ML15243A029

Zion Station Request for Partial Site Release

ML15243A029
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	08/27/2015
From:	VanNoordennen G ZionSolutions
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ZS-2015-0134
Download: ML15243A029 (25)

Text

ZIONSOLUTIONSLLC An EnergySo/uttos Conmpany10 CFR 50.83(b)August 27, 2015 ZS-2015-0134 U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001 Zion Nuclear Power Station, Units 1 and 2Facility Operating License Nos. DPR-39 and DPR-48NRC Docket Nos. 50-295 and 50-304

Subject:

Zion Station Request for Partial Site Release

References:

1) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission, "License Amendment Request for the License Termination Plan," datedDecember 19, 2014ZionSolutions, the licensee for the Zion Nuclear Power Station (ZNPS), is requesting approval toremove a portion of the site from the Part 50 licenses (License Nos. DPR-39 and DPR-48).Specifically, ZionSolutions intends to remove/release the non-impacted survey units from its Part50 license in accordance with 10 CFR 50.83(b),

"Release of part of a power reactor facility orsite for unrestricted use."Attachment 1, "Zion Nuclear Power Station Supporting Information for Request for Partial SiteRelease,"

provides the supporting information for a partial release of the site for unrestricted usebefore receiving approval of the License Termination Plan (LTP) in accordance with theprovisions of 10 CFR 50.83(b).

The ZNPS LTP was previously submitted as documented inReference 1 and is currently under review by the NRC. Attachment 1 includes a description ofthe property and evaluation of the effect of releasing this property.

The evaluation concludes that all applicable regulatory requirements will continue to be met and no change to the ZNPSOperating License or the Permanently Defueled Technical Specifications is required.

There are no regulatory commitments made in this submittal.

ZionSolutions requests NRCapproval of this request by February 28, 2016. If you should have any questions regarding thissubmittal, please contact Robert Yetter at (224) 789-4250.

Respectfully, Gerard van Noordennen Vice President Regulatory Affairs ]00101 Shiloh Boulevard, Zion* I L 60099 (J- gtQ- ,,(224) 789-4016

• Fax: (224) 789-4008

• www.zionsolutionscompany.com ZionSolutions, LLCZS-2015-0134 Page 2 of 2Attachments

1) Attachment 1, "Zion Nuclear Power Station Supporting Information for Request forPartial Site Release"cc: John Hickman, U.S. NRC Senior Project ManagerService List Zion Nuclear Power Station, Unit 1 and 2 License Transfer Service Listcc:"Ken RobuckPresident Logistics Processing andDisposal GroupEnergySolutions 299 South Main Street, 17th FloorSalt Lake City, UT 84111John SaugerExecutive VP & General ManagerZionSolutions, LLC101 Shiloh Boulevard Zion, IL 60099Gerard van Noordennen VP Regulatory AffairsZionSolutions, LLC101 Shiloh Boulevard Zion, IL 60099Anthony OrawiecDecommissioning Plant ManagerZionSolutions, LLC101 Shiloh Boulevard Zion, IL 60099Dan ShrumSenior VP Regulatory AffairsEnergySolutions 299 South Main Street, 17th FloorSalt Lake City, UT 84111Russ WorkmanGeneral CounselEnergySolutions 299 South Main Street, 17th FloorSalt Lake City, UT 84111Alwyn C. SettlesSection Head, Nuclear Facility Inspection Bureau of Nuclear Facility SafetyIllinois Emergency Management Agency1011 North Street, P0 Box 250Mazon, IL 60444Kelly F. GrahnSenior Health Physicist, Unit Supervisor Illinois Emergency Management AgencyBureau of Radiation Safety, Environmental Management 245 W Roosevelt Road, Building 8, Suite 55West Chicago, IL 60185Kent McKenzieEmergency Management Coordinator Lake County Emergency Management Agency1303 N. Milwaukee AvenueLibertyville, IL 60048-1308 Regional Administrator U.S. NRC, Region III2443 Warrenville RoadLisle, IL 60532-4352 John E. MatthewsMorgan, Lewis & Bockius LLP1111 Pennsylvania Avenue, NWWashington, DC 20004 ZionSolutions, LLCZS-2015-0134:

Attachment 1ATTACHMENT 1Zion Nuclear Power StationSupporting Information for Request for Partial Site ReleasePage 1 of 22 ATTACHMENT 1Zion Nuclear Power StationSupporting Information for Request for Partial Site Release:ZIONSOLUTIONS,~-d=

PURPOSEThe purpose of this report is to inform the Nuclear Regulatory Commission (NRC) ofZionSolutions' intent to remove a portion of the Zion Nuclear Power Station (ZNPS) site fromthe Part 50 licenses (License No. DPR-39 and DPR-48).

Specifically, ZionSolutions intends toremove/release eleven (11) non-impacted survey units from its Part 50 License in accordance with 10 CFR 50.83(b),

"Release of Part of a Power Reactor Facility or Site for Unrestricted Use" and 10 CFR 100, "Reactor Site Criteria."

ZionSolutions has also reviewed and assessed thesubject property to ensure that the subject land area will have no adverse impact on the ability ofthe site in aggregate to meet 10 CFR Part 20, Subpart E, criteria for unrestricted release.

Thisreport contains a summary of the assessment performed, as well as a summary of thecharacterization surveys performed in these survey units. It is noted that this report does notcontain the Final Status Survey (FSS) Report for this area because the survey units within thisarea are characterized as non-impacted and as such, no statistical tests, scan and staticmeasurements or elevated measurement comparisons are required.

Table 1 provides aclassification and description list for the subject survey units. Figure 1 provides a depiction of thesite's geographical location and Figures 2 and 3 depict an overview of the survey unit boundaries and the site boundary/non-impacted survey unit corner coordinates, respectively.

Table 1 -Classification and Description List of Non-Impacted Open Land Survey UnitsSurveyApproximate SunitIDy Survey Unit Description Classification Survey UnitUnitID #Area (m 2)10200 Restricted Area Grounds10215 Area Northwest of Switchyard Non-Impacted 26,00810216 Area West Northwest of Switchyard Non-Impacted 31,17110217 Area Southwest of Switchyard Non-Impacted 50,88010300 Owner Controlled Area Grounds (included in Final Safety Analysis Report)10302 Northwest Corner of FSAR Area Non-Impacted 64,74010303 Southwest Corner of FSAR Area Non-Impacted 68,84710304 Southern Area of FSAR Non-Impacted 34,01010305 Area West of Survey Unit #10217 Non-Impacted 121,53510306 Area West of Survey Unit #1 0216 Non-Impacted 85,26810400 Owner Controlled Area Grounds (not included in FSAR)10402 MET Tower Area Non-Impacted 133,56510403 Area North of West Training Non-Impacted

{ 139,28210404 Northwest Corner of Owner Controlled Property Non-Impacted 118,734Page 2 of 22 ATTACHMENT 1Zion Nuclear Power StationSupporting Information for Request for Partial Site Release:Z IO Figure 1, Zion Nuclear Power Station Geographical LocationZl0.OLU17O o 4.75 9.5 Wlo 4.5 9 18 .+...+..

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N N 8,t"It,-,++ M' q, ,Page 3 of 22 ATTACHMENT IZion Nuclear Power StationSupporting Information for Request for Partial Site ReleaseSZ IO NSOLUTIONS Figure 2, Boundaries of Non-Impacted Open Land Survey UnitsPage 4 of 22 ATTACHMENT 1Zion Nuclear Power StationSupporting Information for Request for Partial Site ReleaseSZ I6ONSOLUTIONS~Figure 3, Site Boundary/Non-Impacted Survey Units Corner Coordinates 3418~3342AUt341.23$343J07Page 5 of 22 ATTACHMENT 1Zion Nuclear Power Station Supporting Information for Request .for Partial Site Release ....BACKGROU1ND The Zion Nuclear Power Station (ZNPS) consists of two (Units 1 and 2) Pressurized WaterReactors (PWR). The station is located near the city of Zion in northeast Illinois on the westshore of Lake Michigan.

The site is approximately 40 miles north of Chicago, Illinois and42 miles south of Milwaukee, Wisconsin.

The station was comprised of two essentially identical pressurized water reactors with supporting facilities.

Each unit's primary coolant system consisted of a pressurized water reactor systemdesigned by the Westinghouse Corporation and was comprised of the reactor vessel and four heattransfer loops. Each loop contained a reactor coolant pump, steam generator, and associated piping and valves. In addition, each unit includes a pressurizer, a pressurizer relief tank,interconnecting piping, and the instrumentation necessary for operational control.

All majorcomponents of each unit's reactor coolant system were located in their respective containment building.

The designed reactor thermal power level was 3250 Megawatts thermal (MWth). Thecorresponding electrical output was approximately 1,085 Megawatts electric (MWe) for eachunit.The initial construction of the station was authorized on December 26, 1968. Unit 1 and Unit 2achieved initial criticality on June 19, 1973 and December 24, 1973, respectively.

Next, Unit 1was synchronized to the grid for the first time on June 28, 1973 and Unit 2 onDecember 26, 1973. Finally, Unit 1 and Unit 2 began commercial operation onDecember 31, 1973 and September 19, 1974, respectively.

Between the two units, ZNPSoperated for approximately 248,23 8,983 effective MWhrs over the course of its operating lifetime.

On January 15, 1998, Commonwealth Edison (CoinEd) announced the permanent shutdown ofboth Zion reactors.

The shutdown decision was based on the corporation's economicdeternination that neither Zion reactor would be able to produce competitively priced electricity in a deregulated marketplace over the facility's remaining useful life. On February 13, 1998,CoinEd certified the permanent cessation of operation of ZNPS Units 1 and 2 to the NRC(Reference 1). On March 9, 1998, CoinEd certified to the NRC that all fuel assemblies had beenpermanently removed from both ZNPS reactor vessels and placed in the Spent Fuel Pool(Reference 2). Both units at ZNPS were subsequently placed in a SAFSTOR condition (a periodof safe storage of the stabilized and defueled facility) until eventual final decommissioning anddismantlement.

In 2000, the license was transferred from CornEd to Exelon Nuclear Generation, LLC (lExelon).

On January 25, 2008, Exelon and ZionSolutions, LLC submitted an Application for LicenseTransfers and Conforming Administrative License Amendments to the NRC requesting that theNRC consent to the transfer of Exelon's Facility Operating Licenses for ZNPS to ZionSolutions (Reference 3). On September 1, 2010, the licenses were transferred from Exelon toZionSolutions (Reference 4). ZionSolutions is now the current licensee.

The operating licensesthat were scheduled to expire in April 2013 for Unit 1 and November 2013 for Unit 2 continue toremain in effect until the NRC notifies ZionSolutions that the licenses have been terninated.

Page 6 of 22 ATTACHMENT 1Zion Nuclear Power Station Supporting Information for Request for Partial Site Release.....

EVALUATION OF EFFECT OF PROPOSED RELEASEZionSolutions has evaluated the effect of releasing the subject property from the Part 50 Licensein accordance with the criteria specified in 10 CFR 50.83(a)(1-3) in order to ensure that ZNPSwill continue to comply with all applicable statutory and regulatory requirements that may beaffected by the release of the subj ect property.

Specifically, ZionSolutions' evaluation confirmed the following with respect to each of theregulatory areas identified in 10 CFR 50.83(a)(l)(i)-(vi),

(a)(2) and (a)(3):(a)(1) Evaluate thle effects of releasing dhe property to ensure that:1. The dose to individual members of the public does not exceed the limits and standards of 10 CER Part 20, Subpart D.ZionSolutions strictly controls effluents to ensure radioactivity released to theenvironment is maintained ALARA and does not exceed federal release limit criteria.

Effluent controls include the operation of radiation monitoring systems within the plantas well as an offsite environmental analysis program.

The release of the subject propertydoes not change any controls used to comply with dose limits for individual members ofthe public and the conservatively estimated yearly dose to a member of the public is wellbelow the 10 CFR Part 20, Subpart D limits and standards.

A review of the latest quarterly REMP and boundary TLD readings (see Figure 4) showsthat the highest possible dose to a member of the public is 3.73 mR/year at TLD locationno. 125 just south of the ISFSI fence line. Table 4 provides the yearly dose to a memberof the public at the seven locations closest to site source term. Note, this is the firstquarter results of 2015 with all 61 Vertical Concrete Casks (VCCs) containing spent fueland 4 VCCs containing GTCC on the ISFSI pad. Also, note that up to half of the yearlydose is estimated to be attributed to waste source term on site which will lessen asdecommissioning completes.

Table 2, REMP and Boundary TLD Readings for 1st Quarter of 2015Highest AVG Occupancy Estimates TLD # TLD BKG Neutron m/t Rya(gross (~J~) Factor Hours Factor miit miyr101 20OmR 22.5 mR 0.12 2920 0.33 0.00 0.00110 34rmR 22.5 mR 0.12 160 0.02 0.24 0.94111 29 mR 22.5 mR 0.12 160 0.02 0.13 0.53124 21 mR 22.5 mR 0.12 2920 0.33 0.00 0.00125 25 mR 22.5 mR 0.12 2920 0.33 0.93 3.73129 20 mR 22.5 nmR 0.12 160 0.02 0.00 0.00131 56 mR 22.5 mR 0.12 160 0.02 0.69 2.74Page 7 of 22 ATTACHMENT 1Zion Nuclear Power Station Supporting Information for Request for Partial Site Release .....ii. There is no reduction in the effectiveness of emergency planning or physical security.

No credit is taken for this land in either the Emergency Plan or Security Plan. Therefore, the release of the subject property has no adverse effect on either plan.ii. Effluent releases remain within license conditions.

The ZNPS programs to monitor and maintain effluent releases within license conditions remain in effect and the early release of the subject property does not impact thoseprograms.

Therefore, the effluent releases from ZNPS will remain within licenseconditions.

iv. The environmental monitoring program and offsite dose calculation manual (ODCM)are revised to account for the changes.The owner controlled boundary will remain the same and therefore, the Environmental Monitoring

Program, ODCM and supporting documents are still valid and no changes areneeded.v. The siting criteria of 10 CFR Part 100 continue to be met.The release of the subject property has been reviewed with respect to the siting criteria in10 CFR 100 and it has been determined that the requirements of 10 CFR 100 are eithernot impacted (e.g., 10 CFR 100.11, low population zone or population center distance or10 CFR 100 Appendix A, Seismic and Geologic Siting Criteria) or are not applicable (e.g., 10 CFR 100, Subpart B, Evaluation Factors for Stationary Power Reactor SiteApplication on or after January 10, 1997). ZionSolutions will continue to control theexclusion area and maintain the ability to remove members of the public from theexclusion area in the case of a radiological emergency.

Both reactor vessels have beenpermanently defueled and both reactor internals have been removed from site. The Unit 2reactor vessel has been removed fi'om site. The Unit 1 reactor vessel is in the process ofbeing removed fi'om the site.vi. All other applicable statutoly and regulatory requirements continue to be met.There are no changes to the ZNPS policies and procedures to ensure that statutory andregulatory requirements continue to be met as a result of this early release of the subjectproperty.

In summary, the proposed release of the subject property from the Part 50 License will not haveany impact on the ZNPS facility's continued compliance with applicable NRC regulatory standards.

Page 8 of 22 ATTACHMENT 1Zion Nuclear Power Station Supporting Information for Request for Partial Site Release ....(a)(2) Peiform a historical site assessment of the part of the facility or site to be released.

In accordance with the guidance provided in NUREG-1575, "Multi Agency Radiation Surveyand Site Investigation Manual (MARSSIM)"

(Reference 5), section 3.0, a Historical SiteAssessment (HSA) was performed and documented in September 2006 (Reference 6). Historical information, including any 10 CFR 50.75(g) files, employee interviews, radiological incidentreports, pre-operational survey data, spill reports, special surveys (e.g., site aerial surveys,marine fauna and sediment surveys),

operational survey records, and Annual Radiological Operating Reports (including sampling of air, groundwater, estuary water, milk, invertebrates, fish and surface vegetation) were reviewed and compiled for this investigation.

The I-SA was a detailed investigation to collect existing information (from the start of ZionStation's activities related to radioactive materials or other contaminants) for the site and itssurroundings.

The HSA focused on historical events and routine operational processes thatresulted in the contamination of the plant systems, onsite buildings, surface and subsurface soilswithin the Radiologically Controlled Area (RCA) as well as support structures, open land areasand subsurface soils outside of the RCA, but within the owner controlled area. The information compiled by the HSA was used to establish initial area survey units and classifications andeventually, input into the development of potential site-specific Derived Concentration Guideline Levels (DCGL), development of remediation plans and the design of the Final Radiation Survey(FRS). The scope of the HSA included potential contamination from radioactive materials, hazardous materials, and state-regulated materials.

The HSA investigation was designed to obtain sufficient information to provide initialclassification of the site land areas and structures as impacted or non-impacted.

Impacted areashave a potential for contamination (based on historical data) or contain known contamination (based on past or preliminary radiological surveillance).

MARSSIM defines non-impacted areasas those areas where there is no reasonable possibility of residual contamination.

Based on a review of the operating history of the facility, historical incidents, and operational radiological surveys as documented in the HSA, as well as subsequent characterization surveysdiscussed in the next section, the subject open land areas were deemed not impacted by licensedactivities or materials and therefore, it was determined that the "non-imapacted" classification isappropriate.

(a)(3) Peiforin surveys adequate to demonstrate compliance with the radiological criteria forunrestricted use specified in 10 CER 2 0.1402 for impacted areas.MARSSIM Section 2.5.2 states, "Non-impacted areas represent areas where all of theinformation necessary to demonstrate compliance is available from existing sources.

For theseareas, no statistical tests are considered necessary."

Additionally, Table 2.2 of MARS SIM,"Recommended Conditions for Demonstrating Compliance Based on Survey Unit Classification for a Final Status Survey,"

requires no elevated measurement comparison, no sampling and/ordirect measurements and no scanning to be performed in non-impacted areas. Despite thisavailable waiver, a comprehensive characterization survey was performed.

The site-release criteria for the ZNPS site correspond to the 10 CFR 20.1402 criteria forunrestricted use. The residual radioactivity, including that from ground water sources, that isdistinguishable from background, must not cause the total effective dose equivalent (TEDE) toPage 9 of 22 ATTACHMENT 1Zion Nuclear Power Station Supporting Information for Request for Partial Site Release ....an average member of the critical group to exceed 25 mrem/yr.

The residual radioactivity mustalso be reduced to levels that are ALARA.The characterization survey was designed and executed using the guidance provided inMARSSIM and NUREG-1757, Volume 2, Revision 1, "Consolidated Decommissioning Guidance-Characterization, Survey, and Determination of Radiological

Criteria, Final Report."(Reference 7). In addition, surveys were designed and executed in accordance with theZionSolutions ZS-LT-02, "Characterization Survey Plan," (Reference

8) and ZS-LT-01, "Quality Assurance Project Plan (for Characterization and FSS)" (Reference

9) which describes policy, organization, functional activities, the Data Quality Objective (DQO) process, andmeasures necessary to achieve quality data. In addition to the above, the survey design for thecharacterization of the subject property was implemented in accordance with ZS-LT-03, "SurveyPlan, Non-Impacted Open Land Survey Units" (Reference 10).Areas classified as non-impacted received surveys developed to include a combination ofsystematic and biased survey measurement locations and scan areas. Biased survey designs usedknown information to select locations for static measurements and/or samples.

Systematic surveydesign selected static measurement and/or sample locations at random or by using a systematic sampling design with a random start. The decision of whether to use primarily a biased surveydesign or a systematic approach was addressed by the DQO process for each survey unit.From June to September 2013, sufficient survey coverage and an adequate number of sampleswere obtained in the subject survey units to serve as the basis for the "Non-Impacted" classification.

Within each of the survey units specified, the survey focused primarily on surface(0 to 15 cm) soils. Subsurface (15 to 100 cm) soil samples were included in the survey designonly if the analysis of surface soil samples indicated the presence of detectable plant-derived radioactivity.

The sample and static measurement locations were based on a random design toensure an unbiased survey.The characterization survey of each survey unit consisted of both qualitative evaluations andquantitative analysis results.

The qualitative evaluation consisted of static measurements usingthe Canberra In Situ Object Counting System (ISOCS).

Investigative and verification gammascans using a Ludlum Model 23 50-1 and a Model 44-10 NaI detector were also performed.

Minimum Detectable Concentrations (MDC) and gamma scanning sensitivities were estimated based on the assumed geometry and the potential plant-derived gamma-emitting radionuclides that may be present.

Quantitative analysis results were obtained from radionuclide specificanalysis of surface soil media using a calibrated counting geometry.

Analysis times were set toachieve the required MDCs that were based on the expected Cs-137 background due to global.fallout.

The minimum number of random-based direct measurements was adjusted to approximate one (1) measurement location for every 2,000 m2 of land area. Surface scanning using a NaIdetector was performed in the vicinity of each static measurement location and for investigations of elevated results.

Surface soil samples were taken at 25% of the measurement locations.

Specific ISOCS measurement locations were determined by generating random pairs ofcoordinates that corresponded to specific locations within each survey unit. If a randomlyselected location was found to be either inaccessible or unsuitable (e.g., a portion of the surfacePage 10 of 22 ATTACHMENT 1Zion Nuclear Power Station :ZlONSOLUTIONS;---

Supporting Information for Request for Partial Site Release.....

area in the instruments "Field-of-View" (FOV) was covered in standing water), then the locationwas adjusted to the closest adjacent suitable location.

The "Non-Impacted" subject open land areas at ZNPS totaled 864,563 square meters of surfacearea. The non-impacted surface area was broken into 11 survey units in accordance with the areadescriptions, sizes and boundaries presented in the HSA. Of the 864,563 square meters,182,127 square meters was deemed as "inaccessible".

In this context, "inaccessible" is definedas an area where personnel or vehicle transit was inhibited by the presence of standing water,marsh or wet-lands, thick underbrush, trees or natural grasses where clearing would beprohibitive.

The total surface area deemed "accessible" was 682,436 square meters.Of the 682,436 square meters of surface area, 9,378 square meters were scanned by aModel 2350 paired with a Model 44-10 NaI detector.

Alarm set-points for the instrument wereset at the observed background plus the Minimum Detectable Count Rate (MDCR) of theinstrument.

With an average background of 4,337 cpm, the average observed scan result was4,677 cpm. Twenty-four (24) instrument alarms were logged with a maximum observed scanreading of 9,550 cpm. All alarms were investigated and soil samples were taken at locations where the elevated reading was verified.

In all instances, the elevated readings were attributed toNaturally Occurring Radioactive Material (NORM). Two hundred and thirty-six (236) staticmeasurements were taken with the ISOCS. This equated to a coverage area of 6,608 squaremeters using a 28 square meter FOV. Of the total measurements taken, 75 measurement resultsindicated the presence of Cs-l137 in concentrations greater that the MDC of the instrument butnot in excess of the established background levels.One hundred and sixty-six (166) surface soil samples were taken to verify ISOCS results, or asinvestigations.

Of the total number of surface soil samples taken and analyzed, Cs-137 wasidentified at concentrations greater than the MDC of the instrument in 106 surface soil samplesbut not in excess of the established background levels. Additional detail on the survey andsampling methodology and results of the radiological analysis of each measurement and soilsample obtained during the characterization of non-impacted open land survey units arepresented in ZionSolutions TSD 14-028, "Radiological Characterization Report" (Reference 11)and Chapter 2 of the Zion Station Restoration Project License Tennination Plan (LTP),(Reference 12). Based upon the results of the characterization surveys performed of the non-impacted open land areas, it can be concluded that a non-impacted classification for these areasis appropriate.

Cs-137 was the only radionuclide positively identified that could potentially beclassified as plant-derived.

However, the concentrations observed are well within the range ofactivity defined as background due to global fallout.

The locations of ISOCS measurements andsurface soil samples are illustrated on Figure 4. A summary of the findings of the survey for eachindividual survey unit are presented in Table 3.Non-impacted areas are defined in MARS SIM as areas that have no reasonable potential forresidual contamination, no radiological impact from site operations and are typically identified during the HSA. ZionSolutions has found no evidence of using, storing, or burying radioactive material in the subject property.

None of the event records in the HSA indicated the uncontrolled release of radioactive material to the subject property.

Therefore, it can be concluded that therelease of the subject property will have no adverse impact on the ability of the ZNPS site inaggregate to meet the Part 20, Subpart E requirements for unrestricted release.Page 11 of 22 ATTACHMENT 1Zion Nuclear Power StationSupporting Information for Request for Partial Site ReleaseSZ I ONSOLUTIONS Figure 4, Non-Impacted Open Land Survey Units Measurement and Sample Locations Page 12 of 22 ATTACHMENT 1Zion Nuclear Power StationSupporting Information for Request for Partial Site ReleaseSZ IO NSOLUTIONS Table 3, Non-Impacted Open Land Survey Units -Characterization Survey Summary1021$ 10216 10217Surv ey 1t i iSurface AreaDescription SraesoilSipe

1. of Samples# >MDCMeanMedianMaxMinStandard Deviation

1. of Measurements

1. >MDCMeanMedianMaxMinStandard Deviation

% Scanned# of AlarmsMean ScanMax Scan26,007.80 m2Area Northwest of Switchyard 4 40 0<0.06 pCi/g <0.09 pCiig<0.05 pCi/g <0.09 pCi/g<0.09 pCi/g <0.10 pCi/g<0.04 pCi/g <0.08 pCi/gN/A N/A14 140 1<0.04 pCiig 0.05 pCi/g<0.04 pCi/g 0.05 pCi/g<0.05 pCi/g 0.05 pCi/g<0.02 pCi/g 0.05 pCi/gN/A N/A1%03,995 cpm4,725 cpm1) 9 of 14 samples in west sectionof survey unit were relocated asarea was deemed asinaccessible.

2) Additional ISOCS measurement

(#14) was taken on discovered debris pile.31,171.10 mn2Area West of Switchyard 4 40 3<0.04 pCi/g 0.23 pCi/g<0.04 pCi/g 0.23 pCi/g<0.05 pCi/g 0.26 pCi/g<0.01 pCi/g 0.20 pCi/gN/A 0.0316 160 8<0.04 pCiig 0.19 pCi/g<0.04 pCi/g 0.27 pCi/g<0.05 pCi/g 0.27 pCi/g<0.03 pCi/g 0.07 pCi/gN/A 0.071%04,828 cpm5,389 cpm1) 9 of 16 samples in west sectionof survey unit were relocated asarea was deemed asinaccessible.

50,880.20 m2Area Southwest of Switchyard 7 70 7<0.05 pCi/g 0.41 pCi/g<0.05 pCi/g 0.43 pCi/g<0.06 pCi/g 0.52 pCi/g<0.05 pCi/g 0.26 pCi/gN/A 0.09C-0C-3727 270 10<0.04 pCi/g 0.20 pCi/g<0.04 pCi/g 0.21 pCi/g<0.06 pCi/g 0.30 pCi/g<0.04 pCi/g 0.04 pCi/gN/A 0.081%04,563 cpm5,070 cpm1) 3 additional judgmental ISOCSmeasurement locations wereadded to account for additional area.2) 1 additional ISOCSmeasurement added fordiscovered abandoned drainpipe.Page 13 of 22 ATTACHMENT 1Zion Nuclear Power StationSupporting Information for Request for Partial Site Release: ZIONSOLUTIONS

-Table 3, Non-Impacted Open Land Survey Units -Characterization Survey Summary (continued)

V I 10304Surface AreaDescription

1. of Samples# >MDCMeanMedianMaxMinStandard Deviation

1. of Measurements

1. >MDCMeanMedianMaxMinStandard Deviation

% Scanned# of AlarmsMean ScanMax Scan64,739.50 m2 ....Northwest Corner of FSAR Area11 110 9<0.05 pCi/g 0.30 pCiig<0.06 pCi/g 0.27 pCi/g<0.08 pCiig 0.46 pCilg<0.02 p~i/g 0.12 pCi/gN/A 0.1119 190 7<0.05 pCi/g 0.25 pCi/g<0.05 pCi/g 0.22 pCi/g<0.06 pCi/g 0.34 pCi/g<0.04 pCi/g 0.20 pCi/gN/A 0.061%04,951 cpm7,474 cpm1) 33 designed locations reduced to22 due to accessibility.

2) 3 of 22 locations scanned withNaI & soil sample only.3) 6 of 18 ISOCS taken at height of1 meter due to obstructions

-FOV =3 in2.....68,847.10

.... 2mSouthwest Corner of FSAR Area25 250 13<0.06 pCiig 0.17 pCi/g<0.06 pCi/g 0.15 pCi/g<0.10 pCi/g 0.39 pCi/g<0.02 pCi/g 0.06 pCi/gN/A 0.1018 180 9<0.05 pCi/g 0.21 pCi/g<0.05 pCi/g 0.23 pCi/g<0.06 pCi/g 0.30 pCi/g<0.03 pCi/g 0.09 pCi/gN/A 0.071%75,858 cpm9,550 cpmn1) 35 designed locations reduced to18 due to accessibility.

2) 5 of 18 locations scanned withNaI & soil sample only.3) 17 additional random and 3additional judgmental soilsamples taken.34,009.70 in2Southern Area of FSARC-0Cs-137 5 50 3<0.05 pCi/g 0.26 pCi/g<0.06 pCi/g 0.23 pCi/g<0.07 pCilg 0.35 pCi/g<0.02 pCi/g 0.21 pCi/gN/A 0.0817 170 8<0.04 pCi/g 0.17 pCi/g<0.04 pCi/g 0.16 pCi/g<0.05 pCi/g 0.27 pCi/g<0.02 pCi/g 0.09 pCi/gN/A 0.061%44,456 cpmn5,704 cpmn1) 16 of 17 random locations relocated due to accessibility.

Page 14 of 22 ATTACHMENT 1Zion Nuclear Power StationSupporting Information for Request for Partial Site ReleaseSZ I ONSOLUTIONS Table 3, Non-Impacted Open Land Survey Units -Characterization Survey Summary (continued)

U 10402sure ~~Surface AreaDescription

1. of Samples# >MDCMeanMedianMaxMinStandard Deviation

1. of Measurements

1. >MDCMeanMedianMaxMinStandard Deviation

% Scanned# of AlarmsMean ScanMax ScanN otes ii~ii~iiiiiii

!l121,535.20 mn2Area West of Survey Unit #1021717 170 4<0.05 pCi/g 0.19 pCilg<0.05 pCi/g 0.18 pCi/g<0.08 pCi/g 0.33 pCi/g<0.01 pCi/g 0.07 pCi/gN/A 0.1461 610 10<0.04 pCi/g 0.19 pCiig<0.04 pCi/g 0.20 pCi/g<0.06 pCi/g 0.30 pCi/g<0.03 pCi/g 0.08 pCi/gN/A 0.061%95,473 cpmn7,343 cpm85,267.80 m2Area West of Survey Unit#10216Co6 C-i374 40 4<0.05 pCi/g 0.26 pCi/g<0.04 pCi/g 0.23 pCi/g<0.08 pCi/g 0.40 pCi/g<0.02 pCi/g 0.20 pCilgN/A 0.0918 180 14<0.04 pCi/g 0.17 pCi/g<0.04 pCi/g 0.17 pCi/g<0.06 pCi/g 0.27 pCi/g<0.01 pCi/g 0.08 pCi/gN/A 0.051%04,407 cpm5,337 cpm1) 43 designed ISOCSmeasurement locations reducedto 18 due to accessibility.

2) 4 of 18 locations scanned withNaI & soil sample only.133,565.00 mn2MET Tower Area41 410 31<0.04 pCi/g 0.20 pCi/g<0.04 pCi/g 0.18 pCi/g<0.07 pCi/g 0.42 pCi/g<0.01 pCi/g 0.04 pCi/gN/A 0.10C-6 s339 390 5<0.05 pCi/g 0.10 pCi/g<0.05 pCi/g 0.11 pCi/g<0.08 pCi/g 0.12 pCi/g<0.03 pCi/g 0.07 pCi/gN/A 0.021%04,835 cpm5,543 cpm1) 67 designed ISOCSmeasurement locations reducedto 39 due to accessibility.

2) 30 additional random locations designated for NaI scanningand surface soil samples.APage 15 of 22 ATTACHMENT 1Zion Nuclear Power StationSupporting Information for Request for Partial Site Release: Z ION SOLUIONS Table 3, Non-Impacted Open Land Survey Units -Characterization Survey Summary (continued)

I04~.... Surface AreaDescription

1. of Samples# >MDCMeanMedianMaxMinStandard Deviation

1. of Measurements

1. >MDCMeanMedianMaxMinStandard Deviation Surac $I u% Scanned# of AlarmsMean ScanMax Scan1........

39,282.00 mArea North of West Training18 180 12<0.04 pCi/g 0.18 pCi/g<0.04 pCiig 0.17 pCi/g<0.07 pCi/g 0.39 pCi/g<0.01 pCi/g 0.05 pCi/gN/A 0.09Co-6%C Cr437 70 3<0.04 pCi/g 0.19 pCiig<0.04 pCiig 0.19 pCilg<0.05 pCi/g 0.23 pCi/g<0.03 pCi/g 0.14 pCiigN/A 0.04<1%43,959 cpm5,310 cpm1) Approximately 90% of areawas inaccessible to the ISOCS.2) 70 ISOCS measurements reduced to 7.3) 4.8% of accessible 13,928 m2of land area scanned.4) 16 additional random locations designated for NaI scanningand surface soil samples.118,735.00 m2NW Corner of Owner Controlled Property30 300 20<0.04 pCi/g 0.20 pCi/g<0.04 pCi/g 0.20 pCi/g<0.06 pCi/g 0.57 pCi/g<0.01 pCi/g 0.02 pCi/gN/A 0.140 00 0N/A pCi/g N/A pCilgN/A pCi/g N/A pCi/gN/A pCi/g N/A pCi/gN/A pCi/g N/A pCi/gN/A N/A1%03,391 cpm6,964 cpm1) 60 ISOCS locations weredesigned.

Entire area wasinaccessible to the ISOCS. Tocompensate, additional scan andsoil sample locations wereevenly distributed in areas thatwere accessible.

The total areascanned equates to 1,200 m , orapproximately 1%.Page 16 of 22 ATTACHMENT 1Zion Nuclear Power Station :ZIONSOLUTIONS.--;

Supporting Information for Request for Partial Site Release .. .. 'DESCRIPTION OF THE PROPERTYFor non-impacted areas, 10 CFR 50.83 (b)(2) requires a description of the part of the facility orsite to be released.

The owner-controlled site is approximately 331 acres in size. For ZNPS, thenon-impacted open land areas include most of the surrounding Exelon owned land outside of thefootprint of the 87 acre, fence-enclosed "Radiologically-Restricted Area." The property that issubject to this release request is an approximately 214 acre parcel of uninhabited, essentially undeveloped land that has not been negatively impacted by ZNPS operations or subsequent decommissioning activities.

The ZNS property is located in the extreme eastern portion of the City of Zion in Lake County,Illinois on the west shore of Lake Michigan.

Although the Site encompasses approximately 331acres, it is relatively isolated as the property is bordered to the north and south by Illinois BeachState Park, a small industrial area followed by railroad tracks to the west and Lake Michigan tothe east. The center of the community of Zion is approximately 1.6 miles from the plant locationon the Site. There are no schools or hospitals within one mile and there are no residences within2,000 feet of station structures.

Based upon the information compiled in the HSA, thirteen (13) large outlying open land surveyunits received an initial classification as "non-impacted,"

but were subsequently reduced toeleven (11) survey units when two of these areas were deemed "impacted" as a result of thecharacterization or review of past use. These include the site parking lot and the area alongShiloh Boulevard designated as the West Training area. The parking lot was designated asimpacted because it represents the major path for material egress on and off of the site. The WestTraining area was the location of a former Westinghouse training reactor that wasdecommissioned in 1988 (NRC License # R-1 19, Docket # 50-87). Therefore, the 214 acreparcel of land that is subject to this request has been sub-divided into eleven (11) survey units.Non-impacted areas have no reasonable potential for residual contamination because historical information indicates there was no known impact fr'om site operations.

These include theoutlying open land areas of the site, as well as contiguous areas that have no impact from siteoperations based upon the location(s) of licensed operations, site use, topography, site discharge locations, and other site physical characteristics.

These areas are not required to be surveyed fordemonstrating compliance beyond any characterization surveys performed to provide a basis forthe classification.

Portions of the 214 acre parcel have limited access for personnel or vehicle transit due to thepresence of standing water, marsh or wetlands, thick underbrush, trees or natural grasses.

Surveyunit 10402 contains an area for public parking and a travel path to Hosah Park. A meteorological tower, previously located in survey unit 10402, has been removed.

A portion of the site railsystem traverses survey units 10402, 10403 and 10404 and rail cars loaded with low levelradioactive waste are sometimes staged in the area while awaiting transfer to a disposal facility.

Note, the exterior of the rail cars are always checked for loose surface contamination prior tothem leaving the "Radiologically-Restricted Area." A CoinEd substation is located in survey unit10302. A roadway (gated) to the ISFSI traverses survey units 10215, 10216 and 10217. Surveyunit 10304, located in the southern most area of the site, is frequently traversed by members ofthe public as this area adjoins a nearby campground to the south of the site.Page 17 of 22 ATTACHMENT 1Zion Nuclear Power Station :ZIONSOLUTIONSy-:

Supporting Information for Request for Partial Site Release......

"SCHEDULE FOR SUBJECT PROPERTY RELEASEFor non-impacted areas, 10 CFR 50.83 (b)(3) requires the schedule for release of the property.

ZionSolutions intends to begin undertaking activities associated with the release of the subjectproperty from the ZNPS Part 50 License on or before March 21, 2016. Therefore, ZionSolutions requests that the NRC approve the acceptability of the release of the subject property from thePart 50 License by February 28, 2016.RESULTS OF 10CFR 50.59 EVALUATION 10 CFR 50.83(b)(4) requires for non-impacted areas that the licensee submit the results of theevaluation performed in accordance with 10 CFR 50.59. The assessment of the release of thesubject property is as follows:The partial site release involves approximately 214 acres of non-impacted land out of theapproximate 331 acres the site owns. The release does not involve property that is actively usedby the plant for routine or decommissioning operations or that is needed for the site's emergency plan.The 10 CFR 50.59 review assessed the impact of the change in the site boundary on offsite dosecalculations and effluent releases and concluded that the change:* does not adversely affect any design function as described in the Defueled SafetyAnalysis Report (DSAR)(Reference 13)* does not adversely affect how a design function as described in the DSAR is performed or controlled

• does not revise or replace an evaluation method used to establish design basis or safetyanalysis, and* does not involve a test or experiment not described in the DSAR.ENVIRONMENTAL IMPACTSUnder 10 CFR 50.83 (b)(5), a request for NRC approval of a release of non-impacted areas mustinclude the reasons for concluding that the environmental impacts associated with the proposedrelease of property will be bounded by appropriate previously issued Environmental ImpactStatements.

The original Final Environmental Statement (FES) for the ZNPS was issued inDecemnber 1972 (Reference 14).More recently, in connection with the development of the License Termination Plan, Chapter 8,"Supplement to the Environmental Report,"

was prepared (and submitted to the NRC inDecember 2014) to describe any new information or significant environmental changesassociated with the site-specific decommissioning and site closure activities performed at ZNPS.The supplement includes a detailed description of the remaining decommissioning and siteclosure activities, the interaction between those activities and the environment, and the likelyenvironmental impact of those activities.

The supplement discusses whether the activities andPage 18 of 22 ATTACHMENT 1Zion Nuclear Power Station :ZIONSOLUTIONST=

Supporting Information for Request for Partial Site Release ..... °their impacts are bounded by the impacts predicted in the original FES. Chapter 8 of the LicenseTermination Plan concludes the non-radiological environmental impacts from decommissioning are temporary and not significant.

ZionSolutions has evaluated the environmental impacts associated with the proposed release ofthe subject property and considered those impacts in light of the original FES and Chapter 8 ofthe License Termination Plan. The evaluation did not identify any significant new environmental impacts or any significant changes from the environmental impacts previously

assessed, orcurrently being assessed, by the NRC. In particular, the evaluation found as follows:* The land transfer will have no more than a negligible increase in offsite doseconsequences and no change in effluent releases.

• The ZNPS radiological monitoring program will account for the revised site areaboundary, and no increases in effects are anticipated.

Accordingly, ZionSolutions concludes that the environmental impacts associated with theproposed release of the subject property are bounded by the NRC's previous or current reviews,of the ZNPS facility.

ADDITIONAL AREAS TO BE ADDRESSED TO SUPPORT RELEASE OFTHE SUBJECT PROPERTYStatement of Dismantling Activities No dismantlement activities are required in the subject survey units.Potential for Cross-Contamination from Subsequent Activities The potential for cross-contamination of the subject non-impacted areas due to subsequent decommissioning activities is diminutive.

The subject areas are bounded on the north by IllinoisState Department of Conservation (ISDC) property, the west by general industrial zoned areasand Zion Park District

property, the south by ISDC property (camp ground) and the east byHosah Park, the north contractor parking lot and VCC Pad area (both MARSSIM Class 3 surveyunits), the Switchyard and the ISFSJ. It is highly unlikely that radioactive materials could beintroduced into the subject survey units via these borders.

Characterization surveys performed inthe Class 3 land areas show that residual contamination levels are below those established forunrestricted use. Since decommissioning activities are being conducted onsite in parallel withfinal status survey and release decisions, measures have been taken to protect these adjacentsurvey areas from contamination during and subsequent to the FSS. The LTP Section 5.6.3describes isolation and control measures during and following the FSS. Isolation and controlmeasures in owner-controlled areas adjacent to the subject property have been implemented through approved procedures and will remain in force throughout site final survey activities anduntil there is no undue risk of recontamination from decommissioning.

In the event that isolation and control measures established for these survey areas are compromised, evaluations will beperformed and documented to confirm that no radioactive material was introduced into the areaPage 19 of 22

.ATTACHMENT 1Zion Nuclear Power Station Supporting Information for Request for Partial Site Release......

°that would affect the results of the FSS. Given the isolation and controls established for the FSSareas adjacent to the subject property it is highly unlikely that radioactive materials could beintroduced into the subject property borders.

Radioactive material generated during thedecommissioning process will be handled and controlled in a manner to prevent contamination of the subject non-impacted areas. These controls include contamination containment, dustcontrol measures, storm water runoff control measures, and proper radiological protection program implementation (including periodic surveillances).

Additionally, open-air demolition controls of primary side structures are implemented to limit the spread of contamination duringdemolition (limits on residual contamination levels that allow for the open-air demolition ofprimary side structures without adverse effects on the environment have been established.

Priorto structure demolition, a Contamination Verification Survey is performed to verify the residualcontamination levels are below the established limits).Impact of Releasing the Subject Property on Part 50 License BasisThe license basis for the ZNPS includes the maintenance of certain programs to fulfill regulatory requirements and functional responsibilities.

Throughout decommissioning, these programs aremodified as necessary and terminated when the applicable concern is no longer relevant.

Theseprogram changes are implemented using the change processes specified for each type ofprogram.

The methodology for releasing land requires a review and assessment of the impact onlicense program for the site lands remaining within the domain of the Part 50 License.* The Technical Specifications are not impacted by the early release of the subjectproperty.

• The Defueled Safety Analysis Report (DSAR) will require minor changes to describe thereduced site licensed area boundaries resulting from the release of the subject propertyfrom the Part 50 License.* The Radiological Groundwater Protection Program will not be affected by early releaseof the subject property.

• The Fire Protection Program will not be affected by early release of the subject property.

• The Training Program will not be affected by the early release of the subject property.

• The License Termination Plan (LTP), currently being reviewed by the NRC, will berevised to describe the reduced site area resulting from the release of the subject property.

CONCLUSION The release of the subject property is part of ZionSolutions' overall efforts to terminate the ZNPSPart 50 License and to achieve unrestricted release of the entire site (with the exception of theISFSI area) in accordance with the criteria in subpart E of 10 CFR 20.In addition, 10 CFR 50.82(a)(1

1) establishes the criteria to be used by the NRC for terminating license of a power reactor facility.

These criteria include (1) dismantlement has been performed in accordance with the approved license termination plan and, (2) the final radiation survey andassociated documentation demonstrate that the facility and site have met the criteria fordecommissioning in 10 CFR 20, Subpart E. This early release of the subject property area alsoPage 20 of 22 ATTACHMENT 1Zion Nuclear Power Station :ZIONSOLUTIONSLW----

Supporting Information for Request for Partial Site Release ..... °supports the process of license termination by demonstrating that this portion of the site landscan be released from ZNPS license.

This report along with future reports provides documentation that demolition activities have been performed in accordance with the LTP and thecharacterization survey confirms the residual radioactivity in each survey unit meets the criteriaestablished in the LTP. Thus this action of the early release of the subject land supports theoverall license termination process in accordance with NRC regulations.

In summary, based on the considerations discussed above, this release of the subject propertyfrom the ZNPS Part 50 License has no impact on ZionSolutions' continued compliance withapplicable NRC regulatory standards.

ZionSolutions has determined that we have adequately evaluated the effect of releasing the subject property, and that the release area has been properlyclassified as "non-impacted."

Accordingly, ZionSolutions is requesting the NRC to approve therequested release.Page 21 of 22 ATTACHMENT 1Zion Nuclear Power Station :ZIONSOL UTIONS Supporting Information for Request for Partial Site Release....

°REFERENCES

1) Letter from 0. Kingsley Jr. (Commonwealth Edison) to NRC, "Certification ofPermanent Cessation of Operations"

-February 13, 19982) Letter from 0. Kingsley Jr. (Commonwealth Edison) to NRC, "Certification ofPermanent Fuel Removal" March 9, 19983) Letter from T.S. O'Neill (Exelon Generation Company) and J. Christian (ZionSolutions) to NRC, "Application for License Transfers and Conforming Administrative License Amendments"

-January 25, 20084) Letter from J.B. Hickman (U.S. Nuclear Regulatory Commission) to J. Christian (ZionSolutions),

"Issuance of Conforming Amendments Relating to Transfer ofLicenses for Zion Nuclear Power Station, Units 1 and 2" -September 1, 20105) U.S. Nuclear Regulatory Commission NUREG-1575, Revision 1, "Multi-Agency Radiation Survey and Site Investigation Manual (MARS SIM)" -August 20006) "Zion Station Historical Site Assessment" (HSA) -September 20067) U.S. Nuclear Regulatory Commission NUREG-1757, Volume 2, Revision 1,"Consolidated Decommissioning Guidance

-Characterization, Survey, andDetermination of Radiological

Criteria, Final Report" -September 20038) ZionSolutions ZS-LT-02, "Characterization Survey Plan," Revision 3, July 6, 20159) ZionSolutions ZS-LT-0 1, "Quality Assurance Project Plan (for Characterization andFSS)" (QAPP), Revision 2, February 10, 201410O) ZionSolutions ZS-LT-03, "Survey Plan, Non-Impacted Open Land Survey Units,"Revision 1, June 11, 201311) ZionSolutions Technical Support Document 14-028, "Radiological Characterization Report,"

Revision 0, December 15, 201412) "Zion Station Restoration Project License Termination Plan, "Revision 0,December 19, 201413) Zion Station "Defueled Safety Analysis Report (DSAR),"

March 201514) U.S. Atomic Energy Commission, Directorate of Licensing, "Final Environmental Statement related to the Operation of Zion Nuclear Power Station Units 1 and 2",Docket Nos. 50-295 and 50-304 -December 1972Page 22 of 22