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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 8-i TABLE OF CONTENTS

8. SUPPLEMENT TO THE ENVIRONMENTAL REPORT

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8-1 8.1. Introduction

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..... 8-1 8.1.1. Purpose ................................

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8-1 8.1.2. Background

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..... 8-1 8.2. Site Location and Description

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......... 8-2 8.2.1. Site Description After Unrestricted Release

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8-2 8.3. Remaining Dismantlement and Decommissioning Activities

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8-4 8.4. Impacts to the Post

-Shutdown Decommissioning Activities Report (PSDAR)

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8-4 8.5. Zion Station Environment Description

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8-5 8.5.1. Geography and Demography

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8-5 8.5.2. Climate ................................

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8-6 8.5.3. Geology and Seismology

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8-6 8.5.4. Hydrology and Hydrogeology

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......... 8-7 8.6. Environmental Effects of Decommissioning

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8-8 8.6.1. Summary ................................

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......... 8-8 8.6.2. Radiological Effects of Decommissioning

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8-9 8.6.3. Non-radiological Effects of Decommissioning

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8-12 8.7. Overview of Regulatory Governing Decommissioning Activities and Site Release

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8-22 8.7.1. Federal Requirements

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8-22 8.7.2. State and Local Requirements

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....... 8-23 8.8. Conclusion

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..... 8-24 8.9. References

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..... 8-24 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-ii LIST OF TABLES Table 8-1 Summary of the Environmental Impacts from Decommissioning Nuclear Power Facilities

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8-26 LIST OF FIGURES Figure 8-1 Zion Nuclear Power Station Geographical Location

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8-29 Figure 8-2 Zion Nuclear Power Station Owner Controlled Area

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8-30 Figure 8-3 Zion Nuclear Power Station Topographical Map

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8-31

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-i LIST OF ACRONYMS AND ABBREVIATIONS 1 ACS American Community Survey 2 AEC Atomic Energy Commission 3 ALARA As Low As Reasonably Achievable 4 AMSL Above Mean Sea Level 5 BMP Best Management Practices 6 ComEd Commonwealth Edison 7 CCDD Clean Construction Demolition Debris 8 DOE Department of Energy 9 DOT Department of Transportation 10 DSAR Defueled Safety Analysis Report 11 EPA Environmental Protection Agency 12 ES Environmental Statement 13 FSAR Final Safety Analysis Report 14 GEIS Generic Environmental Impact Statement 15 GTCC Greater-Than- Class- C 16 HASP Health and Safety Plan 17 H SA Historical Site Assessment 18 ICMP Illinois Coastal Management Program 19 IDNR Department of Natural Resources 20 IEPA Illinois Environmental Protection Agency 21 IRSF Interim Radioactive Storage Facility 22 ISFSI Independent Spent Fuel Storage Installation 23 LTP License Termination Plan 24 NOI Notice of Intent 25 NPDES National Pollutant Discharge Elimination System 26 NRC Nuclear Regulatory Commission 27 NSSD North Shore Sanitary District 28 ODCM Off-site Dose Calculation Manual 29 OSHA Occupational Health and Safety Administration 30 PCB Polychlorinated Biphenyls 31 PDSAR Post Shutdown Decommissioning Activity Report 32 PWR Pressurized Water Reactors 33 RCRA Resource Conservation and Recovery Act 34 REMP Radiological Environmental Monitoring Program 35 RGPP Radiological Groundwater Protection Program 36 SMC Storm Water Management Commission 37 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-ii SWPPP Storm Water Pollution Prevention Plan 38 TEDE Total Effective Dose Equivalent 39 VCC Vertical Concrete Cask 40 WCS Waste Control Specialist 41 WDO Watershed Development Ordinance 42 WWTF Waste Water Treatment Facility 43 ZNPS Zion Nuclear Power Station 44 ZSRP Zion Station Restoration Project 45 46 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-1 8. SUPPLEMENT TO THE ENVIRONMENTAL REPORT 47 8.1. Introduction 48 In accordance with the requirements of 10 CFR 50.82 (a)(9)(ii)(A) and the guidance of 49 Regulatory Guide 1.179, "Standard Format and Contents for License Termination Plans for 50 Nuclear Power Reactors" (Reference 8-1), this chapter provides a supplement to the 51 environmental report describing any new information or significant environmental change 52 associated with the site

-specific decommissioning and site closure activities performed at the 53 Zion Nuclear Power Station (ZNPS) site.

54 8.1.1. Purpose 55 This chapter supplements the Commonwealth Edison Company, "Environmental Report

- Zion 56 Nuclear Power Station" as supplemented (Reference 8-2), describing any new information or 57 significant environmental changes associated with the site

-specific decommissioning and license 58 termination activities presented in this License Termination Plan (LTP). The supplement 59 includes a detailed description of the remaining decommissioning and site closure activities, the 60 interaction between those activities and the environment, and the likely environmental impact of 61 those activities. The supplement discusses whether the activities and their impacts are bounded 62 by the impacts predicted by the United States Atomic Energy Commission (AEC) "Final 63 Environmental Statement related to operation of Zion Nuclear Power Station Units 1 and 2", - 64 December 1972 (AEC Environmental Statement) (Reference 8-3) issued in December 1972; 65 NUREG-0586, Supplement 1, Volume 1 "Generic Environmental Impact Statement on 66 Decommissioning of Nuclear Facilities

" (Reference 8-4); and the Zion Nuclear Power Station, 67 "Post Shutdown Decommissioning Activity Report

" (PSDAR) (Reference 8-5). This chapter 68 discusses decommissioning activities, with a focus on those activities to be performed from time 69 of submittal of this LTP until the license transfer back to Exelon.

70 8.1.2. Background 71 ZNPS is comprised of two 1,100

-Mwe Pressurized Water Reactors (PWR), Units 1 and Unit 2, 72 with supporting facilities, which was owned and operated by Commonwealth Edison Company 73 (now Exelon) from 1973 to 1998.

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

75 Commercial operation was achieved in 1973 for Unit 1 and 1974 for Unit

2. Due to a variety of 76 factors, including economic analysis associated with proposed steam generator replacements, 77 Commonwealth Edison made the decision to shut down ZNPS. Permanent cessation of 78 operations at ZNPS occurred on February 13, 1998. Certification of Permanent Defueled Status 79 for both Units was achieved in March 09, 1998. 80 In accordance with the requirements of 10 CFR 50.82, Commonwealth Edison Company (now 81 Exelon) submitted the initial revision of the PSDAR to th e Nuclear Regulatory Commission 82 (NRC) on February 14, 2000. The reactors at ZNPS remained in a SAFSTOR condition until 83 September of 2010. At this point, the license for the facility was transferred from Exelon (the 84 licensee at that time) to ZionSolutions LLC. This was accomplished to allow ZionSolutions to 85 begin the process of the physical decommissioning of the ZNPS. Integral to the license transfer, 86 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-2 the PSDAR was amended on March 18, 2008 to address the acceleration of decommissioning 87 activities, changes to the decommissioning schedule and cost milestones.

The amended PSDAR 88 established the DECON method as the current decommissioning approach and described the 89 accelerated decommissioning schedule with a lower revised cost estimate to reflect current 90 knowledge and waste disposal options.

91 The environmental impacts of decommissioning operations at ZNPS were previously assessed in 92 both revision of the PSDAR. The assessments included the evaluation of impacts against those 93 noted in the AEC Environment Statement and NUREG-0586. The reference facility in NUREG

-94 0586 is a 1,175

-MWe PWR owned by Portland General Electric and designed by Westinghouse.

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

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

101 8.2. Site Location and Description 102 ZNPS is located in northeastern Illinois on the west shore of Lake Michigan, about 40 miles 103 north of Chicago, Illinois and about 42 miles south of Milwaukee, Wisconsin.

The site is located 104 in the eastern portion of the City of Zion in Lake County, Illinois, about 3.2 miles south of the 105 Illinois-Wisconsin State line.

See Figure 8-1 for a map showing the site location, including 106 nearby prominent features such as highways, rivers and lakes. The map coordinates for ZNPS 107 are longitude 87 degrees, 48.1 minutes West and latitude 42 degrees, 26.8 minutes North.

108 The site comprises approximately 331 acres which is owned and controlled by ZionSolutions , 109 LLC under a lease agreement with Exelon Generation, Inc.

integral to the "Zion Nuclear Power 110 Station, Units 1 and 2 Asset Sale Agreement" (Reference 8-6). The site is accessed by Shiloh 111 Boulevard which enters the site on the north side.

The site is bordered on the west by an 112 industrial area located immediately east of the Chicago and Northwestern railway.

The site is 113 bordered on the north by the City of Zion Hosah Park, and further north as well as south by the 114 Illinois State Beach Park along the Lake Michigan shoreline. Figure 8-2 is an aerial view of the 115 local area showing the site boundaries.

Figure 8-3 presents a topographic map of the site with 116 contour intervals; the site grade is at 591 feet Above Mean Sea Level (AMSL)

. 117 8.2.1. Site Description After Unrestricted Release 118 This section provides a summary of the final condition of the site at the conclusion of 119 decommissioning and site closure activities. The "End State" is defined as the configuration of 120 the remaining below ground buildings, structures, piping and open land areas at the time of 121 license termination.

122 Section 8.5 of Exhibit C, Lease Agreement, titled "Removal of Improvements; Site Restoration" 123 integral to the Asset Sale Agreement requires the demolition and removal of all on

-site buildings, 124 structures, and components to a depth of at least three feet below grade (designated as an 125 elevation of 588 foot AMSL. All systems, components, piping, buildings and structures above 126 588 foot elevation will be removed during decommissioning and disposed of as waste. The 127 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-3 demolition debris will be segregated for recycling, reuse, or disposal. The decommissioning 128 approach also calls for the beneficial reuse of concrete from building demolition as clean fill.

129 Only concrete that meets the definition of Clean Construction and Demolition Debris (CCDD) 130 a nd, where radiological surveys demonstrate that the concrete is free of plant derived 131 radionuclides above background will be considered for use as fill. 132 In both Containment basements (Unit 1 and Unit 2), all concrete will be removed from the inside 133 of the steel liner, leaving only the remaining exposed liner below the 588 foot elevation and the 134 structural concrete outside of the liner. In the Auxiliary and Turbine building basements, all 135 internal walls and floors will be removed, leaving only the reinforced concrete floors and outer 136 walls of the building structures. For the Fuel Handling Building, the only portion of the structure 137 that will remain is the lower 12 feet of the fuel pool below the 588 foot elevation and the 138 concrete structure of the Fuel Transfer Canals after the steel liner has been removed. There are 139 four additional below ground structures that will remain including the lower concrete portions of 140 the Waste Water Treatment Facility (WWTF), Main Steam Tunnels, Circulating Water Inlet 141 Piping and Circulating Water Discharge Tunnels. 142 An evaluation was performed regarding the disposition of the Intake/Discharge structures. The 143 alternative to leave in place was determined to be the least disruptive to the environment and was 144 recommended. The impact of leaving the intake and discharge piping in place is discussed in an 145 AMEC, Inc. report titled "Final Environmental Analysis of Alternatives Regarding 146 Intake/Discharge Structure Disposition at the Former Zion Nuclear Generating Station, Zion, 147 Illinois" (Reference 8-7). 148 Remaining below grade structures such as basement foundations will be filled with clea n 149 concrete debris, soil, sand or other suitable media. The e nd-state will also include a range of 150 buried, embedded piping and penetrations. All buried piping that is abandoned in place will be 151 capped and/or filled with grout. The restored areas on the site will be back

-filled, graded and 152 returned to natural contours. Several structures will remain at license transfer as requested by 153 Exelon. These structures are as follows; 154 North Access Control Security Gate 155 Owner Controlled Fence Line 156 Commonwealth Edi son Electrical Switchyard (note: the Switchyard will remain in active use 157 after decommissioning in support of the existing Commonwealth Edison offsite electrical 158 transmission and distribution system) including the microwave tower 159 Sanitary sewage system Lift Station (note: the Lift Station is required to remain to support 160 the Independent Spent Fuel Storage Installation

[ISFSI] Monitoring Building

). 161 Paved roadways and rail lines, including the lines and rail spur constructed in 2011, allowing 162 for rail service at the site via connection to the nearby Union Pacific railway 163 After all demolition and remediation activities are compete, ZionSolutions will use the final 164 survey process described in Chapter 5 of this LTP to demonstrate that the ZNPS and surrounding 165 open land areas, with the exception of the ISFSI facility, comply with radiological criteria for 166 unrestricted use specified in 10 CFR 20.1402. As part of the decommissioning process, all 167 reactor fuel and greater than Class C waste will be loaded into casks and transferred to the ISFSI.

168 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-4 It is expected that the fuel will remain on

-site in dry storage within the ISFSI until it is 169 transferred to the Department of Energy (DOE). The ISFSI, which occupies approximately 170 5 acres, has been constructed in the southwest corner of the ZNPS site, immediately south of the 171 Switchyard.

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

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

185 8.3. Remaining Dismantlement and Decommissioning Activities 186 Key dismantlement and decommissioning activities that have been completed include

activities 187 associated with the removal of system piping and components

the segmentation and packaging 188 of the internals from both Unit 1 and Unit 2 reactors

the on-going transfer of spent nuclear fuel 189 from the Fuel Handling Building to the ISFSI and the demolition and disposal of several 190 ancillary structures, including the Interim Radioactive Storage Facility (IRSF) and the storage 191 tank farms located east of the Turbine Building. 192 Chapter 3 of this LTP provides details on the dismantlement, demolition and remediation 193 activities currently performed and remaining activities to be executed to achieve the End State 194 condition.

195 8.4. Impacts to the Post

-Shutdown Decommissioning Activities Report (PSDAR) 196 The PSDAR , amended in March 2008 , described the planned decommissioning operations at the 197 site and concluded that the potential environmental impacts associated with decommissioning the 198 site have already been postulated in

, and will be bounded by the previously issued environmental 199 impact statements, specifically:

200 Final Environmental Statement

, 201 NUREG-0586, 202 NUREG-1496 "Generic Environmental Impact Statement in Support of Rulemaking on 203 Radiological Criteria for License Termination of NRC

-Licensed Nuclear Facilities

" 204 (Reference 8-8), dated July 1997.

205 Chapter 3 of this LTP identified the dismantlement and decontamination activities that are 206 scheduled to be completed prior to unrestricted release of the site (excluding the ISFSI footprint) 207 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-5 and the transfer of the license back to Exelon. These identified activities are not significantly 208 different than what was proposed in the PSDAR. Although additional details regarding major 209 decommissioning activities will be defined during ongoing decommissioning planning efforts, no 210 significant impacts beyond those identified in the PSDAR have been identified. Subsequent 211 sections in this chapter provide additional evaluation and information regarding the 212 environmental effects of decommissioning.

213 8.5. Zion Station Environment Description 214 8.5.1. Geography and Demography 215 8.5.1.1. Site Location and Description 216 The site location and description were previously discussed in Section 8.2. In addition, the site 217 occupies portions of Sections 22, 23, 26, and 27 in Township 46 North, Range 23 East. The site 218 is located on a narrow strip of lake deposits which borders the Lake Michigan shoreline. A 219 series of low, parallel beach ridges, oriented north

-south, separated by marshy depressions

, cross 220 the site. The topography at the site ranges from approximately 580 feet to 605 feet AMSL and 221 represents recessional beach lines deposited along the Lake Michigan shoreline subsequent to the 222 most recent period of glaciations. The beach ridges are composed primarily of sand.

223 8.5.1.2. Population 224 The U.S. Census Bureau American Community Survey (ACS) latest 5-year report 225 (Reference 8-9) provide s the most reliable census data for the City of Zion, nearby cities, and 226 Lake County. The estimated total population in 2012 was: 24,400 for the City of Zion; 6,752 for 227 Winthrop Harbor, located 3 miles to the north of Zion; 88,982 for Waukegan, located 7 miles 228 south of Zion; and 701,282 for Lake County

. 229 8.5.1.3. Site Access, Land, and Water Use 230 The ZN PS property is located in the extreme eastern portion of the City of Zion in Lake County, 231 Illinois on the west shore of Lake Michigan. Although the site encompasses approximately 232 331 acres, it is relatively isolated as the property is bordered to the north and south by Illinois 233 Beach State Park, a small industrial area followed by railroad tracks to the west and Lake 234 Michigan to the east.

The center of the community of Zion is approximately 1.6 miles from the 235 plant location on the site. There are no schools or hospitals within one mile of the site and there 236 are no residences within 2,000 feet of any ZNPS structures (Zion "Historical Site Assessment" 237 (HSA) [Reference 8-10]). 238 The area o f Lake Michigan adjacent to ZNPS is used by recreational boaters.

The nearest 239 marina/public boat launch is located approximately 2.5 miles north of the site. There are also 240 several fishing charter services in Winthrop Harbor that are located approximatel y 3 miles north 241 of the site. Lake Michigan is also used for commercial barge and ship traffic, however this 242 traffic does not ordinarily operate within 5 miles of the site. 243 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-6 8.5.2. Climate 244 Zion's climate is continental with cold winters, warm summers, and frequent short fluctuations 245 in temperature, humidity, cloudiness, and wind direction. The average temperature in the 246 summer is 72 degrees F and the average temperature in the winter is 24 degrees F. Because the 247 eastern edge of Zion is bounded by Lake Michigan, inland lake breezes can cool the air along the 248 lake shore by 10 to 15 degrees F in the summer and can warm the air by as much as 20 degrees F 249 in the winter (Conestoga-Rovers and Associates, "Hydrogeologic Investigation Report, 250 Fleetwide Assessment, Zion Station", Revision 1

[Reference 8-11]). 251 The average annual rainfall is 32.0 inches and the average annual snowfall is 41.0 inches (Illinois 252 Department of Commerce and Economic Opportunity, "Zion Illinois, General Information, 253 Climate" [Reference 8-12]). Winter storms, with snowfalls exceeding 6 inches, occur about 254 once every 2 years in the northeastern part of Illinois

("Illinois State Water Survey (1971

-2000)" 255 [Reference 8-13]). 256 Wind speeds in the northeastern portion of Illinois, encompassing Zion, typically average 8 to 257 10 mph ("Illinois Climate Network, 1991

-2000 Data Set"

[Reference 8-14]). High winds (on the 258 order of 70 mph) can be expected once in 50 years from storms (Commonwealth Edison 259 Company, "Zion Station Defueled Safety Analysis Report

" [DSAR] [Reference 8-15]). The Zion 260 area has rarely experienced tornados. On September 28, 1972, a category F4 tornado 5.8 miles 261 away from the Zion city center injured 20 people and caused between $500,000 and $5,000,000 262 in damages

. On April 21, 1967, a category F4 tornado 20.9 miles away from the city center 263 killed one person and injured 100 people and caused between $500,000 and $5,000,000 in 264 damages ("City of Zion Illinois Data"

[Reference 8-16]). 265 8.5.3. Geology and Seismology 266 The near-surface geology of northeastern Illinois is comprised of unconsolidated glacial deposits 267 which range from 90 to 150 feet in thickness.

The surface deposits overlay a series of 268 sedimentary rock layers deposited in the Paleozoic Era.

The thickness of the Paleozoic 269 sedimentary rocks in northeastern Illinois is approximately 4,000 feet. These sedimentary 270 bedrock layers dip gently toward the east at an incline of approximately 10 feet per mile and 271 overlay on the Precambrian basement rock (Commonwealth Edison Company "Zion Nuclear 272 Power Station Final Safety Analysis Report" (FSAR) [Reference 8-17]). 273 At ZNPS , in the vicinity of the major buildings, the surface deposits are comprised of three 274 layers, or units, of irregular thickness.

In descending order, the following overburden 275 stratigraphic units have been identified and characterized during the various site investigations

, 276 ZionSolutions TSD 14-003, Conestoga Rovers & Associates (CRA)

Report, "Zion 277 Hydrogeologic Investigation Report

" (Reference 8-18): 278 Upper sand unit (also known as the Shallow Aquifer):

Dense to very dense granular soils 279 which range in gradation from very fine sand to fine to coarse sand, and which contains some 280 gravel and occasional cobbles and boulders (i.e. shallow granular lake deposits). This unit 281 includes both native and fill sand. Depth ranges from the ground surface to an elevation of 282 approximately 555 feet AMSL. 283 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-7 Upper silty clay unit:

Hard silt, silty clay, clayey silt, and sandy silt which contain some sand 284 and gravel and occasional cobbles and boulders. Depth ranges from approximately 525 feet 285 to 555 feet AMSL. 286 Lower sand unit:

Dense to very dense sands and silty sands which contain some gravel, 287 occasional cobbles and boulders, and layers of hard silty clay, clayey silt, and sandy silt.

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

289 The lower unconsolidated sand unit layer overlies an upper bedrock layer. This upper bedrock 290 layer is the Niagara Dolomite, a consolidated layer of carbonaceous marine sediments laid down 291 in the Silurian Period.

It is about 2 00 feet thick in the vicinity of ZN P S. 292 There is no indication of faulting beneath the site. The area within 100 miles of the site is 293 considered to be one of minor seismic activity. Few events of moderate significance have 294 occurred in the region in the last 150 to 200 years. 295 Information on recent earthquakes near Lake County was obtained from the Illinois State 296 Geological Survey (Reference 8-19). This review indicated a small 2.4

-magnitude earthquake on 297 January 30, 2012 at an epicenter of 42.340 latitude and

-88.243 longitude, 2 miles east of 298 McHenry and approximately 30 miles west of ZNPS. A previous earthquake of 3.8 magnitude 299 occurred on Februa ry 10, 2010; this seismic event was located about 2 miles northwest of Lily 300 Lake in Kane County, southwest of Zion, approximately 70 miles from ZNPS. 301 8.5.4. Hydrology and Hydrogeology 302 Hydrology and hydrogeology information was primarily obtained from two Conestoga Rovers &

303 Associates reports (References 8-11 and 8-18). Groundwater is encount ered at a depth less than 304 20 feet below ground surface in the shallow granular lake deposits identified above as the Upper 305 Sand Unit Th is shallow water-bearing zone is isolated from the underlying regional bedrock 306 aquifers by a significant thickness

(~30 to 50 feet) of glacial silts and clays that act as an 307 aquitard. 308 Lake Michigan it the major regional discharge zone for groundwater. The groundwater flow in 309 the region is generally towards the lake. Based on borehole observations and the 310 hydrogeological setting, groundwater flow at ZN PS proceeds predominantly easterly to 311 southeasterly toward Lake Michigan, with a more complex localized flow around deep 312 foundations, utilities and the retaining wall that was installed during construction.

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

316 these deep structu res local alters the local flow patter n s, however ultimate discharge of 317 groundwater is to the Lake

. Vertical groundwater flow is limited by the underlying Silt

-Clay 318 Unit which has a low permeability and is approximately 30 feet thick (Dames and Moore 319 "Foundation Investigation, Proposed Nuclear Power Plant, Zion, Illinois" [Reference 8-20]). 320 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-8 8.6. Environmental Effects of Decommissioning 321 8.6.1. Summary 322 The evaluation of the environmental effects (or impacts) of the decommissioning of ZNPS 323 follows the approach outlined in NUREG-0586. The methodology is described in NUREG-324 0586, Supplement 1. This approach includes identification of environmental issues as either 325 generic or site

-specific.

If the issue is considered to be generic, it is assigned a significance level 326 of either "Small", "Moderate", or "Large."

If identified as generic, the environmental impact is 327 considered to be bounded by the evaluation in the GEIS which concludes that the impact 328 significance is "Small."

In this event, site specific evaluation by licensees is generally not 329 required.

330 For those environmental issues or decommissioning activities that require site

-specific 331 evaluation, a standard approach is followed.

It is summarized as follows

332 1) The issue or activity is summarized including a summary of the impacts as reported in the 333 original Environmental Statement (ES) and PSDAR.

Note that many decommissioning 334 activities are not identified in these documents.

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

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

338 4) An evaluation is performed.

This includes analysis and professional judgment to estimate or 339 determine whether the activity is likely to make a noticeable impact on the environment 340 considering the available information.

If an impact is likely, existing and additional 341 mitigation measures that can be taken are evaluated.

If an impact cannot be avoided, a 342 determination is made as to whether the impact is likely to seriously damage the resource or 343 attribute. 344 5) A conclusion is reached.

345 A conclusion is derived from the evaluation steps summarized above.

The conclusion identifies 346 the level of significance of the impacts.

Site-specific issues are not bounded by the GEIS 347 evaluation.

348 Table 8-1 was used as the basis for the site specific environmental impact assessment for ZNPS. 349 It is excerpted from Table 6.1 of NUREG-0586, Supplement

1. The first step in this process is to 350 screen the issues to identify site

-specific issues.

Decommissioning activities specific to ZNPS 351 are then reviewed and the activities that may require site

-specific evaluation are identified

. The 352 screening identified the following; 353 Offsite land use activities: changes in demographics and zoning that have occurred in the past 354 40 years. 355 Aquatic ecology affected by activities beyond the operational area; changes in designation of 356 sensitive areas (local wetlands and expansion of Illinois State Beach)

. 357 Terrestrial Ecology affected by activities beyond the operational area: changes in designation 358 of sensitive areas (local wetlands and expansion of Illinois State Beach)

. 359 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-9 Threatened and endangered species: changes in local flora and fauna and designation of 360 threatened and endangered species that have occurred in the past 40 years. 361 Environmental Justice: changes in demographics and socioeconomic status in the past 362 40 years. 363 Cultural and Historic Resource impacts beyond the operational areas: changes in local 364 historic landmark designations and other cultural resources.

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

367 ISFSI construction: land use impacts (onsite)

. 368 Vertical Concrete Cask (VCC) construction for the ISFSI: land use impacts (onsite). 369 Rail line upgrade and extension (onsite and offsite)

. 370 Circulating Water inlet and outlet piping disposition: aquatic ecology (within and beyond the 371 operational area)

. 372 Placement of clean construction demolition debris (CCDD) and sand mix in major building 373 basements: terrestrial ecology and transportation.

374 8.6.2. Radiological Effects of Decommissioning 375 8.6.2.1. Occupational Radiation Exposure 376 During decommissioning, ZionSolutions has and will continue to implement a Radiation 377 Protection Program in accordance with the license specifications and the requirements of 10 CFR 378 Part 20. The objectives of the Radiation Protection Program are to control radiation hazards, 379 avoid accidental radiation exposures, maintain occupational worker exposures to less than the 380 administrative limit of less than 2,000 mrem/yr Total Effective Dose Equivalent (TEDE) and, to 381 maintain doses to workers and the public As Low As Reasonably Achievable (ALARA).

382 On March 9, 1998, Commonwealth Edison (ComEd), the licensee at the time, placed both unit s 383 at ZNPS in a SAFSTOR condition (a period of safe storage of the stabilized and defueled 384 facility). The reactors at Zion remained in a SAFSTOR condition until September of 2010, when 385 active decommissioning activities commenced. This period of time allowed for the decay of 386 most short

-lived radionuclides which subsequently, reduced radiation levels at the facility. This 387 fact, combined with the effective implementation of the Radiation Protection Program and 388 ALARA measures minimizes the projected and actual occupational radiation dose exposure 389 during the decommissioning of ZNPS. It is anticipated that the most significant contributors to 390 occupational dose from remaining dismantlement activities is the segmenting, packaging and 391 shipping of the reactor vessel internals and the reactor vessel

. 392 The GEIS estimates that 1,115 Rem will be needed to decommission a PWR similar in size to the 393 Zion units.

Current occupational dose expended and dose expected to complete 394 decommissioning for both units is less than 1,000 Rem. This is well below the GEIS estimate of 395 2,230 Rem for two units.

396 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-10 As the occupational dose for the decommissioning will meet the regulatory standards of 397 10 CFR 20, it is therefore bounded by the criteria in the GEIS and the impact is considered as 398 "Small". 399 8.6.2.2. Offsite Radiation Exposure and Monitoring 400 ZionSolutions implements a regulatory compliant Radiological Environmental Monitoring 401 Program (REMP) at ZNPS, which provides annual reports with an accurate assessment of the 402 radiological environment in and around the environs of the site.

The REMP program provides 403 assurance that the radioactive gaseous and liquid effluent releases during plant operations do not 404 exceed the concentration limits of 10 CFR 20, the dose limits of 10 CFR 50, Appendix I, or the 405 fuel cycle dose limits of 40 CFR 190. ZionSolution s will continue to adhere to these limits 406 throughout the course of the decommissioning. Consequently, the public dose from 407 decommissioning is bounded by the criteria in the GEIS and the impact is considered as "Small". 408 At ZNPS , the Circulating Water Discharge Tunnels are the main authorized effluent release 409 pathway for the discharge of treated and filtered radioactive liquid waste to Lake Michigan.

410 Liquid effluent s are monitored and sampled prior to release from onsite storage tanks. 411 The gaseous pathway analysis is subject to the meteorological conditions during the time of the 412 release. Due to plant shutdown and cessation of noble gas and other radionuclide generati on, 413 gaseous effluents do not present a significant release or exposure pathway. Routine grab air 414 sampling is performed to determine the dose due to radioactive gaseous releases.

415 The direct radiation exposure is measured continuously with the use of passive monitoring 416 devices. The dose is integrated over three months to accumulate a statistically significant 417 exposure. 418 The design basis for the ISFSI precludes airborne radioactive releases during spent fuel storage 419 and provides adequate shielding to minimize exposure. Radiation monitoring for the ISFSI is 420 performed in accordance with the Radiation Protection Program implemented at ZNPS. In 421 accordance with the worst case scenario in the design basis , the projected doses at the site 422 boundary are substantially below the limits established in 10 CFR 72.106(b) where there is total 423 loss of the confinement barrier

. Exposure from the ISFSI to the nearest permanent resident will 424 not exceed 25 mrem/year as specified in 10 CFR 72.104 and 40 CFR Part 190. 425 8.6.2.3. Environmental Effects of Accidents and Decommissioning Events 426 Decommissioning accident analysis is integral to the licensing design basis for ZNPS. While 427 decommissioning radioactively contaminated structures, systems and components at ZNPS, it is 428 necessary to assure the safety of the public in the surrounding area and workers. Worker safety 429 is addressed in the Radiation Protection and Safety programs for the Zion Station Restoration 430 Project (ZSRP) which rely on ALARA principles and the ZionSolutions ZS-SA-01, "Zion 431 Restoration Project Health and Safety Plan" (HASP) (Reference 8-21). The safety of the public 432 is principally related to potential hazards associated with an airborne release of radioactive 433 materials during decommissioning operations.

434 During decommissioning, ZSRP will perform decontamination and dismantlement of structures, 435 systems, and components in addition to maintenance, waste management, and surveillance. The 436 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-11 accidents discussed in NUREG-0586, Supplement 1 associated with immediate dismantling 437 would also be applicable during the decommissioning of ZNPS. However, the potential 438 consequences associated with those accidents would be less at ZNPS due to the reduction of the 439 total radionuclide inventory at ZNPS due to: 440 Decontamination efforts made before decommissioning, 441 Prior radioactive waste shipments, and 442 Radioactive decay.

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

1. 445 Operational accidents during decommissioning could result from equipment failure, human error, 446 and service conditions. With the spent nuclear fuel removed from the reactors, operational 447 accidents during decommissioning can be categorized as follows:

448 Radioactive waste transportation accidents, 449 Explosions and/or fires associated with explosive and/or combustible materials, 450 Loss of contamination control, 451 Natural phenomena, and 452 Human caused events external to ZNPS. 453 These potential operational accidents during decommissioning are addressed in NUREG-0586, 454 Supplement 1 for immediate dismantlement and consequently, are bounding for the 455 decommissioning of ZNPS

. 456 8.6.2.4. Storage and Disposal of Low

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

464 The majority of the Class A low-level radioactive waste from ZNPS will be shipped to the 465 EnergySolutions disposal site in Clive, Utah. The radioactive materials are typically packaged in 466 SuperSacs and then placed into EnergySolutions owned 100 ton, high-capacity SuperGondola 467 railcars for transport on Union Pacific rail lines to the disposal site.

Oversized or overweight 468 components, such as the Reactor Vessel Head, are shipped using multiple axle tractor/trailer rigs 469 or special rail cars

. Rail and truck shipments are made in accordance with Department of 470 Transportation (DOT) regulations. Class B and C low

-level radioactive waste from ZNPS will 471 be shipped to the Waste Control Specialists disposal site in Andrews, Texas.

472 ZionSolutions completed the construction of the ISFSI in August 2013 and started spent nuclear 473 fuel cask loading in December 2013. ZionSolutions anticipates completing the transfer of all its 474 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-12 spent nuclear fuel, in sixty-one (61) VCC to the ISFSI by early 2015

. The multi-purpose fuel 475 canisters within the casks are seal

-welded and leak tight; therefore no leakage is expected during 476 normal operation, off

-normal conditions, or design basis accidents.

The storage of the fuel at the 477 ISFSI does not generate any gaseous, liquid, or solid radioactive waste. The spent nuclear fuel 478 will remain in storage at the ISFSI under the Part 50 license until the fuel is transferred to a 479 permanent repository.

Greater-Than-Class C low

-level radioactive waste will be stored in four 480 seal-welded leak tight canisters within storage casks co

-located at the ISFSI with the spent fuel.

481 8.6.2.5. Radiological Criteria for License Termination 482 Following the completion of decontamination, dismantlement and remediation activities, 483 radiological surveys will be performed to demonstrate that the dose from any residual 484 radioactivity remaining in as

-left structure basements and soils at ZNPS (excluding the ISFSI) to 485 the unrestricted release criteria as specified in 10 CFR 20.1402. Once the balance of the site is 486 remediated and the as

-left radiological conditions are demonstrated to be below the unrestricted 487 release criteria, the 10 CFR Part 50 license will be reduced to the area around the ISFSI and the 488 site will be transferred back to Exelon under the 10 CFR Part 50 license.

LTP Chapter 5 and 489 Chapter 6 provide the methodology for demonstrating compliance with the unrestricted release 490 criteria. 491 8.6.3. Non-radiological Effects of Decommissioning 492 8.6.3.1. Onsite Land Use 493 The environmental impact associated with onsite land uses have been determined by the NRC , 494 within section 4.3.1 of NUREG-0586, Supplement 1 to be generically considered as a "Small" 495 impact. 496 The decommissioning project is located and executed within the boundary of the existing ZNPS 497 property previously used for power generation; all work will be conducted in previously 498 developed footprint. Some onsite roads have been refurbished and a reinforced heavy haul path 499 was constructed to support the transfer of VCCs to the ISFSI.

No barge slips are being 500 constructed.

The rail was originally installed during the construction of the station and was part 501 of the operation of the facility. The onsite rail line was modified and refurbished to support 502 decommissioning activities. Containers will be unloaded and loaded onsite.

Onsite land 503 activities such as vehicle parking and equipment/container laydown, storage, staging and waste 504 loading are and continue to occur in a manner similar to when the facility was operational. 505 Several structures such as the Switchyard, the ISFSI, the ISFSI warehouse, the microwave tower, 506 and the Sewage Lift Station, as well as all roadways and rail lines, will remain at license 507 termination as requested by Exelon.

508 Section 8.5 of Exhibit C, Lease Agreement, titled "Removal of Improvements; Site Restoration" 509 integral to the Asset Sale Agreement requires the demolition and removal of all on

-site buildings, 510 structures, and components to a depth of at least three feet below grade. The major structures 511 that will remain at license termination are the basements of the Unit 1 Containment Building, 512 Unit 2 Containment Building, Auxiliary Building, Turbine Building, WWTF, the lower portion 513 of the Spent Fuel Pool, Crib House and Forebay, Unit 1 and Unit 2 Steam Tunnels and the 514 Circulating Water Intake and Discharge Tunnels below the 588 foot elevation. All systems, 515 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-13 components as well as all structures above the 588 foot elevation (with the exception of the 516 structures previously noted) will be removed during the decommissioning process and disposed 517 of as a waste stream. In both Containment basements, all concrete will be removed from the 518 interior side of the steel liner, leaving only the remaining exposed liner below the 588 foot 519 elevation and the structural concrete outside of the liner. In the Auxiliary Building, all interior 520 walls and floors will be removed, leaving only the exterior walls and basement floor. In the 521 Turbine Building basement, the remaining structures will consist of reinforced concrete floors 522 and exterior foundation walls and the sub

-grade portions of the pedestals below the 588 foot 523 elevation. For the Fuel Handling Building, the only portion of the structure that will remain is 524 the lower 12 feet of the Spent Fuel Pool below 588 foot elevation and the concrete structure of 525 the Fuel Transfer Canals once the steel liner has been removed. Other below ground structures 526 that will remain are the lower concrete portions of the WWTF, Main Steam Tunnels, and 527 Circulating Water Inlet Piping and Discharge Tunnels. 528 The decommissioning approach for ZSRP also calls for the beneficial reuse of concrete from 529 building demolition as clean fill.

Uncontaminated concrete that meets the definition of CCDD 530 and where radiological surveys demonstrate that the concrete is free of plant derived 531 radionuclides above background will be used

. Demolition debris found to be contaminated or 532 potentially contaminated based on process knowledge will be disposed of as low

-level 533 radioactive waste. Consequently, the burial of demolition debris contaminated with residual 534 radioactivity will not have the potential to affect land use and ground or surface water quality.

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

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

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

543 In accordance with the guidance presented in the GEIS, the potential impacts to land use onsite 544 are considered as "Small". 545 8.6.3.2. Offsite Land Use (in the Vicinity) 546 Only areas within the existing site boundary will be used to support decommissioning and 547 license termination activities (such as temporary storage and staging areas). Appropriate 548 isolation and control measures will be instituted to prevent the spread of contamination. These 549 measures will also be monitored to ensure their effectiveness. Thus, no environmental impacts 550 associated with the use of offsite lands are anticipated from the decommissioning activities at 551 ZNPS. 552 Of the 331 acre site, about 87 acres are located within the fence

-enclosed "Radiologically

-553 Restricted Area". The remainder, which lies mostly to the west of the station switchyard, which 554 belongs to ComEd, is an open marshy area.

This area is undeveloped except for overhead 555 transmission lines and corridors maintained by ComEd. 556 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-14 The land area immediately west of the site, located between the site and the railway is zoned 557 light industrial by the City of Zion (The City of Zion, Illinois, "Comprehensive Plan 2010" 558 [Reference 8-22]). This area is about five blocks long, extending from 29 th Street on the south to 559 Shiloh Boulevard on the north and is about four blocks wide in the east

-west direction centered 560 on Deborah Avenue.

It is currently occupied by several warehouses and associated truck 561 shipping operations, an industrial cleaning

-service company, several auto service garages, a 562 salvage yard, a former manufacturing facility and a number of vacant lots.

563 A significant factor which affects land use in the near vicinity of ZNPS is the Illinois Beach State 564 Park. The Illinois Beach State Park has been expanded since the construction of ZNPS, at which 565 time it only comprised an area located south of the site along the Lake Michigan shoreline.

The 566 present day Illinois Beach State Park is comprised of a section north and a section south of 567 ZNPS. The Park is part of a sta te-owned co astal management area

, which extends from 568 Winthrop Harbor (about three miles north of the ZN PS site) to about three miles south of the 569 ZNPS site. The area from Winthrop Harbor Marina on the north to the southern end of the 570 Illinois Beach State Park has been incorporated into the Illinois Coastal Management Program 571 (ICMP). The ICMP has identified this area as a unique public resource requiring special 572 attention for preservation, protection and restoration of areas impacted by shoreline erosion, 573 invasive species and damage caused by previous industrial activities (Illinois Coastal 574 Management Program, "Illinois Beach State Park and North Point Marina, Including the Dead 575 River and Kellogg Creek Watersheds, 2011"

[Reference 8-23]). 576 The ZNPS site and the surrounding land on all sides are identified as "environmentally sensitive" 577 in the Zion City planning document. The Lake County Regional Framework Plan identifies the 578 western portion of the ZNPS site and adjacent land, as wetlands and areas with "environmental 579 limitations".

In the Lake County Plan, this area is also assigned a "high priority for open space".

580 This includes the strip of land between the Chicago and Northwestern Railway on the west and 581 the Illinois Beach State Park on the east, bisected by the Deborah Avenue light industrial area 582 and the ZNPS site. 583 Decommissioning activities are not being performed in areas defined as "environmentally 584 sensitive" within the site boundary, nor in land which adjoins similar offsite land areas, City of 585 Zion industries, or the State beach park areas. Consequently, the offsite land areas are not 586 affected by the decommissioning activities and the potential impacts to land use offsite are 587 considered "Small". 588 8.6.3.3. Water Use 589 In accordance with section 4.3.2 of NUREG

-0586, Supplement 1, the environmental impact 590 associated with water use has been determined to be generally applicable with a "Small" impact. 591 ZN PS is located on the shores of Lake Michigan.

The lake is 307 miles long from north to south 592 and has an average width of 70 miles. The predominant water usage during the operation of 593 ZNPS was the use of water from Lake Michigan as secondary cooling water for the reactor 594 systems. With the plant shutdown and fuel removed from the reactor, the cooling water system 595 is currently used for the cooling of the Spent Fuel Pool, building environmental systems such as 596 air conditioning and heating, and fire suppression. The use of water from Lake Michigan during 597 decommissioning activities is significantly less than the usage during operations. 598 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-15 Water from Lake Michigan is also extensively used for municipal and domestic water supplies.

599 There is multiple potable water intakes located in Lake Michigan in the vicinity of ZNPS. The 600 nearest intake is located about 1 mile north of the ZNPS site and approximately 3,000 feet out 601 in to the lake. The City of Zion provides potable water services to support ZNPS. The sewage 602 system is connected to the North Shore Sanitary District (NSSD).

Potable water use during 603 decommissioning operations is not expected to be greater than the potable water use experience 604 during operations

. Water will continue to be processed in accordance with the site National 605 Pollutant Discharge Elimination System permit (NPDES). Consequently, in accordance with the 606 GEIS, the potential impacts to water use are considered "Small".

607 8.6.3.4. Water Quality 608 This section evaluates potential project effects on those portions of the natural environment 609 related to surface water and groundwater. Surface water generally refers to streams, rivers, 610 ponds, reservoirs and lakes. At ZNPS, the nearby bodies of water are Lake Michigan and 611 surface streams near the site, including Kellogg Creek (1.25 miles north), Dead River (3 miles 612 south), and Bull Creek (0.2 mile south) and surrounding wetlands

. 613 The environmental impact evaluation associated with surface and groundwater quality in 614 section 4.3.3 of NUREG

-0586, Supplement 1 has been determined to be generally applicable to 615 ZNPS with a "Small" impact.

616 At ZN PS, a ll non-radiological water discharges to Lake Michigan are controlled under a n 617 NPDES permit which is issued by the Illinois Environmental Protection Agency (IEPA).

618 ZionSolutions has filed a Notice of Intent (NOI) with the IEPA

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

624 Radiological impacts are minimized through adherence to Off-site Dose Calculation Manual 625 (ODCM) limits and assessed through the Radiological Environmental Monitoring Program 626 (REMP) and the Radiological Groundwater Protection Program (RGPP). Potential groundwater 627 impacts are monitored by the routine sampling of eleven (11) permanent onsite RGPP wells at 628 ZN P S. 629 As the water from Lake Michigan is no longer used to cool operating reactor systems at ZNPS, 630 the thermal impact to Lake Michigan has been reduced

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

634 8.6.3.5. Air Quality 635 The environmental impact evaluation associated with air quality in section 4.3.4 of NUREG

-636 0586, Supplement 1 has been determined to be generally applicable to ZNPS with a "Small" 637 impact. 638 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-16 Z NPS complies with all applicable Federal and State air quality regulations, including the 639 requirements of the IEPA, Bureau of Air, and will implement BMP to minimize fugitive dust 640 during demolition and decommissioning activities.

Air emission sources such as the diesel 641 generators are no longer in service and the auxiliary boiler has been removed

. A minor emission 642 source for the above ground storage gasoline tank (1000 gallons) is permitted under the IEPA 643 Registration of Smaller Sources (ROSS) program.

This tank will be removed when the 644 decommissioning is complete.

645 Fugitive dust will be generated from various decommissioning activities, including the 646 demolition of concrete building structures and the excavation of soil. Careful planning and 647 controlled demolition and dismantlement techniques, with appropriate assessments by 648 ZionSolutions Radiation Protection, Environment, and Health and Safety staff, will be conducted 649 to ensure excessive and harmful dust emissions are not generated.

As necessary, measures such 650 as dust suppression by misting water will be used to mitigate dust emissions. 651 Demolition equipment will be operated and maintained in accordance with manufacturer's 652 specifications which will prevent increased exhaust emissions. Appropriate Health and Safety 653 assessments and controls will also be established during expected extended periods of operation 654 to ensure that personnel and the environment are not adversely impacted by excessive exhaust 655 emissions.

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

659 8.6.3.6. Aquatic Ecology 660 The environmental impact evaluation associated with aquatic ecology in section 4.3.5 of 661 NUREG-0586, Supplement 1 has been determined to be generally applicable to ZNPS with a 662 "Small" impact.

663 The aquatic habitat at ZNPS includes the area from the intake structure integral to the Crib 664 House at the shoreline to the diffuser structure that extends out into Lake Michigan 665 approximately 870 feet from the lakeshore

. Habitats associated with this area were previously 666 disturbed during the initial construction of the facility. However, the implementation of 667 decommissioning activities is not expected to disturb existing aquatic habitats , their flora and 668 fauna in the lake and also nearby streams and wetlands. 669 Various fresh water fish species , macro-invertebrate populations

, and vegetation exist within 670 these aquatic environments and were identified during a study contracted by ZionSolutions. 671 ZionSolutions contracted an independent environmental analysis to assist with the decision for 672 removing or leaving the Forebay and Circulating Water Discharge Tunnels at ZN P S. This 673 analysis was documented in the previously cited report by AMEC, Inc. pertaining to the 674 Discharge Piping. The report concludes that no action should be taken for the removal of the 675 Forebay and Circulating Water Discharge Tunnels as no action decision resulted in the least 676 impact to the environment, including aquatic ecology considerations

. 677 Plans for the demolition of structures at ZNPS do not include the removal of waste or equipment 678 by barge. Consequently, there is no impact to the beach or shoreline from this type of activity. 679 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-17 ZionSolutions will continue to maintain its NPDES permit and decommissioning operations will 680 be performed within applicable NPDES limits.

Furthermore, protection of the onsite and 681 adjacent wetlands is, and will continue to be a priority when planning any onsite dismantlement 682 or waste management operation. In addition, the SWPPP is implemented with BMPs to prevent 683 impacts to the aquatic systems.

684 Exotic species can threaten native species and ecosystems due to aggressive growth, 685 reproduction or survival rate, and diseases or parasites they may transmit to native species. The 686 decommissioning of ZNPS will not introduce any exotic plants or animals into the environment. 687 The potential impacts to the aquatic ecology within the site boundary are bounded by the GEIS 688 and considered to be "Small". The potential impacts to the aquatic ecology beyond the site 689 boundary have also been evaluated and considered to be "Small". 690 8.6.3.7. Terrestrial Ecology 691 The environmental impact evaluation associated with terrestrial ecology in section 4.3.6 of 692 NUREG-0586, Supplement 1 has been determined to be generally applicable to ZNPS with a 693 "Small" impact.

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

To minimize the introduction of exotic or invasive species, 701 appropriate BMPs are, and will continue to be followe

d. 702 The land around ZNPS was initially disturbed by the construction of the facility and no longer 703 resembles the dune formations prevalent in surrounding areas.

This alteration results in a less 704 desirable habitat for many species that rely on dune formations for habitat.

Given the short

-term 705 nature of the work associated with decommissioning, and the fact that the project area is 706 separated from the Illinois Beach State Park, no direct impacts to sensitive species are 707 anticipated. Additionally, upon completion of construction activities, the land is going to be 708 brought to existing grade and stabilized with guidance on native vegetation, therefore 709 minimizing any long-term impacts to sensitive species.

In addition, the planned demolition 710 activities do not include the removal of waste or equipment by barge and consequently, there is 711 no anticipated impact to the beach or shoreline.

712 Floodplain management requires that long

-term and short

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

715 Wetlands have been delineated and permits have been obtained for work activities that are in the 716 vicinity of wetlands and wetland buffer zones. Compliance with these permits and the 717 implementation of BMPs mitigates the potential impact on wetlands from decommissioning 718 activities. 719 The potential impacts to terrestrial ecology are bounded by the GEIS and considered "Small". 720 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-18 8.6.3.8. Threatened or Endangered Species 721 The only "Threatened

" or "Endangered

" species that has been observed at ZNPS is the 722 Blanding's turtle. The Blanding's Turtle (Emydoidea, blandingii) is listed as a "Threatened" 723 species in the state of Illinois. During the decommissioning process, Blanding's turtles have 724 been observed, rescued, and protected. Blanding's turtle awareness signs have been posted and 725 inspections are performed to ensure that the Blanding's turtles are protected in accordance with 726 the IDNR recommendations and the IEPA

, NPDES, and SWPPP. During the refurbishment of a 727 rail crossing located north of ZNPS , ZionSolutions worked with local stakeholders and the IDNR 728 to rescue a den of snakes which included several Western Fox snakes.

A hibernacul um was 729 established nearby for the relocation of the rescued snakes.

The Western Fox snake is not listed 730 as "Threatened

" or "Endangered

" but they are considered an important part of the ecosystem.

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

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

738 8.6.3.9. Occupational Issues/Safety 739 The environmental impact evaluation associated with occupational issues in section 4.3.10 of 740 NUREG-0586, Supplement 1 has been determined to be generally applicable to ZNPS with a 741 "Small" impact. While decommissioning involves increased industrial activities and safety 742 focus, similar programs addressing worker safety were implemented during the operation of the 743 facility and also during repair and refueling outages. The occupational issues and safety impacts 744 assessed are those related to human health and safety, including impacts from physical, chemical, 745 ergonomic, and biological hazards.

Radiological impacts, were previously discussed in 746 section 8.6.2.1. 747 ZionSolutions is committed to decommissioning ZNPS safely and has established a HASP to 748 implement a program to effectively control hazards in the work environment and prevent 749 occupational injuries and illnesses. The HASP and ZionSolutions Health and Safety Program 750 complies with federal and state regulations including Illinois Department of Labor and the U.S.

751 Occupational Health and Safety Administration (OSHA) requirements.

The HASP applies to all 752 ZionSolutions employees as well as visitors and contract personnel working under direct 753 ZionSolutions supervision.

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

756 Safety is emphasized as the first topic of discussion at meetings

. 757 All workers are provided a Health and Safety booklet

. 758 Worker training and required certifications are reviewed prior to assignment to tasks 759 requiring specific worker qualifications. Certain specialty subcontractors are mobilized, as 760 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-19 necessary, such as the asbestos abatement firm contracted for the removal of all asbestos 761 from the Turbine Building

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

. 763 Health and Safety staff are involved in reviewing and approving decommissioning work 764 packages and participating in pre

-job walkdowns, work condition assessments and revie ws. 765 Daily and weekly safety messages are issued as well as Safety Bulletins to communicate 766 awareness of significant safety issues and lessons learned

. 767 Safety stand

-downs are held whenever serious safety events occur to communicate and 768 reinforce safety events and lessons learned site-wide. 769 Therefore, occupational issues/safety is evaluated to be bounded by the GEIS and the impact is 770 considered "Small". 771 8.6.3.10. Cost 772 A detailed discussion of the site decommissioning project costs is presented in Chapter 7 of this 773 LTP. 774 8.6.3.11. Socioeconomic Impacts 775 ComEd's original decision to permanently cease plant operations was not subject to NRC review 776 or approval.

On January 14, 1998, the Unicom Corporation and ComEd Boards of Directors 777 authorized the permanent cessation of operations at ZNPS for economic reasons. The economic 778 growth and job opportunities in the Chicago Metropolitan area and the nuclear industry at the 779 time of shutdown in 1998, minimized the effects of unemployment that resulted from the plant 780 shutdown. 781 In September of 2010, decommissioning activities began and a demolition permit was obtained 782 from the City of Zion.

Some of the labor requires specialized skills and equipment from out

-of-783 state. Overall, the decommissioning activities have a short

-term positive economic impact on the 784 local community due to the permit fee, and the impact on the local workforce and opportunities 785 for local business.

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

788 8.6.3.12. Environmental Justice 789 While low-income and minority populations are present in the vicinity of the former ZNPS, the 790 percentages of low

-income and minorities within the ZNPS census tract are lower than those in 791 other City of Zion census tracts. No impact to the greater population, including special groups, 792 is expected. 793 An existing rail spur was refurbished to transport large components from ZNPS. The refurbished 794 rail spur will be used to transport waste over an existing route.

Decommissioning activities will 795 cause increases in truck traffic to and from ZNPS to transport equipment and debris. The truck 796 traffic will use existing main street routes. Since approximately 90% of the waste will be 797 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-20 removed by rail , the increase in truck traffic will be temporary. There will be no environmental 798 justice impact relative to rail and truck transportation as a result of decommissioning.

799 There is no reason to believe that low

-income and minority populations will be adversely 800 impacted by the decommissioning project. Per the GEIS and this evaluation, the potential site 801 specific impact is considered "Small".

802 8.6.3.13. Cultural, Historic, and Archaeological Resources 803 The AEC Environmental Statement included documentation from the State of Illinois , 804 Department of Conservation which stated the following:

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

808 ZNPS had an existing rail spur that was refurbished to ship waste and large components off

-site. 809 Land disturbance for the removal of large components is minimized since removal is primarily 810 conducted via site rail system.

811 Land that was disturbed for projects beyond the operational areas (within the owner controlled 812 site) was performed in accordance with the IEPA, NPDES permits and the Lake County SMC , 813 Watershed Development Ordinance which included soil erosion controls and stormwater 814 pollution prevention plans.

Additional IEPA and SMC permits were obtained during 2014 for 815 the demolition phase that will take place within the "Radiologically

-Restricted Area". These 816 permits include d a review by the Illinois Historic Preservation Agency which identified no 817 historic, architectural or archaeological sites exist on the ZNPS site.

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

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

824 8.6.3.14. Aesthetics 825 The environmental impact evaluation associated with aesthetics in section 4.3.15 of NUREG-826 0586, Supplement 1 has been determined to be generally applicable to ZNPS with a "Small" 827 impact. 828 The impact of decommissioning on site aesthetics (e.g. visual skyline) is limited in terms of land 829 disturbance and duration.

These impacts are temporary and will cease when decommissioning is 830 completed.

831 The location of the ISFSI is set back several hundred yards from the lake frontage and located 832 adjacent to the existing switchyard. Once all of the major plant structures and buildings on the 833 lake front are removed, aesthetics will improve by providing a more open view of Lake 834 Michigan. Due to the proximity of the Illinois State Beach Park on the north and south of ZNPS , 835 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-21 restoration of the site to a natural grade will result in a contiguous open view of the Lake 836 Michigan shoreline.

837 Aesthetics will improve once the site is returned to open space. The final determination on usage 838 for the lake front property will be made by Exelon upon completion of the decommissioning and 839 transfer of the license back to Exelon. 840 Therefore, the environmental impact associated with aesthetics is evaluated to be bounded by the 841 GEIS and the impact is considered "Small". 842 8.6.3.15. Noise 843 The environmental impact evaluation associated with noise in section 4.3.16 of NUREG

-0586, 844 Supplement 1 has been determined to be generally applicable to ZNPS with a "Small" impact.

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

849 Noise generation will primarily result from demolition activities involving heavy construction 850 equipment. The noise from the shipment of waste will be minimal since the primary 851 transportation method for shipment of low level radioactive waste will be by rail. Noise 852 associated with decommissioning and shipment of waste is intermittent and temporary and will 853 occur primarily during daylight hours.

The ISFSI construction was completed in 2013

. The 854 ISFSI is a passive facility and there will be minimal noise generated from its operation

. Once the 855 decommissioning is complete, noise levels in the vicinity of the ZNPS site will be reduced to 856 levels below those experienced during the operation of the facility. 857 Due to the distance of the station from sensitive receptors, there will be limited temporary 858 impacts on noise levels during decommissioning and demolition activities. During the 859 decommissioning, ZionSolutions agrees to comply with any noise limitation s imposed by the 860 City of Zion.

861 Therefore, the environmental impact associated with noise is evaluated to be bounded by the 862 GEIS and the impact is considered "Small". 863 8.6.3.16. Irretrievable Resources 864 The environmental impact evaluation associated with irretrievable resources in section 4.3.18 of 865 NUREG-0586, Supplement 1 has been determined to be generally applicable to ZNPS with a 866 "Small" impact.

867 During the demolition and structural dismantlement of the station, recycling and asset recovery 868 efforts will be made.

Some metals (e.g. from turbine, transformer components, etc.) have been 869 released as clean scrap. Low level radioactive waste has been and will be continue to be shipped 870 to the EnergySolutions disposal site in Clive, Utah. This facility has sufficient space for the 871 disposal of this waste.

In addition, any Class B/C waste that is generated will be shipped to the 872 Waste Control Specialist (WCS) facility in Andrews, Texas. 873 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-22 As stated in the GEIS, irretrievable resources that would occur during the decommissioning 874 process are the materials used to decontaminate the facility (e.g., rags, solvents, gases, and tools), 875 and fuel used for construction machinery and for transportation of materials to and from the site.

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

878 Therefore, the environmental impact associated with irretrievable resources is evaluated to be 879 bounded by the GEIS and the impact is considered "Small". 880 8.6.3.17. Traffic and Transportation 881 The environmental impact evaluation associated with transportation issues in section 4.3.17 of 882 NUREG-0586, Supplement 1 has been determined to be generally applicable to ZNPS with a 883 "Small" impact.

884 The number of shipments and the volume of waste shipped are greater during decommissioning 885 than during the operation of the facility. Non-radiological impacts of transportation include 886 increase d traffic and wear and tear on roadways. Because the majority of the waste will be 887 transported by rail, the average number of daily shipments from the site will be relatively small. 888 Consequently, it is anticipated that there will be no significant effect on traffic flow or road wear.

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

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

. 892 8.6.3.18. Placement of Clean Construction Demolition Debris (CCDD) and Sand Mix in 893 Major Building Basements: Terrestrial Ecology and Transportation 894 ZionSolutions evaluated the use of CCDD for basement fill end-state and submitted a Request 895 for Concurrence for Basement Fill End-State (ZS-2014-0272) to the Illinois EPA in August of 896 2014. This request included the results of a sampling plan for concrete candidate fill material to 897 be used for the basement fill end

-state. On October 3, 2014 ZionSolutions received a Letter of 898 Concurrence from the Illinois EPA (ZS

-2014-0349) for the use of CCDD for the basement fill 899 end-state. 900 8.7. Overview of Regulatory Governing Decommissioning Activities and Site Release 901 8.7.1. Federal Requirements 902 Decommissioning activities that are subject to federal regulations include:

903 Spent fuel storage at the ISFSI

. 904 Handling, packaging, and shipment of radioactive waste

. 905 Worker radiation protection

. 906 License termination and final site release

. 907 Worker health and safety

. 908 Liquid effluent releases

. 909 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-23 Hazardous waste generation/disposition

. 910 Handling and removal of asbestos

. 911 Characterization and removal of polychlorinated biphenyls (PCBs).

912 Handling and removal of lead paint

. 913 8.7.1.1. Nuclear Regulatory Commission 914 The majority of radiological activities falls under Title 10 of the Code of Federal Regulation and 915 are administered by the NRC. Applicable Title 10 regulations include: 916 Part 20 - Radiation protection

. 917 Part 50 - Decommissioning activities

. 918 Part 51 - Environmental protection

. 919 Part 61 - Disposal of radioactive waste

. 920 Part 71 - Packaging and transportation of radioactive waste (regulations in 49 CFR Parts 171 921 through 174 also apply)

. 922 Part 72 - Licensing requirements for the independent storage of spent nuclear fuel, high

-level 923 radioactive waste, and reactor

-related Greater

-Than- Class- C (GTCC) waste. 924 Part 73 - Physical Protection of Plants and Materials.

925 8.7.1.2. U.S. Environmental Protection Agency 926 The Environmental Protection Agency (EPA) regulations outlined in Title 40 of the Code of 927 Federal Regulations apply as follows:

928 Part 61 - Asbestos Handling and Removal 929 Parts 122 to 125

-NPDES 930 Part 141 - Safe Drinking Water Standards 931 Part 190 - Radiation Protection Standards for Nuclear Power Operations 932 Parts 260 to 272

- Resource Conservation and Recovery Act (RCRA) 933 Part 280 - Underground Storage Tanks 934 Part 761 - Toxic Substance Control Act (TSCA) for Polychlorinated Biphenyls (PCB s) 935 Part 129-132 - Clean Water Act 936 8.7.2. State and Local Requirements 937 Permits and approvals from or notifications to state and local agencies are required for safety and 938 environmental protection purposes. Decommissioning activities and related site operations that 939 fall under State and local jurisdiction include but are not limited to the following:

940 Lake County Stormwater Management Commission, Watershed Development Ordinance 941 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-24 Illinois Environmental Protection Agency 942 Illinois Historic Preservation Agency 943 Clean Construction or Demolition Debris, Il linois Environmental Protection Act, Section 944 3.160(b) 945 City of Zion Demolition Permit 946 This information provided above is a general overview of the applicable regulations and not 947 intended to be all-inclusive.

948 8.8. Conclusion 949 As previously evaluated in the Zion PSDAR, the non-radiological environmental impacts from 950 decommissioning ZNPS are temporary and not significant. The potential issues identified as 951 "site-specific" in NUREG-0586, Supplement 1 (such as "Threaten ed" and "Endangered

" species 952 and environmental justice) have been evaluated and there is no significant impact. The potential 953 environmental impacts associated with decommissioning ZNPS have already been predicted in 954 and will be bounded by the previously issued environmental impacts statements (PSDAR, 955 NUREG-0586, and Zion Environmental Statement). Therefore, there are no new or significant 956 environmental change associated with decommissioning.

957 8.9. References 958 8-1 U.S. Nuclear Regulatory Commission Regulatory Guide 1.179, "Standard Format and 959 Content of License Termination Plans for Nuclear Power Reactors"

- January 1999 960 8-2 Commonwealth Edison Company, "Environmental Report

- Zion Nuclear Power Station" 961 - May 1971, Supplement 1 - November 1971, Supplement II - December 1971, 962 Supplement III - February 1972, Supplement IV - April 1972, Supplement V - 963 May 1972 964 8-3 United States Atomic Energy Commission, Directorate of Licensing, "Final 965 Environmental Statement related to the Operation of Zion Nuclear Power Station Units 1 966 and 2", Docket Nos. 50

-295 and 50

-304 - December 1972 967 8-4 U.S. Nuclear Regulatory Commission NUREG-0586, "Generic Environmental Impact 968 Statement on Decommissioning of Nuclear Facilities", Supplement 1, Volume 1" - 969 November 2002 970 8-5 Zion Nuclear Power Station, "Post Shutdown Decommissioning Activity Report" 971 (PSDAR), - March 2008 972 8-6 "Zion Nuclear Power Station, Units 1 and 2 Asset Sale Agreement"

- December 2007 973 8-7 AMEC, Inc., "Final Environmental Analysis of Alternatives Regarding Intake/Discharge 974 Structure Disposition at the Former Zion Nuclear Generating Station, Zion, Illinois"

- 975 October 2013 976 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-25 8-8 U.S. Nuclear Regulatory Commission, NUREG

-1496, Volume 2, "Generic 977 Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for 978 License Termination of NR C-Licensed Nuclear Facilities"

- July 1997 979 8-9 US Census Bureau

, "2008-2012 American Community Survey"

- 2012 980 8-10 "Zion Station Historical Site Assessment" (HSA)

- September 2006 981 8-11 Conestoga-Rovers and Associates, "Hydrogeologic Investigation Report, Fleetwide 982 Assessment, Zion Station, Zion Illinois", Revision 1

- September 2006. 983 8-12 Illinois Department of Commerce and Economic Opportunity, "Zion Illinois, General 984 Information, Climate"

- September 2012 985 8-13 "Illinois State Water Survey 1971

- 2000" 986 8-14 "Illinois Climate Network, 1991 - 2000 Data Set" 987 8-15 Zion Station, "Defueled Safety Analysis Report" (DSAR)

- September 2014 988 8-16 "City of Zion" www.city-data.com/city/Zion

-Illinois 989 8-17 Commonwealth Edison Company, "Zion Nuclear Power Station - Final Safety Analysis 990 Report" (FSAR)

- November 1970 991 8-18 ZionSolutions Technical Support Document 14-003, Conestoga Rovers & Associates 992 (CRA) Report, "Zion Hydrogeologic Investigation Report" 993 8-19 "Illinois State Geological Survey" www.isgs.illnois.edu 994 8-20 Dames and Moore, "Foundation Investigation, Proposed Nuclear Power Plant, Zion, 995 Illinois"

- October 1967 996 8-21 ZionSolutions ZS-SA-01, "Zion Restoration Project Health and Safety Plan" (HASP) 997 8-22 The City of Zion, Illinois, "Comprehensive Plan 2010"

- January 1992 998 8-23 Illinois Coastal Management Program, "Illinois Beach State Park and North Point Marina 999 Including the Dead River and Kellogg Creek Watersheds"

- 2011 1000 1001 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-26 Table 8-1 Summary of the Environmental Impacts from Decommissioning Nuclear 1002 Power Facilities 1003 Section Environmental Issue GEIS Impact Significance 8.6.2 Radiological Activities resulting in occupational dose to workers Yes Small 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 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-27 Table 8-1 Summary of the Environmental Impacts from Decommissioning Nuclear 1004 Power Facilities (continued) 1005 Section Environmental Issue GEIS Impact 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 debris (CCDD) and sand mix in major building basements: terrestrial ecology and transportation.ISFSI construction: land use impacts (onsite)

No No Site-specific Site-specific 8.6.3.19 VCC construction for the ISFSI: land use impacts (onsite)

No Site-specific 8.6.3.20 Rail line upgrade and extension (onsite and offsite) No Site-specific 8.6.3.21 Circulating Water inlet and outlet piping disposition: aquatic ecology (within and beyond the operational area)

No Site-specific 8.6.3.22 Placement of clean construction demolition debris (CCDD) and sand mix in major building basements: terrestrial ecology and transportation.

No Site-specific Note: Cost, section 4.3.11 in GEIS Supplement 1, is not evaluated using environmental significance levels and is 1006 not identified as a generic or site

-specific issue.

1007 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-28 1008 1009 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-29 Figure 8-1 Zion Nuclear Power Station Geographical Location 1010 1011 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-30 Figure 8-2 Zion Nuclear Power Station Owner Controlled Area 1012 1013 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 8-31 Figure 8-3 Zion Nuclear Power Station Topographical Map 1014 1015

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