643 source for the above ground storage gasoline tank (1000 gallons) is permitted under the IEPA 644 Registration of Smaller Sources (ROSS) program. This tank will be removed when the 645 decommissioning is complete.

646 Fugitive dust will be generated from various decommissioning activities, including the 647 demolition of concrete building structures and the excavation of soil. Careful planning and 648 controlled demolition and dismantlement techniques, with appropriate assessments by 649 ZionSolutions Radiation Protection, Environment, and Health and Safety staff, will be conducted 650 to ensure excessive and harmful dust emissions are not generated. As necessary, measures such 651 as dust suppression by misting water will be used to mitigate dust emissions.

652 Demolition equipment will be operated and maintained in accordance with manufacturers 653 specifications which will prevent increased exhaust emissions. Appropriate Health and Safety 654 assessments and controls will also be established during expected extended periods of operation 655 to ensure that personnel and the environment are not adversely impacted by excessive exhaust 656 emissions.

657 No adverse impacts on air quality are expected from the implementation of decommissioning 658 activities. Consequently, the potential impacts to air quality are bounded by the GEIS and 659 considered Small.

660 8.6.3.6. Aquatic Ecology 661 The environmental impact evaluation associated with aquatic ecology in section 4.3.5 of 662 NUREG-0586, Supplement 1 has been determined to be generally applicable to ZNPS with a 663 Small impact.

664 The aquatic habitat at ZNPS includes the area from the intake structure integral to the Crib 665 House at the shoreline to the diffuser structure that extends out into Lake Michigan 666 approximately 870 feet from the lakeshore. Habitats associated with this area were previously 667 disturbed during the initial construction of the facility. However, the implementation of 668 decommissioning activities is not expected to disturb existing aquatic habitats, their flora and 669 fauna in the lake and also nearby streams and wetlands.

670 Various fresh water fish species, macro-invertebrate populations, and vegetation exist within 671 these aquatic environments and were identified during a study contracted by ZionSolutions.

672 ZionSolutions contracted an independent environmental analysis to assist with the decision for 673 removing or leaving the Forebay and Circulating Water Discharge Tunnels at ZNPS. This 674 analysis was documented in the previously cited report by AMEC, Inc. pertaining to the 675 Discharge Piping. The report concludes that no action should be taken for the removal of the 676 Forebay and Circulating Water Discharge Tunnels as no action decision resulted in the least 677 impact to the environment, including aquatic ecology considerations.

678 Plans for the demolition of structures at ZNPS do not include the removal of waste or equipment 679 by barge. Consequently, there is no impact to the beach or shoreline from this type of activity.

8-16

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 680 ZionSolutions will continue to maintain its NPDES permit and decommissioning operations will 681 be performed within applicable NPDES limits. Furthermore, protection of the onsite and 682 adjacent wetlands is, and will continue to be a priority when planning any onsite dismantlement 683 or waste management operation. In addition, the SWPPP is implemented with BMPs to prevent 684 impacts to the aquatic systems.

685 Exotic species can threaten native species and ecosystems due to aggressive growth, 686 reproduction or survival rate, and diseases or parasites they may transmit to native species. The 687 decommissioning of ZNPS will not introduce any exotic plants or animals into the environment.

688 The potential impacts to the aquatic ecology within the site boundary are bounded by the GEIS 689 and considered to be Small. The potential impacts to the aquatic ecology beyond the site 690 boundary have also been evaluated and considered to be Small.

691 8.6.3.7. Terrestrial Ecology 692 The environmental impact evaluation associated with terrestrial ecology in section 4.3.6 of 693 NUREG-0586, Supplement 1 has been determined to be generally applicable to ZNPS with a 694 Small impact.

695 Exotic/invasive species are known to occur in only few locations near ZNPS. These 696 exotic/invasive species include common reed (Phragmites australis) and purple loosestrife 697 Lythrum salicaria), both of which are found in the swale and wetland habitats that are located 698 behind the sand dunes along Lake Michigan. ZionSolutions continues to be a partner and 699 support the work of Illinois Department of Natural Resources (IDNR) to remove invasive species 700 (Lime Grass) along the beach. No known exotic or invasive species occur within the 701 decommissioning project area. To minimize the introduction of exotic or invasive species, 702 appropriate BMPs are, and will continue to be followed.

703 The land around ZNPS was initially disturbed by the construction of the facility and no longer 704 resembles the dune formations prevalent in surrounding areas. This alteration results in a less 705 desirable habitat for many species that rely on dune formations for habitat. Given the short-term 706 nature of the work associated with decommissioning, and the fact that the project area is 707 separated from the Illinois Beach State Park, no direct impacts to sensitive species are 708 anticipated. Additionally, upon completion of construction activities, the land is going to be 709 brought to existing grade and stabilized with guidance on native vegetation, therefore 710 minimizing any long-term impacts to sensitive species. In addition, the planned demolition 711 activities do not include the removal of waste or equipment by barge and consequently, there is 712 no anticipated impact to the beach or shoreline.

713 Floodplain management requires that long-term and short-term adverse impacts associated with 714 modification of floodplains be avoided to the extent possible. Diverse wetland habitats, 715 including marsh, fen, panne, sedge meadow, and ponds occur within the ZNPS property.

716 Wetlands have been delineated and permits have been obtained for work activities that are in the 717 vicinity of wetlands and wetland buffer zones. Compliance with these permits and the 718 implementation of BMPs mitigates the potential impact on wetlands from decommissioning 719 activities.

720 The potential impacts to terrestrial ecology are bounded by the GEIS and considered Small.

8-17

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 721 8.6.3.8. Threatened or Endangered Species 722 The only Threatened or Endangered species that has been observed at ZNPS is the 723 Blandings turtle. The Blandings Turtle (Emydoidea, blandingii) is listed as a Threatened 724 species in the state of Illinois. During the decommissioning process, Blandings turtles have 725 been observed, rescued, and protected. Blandings turtle awareness signs have been posted and 726 inspections are performed to ensure that the Blandings turtles are protected in accordance with 727 the IDNR recommendations and the IEPA, NPDES, and SWPPP. During the refurbishment of a 728 rail crossing located north of ZNPS, ZionSolutions worked with local stakeholders and the IDNR 729 to rescue a den of snakes which included several Western Fox snakes. A hibernaculum was 730 established nearby for the relocation of the rescued snakes. The Western Fox snake is not listed 731 as Threatened or Endangered but they are considered an important part of the ecosystem.

732 Other listed species such as the Piping Plover birds and the Massasauga rattlesnake have not 733 been observed on site. No adverse impact to any listed species is anticipated since they are not 734 present in locations expected to be impacted by decommissioning activities. Monitoring and 735 awareness programs have been put in place to for the Blandings turtles and other protected 736 species that may be identified during the decommissioning activities.

737 The potential impacts to Threatened or Endangered species are bounded by the GEIS and 738 considered Small.

739 8.6.3.9. Occupational Issues/Safety 740 The environmental impact evaluation associated with occupational issues in section 4.3.10 of 741 NUREG-0586, Supplement 1 has been determined to be generally applicable to ZNPS with a 742 Small impact. While decommissioning involves increased industrial activities and safety 743 focus, similar programs addressing worker safety were implemented during the operation of the 744 facility and also during repair and refueling outages. The occupational issues and safety impacts 745 assessed are those related to human health and safety, including impacts from physical, chemical, 746 ergonomic, and biological hazards. Radiological impacts, were previously discussed in 747 section 8.6.2.1.

748 ZionSolutions is committed to decommissioning ZNPS safely and has established a HASP to 749 implement a program to effectively control hazards in the work environment and prevent 750 occupational injuries and illnesses. The HASP and ZionSolutions Health and Safety Program 751 complies with federal and state regulations including Illinois Department of Labor and the U.S.

752 Occupational Health and Safety Administration (OSHA) requirements. The HASP applies to all 753 ZionSolutions employees as well as visitors and contract personnel working under direct 754 ZionSolutions supervision.

755 Numerous safety practices and communications are conducted at the site and include, but are not 756 limited to:

757

• Safety is emphasized as the first topic of discussion at meetings.

758

• All workers are provided a Health and Safety booklet.

759

• Worker training and required certifications are reviewed prior to assignment to tasks 760 requiring specific worker qualifications. Certain specialty subcontractors are mobilized, as 8-18

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 761 necessary, such as the asbestos abatement firm contracted for the removal of all asbestos 762 from the Turbine Building.

763

• Safety Data Sheets are obtained and reviewed for chemicals bought onsite.

764

• Health and Safety staff are involved in reviewing and approving decommissioning work 765 packages and participating in pre-job walkdowns, work condition assessments and reviews.

766

• Daily and weekly safety messages are issued as well as Safety Bulletins to communicate 767 awareness of significant safety issues and lessons learned.

768

• Safety stand-downs are held whenever serious safety events occur to communicate and 769 reinforce safety events and lessons learned site-wide.

770 Therefore, occupational issues/safety is evaluated to be bounded by the GEIS and the impact is 771 considered Small.

772 8.6.3.10. Cost 773 A detailed discussion of the site decommissioning project costs is presented in Chapter 7 of this 774 LTP.

775 8.6.3.11. Socioeconomic Impacts 776 ComEds original decision to permanently cease plant operations was not subject to NRC review 777 or approval. On January 14, 1998, the Unicom Corporation and ComEd Boards of Directors 778 authorized the permanent cessation of operations at ZNPS for economic reasons. The economic 779 growth and job opportunities in the Chicago Metropolitan area and the nuclear industry at the 780 time of shutdown in 1998, minimized the effects of unemployment that resulted from the plant 781 shutdown.

782 In September of 2010, decommissioning activities began and a demolition permit was obtained 783 from the City of Zion. Some of the labor requires specialized skills and equipment from out-of-784 state. Overall, the decommissioning activities have a short-term positive economic impact on the 785 local community due to the permit fee, and the impact on the local workforce and opportunities 786 for local business.

787 Therefore, socioeconomic impacts are evaluated to be bounded by the GEIS and the impact is 788 considered Small.

789 8.6.3.12. Environmental Justice 790 While low-income and minority populations are present in the vicinity of the former ZNPS, the 791 percentages of low-income and minorities within the ZNPS census tract are lower than those in 792 other City of Zion census tracts. No impact to the greater population, including special groups, 793 is expected.

794 An existing rail spur was refurbished to transport large components from ZNPS. The refurbished 795 rail spur will be used to transport waste over an existing route. Decommissioning activities will 796 cause increases in truck traffic to and from ZNPS to transport equipment and debris. The truck 797 traffic will use existing main street routes. Since approximately 90% of the waste will be 8-19

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 798 removed by rail, the increase in truck traffic will be temporary. There will be no environmental 799 justice impact relative to rail and truck transportation as a result of decommissioning.

800 There is no reason to believe that low-income and minority populations will be adversely 801 impacted by the decommissioning project. Per the GEIS and this evaluation, the potential site 802 specific impact is considered Small.

803 8.6.3.13. Cultural, Historic, and Archaeological Resources 804 The AEC Environmental Statement included documentation from the State of Illinois, 805 Department of Conservation which stated the following:

806 This letter will certify that the Illinois Department of Conservation has reviewed the land 807 sections to be affected by the Zion Nuclear Power Station and has determined that no 808 archaeological, architectural, or historical resources are evident within the same.

809 ZNPS had an existing rail spur that was refurbished to ship waste and large components off-site.

810 Land disturbance for the removal of large components is minimized since removal is primarily 811 conducted via site rail system.

812 Land that was disturbed for projects beyond the operational areas (within the owner controlled 813 site) was performed in accordance with the IEPA, NPDES permits and the Lake County SMC, 814 Watershed Development Ordinance which included soil erosion controls and stormwater 815 pollution prevention plans. Additional IEPA and SMC permits were obtained during 2014 for 816 the demolition phase that will take place within the Radiologically-Restricted Area. These 817 permits included a review by the Illinois Historic Preservation Agency which identified no 818 historic, architectural or archaeological sites exist on the ZNPS site.

819 Based on the historical information in the AEC Environmental Statement, the results of the 820 reviews of historic, cultural and archaeological resources performed in 2013 and 2014, current 821 transportation methods for large components, and soil erosion control work practices, the 822 decommissioning will have no significant impact on cultural and historic resources.

823 Consequently, as bounded by the GEIS and based upon this evaluation, the potential impacts to 824 Cultural, Historic, and Archaeological Resources are considered Small.

825 8.6.3.14. Aesthetics 826 The environmental impact evaluation associated with aesthetics in section 4.3.15 of NUREG-827 0586, Supplement 1 has been determined to be generally applicable to ZNPS with a Small 828 impact.

829 The impact of decommissioning on site aesthetics (e.g. visual skyline) is limited in terms of land 830 disturbance and duration. These impacts are temporary and will cease when decommissioning is 831 completed.

832 The location of the ISFSI is set back several hundred yards from the lake frontage and located 833 adjacent to the existing switchyard. Once all of the major plant structures and buildings on the 834 lake front are removed, aesthetics will improve by providing a more open view of Lake 835 Michigan. Due to the proximity of the Illinois State Beach Park on the north and south of ZNPS, 8-20

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 836 restoration of the site to a natural grade will result in a contiguous open view of the Lake 837 Michigan shoreline.

838 Aesthetics will improve once the site is returned to open space. The final determination on usage 839 for the lake front property will be made by Exelon upon completion of the decommissioning and 840 transfer of the license back to Exelon.

841 Therefore, the environmental impact associated with aesthetics is evaluated to be bounded by the 842 GEIS and the impact is considered Small.

843 8.6.3.15. Noise 844 The environmental impact evaluation associated with noise in section 4.3.16 of NUREG-0586, 845 Supplement 1 has been determined to be generally applicable to ZNPS with a Small impact.

846 ZNPS is located on the shore of Lake Michigan with the Illinois State Beach Park on the north 847 and south perimeters of the Owner-Controlled Property. There are no residences within 848 2,000 feet of the station structures and no schools or hospitals within one mile. The center of the 849 nearest community, Zion, Illinois is located approximately 1.6 miles to the west of the plant.

850 Noise generation will primarily result from demolition activities involving heavy construction 851 equipment. The noise from the shipment of waste will be minimal since the primary 852 transportation method for shipment of low level radioactive waste will be by rail. Noise 853 associated with decommissioning and shipment of waste is intermittent and temporary and will 854 occur primarily during daylight hours. The ISFSI construction was completed in 2013. The 855 ISFSI is a passive facility and there will be minimal noise generated from its operation. Once the 856 decommissioning is complete, noise levels in the vicinity of the ZNPS site will be reduced to 857 levels below those experienced during the operation of the facility.

858 Due to the distance of the station from sensitive receptors, there will be limited temporary 859 impacts on noise levels during decommissioning and demolition activities. During the 860 decommissioning, ZionSolutions agrees to comply with any noise limitations imposed by the 861 City of Zion.

862 Therefore, the environmental impact associated with noise is evaluated to be bounded by the 863 GEIS and the impact is considered Small.

864 8.6.3.16. Irretrievable Resources 865 The environmental impact evaluation associated with irretrievable resources in section 4.3.18 of 866 NUREG-0586, Supplement 1 has been determined to be generally applicable to ZNPS with a 867 Small impact.

868 During the demolition and structural dismantlement of the station, recycling and asset recovery 869 efforts will be made. Some metals (e.g. from turbine, transformer components, etc.) have been 870 released as clean scrap. Low level radioactive waste has been and will be continue to be shipped 871 to the EnergySolutions disposal site in Clive, Utah. This facility has sufficient space for the 872 disposal of this waste. In addition, any Class B/C waste that is generated will be shipped to the 873 Waste Control Specialist (WCS) facility in Andrews, Texas.

8-21

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 874 As stated in the GEIS, irretrievable resources that would occur during the decommissioning 875 process are the materials used to decontaminate the facility (e.g., rags, solvents, gases, and tools),

876 and fuel used for construction machinery and for transportation of materials to and from the site.

877 These resource commitments are considered to be minor and are neither detectable nor 878 destabilizing.

879 Therefore, the environmental impact associated with irretrievable resources is evaluated to be 880 bounded by the GEIS and the impact is considered Small.

881 8.6.3.17. Traffic and Transportation 882 The environmental impact evaluation associated with transportation issues in section 4.3.17 of 883 NUREG-0586, Supplement 1 has been determined to be generally applicable to ZNPS with a 884 Small impact.

885 The number of shipments and the volume of waste shipped are greater during decommissioning 886 than during the operation of the facility. Non-radiological impacts of transportation include 887 increased traffic and wear and tear on roadways. Because the majority of the waste will be 888 transported by rail, the average number of daily shipments from the site will be relatively small.

889 Consequently, it is anticipated that there will be no significant effect on traffic flow or road wear.

890 The impacts of a transportation accident would be neither detectable nor destabilizing.

891 Therefore, the environmental impact associated with traffic and transportation is evaluated to be 892 bounded by the GEIS and the impact is considered as Small.

893 8.6.3.18. Placement of Clean Construction Demolition Debris (CCDD) and Sand Mix in 894 Major Building Basements: Terrestrial Ecology and Transportation 895 ZionSolutions evaluated the use of CCDD for basement fill end-state and submitted a Request 896 for Concurrence for Basement Fill End-State (ZS-2014-0272) to the Illinois EPA in August of 897 2014. This request included the results of a sampling plan for concrete candidate fill material to 898 be used for the basement fill end-state. On October 3, 2014 ZionSolutions received a Letter of 899 Concurrence from the Illinois EPA (ZS-2014-0349) for the use of CCDD for the basement fill 900 end-state.

901 8.7. Overview of Regulatory Governing Decommissioning Activities and Site Release 902 8.7.1. Federal Requirements 903 Decommissioning activities that are subject to federal regulations include:

904

• Spent fuel storage at the ISFSI.

905

• Handling, packaging, and shipment of radioactive waste.

906

• Worker radiation protection.

907

• License termination and final site release.

908

• Worker health and safety.

909

• Liquid effluent releases.

8-22

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 910

• Hazardous waste generation/disposition.

911

• Handling and removal of asbestos.

912

• Characterization and removal of polychlorinated biphenyls (PCBs).

913

• Handling and removal of lead paint.

914 8.7.1.1. Nuclear Regulatory Commission 915 The majority of radiological activities falls under Title 10 of the Code of Federal Regulation and 916 are administered by the NRC. Applicable Title 10 regulations include:

917

• Part 20 - Radiation protection.

918

• Part 50 - Decommissioning activities.

919

• Part 51 - Environmental protection.

920

• Part 61 - Disposal of radioactive waste.

921

• Part 71 - Packaging and transportation of radioactive waste (regulations in 49 CFR Parts 171 922 through 174 also apply).

923

• Part 72 - Licensing requirements for the independent storage of spent nuclear fuel, high-level 924 radioactive waste, and reactor-related Greater-Than- Class- C (GTCC) waste.

925

• Part 73 - Physical Protection of Plants and Materials.

926 8.7.1.2. U.S. Environmental Protection Agency 927 The Environmental Protection Agency (EPA) regulations outlined in Title 40 of the Code of 928 Federal Regulations apply as follows:

929

• Part 61 - Asbestos Handling and Removal 930

• Parts 122 to 125 -NPDES 931

• Part 141 - Safe Drinking Water Standards 932

• Part 190 - Radiation Protection Standards for Nuclear Power Operations 933

• Parts 260 to 272 - Resource Conservation and Recovery Act (RCRA) 934

• Part 280 - Underground Storage Tanks 935

• Part 761 - Toxic Substance Control Act (TSCA) for Polychlorinated Biphenyls (PCBs) 936

• Part 129-132 - Clean Water Act 937 8.7.2. State and Local Requirements 938 Permits and approvals from or notifications to state and local agencies are required for safety and 939 environmental protection purposes. Decommissioning activities and related site operations that 940 fall under State and local jurisdiction include but are not limited to the following:

941

• Lake County Stormwater Management Commission, Watershed Development Ordinance 8-23

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 942

• Illinois Environmental Protection Agency 943

• Illinois Historic Preservation Agency 944

• Clean Construction or Demolition Debris, Illinois Environmental Protection Act, Section 945 3.160(b) 946

• City of Zion Demolition Permit 947 This information provided above is a general overview of the applicable regulations and not 948 intended to be all-inclusive.

949 8.8. Conclusion 950 As previously evaluated in the Zion PSDAR, the non-radiological environmental impacts from 951 decommissioning ZNPS are temporary and not significant. The potential issues identified as 952 site-specific in NUREG-0586, Supplement 1 (such as Threatened and Endangered species 953 and environmental justice) have been evaluated and there is no significant impact. The potential 954 environmental impacts associated with decommissioning ZNPS have already been predicted in 955 and will be bounded by the previously issued environmental impacts statements (PSDAR, 956 NUREG-0586, and Zion Environmental Statement). Therefore, there are no new or significant 957 environmental change associated with decommissioning.

958 8.9. References 959 8-1 U.S. Nuclear Regulatory Commission Regulatory Guide 1.179, Standard Format and 960 Content of License Termination Plans for Nuclear Power Reactors - January 1999 961 8-2 Commonwealth Edison Company, Environmental Report - Zion Nuclear Power Station 962 - May 1971, Supplement 1 - November 1971, Supplement II - December 1971, 963 Supplement III - February 1972, Supplement IV - April 1972, Supplement V -

964 May 1972 965 8-3 United States Atomic Energy Commission, Directorate of Licensing, Final 966 Environmental Statement related to the Operation of Zion Nuclear Power Station Units 1 967 and 2, Docket Nos. 50-295 and 50-304 - December 1972 968 8-4 U.S. Nuclear Regulatory Commission NUREG-0586, Generic Environmental Impact 969 Statement on Decommissioning of Nuclear Facilities, Supplement 1, Volume 1 -

970 November 2002 971 8-5 Zion Nuclear Power Station, Post Shutdown Decommissioning Activity Report 972 (PSDAR), - March 2008 973 8-6 Zion Nuclear Power Station, Units 1 and 2 Asset Sale Agreement - December 2007 974 8-7 AMEC, Inc., Final Environmental Analysis of Alternatives Regarding Intake/Discharge 975 Structure Disposition at the Former Zion Nuclear Generating Station, Zion, Illinois -

976 October 2013 8-24

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 977 8-8 U.S. Nuclear Regulatory Commission, NUREG-1496, Volume 2, Generic 978 Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for 979 License Termination of NRC-Licensed Nuclear Facilities - July 1997 980 8-9 US Census Bureau, 2008-2012 American Community Survey - 2012 981 8-10 Zion Station Historical Site Assessment (HSA) - September 2006 982 8-11 Conestoga-Rovers and Associates, Hydrogeologic Investigation Report, Fleetwide 983 Assessment, Zion Station, Zion Illinois, Revision 1 - September 2006.

984 8-12 Illinois Department of Commerce and Economic Opportunity, Zion Illinois, General 985 Information, Climate - September 2012 986 8-13 Illinois State Water Survey 1971 - 2000 987 8-14 Illinois Climate Network, 1991 - 2000 Data Set 988 8-15 Zion Station, Defueled Safety Analysis Report (DSAR) - September 2014 989 8-16 City of Zion www.city-data.com/city/Zion-Illinois 990 8-17 Commonwealth Edison Company, Zion Nuclear Power Station - Final Safety Analysis 991 Report (FSAR) - November 1970 992 8-18 ZionSolutions Technical Support Document 14-003, Conestoga Rovers & Associates 993 (CRA) Report, Zion Hydrogeologic Investigation Report 994 8-19 Illinois State Geological Survey www.isgs.illnois.edu 995 8-20 Dames and Moore, Foundation Investigation, Proposed Nuclear Power Plant, Zion, 996 Illinois - October 1967 997 8-21 ZionSolutions ZS-SA-01, Zion Restoration Project Health and Safety Plan (HASP) 998 8-22 The City of Zion, Illinois, Comprehensive Plan 2010 - January 1992 999 8-23 Illinois Coastal Management Program, Illinois Beach State Park and North Point Marina 1000 Including the Dead River and Kellogg Creek Watersheds - 2011 1001 8-25

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1002 Table 8-1 Summary of the Environmental Impacts from Decommissioning Nuclear 1003 Power Facilities Impact Section Environmental Issue GEIS Significance 8.6.2 Radiological Activities resulting in occupational dose to Yes Small workers Activities resulting in dose to the public Yes Small Radiological Accidents Yes Small 8.6.3.1 Onsite land use activities Yes Small 8.6.3.2 Offsite land use activities No Site-specific 8.6.3.3 Water Use Yes Small 8.6.3.4 Water Quality Surface water Yes Small Ground water Yes Small 8.6.3.5 Air Quality Yes Small 8.6.3.6 Aquatic Ecology Activities within the operational area Yes Small Activities beyond the operational area No Site-specific 8.6.3.7 Terrestrial Ecology Activities within the operational area Yes Small Activities beyond the operational area No Site-specific 8.6.3.8 Threatened and Endangered Species No Site-specific 8.6.3.9 Occupational Issues Yes Small 8.6.3.11 Socioeconomic Yes Small 8-26

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1004 Table 8-1 Summary of the Environmental Impacts from Decommissioning Nuclear 1005 Power Facilities (continued)

Impact Section Environmental Issue GEIS Significance 8.6.3.12 Environmental Justice No Site-specific 8.6.3.13 Cultural and Historic Resource Impacts Activities within the operational area Yes Small Activities beyond the operational area No Site-specific 8.6.3.14 Aesthetics Yes Small 8.6.3.15 Noise Yes Small 8.6.3.17 Transportation Yes Small 8.6.3.16 Irretrievable Resources Yes Small 8.6.3.17 Traffic and Transportation Yes Small 8.6.3.18 Placement of clean construction demolition No No Site-specific debris (CCDD) and sand mix in major Site-specific building basements: terrestrial ecology and transportation.ISFSI construction: land use impacts (onsite) 8.6.3.19 VCC construction for the ISFSI: land use No Site-specific impacts (onsite) 8.6.3.20 Rail line upgrade and extension (onsite and No Site-specific offsite) 8.6.3.21 Circulating Water inlet and outlet piping No Site-specific disposition: aquatic ecology (within and beyond the operational area) 8.6.3.22 Placement of clean construction demolition No Site-specific debris (CCDD) and sand mix in major building basements: terrestrial ecology and transportation.

1006 Note: Cost, section 4.3.11 in GEIS Supplement 1, is not evaluated using environmental significance levels and is 1007 not identified as a generic or site-specific issue.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1008 1009 8-28

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1010 Figure 8-1 Zion Nuclear Power Station Geographical Location 1011 8-29

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1012 Figure 8-2 Zion Nuclear Power Station Owner Controlled Area 1013 8-30

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1014 Figure 8-3 Zion Nuclear Power Station Topographical Map 1015 8-31