ML17215A136

Restoration Project License Termination Plan Chapter 2, Revision 1 Site Characterization.

ML17215A136
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	07/20/2017
From:	ZionSolutions
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML17215A095	List: ML17215A098 ML17215A102 ML17215A109 ML17215A110 ML17215A112 ML17215A113 ML17215A114 ML17215A115 ML17215A117 ML17215A118 ML17215A129 ML17215A130 ML17215A131 ML17215A135 ML17215A136 ML17215A137 ML17215A138 ML17215A139 ML17215A140 ML17215A141 ZS-2017-0084, Restoration Project License Termination Plan Chapter 8, Revision 1 Supplement to the Environmental Report.
References
ZS-2017-0084
Download: ML17215A136 (195)

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN CHAPTER 2, REVISION 1 SITE CHARACTERIZATION

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

2. SITE CHARACTERIZATION 2-1 2.1. Historical Site Assessment .................................................................................................. 2-2 2.1.1. Objectives .................................................................................................................... 2-2 2.1.2. Methodology ................................................................................................................ 2-3 2.1.2.1. Preliminary Classification ...................................................................................... 2-4 2.1.2.2. Documents Reviewed ............................................................................................ 2-4 2.1.2.3. Licenses, Permits and Authorizations .................................................................... 2-5 2.1.2.4. Personnel Interviews .............................................................................................. 2-5 2.1.3. Operational History...................................................................................................... 2-6 2.1.4. Incidents ....................................................................................................................... 2-7 2.1.4.1. Radiological Spills ................................................................................................. 2-7 2.1.4.2. Chemical Spills ...................................................................................................... 2-8 2.1.4.3. Loss of Radioactive Material Control .................................................................... 2-8 2.1.4.4. System Cross-Contamination ................................................................................ 2-9 2.1.5. Findings and Conclusions ............................................................................................ 2-9 2.1.6. Initial Survey Units and Classification ...................................................................... 2-10 2.1.6.1. Survey Areas ........................................................................................................ 2-10 2.1.6.2. Survey Units......................................................................................................... 2-11 2.2. Characterization Approach ................................................................................................ 2-15 2.2.1. Data Quality Objectives ............................................................................................. 2-16 2.2.2. Survey Design ............................................................................................................ 2-17 2.2.2.1. Number of Static Measurements and/or Samples ................................................ 2-17 2.2.2.2. Determination of Static Measurement or Sample Locations ............................... 2-18 2.2.2.3. Scan Coverage ..................................................................................................... 2-18 2.2.2.4. Types of Measurements or Samples .................................................................... 2-18 2.2.3. Instrumentation Selection, Use and Minimum Detectable Concentrations (MDCs) . 2-20 2.2.3.1. Instrument Calibration ......................................................................................... 2-20 2.2.3.2. Instrument Use and Control ................................................................................. 2-21 2.2.4. Laboratory Instrument Methods And Sensitivities .................................................... 2-21 2.2.5. Quality Assurance ...................................................................................................... 2-21 2.3. Summary of Characterization Survey Results .................................................................. 2-22 2.3.1. Background Studies ................................................................................................... 2-23 2.3.1.1. EnergySolutions Background Study .................................................................... 2-23 2.3.1.2. Crib House Concrete Study ................................................................................. 2-24 2.3.1.3. ZionSolutions Soil Background Study ................................................................. 2-25 2.3.1.4. Technical Support Document Regarding Cs-137 Global Fallout ........................ 2-26 2.3.2. Potential Radionuclides of Concern........................................................................... 2-26 2.3.3. Impacted Structures and Systems .............................................................................. 2-26 2.3.3.1. Unit 1 and Unit 2 Containments .......................................................................... 2-27 2.3.3.2. Auxiliary Building ............................................................................................... 2-30 2.3.3.3. Fuel Handling Building........................................................................................ 2-33 2.3.3.4. Turbine Building .................................................................................................. 2-34 2.3.3.5. Service Water Intake and Discharge Structure .................................................... 2-35 2-i

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 2.3.3.6. Support Buildings and Miscellaneous Structures ................................................ 2-36 2.3.3.7. Embedded or Buried Pipe .................................................................................... 2-36 2.3.4. Non-Impacted Open Land Areas ............................................................................... 2-37 2.3.4.1. Surface Soils ........................................................................................................ 2-39 2.3.4.2. Subsurface Soils ................................................................................................... 2-40 2.3.5. Impacted Open Land Areas ....................................................................................... 2-40 2.3.5.1. Surface Soils and Paved Areas ............................................................................ 2-41 2.3.5.2. Subsurface Soils ................................................................................................... 2-44 2.3.6. Surface and Groundwater .......................................................................................... 2-45 2.3.6.1. Area Groundwater Use ........................................................................................ 2-45 2.3.6.2. Groundwater Flow ............................................................................................... 2-46 2.3.6.3. Previous Investigations ........................................................................................ 2-46 2.3.6.4. On-Going Investigations ...................................................................................... 2-47 2.3.6.5. Summary of Analytical Results in Groundwater ................................................. 2-47 2.3.6.6. Summary of Analytical Results in Surface Water ............................................... 2-48 2.4. Hazardous Material Characterization ................................................................................ 2-48 2.5. Continuing Characterization ............................................................................................. 2-49 2.6. References ......................................................................................................................... 2-52 2-ii

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 LIST OF TABLES Table 2-1 Operational History.................................................................................................... 2-55 Table 2-2 Historical Incidents/Occurrence................................................................................. 2-59 Table 2-3 Initial List of Structural Survey Units ........................................................................ 2-86 Table 2-4 Initial List of Open Land Survey Units.................................................................... 2-100 Table 2-5 Scan Coverage Guidelines for Characterization ...................................................... 2-103 Table 2-6 Instrument Types and Nominal MDC...................................................................... 2-104 Table 2-7 Typical Vendor Laboratory Standard MDC Values ................................................ 2-105 Table 2-8 EnergySolutions Background Study Results ........................................................... 2-106 Table 2-9 Crib House Concrete Core Sample Analysis Results .............................................. 2-108 Table 2-10 Hosah Park Background Assessment Sample Analysis .......................................... 2-109 Table 2-11 Investigative Levels for Cs-137 Based on Background Studies .............................. 2-110 Table 2-12 Initial Suite of Radionuclides................................................................................... 2-111 Table 2-13 Nominal Radiological Data - Structural Survey Units ............................................ 2-112 Table 2-14 Unit 1 Containment 568 Foot Elevation Concrete Core Sample Analysis Summary .................................................................................................. 2-121 Table 2-15 Unit 1 Bio-Shield Concrete Core Samples Gamma Spectroscopy Analysis ........... 2-122 Table 2-16 Unit 2 Containment 568 Foot Elevation Concrete Core Sample Analysis Summary .................................................................................................. 2-123 Table 2-17 Unit 1 Containment 541 Foot Elevation Concrete Core Sample Analysis Summary .................................................................................................. 2-124 Table 2-18 Unit 2 Containment 541 Foot Elevation Concrete Core Sample Analysis Summary .................................................................................................. 2-125 Table 2-19 Unit 1 Containment Concrete Core Samples - Eberline Laboratory Analysis ........ 2-126 Table 2-20 Unit 2 Containment Concrete Core Samples - Eberline Laboratory Analysis ........ 2-127 Table 2-21 Radionuclide Distributions for Unit 1 and Unit 2 Containments ............................ 2-128 Table 2-22 Auxiliary Building 542 Foot Elevation Concrete Core Sample Analysis Summary .................................................................................................. 2-130 Table 2-23 Auxiliary Building Concrete Core Samples - Eberline Laboratory Analysis ......... 2-131 Table 2-24 Radionuclide Distribution for the Auxiliary Building ............................................. 2-132 Table 2-25 Turbine Building 560 Foot and 570 Foot Elevation Concrete Core Sample Analysis Summary ..................................................................................... 2-133 Table 2-26 Turbine Building 560 Foot Elevation Floor Drain System Sediment Samples Gamma Spectroscopy Analysis ................................................................ 2-134 Table 2-27 Non-Impacted Open Land Survey Units - Characterization Survey Summary ...... 2-135 Table 2-28 Recommended Judgmental Sample Population Size ............................................... 2-139 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary .. 2-140 Table 2-30 Impacted Class 2 Open Land Survey Units - Characterization Survey Summary .. 2-150 Table 2-31 Impacted Class 1 Open Land Survey Units - Characterization Survey Summary .. 2-152 Table 2-32 Surface and Subsurface Soil Samples - Eberline Laboratory Analysis .................. 2-155 2-iii

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 LIST OF FIGURES Figure 2-1 Zion Nuclear Power Station Owner Controlled Area .............................................. 2-156 Figure 2-2 Zion Nuclear Power Station Radiologically Restricted Area (RRA) ...................... 2-157 Figure 2-3 Zion Nuclear Power Station Security Restricted Area ............................................ 2-158 Figure 2-4 Non-Impacted Open Land Survey Units.................................................................. 2-159 Figure 2-5 Class 3 Open Land Survey Units Outside of Radiologically-Restricted Area ..... 2-160 Figure 2-6 Class 3 Open Land Survey Units Inside of Radiologically-Restricted Area ....... 2-161 Figure 2-7 Class 1 and Class 2 Open Land Survey Units.......................................................... 2-162 Figure 2-8 Unit 1 Containment 568 foot el. Class 1 Survey Units ............................................ 2-163 Figure 2-9 Unit 1 Containment 541 foot el. Class 1 Survey Units ............................................ 2-164 Figure 2-10 Unit 2 Containment 568 foot el. Class 1 Survey Units ........................................... 2-165 Figure 2-11 Unit 2 Containment 541 foot el. Class 1 Survey Units ........................................... 2-166 Figure 2-12 Auxiliary Building 542 foot el. Class 1 Survey Units ............................................. 2-167 Figure 2-13 Auxiliary Building 560 foot el. Class 1 Survey Units ............................................. 2-168 Figure 2-14 Auxiliary Building 579 foot el. Class 1 Survey Units ............................................. 2-169 Figure 2-15 Turbine Building 560 and 570 Foot Elevations Class 2 Survey Units .................... 2-170 Figure 2-16 Crib House Suction Forebay Class 2 Survey Units ................................................. 2-171 Figure 2-17 Independent Spent Fuel Storage Installation ........................................................... 2-172 Figure 2-18 Vertical Concrete Cask Construction Area ............................................................. 2-173 Figure 2-19 Energy Solutions Background Study Locations ...................................................... 2-174 Figure 2-20 Zion City Park Districts Hosah Park Background Study Location .................... 2-175 Figure 2-21 Unit 1 Containment 568 foot el. Concrete Core Sample Locations ........................ 2-176 Figure 2-22 Unit 1 Containment 541 foot el. Concrete Core Sample Locations ........................ 2-177 Figure 2-23 Unit 2 Containment 568 foot el. Concrete Core Sample Locations ........................ 2-178 Figure 2-24 Unit 2 Containment 541 foot el. Concrete Core Sample Locations ........................ 2-179 Figure 2-25 Auxiliary Building 542 foot el. Concrete Core Sample Locations ......................... 2-180 Figure 2-26 Turbine Building 560 foot el. and Steam Tunnel 570 foot el. Concrete Core Sample Locations ........................................................................................... 2-181 Figure 2-27 Turbine Building 560 foot el. Floor Drain System Sediment Sample Locations.... 2-182 Figure 2-28 Non-Impacted Open Land Survey Units Measurement and Sample Locations ...... 2-183 Figure 2-29 Class 3 Open Land Survey Units Located Outside of the Radiologically-Restricted AreaMeasurement and Sample Locations ................. 2-184 Figure 2-30 Class 3 Open Land Survey Units Located Inside of the Radiologically-Restricted Area Measurement and Sample Locations ................ 2-185 Figure 2-31 Class 2 Open Land Survey Units Measurement and Sample Locations ................. 2-186 Figure 2-32 Class 1 Open Land Survey Units Measurement and Sample Locations ................. 2-187 Figure 2-33 ZNPS Locations of Outfalls, Groundwater Monitoring Wells and Surface Water Sampling Locations ......................................................................... 2-188 2-iv

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 LIST OF ACRONYMS AND ABBREVIATIONS ALARA As Low As Reasonably Achievable ComEd Commonwealth Edison CR Condition Reports CRA Conestoga-Rovers & Associates CVS Contamination Verification Survey DCGL Derived Concentration Guideline Level DOE Department of Energy DQO Data Quality Objective ENC Engineering and Construction EPA Environmental Protection Agency ESCSG Energy Solutions Commercial Services Group Exelon Exelon Generation Company FOV Field of View FSS Final Status Survey GPS Global Positioning System HSA Historical Site Assessment HTD Hard to Detect IDNS Illinois Department of Nuclear Safety ISOCS In Situ Object Counting System IRSF Interim Radioactive Waste Storage Facility ISFSI Independent Spent Fuel Storage Installation LCPWD Lake County Public Water District LER Licensee Event Reports LTP License Termination Plan MARLAP Multi-Agency Radiological Laboratory Analytical Protocols Manual MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MDC Minimal Detectable Concentrations MDCR Minimum Detectable Count Rate MGD million gallons per day MWe Megawatts electric MWhr Megawatt hour MWth Megawatts thermal NaI Sodium Iodide NGET Nuclear General Employee Training NIST National Institute of Standards and Technology 2-v

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 NPDES Illinois Environmental Protection Agency - National Pollutant Discharge Elimination System NRC Nuclear Regulatory Commission ODCM Off-site Dose Calculation Manual PWST Primary Water Storage Tank QAPP Quality Assurance Project Plan for Characterization and FSS QA/QC Quality Assurance and Quality Control RCA Radiologically Controlled Area REMP Radiological Environmental Monitoring Program RGPP Radiological Groundwater Protection Program ROC Radionuclides of Concern ROR Radiological Occurrence Reports SAFSTOR SAFeSTORe SFP Spent Fuel Pool S/G Steam Generator SST Secondary Condensate Storage Tank TSD Technical Support Document VCC Vertical Concrete Cask WDHS Wisconsin Department of Health Services WWTF Waste Water Treatment Facility ZNPS Zion Nuclear Power Station ZSRP Zion Station Restoration Project 2-vi

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1

2. SITE CHARACTERIZATION In accordance with the requirements of 10 CFR 50.82 (a)(9)(ii)(A) and the guidance of Regulatory Guide 1.179, Standard Format and Contents for License Termination Plans for Nuclear Power Reactors (Reference 2-1), this chapter provides a description of the radiological characterization performed at the Zion Nuclear Power Station (ZNPS) site. The purpose of site characterization is to ensure that the Final Status Survey (FSS) will be conducted in all areas where contamination existed, remains, or has the potential to exist or remain. The results of the characterization survey, including the Zion Station Historical Site Assessment (HSA)

(Reference 2-2), demonstrate that it is unlikely that significant quantities of residual radioactivity have gone undetected. There are areas known to potentially contain contamination that were inaccessible during the initial characterization which will be surveyed during continuing characterization as access is gained (see section 2.5).

The site characterization incorporates the results of investigations and surveys conducted to quantify the extent and nature of contamination at the ZNPS site. In addition, the results of site characterization surveys and analyses have been and continue to be used to identify areas of the site that will require remediation, as well as to plan remediation methodologies, develop waste classification and volumes, and estimate costs.

The characterization survey was designed and executed using the guidance provided in NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)

(Reference 2-3) and NUREG-1757, Volume 2, Revision 1, Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria, Final Report, (Reference 2-4). In addition, surveys were designed and executed in accordance with the ZionSolutions ZS-LT-02, Characterization Survey Plan (Reference 2-5), and ZS-LT-01, Quality Assurance Project Plan (for Characterization and FSS) (QAPP) (Reference 2-6) which describes policy, organization, functional activities, the Data Quality Objectives (DQO) process, and measures necessary to achieve quality data. The information obtained from the characterization provides guidance for decontamination and remediation planning. Materials which were shown to be contaminated with radioactive material at concentrations greater than the unrestricted release criteria have been and will continue to be removed and properly packaged for shipment and disposal.

The site characterization of ZNPS includes the information requirements listed in NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans (Reference 2-7) and NUREG-1757. Measurements and samples were taken in each accessible area, along with the historical information, to provide a clear picture of the residual radioactive materials and its vertical and lateral extent at the site. Using appropriate DQOs, monitoring well water samples, surface soil, sediment, concrete cores and sub-surface soil were collected to provide a profile of the residual radioactivity at the site. Samples were analyzed for the applicable radionuclides with detection limits that provided the level of detail necessary for decommissioning planning. Based upon the volume of characterization data collected and an assessment of the characterization results, the characterization survey is considered adequate to demonstrate that it is unlikely that significant quantities of residual radioactivity have gone undetected.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Section 8.5 of Exhibit C, Lease Agreement, titled Removal of Improvements; Site Restoration integral to the Zion Nuclear Power Station, Units 1 and 2 Asset Sale Agreement (Reference 2-

8) requires the demolition and removal of all on-site buildings, structures, and components to a depth of at least 3 feet below grade. Consequently, the only structures that will remain at license termination are the exposed steel liner and Under-Vessel concrete in the Unit 1 and Unit 2 Containment Buildings (after all other interior concrete is removed) and the below-grade structural concrete outside of the liner, the reinforced concrete basement floor and outer walls of the Auxiliary Building and Turbine Building (after all internal walls and floors are removed), the reinforced concrete floor and walls of the Spent Fuel Pool (SFP) and Fuel Transfer Canal (after the steel liner is removed), the concrete floor and walls of the Crib House, the Waste Water Treatment Facility (WWTF), the Forebay and the Circulating Water Intake and Discharge Piping below the 588 foot elevation.

All systems, and components, as well as all structures above the 588 foot elevation will be removed during the decommissioning process and disposed of as a waste stream. The switchyard, which belongs to Commonwealth Edison, will also remain. As part of the decommissioning process, all reactor fuel and greater than Class C waste was loaded into casks and transferred to an Independent Spent Fuel Storage Installation (ISFSI). The fuel will remain on-site in dry storage within the ISFSI until it is transferred to the Department of Energy (DOE).

The ISFSI has been constructed in the southwest corner of the ZNPS site, immediately south of the switchyard.

2.1. Historical Site Assessment In accordance with guidance provided in MARSSIM, section 3.0, a HSA was issued in August of 1999. Historical information, including any 10 CFR 50.75(g) files, employee interviews, radiological incident reports, pre-operational survey data, spill reports, special surveys (e.g., site aerial surveys, marine fauna and sediment surveys), operational survey records, and Annual Radiological Environmental Reports (including sampling of air, groundwater, estuary water, milk, invertebrates, fish and surface vegetation) to the Nuclear Regulatory Commission (NRC) were reviewed and compiled for this investigation.

2.1.1. Objectives The HSA was a detailed investigation to collect existing information (from the start of ZNPS activities related to radioactive materials or other contaminants) for the site and its surroundings.

The HSA focused on historical events and routine operational processes that resulted in contamination of plant systems, onsite buildings, surface and subsurface soils within the Radiologically Controlled Area (RCA). It also addressed support structures, open land areas and 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 their MARSSIM classifications. This information was used as input into the development of site-specific Derived Concentration Guideline Levels (DCGL), remediation plans and the design of the FSS. The scope of the HSA included potential contamination from radioactive materials, hazardous materials, and other regulated materials.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 The objectives of the HSA were to:

• Identify potential, likely, or known sources of radioactive and chemical contaminants based on existing or derived information.

• Distinguish portions of the site that may need further action from those that pose little or no threat to human health.

• Provide an assessment of the likelihood of contaminant migration.

• Provide information useful to subsequent continuing characterization surveys.

• Provide an initial classification of areas and structures as non-impacted or impacted.

• Provide a graded initial classification for impacted soils and structures in accordance with MARSSIM guidance.

• Delineate initial survey unit boundaries and areas based upon the initial classification.

At the time that the HSA was performed, the facility was in a SAFSTOR condition. As noted in the NRC public meeting in June 1998, the decommissioning approach for the facility specified that the units would remain in a SAFSTOR condition through 2010, when decontamination and dismantlement activities would begin for the structures, systems and components not required for maintenance of the nuclear spent fuel. The intended purpose of the Zion HSA was to provide a compilation and road-map of data and documents relating to the contaminant makeup of the site. This road-map would aid subsequent detailed site characterizations to be conducted in support of decommissioning planning which were anticipated to begin in approximately 2010.

During the SAFSTOR period, no scoping or initial characterization surveys as defined by MARSSIM, sections 5.2 and 5.3 were performed.

2.1.2. Methodology The objective of the HSA records search and interview process was the identification of those events posing a significant probability of impacting the hazardous material or radiological status of ZNPS site land areas and structures. These included system, structure, or area contamination from system failures resulting in airborne releases, liquid spills or releases, or the loss of control over solid material. Depending upon previous site operations and processes, the potential for residual contamination varies by area. In order to facilitate effective characterization surveys to guide future decontamination activities and provide sufficient data for the design of FSS, land areas and structures are classified based upon their potential for contamination.

Each incident identified that posed a realistic potential to impact the characterization of the site was further investigated. This investigation focused on the scope of contaminant sampling and analysis, any remedial actions taken to mitigate the situation, and any post-remedial action sampling, survey, and analysis in an attempt to identify the as left condition of the incident location. Historical records archives provided the source of a vast majority of the documents inspected.

Also included in the research associated with the development of the HSA were:

• Relevant excerpts from written reports and correspondences; 2-3

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1

• Personnel interviews, including the use of questionnaires, of current, former and retired plant personnel to confirm documented incidents and identify undocumented incidents; and

• Site inspection, utilizing historic site drawings, photographs, prints, and diagrams to identify, locate, confirm, and document areas of concern.

Information from this research was used in the HSA development, including the compilation of data, evaluation of results, documentation of findings, and the identification of initial Survey Units.

2.1.2.1. Preliminary Classification The HSA investigation was designed to obtain sufficient information to provide initial classification of the site land areas and structures as impacted or non-impacted. Impacted areas have a potential for contamination (based on historical data) or contain known contamination (based on past or preliminary radiological surveillance). Non-impacted areas are identified through knowledge of site history or previous survey information and are those areas where there is no reasonable possibility for residual radioactive contamination. Areas were classified as impacted from a radiological perspective. Potential chemical hazards incidents on owner-controlled areas were also documented including the confirmed presence of petroleum products, asbestos or other hazardous materials.

If a land area or structure was classified as impacted, then a determination of the initial impacted area classification (e.g. Class 1, Class 2 or Class 3) in accordance with MARSSIM, section 2.2 was made based upon the information obtained.

Initial classification of ZNPS areas was based on historical information and available historical radiological survey data. Classifying a survey area has a minimum of two stages: (1) initial classification and (2) final classification. Initial classification of most areas is performed at the time of identification of the survey area using the information available when the HSA was prepared. Final classification is performed and verified as a DQO during FSS design.

Radiological survey data from characterization surveys, operational surveys in support of decommissioning, routine surveillance, and any other applicable survey data may cause an increase in survey area classifications (for example, from Class 3 to Class 2 and from Class 2 to Class 1) until the time of commencement of the FSS.

2.1.2.2. Documents Reviewed Records maintained to satisfy the requirements of 10 CFR Part 50.75(g)(1) provided a major source of documentation for the HSA records review process. During the conduct of the HSA for ZNPS, many record types were evaluated including paper, microform, and electronic media.

In total, over 29,000 records were reviewed for applicability for the HSA. A complete listing of documents reviewed is provided in Appendix 3 of the HSA. A summary of the types of records reviewed include:

• License and Technical Specification reports,

• Annual operational and environmental reports,

• Environmental investigations performed by independent entities, 2-4

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1

• Regulatory actions against the site,

• Documentation from interviews conducted with currently employed and retired/separated site personnel,

• Radiological and environmental survey documents,

• Site inspection and surveillance documents associated with identified events,

• Annual Environmental and Operational documents,

• Licensee Event Reports (LERs),

• Radiological Occurrence Reports (RORs),

• Condition Reports (CRs),

• Quality Control /Quality Assurance findings.

2.1.2.3. Licenses, Permits and Authorizations ZNPS was operated in accordance with several Federal and State of Illinois licenses and permits.

The NRC Operating Licenses for Units 1 and 2 and supporting Technical Specifications allowed Commonwealth Edison and subsequent license holders to use any quantity of radioactive material at the site, to support operations during its operating lifetime, and to implement decommissioning activities.

The US Environmental Protection Agency (EPA) and applicable State of Illinois agencies maintain files on a variety of environmental programs that are applicable to ZNPS. These include permit applications and monitoring results with information on specific waste types and quantities, sources, type of site operations, and operating status of the facility or site.

The following denotes the licenses and permits relevant to the development of the HSA:

• US Nuclear Regulatory Commission - Docket Number 50-295, Facility Operating License Number DPR-39 (for Unit 1) (Reference 2-9)

• US Nuclear Regulatory Commission - Docket Number 50-304, Facility Operating License Number DPR- 48 (for Unit 2) (Reference 2-10)

• Illinois Environmental Protection Agency - National Pollutant Discharge Elimination System (NPDES) Permit Number IL0002763 (Reference 2-11) 2.1.2.4. Personnel Interviews Interviews with current or previous employees were performed to collect first-hand information about the site and to verify or clarify information gathered from the records that were reviewed.

The personnel interviews included a combination of questionnaires completed by a majority of the participants as well as individual and group interviews with several of the participants. Key personnel were chosen due to their knowledge of and association with the systems and source terms being investigated for the assessment. A number of the personnel interviewed possessed site knowledge and experience that ranged from the site construction period to shutdown.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Two types of interview questionnaires were used in the conduct of the Zion HSA. The first type of questionnaire was designed for permanent site production personnel. The second type of interview questionnaire was used during the personnel exit process (permanent and contractor staff). Typically, individuals were provided the questionnaire as a part of the standard station exit process. These exit interviews/questionnaires were obtained more as a quality check on information obtained during permanent staffing interviews. During the conduct of the Zion HSA, over 300 personnel interviews occurred with current and previous Zion personnel. With few exceptions, the personnel observations were corroborated by either the observations of other interviewees or documentation discovered during the records search.

2.1.3. Operational History The ZNPS is located in Northeast Illinois on the west shore of Lake Michigan. The site is approximately 40 miles north of Chicago, Illinois, and 42 miles south of Milwaukee, Wisconsin.

The site is in the extreme eastern portion of the city of Zion, (Lake County) Illinois, on the west shore of Lake Michigan approximately 6 miles NNE of the center of the city of Waukegan, Illinois, and 8 miles south of the center of the city of Kenosha, Wisconsin.

The station is comprised of two essentially identical pressurized water reactors with supporting facilities. Each units primary coolant system consists of a pressurized water reactor system designed by the Westinghouse Corporation and is comprised of the reactor vessel and four heat transfer loops. Each loop contains 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 major components of each units reactor coolant system are located in their respective containment building. The design reactor thermal power level was 3250 Megawatts thermal (MWth). The corresponding electrical output was approximately 1,085 Megawatts electric (MWe) for both Units 1 and 2.

The initial construction of the station was authorized on December 26, 1968. Unit 1 and Unit 2 achieved initial criticality on June 19, 1973 and December 24, 1973 respectively. Next, Unit 1 was synchronized to the grid for the first time on June 28, 1973 and Unit 2 on December 26, 1973. Finally, Unit 1 and Unit 2 began commercial operation on December 31, 1973 and September 19, 1974 respectively. Between the two units, Zion operated for approximately 248,238,983 effective MWhrs over the course of its operating lifetime.

On January 15, 1998, Commonwealth Edison (ComEd) announced the permanent shutdown of both Zion reactors. The shutdown decision was based on the corporations economic determination that neither Zion reactor would be able to produce competitively priced electricity in a deregulated marketplace over the facilitys remaining useful life.

On February 13, 1998, ComEd certified the permanent cessation of operation of ZNPS Units 1 and 2 to the NRC. On March 9, 1998, ComEd certified to the NRC that all fuel assemblies had been permanently removed from both ZNPS reactor vessels and placed in the SFP. Both units at ZNPS were subsequently placed in a SAFSTOR condition (a period of safe storage of the stabilized and defueled facility) until eventual final decommissioning and dismantlement.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Upon docketing of the certification for permanent cessation of operation and permanent removal of fuel from the reactor vessels, the 10 CFR Part 50 license no longer authorizes operation of the reactors or emplacement or retention of fuel in the reactor vessels. In addition, the operating licenses scheduled to expire in April 2013 for Unit 1 and November 2013 for Unit 2 continue to remain in effect until the NRC notifies ZionSolutions that the licenses have been terminated.

The reactors at Zion remained in a SAFSTOR condition until September of 2010. At this point, the license for the facility was transferred from Exelon Generation Company (Exelon) (the licensee at that time) to ZionSolutions LLC. This was accomplished to allow ZionSolutions to begin the process of the physical decommissioning of the ZNPS.

A synopsis of the operational history is provided in Table 2-1.

2.1.4. Incidents Based on the review of existing plant records (e.g. annual and semi-annual reports, licensee notifications, Occurrence Description Reports, and Personnel Data Questionnaire) approximately 305 incidents with radiological or hazardous material implications occurred between the commencement of plant operation in 1974 and placing both reactor units in a SAFSTOR condition in 1999. A majority of these incidents took place within the Security-Restricted Area and, while contributing to the radiological contamination and potential contamination of the structures and soils directly related to the operation of the reactors, were generally contained within the RCA, which is already known to be impacted. Those incidents occurring outside of the Security-Restricted Area have contributed to the impacted classification of other supporting structures and surrounding open land areas. These include:

• Spills outside of the RCA or incidents involving potential contamination based on leakage from systems that had been historically contaminated by primary to secondary leaks,

• Loss of control of radioactive materials resulting in the potential for contamination outside of the RCA,

• Spills of plant liquid radioactive effluents resulting in soil contamination,

• Hazardous material spills or losses of control, and

• Contamination of systems not originally designed as radioactive systems.

A synopsis index of these incidents is presented in Table 2-2.

2.1.4.1. Radiological Spills The HSA indicates that between 1973 and 1997, 64 documented spills occurred at the facility.

Of those, 18 spills occurred either inside of Unit 1 or Unit 2 Containment, 21 occurred inside of the Auxiliary Building and two occurred inside of the Fuel Handling Building. These spill incidents, while contributing to the radiological contamination of these buildings, were generally contained within the radiologically controlled drains and waste systems of the structures.

Of the remaining 23 documented spill incidents, 14 occurred either inside the Rad Waste Annex trackways or just outside of the trackway doors in the open land areas between the Containment structures and the Turbine Building. The prevalence of these incidents causes concern for the 2-7

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 potential contamination of ground coverings (concrete and asphalt) as well as surface and subsurface soils in these two areas. The HSA specifically refers to these two areas as the most extensively contaminated open land areas on the site. Substantial spills of spent resins and contaminated water were documented. Most significant spills occurred prior to 1980 which preceded the construction of the Rad Waste Annex. The Annex was constructed to provide an enclosure to the area where spent resins were sluiced and solidified for shipment and disposal.

Prior to the construction of the Annex, these activities were conducted in the open on a concrete pad. It is estimated that over 100 gallons of spent resin may have leaked into the soils at these locations.

Other significant spills and releases are summarized as follows;

• Overflow of both Unit 1 and Unit 2 Primary Water Storage Tank (PWST) as well as Unit 1 Secondary Condensate Storage Tank (SST)

• Unmonitored release of potentially contaminated liquids through the normal effluent release pathway to Lake Michigan from the Unit 2 Condenser hotwell, the Turbine Building Fire Sump and the Turbine Building drain system.

• Spill of potentially contaminated water to the 560 ft. elevation of the Turbine Building.

These spills resulted in the affected areas being designated as impacted.

2.1.4.2. Chemical Spills Between 1973 and 1997, the HSA documented 67 incidents involving the unplanned spill or release of chemicals and/or potentially hazardous liquids to the environment. These incidents ranged from spills of acids and caustics used in the plants various systems to the spill of diesel and fuel oil from systems and storage tanks. A majority of the incidents occurred inside of impacted buildings. There were also several instances where caustics and acids exceeding Technical Specification requirements were discharged through the plant WWTF. In addition, significant spills of mercury occurred in the Turbine Building and Crib House.

These spills were controlled and remediated in accordance with the station policies and procedures for identification, control and remediation of hazardous material releases.

2.1.4.3. Loss of Radioactive Material Control The HSA documents 132 incidents involving the loss of control of radioactive material between 1973 and 1997. Of those incidents, 61 involve the identification of radioactive material in non-posted areas inside of the RCA, such as the Maintenance Shop or the Tool Crib. Twenty-two (22) incidents involve the identification of radioactive material in trash piles or dumpsters located in non-posted areas inside the RCA. Twenty-four (24) incidents involve the identification of radioactive material in the trash segregation area located in the Unit 1 Turbine Building trackway. Four (4) incidents pertained to the loss of control of radioactive material while shipping or receiving radioactive material packages. Seven (7) incidents involved personnel leaving site with radioactive material on their person or in their vehicle and 14 incidents involved the loss of control of radioactive material where the material was 2-8

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 discovered and recovered outside of the RCA. Areas affected by these incidents were classified as impacted.

2.1.4.4. System Cross-Contamination Starting in 1981 and expanding dramatically in 1984, the Unit 1 Steam Generators (S/G) exhibited significant primary to secondary leaks. Unit 2 Steam Generators also exhibited primary to secondary leaks, but not to the extent exhibited by Unit 1. On September 10, 1984, Unit 1 was shut down as primary to secondary leakage exceeded the Technical Specification limit of 500 gallons per day. Due to the extensive primary to secondary leakage, secondary systems not originally expected to contain radioactivity became contaminated. The level of contamination varied from system to system.

In addition, many other secondary systems had the potential for cross contamination including open cycle and closed cycle cooling systems, auxiliary systems, and storage tanks. Following the guidance in NRC Bulletin 80-10, Contamination of Nonradioactive Systems and Resulting Potential for Unmonitored Release of Radioactivity to Environment (Reference 2-12), non-contaminated systems was routinely monitored to identify contamination events in a timely fashion. When normally non-contaminated systems became contaminated, they were evaluated against 10 CFR Part 50 Appendix I criteria. In addition, systems already contaminated were monitored according to plant chemistry and surveillance procedures to measure and trend the levels of activity within the systems.

Based on the HSA investigation, several additional secondary systems besides the Main Steam, Condensate and Feedwater systems were identified as contaminated. These systems included the Auxiliary Boiler, Unit 1 and Unit 2 Oil Separators and the Turbine Building equipment and floor drain systems. The structures associated with these systems are classified as impacted.

2.1.5. Findings and Conclusions The ZNPS was designed with multiple boundaries to control and contain the radioactive contents within its many systems, components, and structures. Many of these systems and structures have been impacted due to routine operations and maintenance activities during the operational and post operational history of the plant. Structures classified as impacted by the operation of the facility include Unit 1 and Unit 2 Containments, the Auxiliary Building, the Fuel Handling Building, the Turbine Building, the Service Building, the Crib House and system storage tanks located outdoors adjacent to the Crib House. Secondary systems, components and structures that were not originally anticipated to be contaminated have been impacted as the result of system cross contamination between the primary coolant system and secondary steam systems due to the failure of tubes within both units S/Gs. In addition to the structures, the soils surrounding these building have also been deemed to be directly impacted by the operation of this facility. This area is defined by the surrounding double-security fence and has been designated as the Security-Restricted Area.

The area surrounding the Security-Restricted Area area has been designated as the Radiologically-Restricted Area. This area encompasses the ancillary support buildings such as the Engineering and Construction (ENC) Building, the Gate House, the Interim Radioactive Waste Storage Facility (IRSF), the Switchyard and various warehouses and storage buildings.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Based on the findings documented in the HSA, these structures along with the soils within the Radiologically-Restricted Area fence has also been deemed as impacted.

In addition to the area within the Radiologically-Restricted Area area, several additional areas have been deemed as impacted. These include the site parking lot, the open land area along the south site boundary, the beach adjacent to the site and the area along Shiloh Boulevard designated as the West Training area. The parking lot was designated as impacted as it is a major path for radioactive material movement onto and off of the site. The West Training area was the former location of the Zion Training Building. This building housed a Westinghouse training reactor from 1980 to 1987. The reactor was decommissioned in 1988 and the license was terminated. The building itself was dismantled shortly following the permanent shutdown of the facility.

Figure 2-1 illustrates the Owner-Controlled Area that is under the management of the licensee.

The Radiologically-Restricted Area area is illustrated in Figure 2-2 and the Security-Restricted Area area is illustrated in Figure 2-3.

Based on current and historic sample results from the ZNPS Radiological Environmental Monitoring Program (REMP), there is no indication that surface waters on or near the facility or the ground water beyond the site have been affected by the licensed operation of the facility.

However, further evaluations of the groundwater directly below the licensed facility have been conducted. The initial findings of this study are presented in section 2.3.6. The normal effluent release pathway for the facility is the Circulating Water Discharge Tunnel that discharges to Lake Michigan approximately 870 feet from the lakeshore. During operation, effluent discharges contained measurable amounts of radioactive material resulting from liquid releases conducted in accordance with the license and permit requirements.

There were periods of liquid effluent releases during operation of the plant where it was determined that calculated dose to a maximally exposed individual via the liquid effluent pathway exceeded the design objective of 10 CFR Part 50, Appendix I. However, it was also determined that these liquid effluent releases did not exceed the concentration limits of 10 CFR Part 20 or the EPA fuel cycle dose limit in 40 CFR Part 190. The dose from liquid effluents has already been accounted for in accordance with the regulations governing radioactive effluent from power plants and no remediation is required.

2.1.6. Initial Survey Units and Classification As part of the HSA process, the ZNPS facilities and grounds were divided into preliminary survey areas and assigned initial area classifications based on the operational history and the incidents and processes documented for that survey unit.

2.1.6.1. Survey Areas The entire 331 acre site was divided into survey areas. Survey areas are typically larger physical sections of the site that may contain one or more survey units depending on their classification.

Survey area size was determined based upon the specific area and the most efficient and practical size needed to bound the lateral and vertical extent of contamination identified in the area.

Survey areas that have no reasonable potential for residual contamination were classified as 2-10

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 non-impacted. These areas have no radiological impact from site operations and are identified in the HSA. Survey areas with reasonable potential for residual contamination were classified as impacted.

2.1.6.2. Survey Units The classified survey areas established by the HSA were further divided into survey units. A survey unit is a portion of a structure or open land area that is surveyed and evaluated as a single entity following FSS. Survey units were delineated to physical areas with similar operational history or similar potential for residual radioactivity to the extent practical. To the extent practical, survey units were established with relatively compact shapes and highly irregular shapes were avoided unless the unusual shape was appropriate for the site operational history or the site topography.

The survey units established by the HSA were used as initial survey units for characterization.

Prior to characterization, survey unit sizes for Class 1 open land survey units were adjusted in accordance with the guidance provided in MARSSIM, section 4.6 for the suggested physical area sizes for survey units for FSS.

The decommissioning approach that will be implemented by the ZSRP calls for the complete segmentation, removal and disposal of all impacted systems and above-grade structures. With the exception of structure basement floors and walls that reside 3 feet below grade, and concrete structures that are candidates for the potential reuse of concrete as hard fill, no portion of any structure will remain at site closure and consequently, be subjected to FSS. However, survey units have been established for structures to facilitate other characterization objectives. These objectives include providing survey data for remediation planning, estimating the waste volume contained onsite, and disposition options for the waste.

In addition, the survey units established for structures that are 3 feet below grade are intended for the purpose of characterization planning and do not correspond to the survey units that will be used for the FSS of remaining below grade structures (discussed in section 5.5.2 of Chapter 5).

The non-impacted open land survey units for the site are depicted in Figure 2-4. The impacted Class 3 open land survey units are depicted in Figures 2-5 and 2-6. The impacted Class 1 and Class 2 open land survey units are depicted in Figure 2-7. A summary of the initial survey unit classifications are presented as follows.

2.1.6.2.1. Class 1 Structures The following is a list of some of the major buildings that were initially classified as impacted Class 1 structures in the HSA. The complete list of all initial structural survey units is provided in Table 2-3. These structures contain the nuclear reactors, primary reactor systems, reactor support systems, radioactive waste systems, and nuclear fuel handling and storage systems.

During operations, radioactive material was routinely handled, transferred, and stored within these buildings. A majority of the current radioactive material inventory at Zion resides in these structures:

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1

• Unit 1 Containment Building

• Unit 2 Containment Building

• Fuel Handling Building

• Radioactive Waste Building

• Auxiliary Building Throughout facility operations, these structures were subjected to spills of radioactive liquids, the spread of loose surface contamination, and airborne radioactive material. Structural surfaces were routinely posted as contaminated areas. The decommissioning approach for these structures involves the complete segmentation, removal, and disposal of all systems and structural material as waste. With the exception of structural floors and walls that reside 3 feet below grade, and concrete structures that are candidates for the potential reuse of concrete as hard fill, no portion of these structures will remain at site closure and are therefore not subjected to FSS. The Class 1 structural survey units for building basements below the 588 foot elevation are depicted in Figures 2-8 and 2-9 for Unit 1 Containment, Figures 2-10 and 2-11 for Unit 2 Containment and Figures 2-12, 2-13 and 2-14 for the Auxiliary Building.

2.1.6.2.2. Class 2 and 3 Structures The following is a list of some of the major buildings that were initially classified as impacted Class 2 or 3 structures by the HSA. All are located within the Radiologically-Restricted Area of ZNPS. The complete initial list of all structures and survey units is provided in Table 2-3.

The primary function of these structures is to house the secondary side steam systems or electrical generating systems, or to provide office and/or warehouse space. The primary basis for the initial classification of secondary side systems and structures as impacted is due to a series of primary to secondary side leaks through the S/Gs during plant operations.

• Turbine Building

• Crib House

• Unit 1 Main Steam Valve Houses

• Unit 2 Main Steam Valve Houses

• Waste Water Treatment Facility (WWTF)

• Warehouse/Mechanical Maintenance Training Area

• Station Construction Building

• Illinois Department of Nuclear Safety (IDNS) Building

• Gate House

• North Warehouse

• South Warehouse 2-12

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 These structures did not routinely house radioactive systems or materials during operations.

However, it was possible, due to their physical proximity to effluent release pathways, radioactive contamination of secondary side systems, temporary storage and transport of radioactive materials in and through these buildings, and past incidents involving the loss of control of radioactive material, that residual radioactive material could be found in and on, and around these structures. Consequently, this justified their initial classification as impacted Class 2 or Class 3. As with the Class 1 impacted structures, the decommissioning approach calls for the complete segmentation, removal, and disposal of all Class 2 or 3 systems and structural material as waste or salvage. With the exception of structural below-grade foundations and concrete structures that are candidates for the potential reuse of concrete as hard fill, no portion of these structures will remain at site closure and therefore will not be subjected to FSS. The Class 2 structural survey units for building basements below the 588 foot elevation are depicted in Figures 2-15 for the Turbine Building and Figure 2-16 of the Forebay for the Circulating Water system under the Crib House. There are no Class 3 structures that will remain in the final site configuration.

2.1.6.2.3. Class 1 Open Land Areas The following open land areas have been initially classified as impacted Class 1. The basis for this initial classification is due to a series of documented incidents of the contamination of soil by radioactive material in these areas during facility operations. These incidents include spills of radioactive liquids and resins, radioactive system leakage, and storage of radioactive packages and containers. The complete list of all initial open land survey units is provided in Table 2-4.

• Sludge Drying Bed Area

• WWTF Area

• Unit 1 PWST/SST Area

• Unit 2 PWST/SST Area

• South Yard Area Northeast of the Gate House

• Yard Between Unit 1 Containment and Turbine Building

• Yard Between Unit 2 Containment and Turbine Building

• Soils under and around the Unit 1 Containment, Unit 2 Containment, the Fuel Handling Building and the Auxiliary Building Based on an assessment of historical incidents and events, it was anticipated that the surface and subsurface soils in these areas could possibly contain residual radioactive material in excess of the unrestricted release criteria. Class 1 open land survey units are illustrated on Figure 2-7.

2.1.6.2.4. Class 2 Open Land Areas The following open land areas were initially classified as impacted Class 2. Based upon a review of the historical information and operational radiation and contamination surveys performed in these areas as documented in the HSA, there was a potential for residual 2-13

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 radioactive contamination to exceed the unrestricted release criteria. The complete list of all initial open land survey units is provided in Table 2-4.

• Crib House Area

• Southeast Protected Area Yard

• The Gate House Area and the Protected Area Southwest Yard

• North Protected Area Yard

• Soils under and around the Service Building and the Turbine Building Class 2 open land survey units are illustrated on Figure 2-7.

2.1.6.2.5. Class 3 Open Land Areas The following open land areas were initially classified as Class 3. Historical information contained in the HSA indicated that the presence of residual radioactivity in concentrations in excess of the unrestricted release criteria was not expected. The complete list of all initial open land survey units is provided in Table 2-4.

• Northeast Corner of the Restricted Area adjacent to the Lake

• Interim Radioactive Waste Storage Area (IRSF)/Fire Training Area

• East Training Area

• North Gate Area

• Switchyard

• In-Processing Building/Station Construction Area

• North Warehouse Area

• South Warehouse Area

• Exclusion Area South of Gate House

• Exclusion Area South of Turbine Building

• Southeast Corner of the Restricted Area

• Construction Parking Area

• Area South of Switchyard

• Owner Controlled Area South of Restricted Area

• West Training Area Class 3 open land survey units are illustrated on Figure 2-5 and Figure 2-6.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 2.1.6.2.6. Non-Impacted Areas Based on a review of the operating history of the facility, historical incidents, and operational radiological surveys as documented in the HSA, the following areas have been deemed not impacted by licensed activities or materials. The complete list of all initial open land survey units is provided in Table 2-4.

• Northeast Corner of the Exclusion Area

• Power House Area

• Owner Controlled Area North of Shiloh Boulevard

• Owner Controlled Area West and South of the West Training Area

• Owner Controlled Area West of the Switchyard

• Met Tower Area Non-impacted open land survey units are illustrated on Figure 2-4.

2.2. Characterization Approach Site characterization of the ZNPS was performed in accordance with the Characterization Survey Plan. It was developed to provide guidance and direction to the personnel responsible for implementing and executing characterization survey activities. The Characterization Survey Plan worked in conjunction with implementing procedures and survey unit specific survey instructions (sample plans) that were developed to safely and effectively acquire the requisite characterization data.

Characterization data acquired through the execution of the Plan was used to meet three primary objectives:

• Provide radiological inputs necessary for the design of FSS,

• Develop the required inputs for this License Termination Plan (LTP), and

• Support the evaluation of remediation alternatives and technologies and estimate waste volumes.

The decommissioning approach for the ZSRP calls for the demolition and removal of all on-site buildings, structures, and components to a depth of at least 3 feet below grade. Consequently, characterization efforts focused on open land areas and remaining structures that will be subjected to FSS. Extensive characterization of equipment, systems or structures that will be removed prior to the performance of final surveys is not required in accordance with NUREG-1757, Appendix O.

The decommissioning approach for ZSRP also calls for the beneficial reuse of concrete from building demolition as clean fill. The only concrete structures that will be considered are those where the probability of residual contamination is minimal. Characterization in this case will consist of an in-situ assessment of the concrete under consideration to ascertain if the structure concrete is an acceptable candidate. Concrete that meets the non-radiological definition of Clean 2-15

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Concrete Demolition Debris (CCDD) and has been deemed suitable for offsite release in accordance with the site unconditional release process may be used as basement fill.

A significant question that must be answered by the characterization is whether or not a survey unit is classified correctly. The appropriate classification of a survey unit is critical to the survey design for FSS. A classification which underestimates the potential for contamination could result in a survey design that does not obtain adequate information to demonstrate that the survey unit meets the release criteria. In some cases, this can increase the potential for making decisions errors.

As site-specific DCGLs were not yet established for the Zion decommissioning at the time the characterization survey was performed, alternate action levels were selected. The screening DCGLs presented in NUREG-1757 and the concentration values found in NUREG/CR-5512 Volume 3, Residual Radioactive Contamination from Decommissioning Parameter Analysis (Reference 2-13), Table 6.91 (Pcrit = 0.10) for soils were used as alternate action levels to assess the correct classification of impacted open land or soil survey units.

For structures, the gross screening level that was used during characterization as an action level to evaluate the classification of survey units was the nuclide-specific screening value of 7,100 dpm/100cm2 total gross beta-gamma surface activity based on Co-60 from NUREG-1757, Appendix H. Use of the Co-60 screening value was conservative as it was anticipated that the radionuclide distribution for surface contamination would be principally Co-60 and Cs-137 and, the more conservative approach was to assume a distribution of 100% Co-60 as the screening value for Cs-137 is significantly greater.

2.2.1. Data Quality Objectives DQOs were implemented for characterization surveys in a similar manner as anticipated for the FSS. However, the goal of characterization is contamination quantification and delineation of the nuclide suite, whereas the FSS goal is comparison of data against the unrestricted use criteria to demonstrate compliance with 10 CFR 20.1402. Characterization inspections and surveys of sufficient quality and quantity were performed to determine the nature, extent and range of radioactive contamination in each applicable survey unit, including applicable structures, residues, soils and surface water.

Characterization surveys were designed to gather the appropriate data using the DQO process as outlined in MARSSIM, Appendix D. The seven steps in the DQO development process are:

1) State the problem,

2) Identify the decision,

3) Identify inputs to the decision,

4) Define the study boundaries,

5) Develop a decision rule,

6) Specify limits on decision errors, and

7) Optimize the design for obtaining data.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 The DQOs for site characterization included identifying the types and quantities of media to collect. No structures located above 3 feet below grade will remain following decommissioning and be subjected to FSS. Consequently, sample collection was focused on the assessment of concrete basement structure materials and surrounding soils. Building concrete was sampled by obtaining concrete core samples. Soils were sampled volumetrically. Sufficient measurements were obtained to determine the mean and maximum activity as well as the sample standard deviation. Direct measurements and scans of concrete and surface soils were also made using the same instruments and Minimal Detectable Concentrations (MDC) as will be employed for FSS. Volumetric samples that exhibited the highest activity were sent to an off-site laboratory for analysis of Hard-to-Detect (HTD) radionuclide(s).

2.2.2. Survey Design Characterization surveys were designed and performed in accordance with all applicable approved procedures and the Characterization Survey Plan. Survey design incorporated a graded approach based upon the DQOs for each survey unit. For example, an open land survey unit was designated as Class 1 because it may contain levels of radiological contamination greater than the unrestricted release criteria. Therefore, the characterization surveys that were performed in a Class 1 survey unit focused on bounding the contamination where contamination was potentially present. The survey design was based upon the number of measurements and samples required to identify the lateral and vertical extent of the contamination. Areas classified as non-impacted, Class 2 or Class 3 received surveys developed to include a combination of systematic and biased survey measurement locations and scan areas. Biased survey designs used known information to select locations for static measurements and/or samples. Systematic survey design 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 survey design or a systematic approach was addressed by the DQO process for each survey unit. A biased approach was warranted when the characterization effort was designed to delineate the extent of an area that requires remediation. Alternatively, a systematic approach was warranted if the characterization effort was designed to verify the basis for the classification of a survey unit.

2.2.2.1. Number of Static Measurements and/or Samples The number of measurements and/or samples that were taken in each survey unit was determined by assessing the sample size necessary to satisfy the DQOs.

For the characterization of structural survey units that would not remain at license termination and not be subjected to FSS, the numbers of static measurements and/or samples taken were a sufficient quantity to determine the general radiological condition of the survey unit, including average and maximum concentration of loose surface contamination and total surface contamination if possible.

For the characterization of impacted Class 1 open land areas and Class 1 basement structures that will remain and be subjected to FSS, the sample size was based upon the necessary number of samples needed to assess the lateral and vertical extent of the contamination.

For the characterization of impacted Class 2 open land areas and impacted Class 2 or Class 3 basement structures that will be subjected to FSS, the minimum number of static measurements 2-17

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 and/or samples that were taken in each survey unit was commensurate with the probability of the presence of residual radioactive contamination in the survey unit.

For non-impacted and Class 3 open land survey units, the primary characterization DQO was to validate the basis of the classification. Consequently, the number of systematic static measurements and/or samples was sufficiently robust so that a high degree of confidence was achieved to establish that only diminutive levels of licensee-generated radioactive material resided in these areas.

2.2.2.2. Determination of Static Measurement or Sample Locations For the characterization of non-impacted and impacted open land areas and Class 2 structural survey units that will be subjected to FSS, sample locations were primarily chosen at random.

Sample locations were determined by generating random pairs of coordinates that corresponded to specific locations within the survey unit. The location of biased measurements and/or samples that were taken in each survey unit was determined by the professional judgment of the responsible Radiological Engineer during the survey design process. Consideration was given to locations that exhibited measurable radiation levels above background (i.e. by scanning),

depressions, discolored areas, cracks, low point gravity drain points, actual and potential spill locations, or areas where the ground has been disturbed. Historical information from the HSA aided in the selection of biased locations.

2.2.2.3. Scan Coverage Survey units were scanned to the extent practical in accordance with their classification. The area to be scanned in each survey unit was determined during the survey design process. The area scanned was contingent upon the accessibility of the surface areas in the survey unit and the recommended scan coverage guidelines presented in Table 2-5.

2.2.2.4. Types of Measurements or Samples The characterization survey of building surfaces consisted of a combination of surface scans (beta and gamma); static beta measurements, material samples and smears. The characterization survey of any concrete and/or asphalt-paved open land areas that will remain and be subjected to FSS consisted of a combination of surface scans (beta and gamma), static beta measurements, and volumetric samples. The survey of the open land areas consisted of gamma scans and the sampling of surface and subsurface soil, sediment and surface water for isotopic analysis. The following is a description of the different types of measurements and samples that were utilized.

2.2.2.4.1. Static Measurements Static measurements were performed to detect direct levels on structural surfaces of the buildings or on concrete or asphalt paved areas. These measurements were performed using primarily

~126 cm2 scintillation or gas-flow proportional detectors.

Static measurements were conducted by placing the detector on or very near the surface to be counted and acquiring data over a pre-determined count time. Instrument count times were adjusted as appropriate to achieve an acceptable MDC for static measurements.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 2.2.2.4.2. Beta Surface Scans Scanning was performed in order to locate areas of residual activity above the 7,100 dpm/100cm2 action level. Beta scans were performed over accessible structural surfaces including, but not limited to; floors, walls, ceilings, roofs, asphalt and concrete paved areas.

Floor monitors using large area gas-flow proportional detectors (typically with 584 cm2) were used for floor and other larger accessible horizontal surfaces. Hand-held beta scintillation and/or gas-flow proportional detectors (typically 126 cm2) were used for surfaces not accessible by a floor monitor.

Beta scanning was performed with the detector position maintained within 1.27 cm (0.5 inch) of the surface and with a scanning speed of one detector active window per second. If surface conditions prevented scanning at the specified distance, the detection sensitivity for the alternate distance was determined, and the scanning technique adjusted accordingly. Scanning speed was calculated a priori to ensure that the MDC for scanning was appropriate for the stated objective of the survey.

If not impacted by high ambient noise levels, technicians monitored the audible response of the instrument to identify locations of elevated activity that require further investigation and/or evaluation. Any identified areas of elevated contamination were marked or flagged for further investigation and potential decontamination.

2.2.2.4.3. Gamma Surface Scans Gamma scans were performed over open land surfaces to identify locations of residual surface activity. Sodium iodide (NaI) gamma scintillation detectors (typically 2 x 2) were typically used for these scans. ZionSolutions TSD 11-004, Ludlum Model 44-10 Detector Sensitivity (Reference 2-14) examines the response and scan MDC of the Ludlum Model 44-10 NaI detectors to Co-60 and Cs-137 when used for scanning surface soils.

Scanning was performed by moving the detector in a serpentine pattern, while advancing at a rate not to exceed 0.5 m (20 in) per second. The distance between the detector and the surface was maintained within 15 cm (6 in) of the surface if possible. Audible signals were monitored; and, locations of elevated direct levels were flagged for further investigation and/or sampling.

2.2.2.4.4. Removable Surface Contamination If applicable, removable beta contamination or smear surveys were performed to verify loose surface contamination is less than the action level of 1,000 dpm/100cm2. A 100 cm2 surface area was sampled with a circular cloth or paper filter, using moderate pressure. Smears were then analyzed for the presence of gross beta activity using a proportional counting system or equivalent.

2.2.2.4.5. Concrete Core Sampling Concrete core boring and the sampling of concrete were used to assess the depth of surficial contamination and the presence of volumetric contamination in concrete walls and floors that will remain and be subjected to FSS. Core bore sampling of concrete was accomplished using a diamond bit core drill. The concrete sample produced by the coring was typically sliced into 2-19

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1/2-inch wide pucks, representing a certain depth into the surface. Static measurements were performed on the top and bottom of the pucks to determine contaminant intrusion depth and/or the activation of the concrete matrix. Concrete pucks were also pulverized and analyzed for isotopic content.

2.2.2.4.6. Material Sampling Samples of soil, sediment, and sludge were obtained from designed judgmental and systematic sample locations as well as other biased locations in areas exhibiting elevated activity that were identified by scanning. Surface soil is defined as the top 15 cm (6-inch) layer of soil while subsurface soil is defined as soil below the top 15 cm layer in 1 m increments. Surface soil was collected using a split spoon sampling system or, by using hand trowels, bucket augers, or other suitable sampling tools.

Subsurface soil was sampled by direct push sampling systems (e.g. GeoProbe) or by the excavation of test pits. Subsurface soil sampling was performed as necessary to address the DQOs for the survey unit.

An adequate amount of material (ranging from 0.5 liters up to 2 liters) was collected at each location. Sample preparation included the removal of extraneous material and the homogenization and drying of the soil for analysis. Separate containers were used for each sample and each container will be accounted for throughout the analysis process using positive physical control or by a chain-of-custody record.

2.2.3. Instrumentation Selection, Use and Minimum Detectable Concentrations (MDCs)

The radiation detection and measurement instrumentation for characterization was selected to provide both reliable operation and adequate sensitivity to detect the Radionuclides of Concern (ROC) identified for the decommissioning of the ZNPS at levels sufficiently below the established action levels. Detector selection was based on detection sensitivity, operating characteristics, and expected performance in the field. In all cases, the instruments and detectors selected for static measurements and scanning were capable of detecting the anticipated ROC at a MDC of 50% of the applicable action level.

Commercially available portable and laboratory instruments and detectors were typically used to perform the three basic survey measurements: 1) surface scanning; 2) static measurements; and

3) analysis of material samples.

Instrumentation and nominal MDC values that were employed during characterization are listed in Table 2-6.

2.2.3.1. Instrument Calibration All data loggers, associated detectors, and all other portable instrumentation that were used for characterization were calibrated on an annual basis using National Institute of Standards and Technology (NIST) traceable sources. The calibration of instruments used for characterization is addressed in section 5.2 of the QAPP.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 2.2.3.2. Instrument Use and Control The receipt, inspection, issue, control, and accountability of portable radiological instrumentation used for characterization was performed in accordance with issue and control procedures for portable radiological instrumentation. The issue and control of instruments used for characterization is addressed in section 5.1 of the QAPP.

2.2.4. Laboratory Instrument Methods And Sensitivities Gamma spectroscopy was primarily performed by the on-site radiological laboratory. Gas proportional counting and liquid scintillation analysis was performed by an approved vendor laboratory in accordance with approved laboratory procedures. ZionSolutions ensured that the quality programs of the contracted off-site vendor laboratories that were used for the receipt, preparation and analysis of characterization samples provided the same level of quality as the on-site laboratory under the QAPP.

In all cases, analytical methods were established to ensure that required MDC values are achieved. The analysis of radiological contaminants used standard approved and generally accepted methodologies or other comparable methodologies. Table 2-7 provides the typical analytical methods employed and the laboratory MDC achieved by the off-site vendor laboratories used for characterization.

2.2.5. Quality Assurance MARSSIM, section 2.2 discusses the need for a quality system to ensure the adequacy of data used to demonstrate that site conditions are acceptable for unrestricted release. Laboratory quality for sample analysis taken to support characterization and FSS is discussed in NUREG-1576, Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP)

(Reference 2-15) and Regulatory Guide 4.15, Quality Assurance of Radiological Monitoring Programs (Inception through Normal Operations to License Termination) - Effluent Streams and the Environment (Reference 2-16). Further, MARSSIM and MARLAP both indicate that a Quality Assurance Project Plan may be used in addition to, or in lieu of, existing quality systems to ensure data quality is achieved.

The QAPP was prepared and implemented to ensure the adequacy of data being developed and used during the site characterization and FSS process. The QAPP describes policy, organization, functional activities, the DQO process, and measures necessary to achieve quality data. It supplements the quality requirements and quality concepts presented in ZS-QA-10, Quality Assurance Project Plan - Zion Station Restoration Project (Reference 2-17) which adequately encompass other risk-significant decommissioning activities.

All characterization activities essential to data quality were implemented and performed using approved procedures. The effective implementation of characterization was verified through audit and surveillance activities, including field walk-downs by ZionSolutions Characterization/License Termination management and radiological engineering staff and program self-assessments, as appropriate. Corrective actions were prescribed, implemented, and verified when deficiencies were identified. These measures applied to any applicable services provided by off-site vendors, as well as on-site sub-contractors.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 The Characterization Survey Plan was developed according to the essential elements of the quality assurance and quality control (QA/QC) program for the decommissioning of the ZNPS and is subject to the QAPP. The QA/QC program elements applicable to characterization are as follows:

• Establishment/implementation of plans, procedures, and protocols for the field operations.

• Actions to ensure that the procedures are understood and followed by the implementing staff.

• Documentation of the data collected.

Details of the QA/QC elements specific to characterization are presented in the QAPP, as well as the procedures and sample plan instructions. The characterization operations and the associated data acquisition and recording was guided and conducted in compliance with these QA/QC requirements. The specific QA/QC program components for site characterization are as follows:

• Personnel qualifications, experience, and training.

• Execution in accordance with approved procedures.

• Proper documentation of survey data and sample analyses.

• Selection of appropriate instruments to perform the surveys.

• Proper instrument calibration and daily functional checks.

• Management oversight of characterization activities relative to the adherence to procedures, protocols, and documentation requirements.

All characterization activities were conducted in accordance with the Characterization Survey Plan, the QAPP, all applicable implementing procedures, and approved sample plan instructions.

2.3. Summary of Characterization Survey Results The site characterization of the ZNPS site commenced on November 2, 2011 with the characterization of the open land survey units encompassing the proposed site for the future ISFSI facility. At the time this survey was performed, the site-specific ZionSolutions characterization plans and procedures were still under development. Consequently, due to schedule constraints, ZionSolutions contracted the EnergySolutions Commercial Services Group (ESCSG) to perform characterization of the ISFSI location, the location where the Vertical Concrete Cask (VCC) Construction Area was to be located and the pathway for the new rail tracks. These locations are illustrated on Figures 2-17 and 2-18. These surveys were performed on a turnkey basis using ESCSG technicians, procedures and instrumentation. A survey-specific characterization plan was developed and approved for these areas, survey packages were prepared and executed in accordance with ESCSG procedures and a final report Characterization of the Zion Station Independent Spent Fuel Storage Facility (ISFSI)

(Reference 2-18) dated July 30, 2012 was prepared by ESCSG and approved by ZionSolutions.

The results of these surveys were validated and integrated into the subsequent site-specific characterization program and the results are reported in this chapter as valid characterization data for the affected survey units.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 In February 2012, the site-specific ZionSolutions site characterization program was approved. In addition, all required personnel, equipment and instrumentation necessary to implement the characterization program were procured. Characterization activities, self-performed by ZionSolutions in accordance with the ZionSolutions characterization program commenced on April 10, 2012 with the acquisition of concrete core samples from the 542 foot elevation of the Auxiliary Building. The initial scheduled site characterization effort concluded on November 11, 2013.

Throughout 2012 and 2013, characterization activities were performed in parallel with radioactive commodity removal and radioactive waste shipment activities at ZNPS.

Consequently, the removal and movement of radioactive material directly impacted the ability to access certain structural survey units and open land areas and obtain meaningful characterization survey data. In several specific areas, characterization has been deferred until such time that radiological or physical conditions would allow access for characterization. ZionSolutions intends to continue characterization throughout the decommissioning process, including following the submittal of this LTP. This is discussed further in section 2.5. In the case where significant additional characterization data is obtained, this chapter of the LTP will be updated by revision or addendum as a part of the required 2 year update of the approved LTP.

2.3.1. Background Studies Several background studies were performed on the ZNPS site to assess background for soils and concrete. The first study was performed in February of 2012 by ESCSG as an integral part of the work scope pertaining to the characterization of the ISFSI and VCC construction area. During this study, soil, concrete and asphalt was assessed though surface scanning and volumetric sampling and analysis. In March and April of 2012, ZionSolutions conducted a comprehensive background study of non-contaminated concrete by acquiring and analyzing concrete core samples taken from the 559 foot elevation and 594 foot elevation of the Crib House. This study was conducted to support the eventual evaluation of concrete demolition debris as clean hard fill.

In July of 2012, an additional study was performed to evaluate background for soils. Additional scanning and acquisition and analysis of volumetric soil samples were performed.

2.3.1.1. EnergySolutions Background Study The primary purpose of the EnergySolutions background study was to identify and quantify the levels of natural activity, including fallout, within soils and construction materials. This effort included support of the unconditional release and potential re-use of concrete originating from ZNPS as potential backfill material. The surveys were performed using the same instruments and survey techniques that were to be used during characterization.

This background study was performed through the selection of reference background areas known to be unaffected by plant operations to ensure any measured radioactivity would be of natural origin. It was determined that the best location for measuring background would be outside the restricted area boundary toward the north as based in part on Annual Report on the Meteorological Monitoring Program at Zion Nuclear Power Station for 2010 (Reference 2-19),

which demonstrated that winds are predominately from the west and northwest at the site. As a 2-23

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 result, locations north and northwest of the restricted area were less likely to be impacted by airborne particulate and gaseous effluents from past plant operations.

To ensure that the data was relevant, it was necessary to ensure the background reference areas selected were representative of the materials and areas to be surveyed at the facility. This included soils of similar geology and construction materials of similar age and content.

Consequently, the reference area(s) selected were located as near to the facility as possible and representative of the construction of the plant. It was determined, based upon this selection criterion, that the area around the former Visitors Center would be representative of background at the site. Figure 2-19 represents the background survey locations used during the EnergySolutions background assessment.

Surface scans and direct surface activity measurements were performed for gross beta activity on both asphalt and concrete surfaces within the background reference areas. In addition, gamma walkover scans and direct measurements were performed over soil and vegetation. The scans were distributed evenly over each background reference area. One-minute static measurements were also collected.

In addition to the surface scans and direct measurements, samples were collected for volumetric analysis by gamma spectroscopy analysis. Fifteen (15) samples were taken of asphalt, concrete and surface soils and were analyzed by a qualified off-site vendor laboratory.

To account for any potential difference in geology, subsurface samples were also collected at each surface sampling location to assess for any differences in background if present.

Subsurface samples were collected at depths between 6 inches below grade down to a depth of about 4 feet using GeoProbe'. Subsurface soil samples were composited over the depth of the sampled soil column. As with the surface soils, all composite subsurface samples were also analyzed by a qualified off-site vendor laboratory.

The results of the Energy Solutions background study was presented in CS-RS-PN-028, Background Reference Area Report - Zion Nuclear Power Station (Reference 2-20). A summary of the background survey results from this assessment is provided in Table 2-8. Based upon a review of the sample analysis results for asphalt, concrete and soils, only natural activity expected in background was detected. No other licensed materials were identified in the samples. Additionally, based upon the activities of the daughter products within the decay chain, in approximate equilibrium, the background reference area(s) and samples were deemed representative of background and were not impacted by site activities. A review of both the surface and subsurface soil sample results concluded that there appears to be no difference between the surface and subsurface radionuclide distribution.

2.3.1.2. Crib House Concrete Study In March of 2012, ZSRP commenced an assessment of the concrete 594 foot and 559 foot elevation floors and lower walls of the Crib House. The DQOs established for this survey were to establish a background threshold range for volumetric concrete at ZNPS, evaluate the basement foundations and floors of the Crib House for the presence of volumetric radiological contamination and to provide a sufficient quantity and quality of uncontaminated concrete media 2-24

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 representative of the Basement Fill concrete to an off-site vendor for the derivation of distribution coefficients for the radionuclides of concern.

On each floor (594 foot and 559 foot elevations), 16 six-inch concrete core samples were taken from the floors and 4 six-inch concrete core samples were taken from the lower walls for a total of 40 concrete core samples. Sample locations were selected at random. Prior to acquiring the core samples, the area was scanned to ensure the absence of surficial radioactive contamination at each sample location. Scans were performed with a Ludlum 43-93 100 cm2 alpha-beta scintillator detector. Gross beta background ranged from 150 cpm to 300 cpm. No activity greater than background was observed at each selected sample location.

All concrete core samples were analyzed by the on-site gamma spectroscopy system for gamma emitting radionuclides. Only natural activity expected in background was detected during the analysis. No other licensed materials were identified in the samples. A summary of the survey results from the assessment of the Crib House concrete is provided in Table 2-9.

2.3.1.3. ZionSolutions Soil Background Study In July of 2012, a survey was performed of non-impacted soils adjacent to the ZNPS owner controlled area with the objective of determining background radioactivity concentrations in soils. The area chosen for the survey was the Zion City Park Districts Hosah Park, located north of the ZNPS at the end of Shiloh Boulevard. The park consists of open land areas covered with native grasses and low lying brush. While there did appear to be evidence of soil disturbance on the property, the evidence suggested that this occurred in the past and the land has been undisturbed for a number of years. Figure 2-20 illustrates the location of the area chosen for the survey.

The survey was designed to determine the radionuclide activity concentrations of key naturally occurring and man-made radionuclides, particularly Cs-137, in surface and subsurface soils. The survey design included surface and subsurface soil samples as well as static gamma measurements. Thirty (30) sample locations were chosen, biased towards soils that appeared to be undisturbed with minimal vegetation. At each location, a static one-minute measurement was taken using a sodium iodide detector, a sample was taken from the soils within the first 15 cm of grade and a composite soil sample was taken from soils between 15 cm below grade to 60 cm below grade. All soil samples were analyzed by a qualified off-site vendor laboratory.

The results of the survey were presented in a report titled Determination of Radionuclide Activity Concentrations in Soils in Non-Impacted Soils Adjacent to the Zion Nuclear Station (Reference 2-21). In both surface and subsurface soil populations, the only radionuclide identified, with the exception of naturally occurring radionuclides, was Cs-137. In the surface soil sample population, Cs-137 was positively identified in concentrations greater than MDC in 26 of the 30 samples. In the subsurface soil population, Cs-137 was positively identified in concentrations greater than MDC in five (5) of the 30 samples obtained. Based upon the concentrations observed and the distribution, it was postulated that the presence of Cs-137 was due to global fallout. The results of the sample analysis are presented in Table 2-10.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 2.3.1.4. Technical Support Document Regarding Cs-137 Global Fallout In order to establish an action criteria indicative of Cs-137 contamination levels in soil that are distinguishable from background levels, ZionSolutions TSD 13-004, Examination of Cs-137 Global Fallout In Soils At Zion Station (Reference 2-22) was prepared to document ZionSolutions soil sample results for Cs-137 in soils to date and compare the results to those anticipated from world-wide fallout. The TSD established the technical basis for the anticipated soil concentrations attributable to fallout and established criteria for investigating soil samples due to observed Cs-137 concentrations.

The soil sample data compiled in the TSD concludes that the majority of the soil samples taken for the background studies were from disturbed soils. The Hosah Park data as well as the data obtained during the ESCSG study corresponded with documented fallout levels from disturbed soil at sites in Massachusetts, New York and Pennsylvania. Consequently, predicted ranges for background concentrations of Cs-137 were established for disturbed soils as well as undisturbed soils based on literature. These ranges are presented in Table 2-11. The upper Cs-137 concentration for each category was used as the action level for the characterization of non-impacted open land survey units. The upper Cs-137 concentration for disturbed, non-drainage soil in Table 2-11 was used as the action level for the characterization of Class 2 and 3 open land area survey units.

2.3.2. Potential Radionuclides of Concern ZionSolutions TSD 11-001, Potential Radionuclides of Concern during the Decommissioning of Zion Station (Reference 2-23) was prepared and approved in November 2011. The purpose of this document was to establish the basis for an initial suite of potential ROCs for the decommissioning. Industry guidance was reviewed as well as the analytical results from the sampling of various media from past plant operations. Based on the elimination of some of the theoretical neutron activation products, noble gases and radionuclides with a half-life less than 2 years, an initial suite of potential ROC for the decommissioning of the ZNPS was prepared.

The list of potential radionuclides is listed in Table 2-12.

2.3.3. Impacted Structures and Systems The decommissioning approach for the ZSRP requires the demolition and removal of all impacted buildings, structures, systems and components to a depth of at least 3 feet below grade.

In addition, all systems and exposed metal below 3 feet below grade will also be removed. The accepted elevation for grade at ZNPS is the 591 foot elevation. The only structures that will remain and be subjected to FSS are the exposed steel lined walls and floor from the Unit 1 and Unit 2 Containment Buildings (after all interior concrete is removed) and the below-grade structural concrete outside of the liner, the reinforced concrete basement floor and outer walls of the Auxiliary Building and Turbine Building (after all internal walls and floors are removed), the reinforced concrete floor and walls of the SFP and Fuel Transfer Canal (after the steel liner is removed), the concrete floor and walls of the Crib House, the WWTF, the Forebay and Circulating Water Intake Piping and Discharge Tunnel below the 588 foot elevation.

Consequently, all systems and components and structural surfaces above the 588 foot elevation will be remediated, disassembled and/or demolished, segregated by waste classification and 2-26

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 disposed of as clean demolition debris, clean salvage or radioactive waste. No extensive characterization was or will be performed of equipment, systems or structures that will be removed prior to the performance of FSS.

The current decommissioning approach for ZSRP also calls for the beneficial reuse of concrete from building demolition as clean fill. The only concrete structures that will be considered are those where the probability of the presence of residual contamination is minimal. Only concrete that has been demonstrated to be free of detectable plant-derived radionuclides and hazardous painted surfaces will be used. Characterization in this case will consist of an in-situ assessment of the concrete under consideration to ascertain if the structure concrete is an acceptable candidate. Only concrete that meets the non-radiological definition of CCDD and has been deemed suitable for offsite release in accordance with the site unconditional release process may be used as basement fill.

Radiological surveys of the interiors of structures at the ZNPS are routinely performed to ensure compliance with 10 CFR 20 requirements regarding the posting of areas and to identify radiological conditions for the implementation of controls for the protection of workers in these areas. The radiological information from these surveys will provide the basis for the disassembly and removal of systems and the demolition of impacted structures at the site. When remediation has adequately reduced radiological conditions to levels suitable for controlled demolition, the impacted structures will be demolished, packaged and properly disposed of as waste.

After commodity removal is complete, the structures that will remain at license termination, i.e.,

3 feet below grade, will be re-surveyed to determine the concentrations of the residual radioactivity and the extent of additional remediation required, if any, to meet the unrestricted use criteria.

2.3.3.1. Unit 1 and Unit 2 Containments The Unit 1 and Unit 2 Containment buildings house numerous systems containing primary coolant as well as radioactively contaminated support systems. Physically, both units are basically mirror images of the other. System leakage and maintenance activities over the operating life of both units have resulted in the radiological contamination of most of the interior surfaces of both structures. Some components, equipment, structural steel and concrete have become radioactive due to neutron activation. Based on the building design basis, the operating history as well as the present status of areas that are controlled as contaminated areas, all internal survey units in both the Unit 1 and Unit 2 Containment Buildings are considered to be Class 1 areas.

General area radioactive dose rates within the buildings range from 1 mrem/hr to over 250 mrem/hr. Loose radioactive contamination ranges from <1,000 dpm/100 cm2 to over 110 mrad/swipe. The general radiological conditions within the Unit 1 and Unit 2 Containment buildings are presented per survey unit in Table 2-13.

The basic decommissioning end-state for each Containment building will consist of the walls and floors below 588 foot elevation. In both Containment basements, all concrete will be removed from the interior side of the steel liner above the 565 foot elevation, leaving only the remaining 2-27

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 exposed liner below the 588 foot elevation, the concrete in the In-core Instrument Shaft leading to and including the area under vessel (or Under-Vessel area), and the structural concrete outside of the liner. The exposed metal liner will be cleaned to levels below DCGLs for basement structures (Chapter 5, Table 5-4). It is anticipated that only activity remaining on the steel liner after concrete removal will be loose dust from the demolition of the concrete. Following completion of a FSS in accordance with section 5.5.4 of this LTP, the basements will be backfilled with clean fill, CCDD, grout, or a combination of the three materials.

The large components inside each structure such as the Reactor Vessel, Pressurizer, Steam Generators, Reactor Coolant Pumps, primary piping and all associated systems will be removed and properly disposed of as radioactive waste. Several sections of pipe that is located below the 588 foot elevation that are embedded in concrete may remain as part of the final configuration of the structure. An embedded pipe is defined as a pipe that runs vertically through a concrete wall or horizontally through a concrete floor and is contained within a given building. A penetration is defined as a pipe (or remaining pipe sleeve, if the pipe is removed, or concrete, if the pipe and pipe sleeve is removed) that runs through a concrete wall and/or floor, between two buildings, and is open at the wall or floor surface of each building. A penetration could also be a pipe that runs through a concrete wall and/or floor and opens to a building on one end and the outside ground on the other end. The list of penetrations and embedded piping to remain is provided in ZionSolutions Technical Support Document (TSD)14-016, Description of Embedded Pipe, Penetrations, and Buried Pipe to Remain in Zion End State (Reference 2-24).

The upper steel containment liner, the refuel cavity and all interior walls above the 588 foot elevation in both units will also be removed and disposed of as radioactive waste. The outer containment shells above the 588 foot elevation will be surveyed and demolished. If the exterior concrete is free of detectable plant-derived radioactive material, it may be used as CCDD or disposed of as clean demolition debris. All waste material will be packaged and sent offsite for disposal at approved disposal facilities for radioactive waste or clean demolition debris.

It is anticipated that the most highly activated concrete in either Containment will be the internal radius of the Bio-Shield concrete that surrounded the vessel as it was closest to the active core region. The concrete inside the liner in the Under-Vessel area is also activated. Unit 1 and 2 Containment have interior concrete walls 23.5 inches thick in the Under-Vessel area and 30 inch thick concrete floors inside the liner. Consequently, the potential for activation outside the liner is minimal.

During the time that initial characterization was performed, all radioactive systems and components were still located inside each Containment. Consequently, ambient radiation dose rates inside the Containments prohibited the direct assessment of concrete and steel structural surfaces below the 588 foot elevation by scanning or direct measurement. Once commodity removal is complete in both of these structures, additional characterization will be performed by scan and direct measurement to identify the lateral and vertical extent of surficial contamination and the extent of any remediation that will be necessary on the structural steel and concrete that will remain in the final configuration of the Containments. All continuing Characterization Plans will be provided to the NRC for information and continuing Characterization Reports will be provided to the NRC for evaluation.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 From June of 2012 through January of 2013, a series of concrete core samples were taken in the 568 foot concrete floor, 541 foot In-core tunnel floor and In-core tunnel walls in both Containment buildings. In addition, a single concrete core sample was taken from the reactor centerline location of Unit 1 Bio-Shield. A total of 39 concrete core samples were collected, 20 in Unit 1 Containment and 19 in Unit 2 Containment.

The locations selected for the concrete core sampling were biased toward locations where physical or observed radiological measurements indicated the presence of fixed and/or volumetric contamination of the concrete media. When possible, locations were determined based upon elevated observed contact dose rates or count rates. In addition, visual observations of floor and wall surfaces were used to identify potential locations of surface contamination, such as discoloration or standing water. The goal was to identify, to the extent possible, the locations that exhibited the highest potential of representing the worst case bounding radiological condition for concrete in each survey unit. This judgmental sampling approach also ensured there was sufficient source term in the cores to achieve the sensitivities required to determine the radionuclide distributions of gamma emitters as well as HTD radionuclides.

Sixteen (16) concrete core samples were taken on the 568 foot elevation of both the Unit 1 Containment and the Unit 2 Containment, eight inside the missile shield and eight outside of the missile shield. Three (3) concrete core samples were obtained from each of the In-core tunnel Under-Vessel areas in both Unit 1 and Unit 2 Containments. Two (2) concrete core samples were taken from the 541 foot elevation floor and one was taken from the wall directly under each reactor vessel. A single concrete core sample was obtained from the Unit 1 Bio-Shield. Since the Bio-Shields in both Containments will not remain in the end-state configuration and the concrete is to be removed as waste, this was the only core sample taken of Bio-Shield. No Bio-Shield core was obtained in Unit 2.

A summary of the on-site gamma spectroscopy results for the analysis of the concrete cores taken from the Unit 1 Containment 568 foot elevation is presented in Table 2-14. A summary of the on-site gamma spectroscopy results for the analysis of the concrete cores taken from the Unit 1 Bio-Shield is presented in Table 2-15. A summary of the on-site gamma spectroscopy results for the analysis of the concrete cores taken from the Unit 2 Containment 568 foot elevation is presented in Table 2-16. A summary of the on-site gamma spectroscopy results for the analysis of the concrete cores taken from the Containment In-core tunnel areas are presented in Table 2-17 for Unit 1 Containment and Table 2-18 for Unit 2 Containment. The locations where the core samples were taken are illustrated in Figures 2-21 and 2-22 for Unit 1 Containment and Figures 2-23 and 2-24 for Unit 2 Containment.

ZionSolutions TSD 14-028, Radiological Characterization Report (Reference 2-25) presents additional detail on the concrete sampling methodology and results of the radiological analysis of each concrete core sample obtained from the Containment Building basements. In addition, an in-depth analysis of the results of the concrete core samples taken in the Containment are presented in ZionSolutions TSD 13-006, Reactor Building Units 1 & 2 End State Concrete and Liner Initial Characterization Source Terms and Distributions (Reference 2-26).

With the exception of one (1) core sample where Eu-154 was positively identified, Co-60, Cs-137 and Cs-134 were the only plant-derived gamma emitting radionuclides identified by the analysis of the concrete core samples taken from the 568 foot elevation. The on-site gamma 2-29

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 spectroscopy results identified Co-60, Cs-134, Cs-137, Eu-152 and Eu-154 in the concrete core samples taken from the In-core tunnel areas.

For both Unit 1 and Unit 2 568 foot elevations, the sample analysis indicated that the majority of the radionuclide source inventory resides within the first 1/2-inch of concrete and that Cs-137 is the dominant radionuclide. Co-60 is significantly more prevalent in Unit 2 verses Unit 1. In addition, the analysis also indicates that the overall source inventory in Unit 2 is much lower than Unit 1.

An examination of the Under-Vessel In-core area profiles show diminishing activation at depth.

In Unit 1, the source inventory is dominated by the presence of Cs-137 in the first 1/2-inch of concrete, which contains approximately 63% of the overall source inventory. In Unit 2, the Cs-137 concentrations are significantly less and the source inventory is dominated by Eu-152, which accounts for approximately 74% of the calculated total source inventory.

Analysis of the core taken from Unit 1 Bio-Shield indicates that Eu-152 and Eu-154, which are indicators of the neutron activation of concrete was not detected in concentrations greater than their respective MDC until a depth of 47.5 inches. This supports the postulation that neutrons were successfully attenuated prior to traversing the Bio-Shield and consequently, there is minimal potential for the activation of concrete in areas outside the Bio-Shield.

The top 1/2-inch puck from nine (9) of the 20 cores from Unit 1 and the top 1/2-inch puck from eight (8) of the 19 cores from Unit 2 were sent to Eberline Laboratory for gamma spectroscopy and HTD analyses for radionuclides such as H-3, C-14, Tc-99, Ni-63, Sr-90, and alpha emitters.

The results of the analysis are presented in Table 2-19 for Unit 1 Containment and Table 2-20 for Unit 2 Containment. The radionuclide distribution for Unit 1 and Unit 2 Containments that is based on this sample population is presented in Table 2-21. Significant HTD radionuclides identified by the analysis of the concrete core samples include Ni-63, H-3 and Sr-90. The other radionuclides positively detected at concentrations greater than their respective MDC include; C-14, Tc-99, Pu-238, Pu-239/240, Am-241, Am-243 and Cm-243/244.

2.3.3.2. Auxiliary Building The Auxiliary Building is located between the Unit 1 and Unit 2 Containments and the Turbine Building. The structure is designed to house support systems for the operation of both reactors.

Major support systems that are located in the Auxiliary Building include Containment Spray, Residual Heat Removal, Reactor Water Cleanup, Reactor Water Charging and Safety Injection systems. In addition, the Auxiliary Building contains various filters and tanks designed to batch and/or process gaseous, liquid and solid wastes resulting from reactor operation. With the exceptions of the service water, primary de-ionized water, control air, fire protection, nitrogen gas and service air, all of the systems within the Auxiliary Building are radiologically contaminated internally. The structure itself is designed to contain and control leakage from these systems during normal operation as well as unusual events. System leakage and maintenance activities over the operating life of the facility have resulted in the radiological contamination of most of the interior surfaces of the Auxiliary Building. Most of the cubicles that contain major systems are posted as contaminated areas identifying removable radioactive material. Based on the building design basis, the operating history, as well as the present status 2-30

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 of areas that are controlled as contaminated, all internal survey units within the Auxiliary Building are considered to be Class 1 areas.

General area radioactive dose rates within the Auxiliary Building range from 1 mrem/hr to 60 mrem/hr with contact dose rates on specific components in excess of 1000 mrem/hr. Loose radioactive contamination ranges from <1,000 dpm/100 cm2 to over 250 mrad/swipe. The general radiological conditions within the Auxiliary Building are presented per survey unit in Table 2-13.

The basic decommissioning end-state for the Auxiliary Building will consist of the foundation concrete walls below 588 foot elevation and the 542 foot elevation concrete floor. All systems and components contained within the Auxiliary Building will be disassembled and/or demolished, packaged and properly dispositioned as either a radioactive or non-radioactive waste. The list of penetrations and embedded piping to remain is provided in TSD 14-016.

During the time that initial characterization was performed, all radioactive systems and components were still located inside the Auxiliary Building. Consequently, ambient radiation dose rates inside most of the cubicles on the 542 foot elevation prohibited the direct assessment of concrete surfaces by scanning or direct measurement. Once commodity removal is complete, a contamination verification survey (CVS) will be performed to identify areas requiring remediation to meet the open air demolition limits. Prior to demolition, all structural surfaces that will remain after demolition will be remediated to levels that will ensure that an individual ISOCS measurement will not exceed the DCGLs from Chapter 5, Table 5-4 during FSS.

Following completion of a FSS in accordance with section 5.5.4 of this LTP, the basements will be backfilled with clean fill, CCDD, grout, or a combination of the three materials..

In May and June of 2012, a characterization survey was performed of the Auxiliary Building 542 foot elevation and Auxiliary Building exterior walls. The characterization survey consisted of surface scans and the acquisition of a series of concrete core samples taken in the 542 foot elevation concrete floor and exterior lower walls. In March of 2013, two (2) additional concrete cores were taken in the Auxiliary Building elevator shaft and the Hold-Up tank Cubicle floors as these areas became accessible.

During the characterization of the Auxiliary Building basement, extensive beta gamma scan surveys were performed on the floors and lower walls of the 542 foot elevation in an effort to determine the locations representing the worst case radiological condition for concrete in each survey unit. These scans were performed of accessible walls surfaces to the extent practicable while standing on the 542 foot elevation, to a nominal elevation of approximately six feet up the wall from the floor. The scan surveys indicated that, for a majority of the lower wall surfaces on the Auxiliary Building 542 foot elevation, the residual radioactivity on the wall was indistinguishable from ambient background. This was particularly true for all the outer wall surfaces in the east portion of the Auxiliary Building 542 foot elevation, including the Waste Gas Decay Tank area, the Lake Discharge Tank area, the Blowdown Monitor Tank area and the areas adjacent to the Cavity Fill Pump cubicles. Residual contamination at concentrations greater than the ambient background was only detected on the outer walls of the Unit 1 and Unit 2 Pipe Chases, the Unit 1 and Unit 2 ABEDCT cubicles and the outer walls of the HUT cubicles.

However, with the exception of the HUT cubicles, the contamination identified on the walls in the Pipe Chases and ABEDCT cubicles was not uniform. The contamination on the walls in 2-31

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 these cubicles was primarily from valve leakage and gland seal spray from primary system pumps.

A total of 20 concrete core samples were collected. The locations selected were biased toward locations where physical or observed radiological measurements indicated the presence of fixed and/or volumetric contamination of the concrete media. When possible, locations were determined based upon elevated observed contact dose rates or count rates from scans. In addition, visual observations of floor and wall surfaces were used to identify potential locations of surface contamination, such as discoloration or standing water. The goal was to identify to the extent possible, the locations that exhibited the highest potential of representing the worst case radiological condition for concrete in each survey unit. This judgmental sampling approach also ensured that there was sufficient source term in the cores to achieve the sensitivities required to determine the radionuclide distributions of gamma emitters as well as HTD radionuclides. The locations where the core samples were taken are illustrated in Figure 2-25. The concrete pucks were analyzed on the on-site gamma spectroscopy system. A summary of the on-site gamma spectroscopy results for the analysis of the concrete cores taken from the 542 foot elevation of the Auxiliary Building is presented in Table 2-22. Co-60, Cs-134 and Cs-137 were the only plant-derived gamma emitting radionuclides identified. ZionSolutions TSD 14-028 presents additional detail on the concrete sampling methodology and results of the radiological analysis of each concrete core sample obtained from the Auxiliary Building basement.

Analyses of the concrete core samples taken from the Auxiliary Building 542 foot elevation indicate that there is extensive radiological contamination at depth. This is most likely due to the fact that the 542 foot elevation was routinely flooded with contaminated water during operations.

In the first 1/2-inch of floor, Co-60 concentrations averaged 46 pCi/g with a maximum concentration of 456 pCi/g and Cs-137 concentrations averaged 3,352 pCi/g with a maximum concentration of 25,100 pCi/g. In both Unit 1 and Unit 2 Pipe Tunnel rooms, Cs-137 concentrations of 530 pCi/g and 1,740 pCi/g were observed at depths of 4 and 5 inches respectively. In addition, sample analysis indicated a Cs-137 concentration of 56.80 pCi/g at a depth of 2 inches in the central common area, a Cs-137 concentration of 31.10 pCi/g at a depth of 3.5 inches in the east floor area and a Cs-137 concentration of 63.10 pCi/g at a depth of 2.5 inches in the Unit 1 Equipment Drain Collection Tank room.

The top 1/2-inch puck from six (6) of the 20 cores from the Auxiliary Building were sent to Eberline Laboratory for gamma spectroscopy and HTD analyses for radionuclides such as H-3, C-14, Tc-99, Ni-63, Sr-90, and alpha emitters. The results of the analysis are presented in Table 2-23. The mixture percentages for the initial suite of radionuclides for the Auxiliary Basement concrete were developed in TSD 14-019, Radionuclides of Concern for Soil and Basement Fill Model Source Terms (Reference 2-27) using the results of all core sample analyses, including the cores sent to Eberline as well as those analyzed onsite, and is presented in Table 2-24. Significant HTD radionuclides identified by the analysis of the concrete core samples include Ni-63 and H-3. The other radionuclides positively detected at concentrations greater than their respective MDC include; C-14, Tc-99, Sr-90, Ag-108m, Pu-238, Pu-239/240, Am-241 and Am-243.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 2.3.3.3. Fuel Handling Building The Fuel Handling Building is located between the Unit 1 and Unit 2 Containments and adjacent to the Auxiliary Building. The structure is designed for the storage of new and spent fuel. Major support systems that are located in the Fuel Handling Building include the SFP Heat Exchangers and SFP Skimmer Pumps. The SFP is a 63 ft. long by 33 ft. wide by 40 ft. deep pool located in the east half of the building. The pool is filled with borated water and contains storage racks for the storage of spent fuel assemblies. Spent nuclear fuel, highly irradiated reactor components and other highly radioactive debris were stored in the pool. A new fuel storage area and a fuel unloading area are located in the western portion of the building. A cask decontamination pit is located adjacent to the pool. With the exceptions of the service water, de-ionized water, control air, fire protection, nitrogen gas and service air, all of the systems within the Fuel Handling Building are radiologically contaminated internally. The SFP, the decontamination pit, and the equipment cubicles are all posted as Contaminated Areas. The potential for residual contamination exists throughout the building. Based on the building design basis, the operating history, as well as the present status of areas that are controlled as contaminated, all internal survey units within the Fuel Handling Building are considered to be Class 1 areas.

General area radioactive dose rates within the Fuel Handling Building range from 1 mrem/hr to 25 mrem/hr. Loose radioactive contamination ranges from <1,000 dpm/100 cm2 to 37,000 dpm/100 cm2. The general radiological conditions within the Fuel Handling Building are presented per survey unit in Table 2-13.

The spent fuel located in the SFP was packaged into dry cask storage and transferred to the ISFSI facility. All systems, components and materials located in the Fuel Handling Building will be removed and dispositioned as radioactive or non-radioactive waste as appropriate. A majority of the Fuel Handling Building structure is located above the 588 foot elevation. Consequently, the basic decommissioning end-state for the Fuel Handling Building is the complete removal of the current accessible structure. The only portion of the building that resides below the 588 foot elevation is the bottom 12 feet of the SFP and adjoining Transfer Canal. As part of the building demolition, the steel liner will be removed from the SFP and Transfer Canal. Once the liner is removed and the underlying concrete is exposed, additional characterization surveys will be performed to assess the radiological condition of the underlying concrete pad and remaining pool walls. Following an assessment of the results of the survey, a cost benefit analysis will be performed to determine if the concrete will be remediated and abandoned in place or removed.

Once commodity removal is complete, a contamination verification survey (CVS) will be performed on the concrete surfaces to identify areas requiring remediation to meet the open air demolition limits. Prior to demolition, all concrete surfaces that will remain will be remediated to levels that will ensure that an individual ISOCS measurement will not exceed the DCGLs from Chapter 5, Table 5-4 during FSS. Following completion of a FSS in accordance with section 5.5.4 of this LTP, any remaining remnant of the SFP and Transfer Canal below the 588 foot elevation will be backfilled with clean fill, CCDD, grout, or a combination of the three materials.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 2.3.3.4. Turbine Building The Turbine Building houses the steam turbines and generators for both reactor units as well as secondary steam systems, circulating water systems, lubrication and fuel oil systems and emergency diesel generators. The steam and support systems in the Turbine Building are designed to be operated as non-radioactive systems. However, from 1981 through the facility shutdown in 1998, both Zion units experienced significant primary system to secondary side leakage from leaking Steam Generator tubes. From 1981 to 1984, primary to secondary side leakage was recorded at levels exceeding 500 gallons per day. Consequently, primary to secondary side leakage has resulted in measurable radioactivity in portions of the secondary system piping, primarily in the high-pressure steam components, the condensate re-heaters, the Auxiliary Boiler and the system, equipment and floor drain systems. In addition, several areas/components adjacent to the fire sump have detectable radioactive contamination. In the late 1970's (prior to fire sump modifications), the Turbine Building Equipment Drain Analysis Tank had exposure rates up to 200 mR/hr on contact.

General area radioactive dose rates within the Turbine Building are <1 mrem/hr. Loose radioactive contamination ranges from <1,000 dpm/100 cm2 to 18,000 dpm/100 cm2 located in the Auxiliary Boiler room. The general radiological conditions within the Turbine Building are presented per survey unit in Table 2-13.

The Turbine Building systems and structural surfaces above the 588 foot elevation will be surveyed and released for unconditional use. The concept is to allow a contractor to disassemble, salvage and demolish the Turbine Building as non-radiological. To allow this process to occur, the high-risk systems within the Turbine Building, such as Main Steam, Condensate, Auxiliary Steam, Feedwater and liquid waste systems will be removed and properly dispositioned as radioactive waste. The remaining systems, as well as the Turbine Building structure will be remediated as necessary and surveyed for unconditional use. The drain system embedded in the concrete floor of the 560 foot elevation, which is currently radiologically contaminated, will be surveyed in accordance with Chapter 5, section 5.5.5. The results for the characterization of the Turbine Building floor drains is presented in section 2.3.3.7.

Once the Turbine Building has been verified as meeting the unconditional release criteria, then the building will be gutted and demolished to the 588 foot elevation. Prior to demolition, all concrete surfaces that will remain will be remediated to levels that will ensure that an individual ISOCS measurement will not exceed the DCGLs from Chapter 5, Table 5-4 during FSS.

Following completion of a FSS in accordance with section 5.5.4 of this LTP, the basement void below the 588 foot elevation will be backfilled with clean fill, CCDD, grout, or a combination of the three materials.

In November of 2012, a series of concrete core samples were taken in the 560 foot elevation Turbine Building concrete floor as well as the 570 foot elevation Steam Tunnel concrete floors.

The locations where the core samples were taken are illustrated in Figures 2-26.

A total of 10 concrete core samples were collected, three (3) in the Turbine Building 560 foot elevation floor, five (5) in the Unit 1 Steam Tunnel floor and two (2) in the Unit 2 Steam Tunnel floor. The locations selected were biased toward locations where physical or observed radiological measurements indicated the presence of fixed and/or volumetric contamination of 2-34

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 the concrete media. When possible, locations were determined based upon elevated observed contact dose rates or count rates. In addition, visual observations of floor and wall surfaces were used to identify potential locations of surface contamination, such as discoloration or standing water. The goal was to identify to the extent possible, the locations that exhibited the highest potential of representing the worst case radiological condition for concrete in each survey unit.

A summary of the gamma spectroscopy results for the concrete cores obtained from the Turbine Building 560 foot elevation and the 570 foot elevation Steam Tunnels are provided in Table 2-25. ZionSolutions TSD 14-028 presents additional detail on the concrete sampling methodology and results of the radiological analysis of each concrete core sample obtained from the Turbine Building. Cs-137 was the only plant-derived gamma emitting radionuclides identified. Concentrations for Co-60 were less than the MDC for all samples from the Turbine Building and the Steam Tunnels.

Analyses of the concrete core samples taken from the Turbine Building 560 foot elevation show the presence of Cs-137 at concentrations greater than the MDC of the instrument at two (2) of the three (3) sample locations, and only in the 1st 1/2-inch of concrete. Observed Cs-137 concentrations ranged from 0.55 pCi/g to 46.7 pCi/g. At depths greater than 1/2-inch, concentrations for Cs-137 was less than MDC. In the Steam Tunnels, Cs-137 concentrations in the 1st 1/2-inch on concrete ranged from 6.60 pCi/g to 46.70 pCi/g in Unit 1 and 0.29 pCi/g to 18.60 pCi/g in Unit 2. At depths greater than 1/2-inch, concentrations for Cs-137 was less than the MDC of the instrument used.

Between March 21, 2013 and March 27, 2013, all accessible surfaces of the 560 foot elevation floor in the Turbine Building were scanned using a Ludlum Model 43-37 floor monitor. The average background of the instrument was 900 cpm. The alarm set-point was set at the observed background plus the Minimum Detectable Count Rate (MDCR) for the instrument. The mean observed count rate was 1,493 cpm with a maximum observed count rate of 3,922 cpm.

Three (3) instrument alarms were observed, primarily around a posted radiological area adjacent to the elevator.

2.3.3.5. Service Water Intake and Discharge Structure The Service Water intake and discharge structure is composed of several different components, including the Crib House, which houses the Circulating Water and Fire Pump motors and impeller housings, the Forebay, which acts as the intake pool for the pumps, the Circulating Water Intake Headers, which funnels the Circulating Water Pump discharge flow to the Main Condenser and the Circulating Water Discharge Tunnels, which directs the heated circulating water back to Lake Michigan. The Circulating Water Discharge Tunnels were also the main authorized effluent release pathway for the discharge of treated and filtered radioactive liquid waste to Lake Michigan. During plant operations and following shut-down, the liquid effluent release pathway was monitored and the results presented in the annual REMP report in accordance with the Off-site Dose Calculation Manual (ODCM).

As previously described in section 2.3.1.2, a scan survey and a total of 40 concrete core samples were taken from the floors and lower walls of the Crib House 594 foot and 559 foot elevations.

No activity greater than background was observed by either scan or the isotopic analysis of the concrete samples. The Crib House above the 588 foot elevation will be surveyed for 2-35

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 unconditional release at the same time as the Turbine Building. Once it has been demonstrated that the Crib House is suitable for unconditional release, a non-radiological demolition contractor will salvage materials out of the Crib House. The Crib House structural concrete and cinder block will be surveyed to demonstrate that the material is free of plant-derived radionuclides at concentrations greater than background, demolished and used as CCDD.

At the time of LTP submittal, the Forebay is completely underwater. The Forebay walls will be demolished to elevation 588 foot. The Circulating Water Intake piping that runs from the Forebay to the Main Condenser will be isolated and drained. When accessible, the remaining lower portions of the Crib House and the Forebay structure below the 588 foot elevation and the Circulating Water Intake piping will be remediated to levels that will ensure that an individual ISOCS measurement will not exceed the DCGLs from Chapter 5, Table 5-4 during FSS.

Following completion of FSS, the Forebay will be backfilled with clean fill, clean concrete debris, grout, or a combination of the three materials. The Circulating Water Intake piping will be filed with grout.

The Circulating Water Discharge Tunnels run under the Forebay and discharges to Lake Michigan approximately 870 feet from the lakeshore. The current decommissioning approach is to leave the Circulating Water Discharge Tunnels in place. The interior surfaces of the Circulating Water Discharge Tunnels will be remediated to levels that will ensure that an individual ISOCS measurement will not exceed the Turbine Building DCGLs from Chapter 5, Table 5-4 during FSS.

2.3.3.6. Support Buildings and Miscellaneous Structures The major support buildings and miscellaneous structures include the Service Building, Gate House, Waste Water Treatment Facility, IRSF, ENC Building, NGET Building, Unit 1 and Unit 2 Valve Houses, and several warehouses. The location of these buildings and structures are illustrated on Figures 2-2 and 2-3. The general radiological conditions within these buildings are presented per survey unit in Table 2-13.

As previously stated, the Asset Sale Agreement requires the demolition and removal of all on-site buildings, structures, and components to a depth of at least 3 feet below grade. All support buildings and miscellaneous structures are categorized as structures located above the 588 foot elevation. Consequently, all support buildings and miscellaneous structures within the security-restricted and radiologically-restricted areas at ZNPS will be demolished and dispositioned as a radioactive or non-radioactive waste stream. Several minor structures such as the Switchyard as well as all roadways and rail lines, will remain at license termination as requested by Exelon.

The switchyard was characterized as a Class 3 open land survey unit. The result of the switchyard characterization is presented in section 2.3.5.

2.3.3.7. Embedded or Buried Pipe The End State will also include a range of buried piping, embedded piping and penetrations.

Buried piping is defined as pipe that runs through soil. An embedded pipe is defined as a pipe that runs vertically through a concrete wall or horizontally through a concrete floor and is contained within a given building. A penetration is defined as a pipe (or remaining pipe sleeve, if the pipe is removed, or concrete, if the pipe and pipe sleeve is removed) that runs through a 2-36

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 concrete wall and/or floor, between two buildings, and is open at the wall or floor surface of each building. A penetration could also be a pipe that runs through a concrete wall and/or floor and opens to a building on one end and the outside ground on the other end. The list of buried piping, penetrations and embedded piping to remain is provided in ZionSolutions TSD 14-016.

At the time of LTP submittal, the interior surfaces of most of these sections of pipe were not accessible. As decommissioning progresses and access is achieved, radiological surveys will be performed to assess if any remediation is necessary, to confirm the radiological distribution inside of the pipe and to assess the dose from residual radioactivity remaining in the pipes.

For embedded pipe and penetrations, the pipe interiors will be remediated to levels less than the embedded pipe and penetration specific DCGLs discussed in sections 5.2.4 and 5.2.5 of this LTP. As decommissioning progresses and access is achieved to the interior of these pipe sections, FSS will be performed in accordance with section 5.5.6 of this LTP.

For pipe buried in soil, the pipe interiors will be remediated to levels less than the site-specific DCGLs presented in Table 5-10 of this LTP. FSS surveys will be performed as described in section 5.7.1.8.

In April of 2013, several sediment samples were collected from the floor drain system embedded in the Turbine Building 560 foot elevation. Three (3) sediment samples were collected from the floor drains in the south portion, six (6) sediment samples were collected from the floor drains in the central portion, and seven (7) sediment samples were collected from the floor drains in the north portion of the Turbine Building 560 foot elevation. In addition, two (2) large area wipes were collected and analyzed from the drain pipe interiors of floor drains in the central and north sections. The locations where the sediment samples were taken are illustrated in Figure 2-27.

All sediment and wipe samples were weighed and analyzed using the on-site gamma spectroscopy system. The gamma spectroscopy results for the sediment samples from the Turbine Building 560 foot elevation drain system piping are provided in Table 2-26.

Analysis of the sediment samples indicates the presence of Cs-137 in concentrations greater than the instrument MDC in 12 of the 16 sediment samples, ranging from 0.11 pCi/g to 17.7 pCi/g.

Co-60 was present in three (3) of the 16 samples, ranging from 0.28 pCi/g to 0.44 pCi/g. The large area wipe taken in drain pipes in the central portion of the 560 foot elevation indicated Cs-137 at a concentration of 77.9 pCi/g. The analysis of the large area wipe taken in the north section did not show Cs-137 or Co-60 at concentrations greater than the instrument MDC.

2.3.4. Non-Impacted Open Land Areas Based upon the information compiled in the Zion HSA, several large outlying open land survey units received an initial classification as non-impacted. Non-impacted areas have no reasonable potential for residual contamination because historical information indicates there was no known impact from site operations. These include the outlying open land areas of the site as well as contiguous areas that have no impact from site operations 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 for demonstrating compliance beyond any characterization surveys performed to provide a basis for the classification.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 For ZNPS, the non-impacted open land areas includes most of the surrounding Exelon owned land outside of the footprint of the 87 acre, fence-enclosed Radiologically-Restricted Area as well as tracts of land that are owned by the Town of Zion and adjacent businesses. With the exception of operational surveys performed at the perimeter of the RCA to establish compliance with non-occupational exposure limits, no radiological survey data was available to support this basis.

From June to September 2013, characterization surveys were performed in the non-impacted open land areas of the site. To facilitate data collection, review and evaluation, the non-impacted open land areas were surveyed as designated survey units. A sample plan was prepared for each survey unit in accordance with procedure ZS-LT-100-001-001, Characterization Survey Package Development (Reference 2-28). The objective of the survey was to perform a sufficient radiological characterization to establish the empirical basis for the non-impacted classification and to establish a reasonable assurance that the survey units in question were free of detectable radioactive material resulting from the operation of the reactors.

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 design only 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 to ensure an unbiased survey.

The characterization survey of each survey unit consisted of both qualitative evaluations and quantitative analysis results. The qualitative evaluation consisted of static measurements using the Canberra In Situ Object Counting System (ISOCS). Investigative and verification gamma scans using a Ludlum Model 2350-1 and a Model 44-10 NaI detector were also performed.

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 specific analysis of surface soil media using a calibrated counting geometry. Analysis times were set to achieve the required MDCs that were based on the expected Cs-137 background due to global fallout as set forth in TSD 13-004 and reproduced in Table 2-11. The results of the ISOCS and soil sample measurements were compared to the appropriate background value commensurate with the soil type. Any measurements exceeding these values would be indicative of the presence of plant-derived radioactivity.

The minimum number of random-based direct measurements was adjusted to approximate one (1) measurement location for every 2,000 m2 of land area. This survey frequency was in accordance with the Characterization Survey Plan and procedure ZS-LT-100-001-001. Surface scanning using a NaI detector 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 of coordinates that corresponded to specific locations within each survey unit. If a randomly selected location was found to be either inaccessible or unsuitable (e.g. a portion of the surface area in the instruments FOV was covered in standing water), then the location was adjusted to the closest adjacent suitable location.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 The ISOCS detector was oriented downward and perpendicular to the ground. The exposed face of the detector was positioned at a height of 3 meters above the ground. With the 90-degree collimation shield installed, this orientation corresponded to a nominal FOV of 28 m2. The ISOCS geometry evaluated soil activity to a depth of 15 cm (6 inches below grade) over the geometric FOV. Measurement count times were adjusted to achieve a MDC of 0.40 pCi/g for Cs-137.

The action level was set at any detectable activity greater than the actual measurement MDC for any potential plant-derived gamma emitting radionuclide or the Cs-137 background values. If any measurement would have identified a plant-derived gamma emitting radionuclide that was not found in background or, if the observed activity exceeded the expected background activity concentration, then an investigation would have been performed.

2.3.4.1. Surface Soils The owner-controlled non-impacted open land areas at Zion totaled 874,041 square meters of surface area. The non-impacted surface area was broken into 11 survey units in accordance with the area descriptions, sizes and boundaries presented in the HSA. The non-impacted survey units are illustrated by Figure 2-4. Of the 874,041 square meters, 182,127 square meters was deemed as inaccessible. In this context, inaccessible is defined as 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 be prohibitive. The total surface area deemed accessible was 691,913 square meters.

Of the 691,913 square meters of surface area, 9,378 square meters were scanned by a Model 2350 paired with a Model 44-10 NaI detector. Alarm set-points for the instrument were set at the observed background plus the MDCR of the instrument. With an average background of 4,337 cpm, the average observed scan result was 4,677 cpm. Twenty-four (24) instrument alarms were logged with a maximum observed scan reading of 9,550 cpm. All alarms were investigated and soil samples were taken at locations where the elevated reading was verified.

Two hundred and thirty-six (236) static measurements were taken with the ISOCS. This equated to a coverage area of 6,608 square meters using a 28 square meter FOV. Of the total measurements taken, 75 measurement results indicated the presence of Cs-137 in concentrations greater that the MDC of the instrument. No other potential plant-derived radionuclides were positively identified. Cs-137 concentrations identified by ISOCS measurements averaged 0.17 pCi/g with a maximum observed Cs-137 concentration of 0.34 pCi/g.

One hundred and sixty-six (166) surface soil sample were taken to verify ISOCS results or as investigations. Of the total number of surface soil samples taken and analyzed, Cs-137 was identified at concentrations greater than the MDC of the instrument in 106 surface soil samples.

No other potential plant-derived radionuclides were positively identified. The average Cs-137 concentration observed in the analysis of the surface soil samples was 0.24 pCi/g with a maximum observed concentration of 0.57 pCi/g.

Additional detail on the survey and sampling methodology and results of the radiological analysis of each measurement and soil sample obtained during the characterization of non-impacted open land survey units are presented in ZionSolutions TSD 14-028. The scope and 2-39

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 extent of the surveys performed in the non-impacted classified open land areas were sufficient to demonstrate that the non-impacted classification was appropriate for the open land areas in question and that it is highly unlikely, based upon the findings and conclusions of the HSA, combined with the results of the characterization, that plant-derived radioactivity resides in these areas. 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 areas are appropriate. Cs-137 was the only radionuclide positively identified that could potentially be classified as plant-derived. However, the concentrations observed are well within the range of activity defined as background due to global fallout illustrated in Table 2-11. The locations of ISOCS measurements and surface soil samples are illustrated on Figure 2-28. A summary of the findings of the survey for each individual survey unit are presented in Table 2-27.

2.3.4.2. Subsurface Soils The survey design for the characterization of the non-impacted open land survey units required the acquisition of subsurface soil samples only if an investigation was required prompted by the discovery of plant-derived radionuclides in concentrations greater than background in a surface soil sample or an ISOCS measurement. In addition, a subsurface soil sample would be taken if physical indications would suggest the potential presence of a burial area. Based upon the results of the characterization survey, no investigation was prompted by the discovery of plant-derived radionuclides in concentrations greater than background. In addition, no suspected burial areas were identified during the walkdowns of the survey units. Consequently, no subsurface soil samples were acquired in the non-impacted survey units.

2.3.5. Impacted Open Land Areas The Zion HSA identified the open land area inside the single fenced Radiologically-Restricted Area as impacted by reactor operations. The approximate area of the footprint is 87 acres. In addition, a majority of the open land area inside the double-fenced Security-Restricted Area was primarily classified as Class 1.

Characterization of the impacted open land areas began in November 2011 with the characterization of the Class 3 open land survey units encompassing the proposed site for the future ISFSI facility, the non-impacted location where the Vertical Concrete Cask Construction Area was to be located and the pathway for the new rail tracks. The remaining balance of the impacted open land areas were surveyed between November 2012 and October 2013.

Initial survey units were established by the HSA. A sample plan was prepared for each survey unit in accordance with procedure ZS-LT-100-001-001. Survey techniques were employed to determine the lateral and vertical extent of any contamination identified and the radionuclide concentrations in the soil.

A reference grid was established in each impacted survey unit. The reference grid consisted of a grid coordinate system that can be accessed using a Global Positioning System (GPS) system.

Survey units were scanned in accordance with their initial classification or the anticipated classification based on historical knowledge. Recommended scan coverage guidelines for characterization for each class of survey unit is presented in Table 2-5.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 A combination of random and judgmental survey locations were established in each survey unit in accordance with the survey unit classification. The size of the judgmental sample population was determined using the recommended judgmental sample population sizes stated in procedure ZS-LT-100-001-001 and presented in Table 2-28. The locations of judgmental measurements and/or samples were determined by the professional judgment of the responsible Radiological Engineer. Consideration was given to locations that exhibit measurable radioactivity, depressions, discolored areas, low point gravity drain areas, actual and potential spill locations, or areas where the ground had been disturbed. The number of random-based survey locations was also determined by area classification. Random-based measurements were not required in an open land areas designated as Class 1. In a Class 2 survey unit, a minimum of 15 random-based locations were recommended. In Class 3 open land survey units, the minimum number of random-based survey locations were adjusted to approximate one (1) measurement location for every 2,000 m2 of land area.

A surface soil sample was taken at each selected judgmental and random-based survey location.

Sub-surface soil samples were acquired at a minimum of 10% of the surface soil sample locations identified. Additional subsurface soil samples were acquired if surface soil sample analysis or surface scans indicated elevated activity. Depending on the location, subsurface soil samples were taken from 0.15 cm to depths ranging from 1 to 3 m below grade and composited over 1 m intervals.

Each surface soil and composite subsurface soil sample was analyzed by the on-site radiological laboratory by gamma-spectroscopy for plant-derived gamma emitting radionuclides. Analysis count times were adjusted as necessary to achieve an isotopic MDC equal to or less than 0.18 pCi/gm for Cs-137 and Co-60. In a majority of the survey units, the surface and subsurface composite samples were initially analyzed without drying the sample media. If the initial on-site gamma spectroscopy analysis indicated that no plant-derived radionuclides were detected at a concentration greater than their respective MDC, then the sample was dried and reanalyzed, again using the on-site gamma spectroscopy system. If the initial on-site gamma spectroscopy analysis indicated the presence of plant-derived radionuclides greater than their respective MDC, then a portion of the sample was segregated into a separate container for further analysis and the remainder of the sample was dried and reanalyzed, again using the on-site gamma spectroscopy system. Several soil samples that exhibited concentrations of plant-derived gamma emitting radionuclides greater than MDC were shipped to an approved off-site vendor for full isotopic analysis (HTD radionuclides).

2.3.5.1. Surface Soils and Paved Areas The Radiologically-Restricted Area is illustrated in Figure 2-2. In this area, there are 22 Class 3 open land survey units. The survey unit boundaries are illustrated on Figure 2-6.

Seven (7) Class 3 open land survey units reside outside of the Radiologically-Restricted Area.

These areas include the West Training Area along Shiloh Boulevard, the beach outside of the fenced area along the lakefront (broken into three (3) Class 3 survey units), survey unit 10220C along the south boundary and two (2) areas initially classified as non-impacted in the HSA but reclassified as Class 3 due to current and expected decommissioning activities. These areas include the VCC area and the site parking lot. The Class 3 survey units situated outside of the Radiologically-Restricted Area are illustrated in Figure 2-5.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 The Class 3 open land survey units at Zion have a total surface area of 401,042 square meters.

49,116 square meters of the total Class 3 area was deemed as inaccessible due to obstacles.

The total surface area deemed accessible was 351,926 square meters. Of this area, 104,350 square meters or approximately 30% of the surface area were scanned using a Model 2350 paired with a Model 44-10 NaI detector. This area included asphalt paved surfaces.

Alarm set-points for the instrument were set at the observed background plus the MDCR of the instrument. With an average background of 3,713 cpm, the average observed scan result was 3,753 cpm. Three hundred-seventeen (317) instrument alarms were logged with a maximum observed scan reading of 12,193 cpm. All alarms were investigated and soil samples were taken at locations where an elevated reading was verified.

In the West Training Area, forty-six (46) static measurements were taken with the ISOCS.

This equated to a coverage area of 1,288 square meters using a 28 square meter FOV. Of the total measurements taken, seven (7) measurement results indicated the presence of Cs-137 in concentrations greater that the MDC of the instrument. No other potential plant-derived radionuclides were positively identified. Cs-137 concentrations identified by ISOCS measurements averaged 0.18 pCi/g with a maximum observed Cs-137 concentration of 0.25 pCi/g.

Seven hundred-eighteen (718) surface soil sample were taken at judgmental, random-based and investigation locations. The locations of random and judgmental surface soil samples taken in Class 3 open land survey units located outside of the Radiologically-Restricted Area are illustrated on Figure 2-29. The locations of random and judgmental surface soil samples taken in Class 3 open land survey units located inside of the Radiologically-Restricted Area are illustrated on Figure 2-30. Of the total number of surface soil samples taken and analyzed, Cs-137 was identified at concentrations greater than the MDC of the instrument in 142 surface soil samples and Co-60 was identified at concentrations greater than the MDC of the instrument in one (1) sample. No other potential plant-derived radionuclides were positively identified. The average Cs-137 concentration observed in the analysis of the surface soil samples was 0.12 pCi/g with a maximum observed concentration of 1.14 pCi/g. The one sample where Co-60 was positively identified had a Co-60 concentration of 0.13 pCi/g.

Additional detail on the survey and sampling methodology and results of the radiological analysis of each measurement and soil sample obtained during the characterization of Class 3 open land survey units are presented in ZionSolutions TSD 14-028. Based upon the results of the characterization surveys performed of the Class 3 open land areas, strong evidence is provided to conclude that minimal residual plant-derived radioactivity is present in these areas.

A summary of the findings of the survey for each individual Class 3 open land survey unit are presented in Table 2-29.

The Security-Restricted Area is illustrated in Figure 2-3. In this area, there are 13 Class 1 open land survey units and five (5) Class 2 open land survey units. The survey unit boundaries are illustrated on Figures 2-7. The area of each survey units complies with the recommended survey unit sizes for open land survey units specified in MARSSIM, section 4.6. Additional detail on the survey and sampling methodology and results of the radiological analysis of each measurement and soil sample obtained during the characterization of Class 2 and Class 1 open land survey units are presented in ZionSolutions TSD 14-028.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 The Class 2 open land survey units at Zion total 39,747 square meters of surface area.

9,085 square meters of the total Class 2 area was deemed as inaccessible, mostly due to the presence of buildings (Turbine Building, Crib House, Service Building and Gate House). The total surface area deemed accessible was 30,622 square meters. Of this area, 22,559 square meters or approximately 74% of the surface area were scanned by a Model 2350 paired with a Model 44-10 NaI detector. This area included asphalt paved surfaces. Alarm set-points for the instrument were set at the observed background plus the MDCR of the instrument. With an average background of 3,005 cpm, the average observed scan result was 3,012 cpm. One-hundred-eighteen (118) instrument alarms were logged with a maximum observed scan reading of 11,264 cpm. All alarms were investigated and soil samples were taken at locations where elevated readings were verified.

Fifty-nine (59) surface soil samples were taken at judgmental, random-based and investigation locations in Class 2 open land survey units. The locations of random and judgmental surface soil samples are illustrated on Figure 2-31. Of the total number of surface soil samples taken and analyzed, Cs-137 was identified at concentrations greater than the MDC of the instrument in 12 surface soil samples. No other potential plant-derived radionuclides were positively identified. The average Cs-137 concentration observed in the analysis of the surface soil samples was 0.14 pCi/g with a maximum observed concentration of 0.21 pCi/g. A summary of the findings of the survey for each individual Class 2 open land survey unit are presented in Table 2-30.

There are thirteen (13) open land survey units classified as Class 1 at Zion totaling 24,759 square meters of surface area. Of the 13 Class 1 open land survey units, the surface soils in four (4) survey units, totaling 7,740 square meters of surface area were deemed as inaccessible. A majority of the inaccessible surface area is obstructed by the presence of buildings, namely the two Containment Buildings, the Fuel Handling Building and the Auxiliary Building. However, due to the fact that all the asphalt and concrete ground coverings inside of the Security-Restricted Area will be disposed of as waste, surface soil was also deemed inaccessible if the area was paved. In addition, stored radioactive material in the vicinity of some areas prevented the ability to perform surface scanning due to high background. These surfaces were deemed as inaccessible as well.

The Class 1 surface area deemed accessible was 17,019 square meters. Of this area, 9,444 square meters or approximately 55% of the surface area was scanned by a Model 2350-1 paired with a Model 44-10 NaI detector. Alarm set-points for the instrument were set at the observed background plus the MDCR of the instrument. With an average background of 2,690 cpm, the average observed scan result was 3,361 cpm. Five-hundred forty-six (546) instrument alarms were logged with a maximum observed scan reading of 35,962 cpm. All alarms were investigated and soil samples were taken at locations where an elevated reading was verified.

Ninety-four (94) surface soil samples were taken at locations biased toward observed elevated scan measurements and known spill locations. The locations of surface soil samples taken in Class 1 open land survey units are illustrated in Figure 2-32. Of the 111 surface soil samples taken, Co-60 was positively identified in concentrations greater than the instrument MDC in 14 samples and Cs-137 was positively identified in concentrations greater than the instrument MDC 2-43

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 in 58 samples. No other potential plant-derived gamma-emitting radionuclides were positively identified. The average Co-60 concentration observed in the analysis of the surface soil samples was 0.13 pCi/g with a maximum observed concentration of 1.04 pCi/g. The average Cs-137 concentration observed in the analysis of the surface soil samples was 0.12 pCi/g with a maximum observed concentration of 3.39 pCi/g. A summary of the findings of the survey for each individual Class 1 open land survey unit are presented in Table 2-31.

Nine (9) surface soil samples taken from Class 1 open land survey units were sent to Eberline Laboratory for gamma spectroscopy and HTD analyses for radionuclides such as H-3, C-14, Tc-99, Ni-63, Sr-90, and alpha emitters. The results of the analysis are presented in Table 2-32.

Co-60 and Cs-137 were the only potential plant-derived radionuclide identified in a concentration greater than the analysis MDC. No other plant-derived radionuclides were positively identified by these analyses.

2.3.5.2. Subsurface Soils The HSA was consulted to identify those survey areas where the potential existed for subsurface radioactivity. Such areas include, but are not limited to, areas under buildings, building floors/foundations, or outside components where leakage was known or suspected to have occurred in the past and on-site storage areas where radioactive materials have been identified.

Soil data from both the HSA and any pertinent surface characterization data were used to establish locations and potential depth for any potential sub-surface radioactivity.

A total of 723 composited subsurface soil samples were collected and analyzed during the site characterization. Inside the Security-Restricted Area, subsurface soil samples were typically taken to a depth of approximately 3 m below grade. In the Class 3 survey units, subsurface soil samples were typically taken to a depth of approximately 1 m below grade.

Two-hundred eighty-three (283) subsurface soil samples were taken in Class 1 open land survey units. Cs-137 was positively identified in concentrations greater than the instrument MDC in 14 samples and Co-60 was positively identified in concentrations greater than the instrument MDC in one (1) sample. No other potential plant-derived gamma-emitting radionuclides were positively identified. The average Cs-137 concentration observed in the analysis of the surface soil samples was 0.18 pCi/g with a maximum observed concentration of 0.70 pCi/g. The one sample where Co-60 was positively identified had a Co-60 concentration of 0.10 pCi/g. A summary of the results of the subsurface soil sample analysis by Class 1 open land survey unit are presented in Table 2-31.

One (1) subsurface soil sample taken from a Class 1 open land survey unit was sent to Eberline Laboratory for gamma spectroscopy and HTD analyses for radionuclides such as H-3, C-14, Tc-99, Ni-63, Sr-90, and alpha emitters. The results of the analysis are presented in Table 2-32.

Cs-137 was the only potential plant-derived radionuclide identified in a concentration greater than the analysis MDC. No other plant-derived radionuclides were positively identified by these analyses.

Sixty (60) subsurface soil samples were taken in Class 2 open land survey units. Cs-137 was positively identified in concentrations greater than the instrument MDC in three (3) samples. No other potential plant-derived gamma-emitting radionuclides were positively identified. The 2-44

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 average Cs-137 concentration observed in the analysis of the surface soil samples was 0.11 pCi/g with a maximum observed concentration of 0.15 pCi/g. A summary of the results of the subsurface soil sample analysis by Class 2 open land survey unit are presented in Table 2-32.

Three-hundred eighty (380) subsurface soil samples were taken in Class 3 open land survey units. Cs-137 was positively identified in concentrations greater than the instrument MDC in 32 samples. No other potential plant-derived gamma-emitting radionuclides were positively identified. The average Cs-137 concentration observed in the analysis of the surface soil samples was 0.09 pCi/g with a maximum observed concentration of 0.15 pCi/g. A summary of the results of the subsurface soil sample analysis by Class 2 open land survey unit are presented in Table 2-30.

In October of 2013, a single soil sample was acquired from the soil under the Turbine Building 560 foot floor slab. The basis for the selection of the location assumed groundwater flow from west toward Lake Michigan to the east. The Turbine Building is located between Lake Michigan and four potential sources of radiological contamination (the two Containment Buildings, the Auxiliary Building and the Fuel Handling Building). Other considerations for the selection of the sample location included the accessibility for the GeoProbe equipment and the thickness of the concrete floor slab that must be drilled through in order to access the underlying soils.

A hole was drilled through the concrete floor slab, exposing the underlying soil. The soil consistency found was hard-packed clay. A single sample of the soil was acquired, representing a depth of approximately 38 feet below grade. The sample was analyzed on the on-site gamma spectroscopy system. No plant-derived radionuclides at concentrations greater than the instrument MDC were detected.

The assessment of potential subsurface soil contamination is not currently complete. Soil in difficult to access areas such as under building foundations and surrounding buried structures will be deferred until later in the decommissioning process, when access will be more readily available.

2.3.6. Surface and Groundwater Section 8.5 in Chapter 8 of this LTP contains a summary description of the geology, hydrogeology and hydrology of ZNPS and environs. The information contained in this section was derived directly from ZionSolutions TSD 14-003, Conestoga Rovers & Associates (CRA)

Report, Zion Hydrogeologic Investigation Report (Reference 2-29) and presents a summary of studies that have been performed to investigate radiological groundwater contamination resulting from the operation of ZNPS. TSD 14-003, documents the results of hydrogeologic investigations completed by Conestoga-Rovers & Associates (CRA), Exelon, and ZionSolutions from August 2006 through September 2013.

2.3.6.1. Area Groundwater Use ZNPS is connected to the Zion municipal water supply and does not use groundwater in its operations. The City of Zion provides municipal water to City residents and the surrounding area. The City purchases water from the Lake County Public Water District (LCPWD). The LCPWD obtains its water from Lake Michigan by means of an intake pipe located approximately 2-45

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1 mile north of the Site and extending 3,000 feet into the Lake. The City of Zion municipal code requires all improved properties to be connected to the City's water supply. The code states that it is unlawful for any person to construct, permit or maintain a private well or water supply system within the City which uses groundwater as a potable water supply. There is an exception for some existing wells constructed prior to March 2, 2004. However, it is unlikely that any private well or water supply system exists within the City which uses groundwater as a potable water supply.

2.3.6.2. Groundwater Flow The shallow groundwater in the upper sand unit flows to the east toward Lake Michigan. The sheet pile wall installed along the lakeshore and the building foundations restrict the groundwater flow in the upper sand unit, which causes the groundwater to flow around ZNPS. The shallow water table intercepts the stormwater drainage ditches in the west area of the ZNPS property, but does appear to affect the flow of groundwater to the east and toward Lake Michigan. If the buildings and sheet pile wall are left intact (not perforated for flow) during the decommissioning, then a localized stagnation of groundwater around these barriers will occur since groundwater is prevented from flowing through these structures toward the Lake.

2.3.6.3. Previous Investigations In 2006, CRA prepared a report titled Hydrogeologic Investigation Report, Fleetwide Assessment, Zion Station, Revision 1 (Reference 2-30) to determine whether groundwater at and in the vicinity of ZNPS has been adversely impacted by any releases of radionuclides. With the exception of H-3 and total strontium, no radionuclides were detected above the MDC during the 2006 investigation.

In 2011, the Wisconsin Department of Health Services (WDHS) conducted environmental radiation monitoring around the ZNPS site. This investigation was documented in a report titled, Zion Environmental Radioactivity Survey-2001 (Reference 2-31). In this report, the WDHS concluded:

• Air particulate analysis shows no evidence of influence by ZNPS on air quality.

• The average yearly exposure of ambient gamma radiation is at background levels and is comparable to other areas within Wisconsin.

• The surface water samples showed no unusual concentrations of gross beta, gross gamma, tritium, and strontium.

• The gamma isotopic analysis for surface water indicated radioisotopes below their respective minimum detectable concentration.

• The gamma isotopic analysis on vegetation detected only a small amount of the naturally occurring elements K-40 and Be-7.

• The gamma isotopic analysis for soil detected naturally occurring K-40 and Cs-137, which is attributable to fallout from previous atmospheric nuclear tests (these were also detected in previous years).

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1

• Doses of radiation as a result of gaseous and liquid effluent are less than the limits allowed for an average individual as stated in Federal Regulations.

2.3.6.4. On-Going Investigations Ongoing monitoring of surface water and groundwater at ZNPS include REMP, Radiological Groundwater Protection Program (RGPP) and NPDES Monitoring.

2.3.6.4.1. Radiological Environmental Monitoring Program (REMP)

The REMP at ZNPS was initiated in 1973. The REMP includes the collection of various media samples including air, surface water, groundwater, fish, sediment, vegetation, clams, and crabs.

The samples are analyzed for beta and gamma emitters, H-3, Sr-90 and other radiological constituents. The samples were collected at established locations, identified as stations, so that trends in the data could be monitored. The data for the REMP is collected quarterly and reported annually. The data has consistently supported a conclusion that the operation of ZNPS has and continues to have no adverse environmental impact on the environment.

2.3.6.4.2. Radiological Groundwater Protection Program (RGPP)

Since the fall of 2006, routine monitoring has been completed through the sampling and analysis of groundwater from 11 permanent monitoring wells and surface water from one established sampling location. The location of groundwater monitoring wells and the surface water sample location is presented in Figure 2-33.

2.3.6.4.3. National Pollutant Discharge Elimination System (NPDES)

ZNPS has an NPDES permit that was issued by the Illinois EPA. The NPDES permit covers discharge limitations, monitoring and reporting requirements for station discharges to Lake Michigan through two approved outfalls (#001 and #002). In addition, ZNPS has a General NPDES Permit for Storm Water Discharges from Construction Site Activities. The locations of the outfalls are presented in Figure 2-33.

2.3.6.5. Summary of Analytical Results in Groundwater H-3 was detected in monitoring well MW-ZN-01S (located just south of the WWTF) in May of 2006. The analysis of groundwater samples collected from both the upper and lower portions of the screened intervals in MW-ZN-01S resulted in H-3 concentrations of 261 +/- 124 pCi/L and 506 +/- 141 pCi/L respectively. Well MW-ZN-01S was re-sampled in June of 2006, and the analysis of the samples resulted in H-3 concentrations of 220 +/- 123 pCi/L and <200 pCi/L for the upper and lower screened intervals respectively. Since the initial sample results noted above, tritium has not been observed in MW-ZN-01S or any other ZNPS monitoring well greater than the MDC of 200 pCi/L. It was noted that following the initial sampling in June of 2006 the tritium analysis method was changed to include distillation of the samples for tritium. It should also be noted that even though the level of H-3 was greater than the detection limit, the reported values were significantly less than the EPA drinking water standard of 20,000 pCi/L.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Sr-90 was also detected during the May 2006 sampling event, specifically at monitoring wells MW-ZN-05S (located south of the Service Building parking lot) and MW-ZN-06S (located near the access road west of the Switchyard and up-gradient of ZNPS). The Sr-90 concentrations were respectively, 1.93 +/- 0.8 pCi/L (MDC: 1.3 pCi/L) and 1.77 +/- 0.72 pCi/L, (MDC:

1.15 pCi/L). Based on the uncertainty and associated MDC both samples are very near the detection limit. These concentrations were less than the EPA drinking water standard of 8 pCi/L.

Both of these locations are up-gradient from the groundwater flow direction and should not be impacted by ZNPS activities.

Between 2006 and 2013, other radionuclides have been detected in groundwater at the Facility at concentrations greater than their respective detection limits. These include the natural radionuclides associated with the soils, silts and clays. These radionuclides were K-40, Th-228, Ra-226 and Ac-228. These naturally occurring radionuclides are expected to be within the soils and detected during sample analyses. Appendix D of TSD 14-003 presents the 2006 through 2011 analytical data for groundwater analysis. Table 6.2 of TSD 14-003 presents the 2012 through 2nd Quarter 2014 analytical results for groundwater analysis.

2.3.6.6. Summary of Analytical Results in Surface Water Between 2006 and 2014, H-3 and site-derived radionuclides has not been detected in surface water at ZNPS at concentrations greater than the respective detection limit. Gross Beta was detected within background range. K-40 was detected in a surface soil sample in May 2006 at a concentration of 106.8 pCi/L. Appendix D of TSD 14-003 presents the 2006 through 2011 analytical data for surface water. Table 6.2 of TSD 14-003 presents the 2012 through 2nd Quarter 2014 analytical results for surface water analysis.

2.4. Hazardous Material Characterization The decommissioning approach for ZSRP calls for the beneficial reuse of concrete from building demolition as clean fill. A sampling plan was developed and implemented for testing of paints and coatings on structures and concrete. ZionSolutions evaluated the use of Clean Construction or Demolition Debris (CCDD) for the end-state of the basements and submitted a Request for Concurrence for Basement Fill End-State to the Illinois EPA in August of 2014. This request included the results of a sampling plan for concrete candidate fill material to be used for the basement fill end-state. On October 3, 2014, ZionSolutions received a Letter of Concurrence from the Illinois EPA for the use of CCDD for the basement fill end-state. In accordance with Section 3.160(b) of the Illinois Environmental Protection Act, CCDD is defined as uncontaminated broken concrete without protruding metal bars, bricks, rock, stone, reclaimed or other asphalt pavement or soil generated from construction or demolition activities. Only concrete debris that meets the definition of CCDD will be considered for use as clean hard fill and only when surveys have demonstrated that the concrete is free of detectable residual radioactivity. Concrete debris that is surveyed and found contaminated with detectable residual radioactivity will be disposed of as low-level radioactive waste.

Integral to the decommissioning process, ZionSolutions has undertaken a comprehensive asbestos abatement project. Asbestos containing material that is identified on equipment and 2-48

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 structures is remediated prior to demolition. Lead and PCB surveys are also performed on structures and remediation actions identified prior to demolition.

A sampling program has been developed to assess potential impacts to the environment. Non-radiological site characterization activities focus on areas of interest that have been identified based on the HSA and current site conditions. Characterization activities have included surface and subsurface soil sampling as well as groundwater sampling, with primary constituents of concern including, but not limited to: volatile organic compounds, semi-volatile organic compounds, polychlorinated biphenyls, metals, and dioxins. A preliminary list of areas of interest has been developed and will be evaluated for potential impacts to the environment. The areas of interest include the following:

• Fire Training, IRSF, and Mechanical Maintenance Training Warehouse Area

• Underground Fuel Oil Tanks (2 locations)

• Crib House

• East Yard Above Ground Storage Tanks (4 locations)

• Aboveground 150,000 gallon Fuel Oil Tank

• Transformer Areas

• Unit 1 Containment Tendon Area

• Used Oil Storage Pad

• Aboveground Diesel Fuel Tank north of ENC

• North Parking Lot

• Site Warehouses

• Oil/Water Separators

• Wastewater Treatment Facility

• Compactor and Dumpster Areas Initial characterization activities have been completed at the Fire Training, IRSF, Mechanical Maintenance Training Warehouse Area, the Crib House, and the above ground 150,000 gallon Fuel Oil Tank. Environmental sampling completed for the areas of interest identified elevated poly-nuclear aromatic hydrocarbon (PAH) results in surface soils in the fuel oil tank area. A remediation plan will be required to address the impacted soils to reach closure of this area under IEPA regulations. Characterization activities will be completed at the remaining areas of interest as site decommissioning activities allow. Site closure activities will comply with applicable USEPA and IEPA regulatory requirements.

2.5. Continuing Characterization The survey of many inaccessible or not readily accessible subsurface soils or surfaces has been deferred. All continuing Characterization Plans will be provided to the NRC for information and all continuing Characterization Reports will be provided to the NRC for evaluation. The 2-49

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 following are areas at Zion where additional or continuing characterization will occur. These areas are;

• The underlying concrete of the SFP/Transfer Canal below the 588 foot elevation after the steel liner has been removed. Continuing characterization will consist of scanning of the exposed concrete surfaces and the acquisition of concrete core sample(s) at the location of highest activity. The number and location of the additional concrete core sample(s) will be determined by DQO during survey design.

• The concrete walls and floor of the Under-Vessel areas in Unit 1 and Unit 2 Containments.

Continuing characterization will consist of the acquisition of additional concrete core sample(s). The number and location of the additional concrete core samples will be determined by DQO during survey design.

• The floors and walls of the Hold-Up Tank (HUT) cubicle. Continuing characterization will consist of the acquisition of additional concrete core sample(s). The number and location of the additional concrete core samples will be determined by DQO during survey design.

• The floor of the Auxiliary Building 542 foot elevation Pipe Tunnel floors. Continuing characterization will consist of the acquisition of additional concrete core sample(s). The number and location of the additional concrete core samples will be determined by DQO during survey design.

• The floor and lower walls of the 542 foot elevation of the Auxiliary Building to augment the existing characterization data. The number and location of the additional concrete core samples will be determined by DQO during survey design.

• The subsurface soils in the keyways between the Containment Buildings and the Turbine Building once subsurface utilities have been removed and the removal of subsurface structures in this area create access (e.g., Waste Annex Building). Continuing characterization will consist of the scanning of soils exposed by the demolition and building removal, the acquisition of soil sample(s) of the exposed soil and the acquisition of additional subsurface soil samples using test pits or soil borings. The number and location of the additional subsurface soil samples will be determined by DQO during survey design.

• The soils under the basement concrete of the Containment Buildings, the Auxiliary Building and the SFP/Transfer Canal once commodity removal and building demolition have progressed to a point where access can be achieved. Continuing characterization will consist of soil borings at the nearest locations along the foundation walls that can be feasibly accessed, angled soil bores to access the soils under the concrete, and deep cores from building floors, but not entirely through the foundation, at bias locations to assess migration potential from building interiors to soils under basement concrete. The number and location of the additional subsurface soil samples will be determined by DQO during survey design.

Additional investigations and sampling will be performed in accordance with a sample plan if activity is positively identified.

• When the interior surfaces become accessible, several potentially contaminated embedded and buried pipe systems that will be abandoned in place. Continuing characterization will 2-50

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 consist of direct measurements on pipe openings and the acquisition of sediment and/or debris samples (if available) for analysis.

• The Containment basements after concrete removal. Continuing characterization of the steel liner will consist of beta gamma scans and swipe samples.

All surface soil at ZNPS has been adequately characterized and additional characterization of surface soil is not anticipated during continuing characterization. Radiological Assessment (RA) surveys will be performed in currently inaccessible soil areas that are exposed after removal of asphalt or concrete roadways and parking lots, rail lines, or building foundation pads (slab on grade).

The decision to defer the characterization of a soil or structure was based on one or more of the following conditions:

• ALARA considerations (e.g., the area is either a high radiation or high contamination area and additional data would likely not change the survey area or area classification of the location or surrounding areas),

• Safety considerations (e.g., difficulty of access to the upper reaches of the Containments due to height),

• Historical data shows that the area could be classified without further characterization,

• Access for characterization would require significant deconstruction of adjacent systems, structures or other obstacles where the removal could result in an unsafe condition or interfere with continued operation of operating systems, or

• The ability to use engineering judgment in assigning the area classification based on physical relationship to surrounding areas and the likelihood of the area to have radiological conditions represented by the conditions in these adjacent areas.

Continuing characterization surveys as specified will be performed when these areas become accessible. Characterization survey plans will be generated for each using the approved characterization survey procedures. All additional characterization data will be collected as necessary, evaluated, documented in a Characterization report and stored with previous characterization survey data in a survey history file for the survey unit. This data will be used along with existing data to update the types of radionuclides present and update the variability in the radionuclide mix for both gamma-emitting and HTD radionuclides. In addition, as the decommissioning progresses, data from operational events caused by equipment failures or personnel errors, which may affect the radiological status of a survey unit(s) will be captured.

These events will be evaluated and, when appropriate, stored in the characterization database.

This additional characterization data will be used in validating the initial classification and in planning for the FSS.

There are several previously inaccessible soils and buried pipe where historical information, process knowledge or operational survey data indicate that no significant concentrations of residual radioactivity is identified or anticipated and, that the soil or pipe is classified correctly.

In these cases, survey design for FSS will be use a coefficient of variation of 30% as a reasonable value for sigma () in accordance with the guidance in MARSSIM, section 5.5.2.2.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 As decommissioning proceeds, areas will, as necessary, be decontaminated to remove loose surface decontamination (as well as fixed contamination) to levels that will meet the conditions for controlled demolition or unrestricted release conditions for demolition. When a structure is ready for demolition, a documented survey and a formal turnover will be made by the Radiological Protection group for the group preforming demolition, validating that the radiological conditions in the structure are suitable.

Following the demolition and/or remediation, and when an area is believed to be ready for FSS, a "turnover assessment" will be performed. If the results of this assessment indicate that the FSS acceptance criteria will be met, then physical and administrative control of the area will be transferred to Characterization/License Termination group personnel for preparation, design, and performance of the FSS. Otherwise, additional remediation may be required. This assessment may include a "turnover survey," primarily for Class 1 and 2 areas within the Security-Restricted Area.

The "turnover survey" process, together with any additional characterization and remediation survey performed, represent at least one, but possibly several, opportunities to collect additional survey data prior to conducting the FSS. For each type of survey (characterization, remediation, turnover, and FSS), a documented survey plan will be developed using the DQO process. These survey plans will contain the appropriate data assessment to ensure that several objectives are met. These objectives include;

• Appropriate instrument selection to ensure the proper sensitivity relative to the applicable action level and/or release criteria,

• Appropriate instrument quality control measures to ensure operability,

• Appropriate survey techniques to ensure that the field measurement techniques are consistent with the calibration methodologies,

• Appropriate sample collection and analysis to determine spatial variability and variability in radionuclide ratios,

• Data analysis criteria to identify follow-up actions such as remediation and the collection of additional samples and,

• Appropriate classification of the survey area.

2.6. References 2-1 U.S. Nuclear Regulatory Commission Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors - January 1999 2-2 Zion Station Historical Site Assessment (HSA) - September 2006 2-3 U.S. Nuclear Regulatory Commission NUREG-1575, Revision 1, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), - August 2000 2-4 U.S. Nuclear Regulatory Commission NUREG-1757, Volume 2, Revision 1, Consolidated Decommissioning Guidance - Characterization, Survey, and 2-52

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Determination of Radiological Criteria, Final Report - September 2003 2-5 ZionSolutions ZS-LT-02, Characterization Survey Plan 2-6 ZionSolutions ZS-LT-01, Quality Assurance Project Plan (for Characterization and FSS) (QAPP) 2-7 U.S. Nuclear Regulatory Commission NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans 2-8 Zion Nuclear Power Station, Units 1 and 2 Asset Sale Agreement - December 2007 2-9 U.S. Nuclear Regulatory Commission Docket Number 50-295, Facility Operating License Number DPR-39 (for Unit One) 2-10 U.S. Nuclear Regulatory Commission Docket Number 50-304, Facility Operating License Number DPR-48 (for Unit Two) 2-11 Illinois Environmental Protection Agency - National Pollutant Discharge Elimination System (NPDES) Permit Number IL0002763 2-12 U.S. Nuclear Regulatory Commission IE Bulletin 80-10, Contamination of Nonradioactive Systems and Resulting Potential for Unmonitored Release of Radioactivity to Environment, - May 1960 2-13 Sandia National Laboratories, NUREG/CR-5512, Volume 3, Residual Radioactive Contamination From Decommissioning Parameter Analysis - October 1999 2-14 ZionSolutions Technical Support Document 11-004, Ludlum Model 44-10 Detector Sensitivity 2-15 U.S. Nuclear Regulatory Commission NUREG-1576, Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP) - August 2001 2-16 U.S. Nuclear Regulatory Commission Regulatory Guide 4.15, Quality Assurance or Radiological Monitoring Programs (Inception Through Normal Operations to License Termination) - Effluent Streams and the Environment - July 2007 2-17 ZionSolutions ZS-QA-10, Quality Assurance Project Plan - Zion Station Restoration Project 2-18 Energy Services Commercial Services Group Report, Characterization of the Zion Station Independent Spent Fuel Storage Facility (ISFSI) - July 2012 2-19 Annual Report on the Meteorological Monitoring Program at Zion Nuclear Power Station for 2010, Murray and Trettel, Inc. - February 2011 2-53

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 2-20 Energy Services Commercial Services Group Report CS-RS-PN-028, Background Reference Area Report - Zion Nuclear Power Station, - February 2012 2-21 ZionSolutions Report, Determination of Radionuclide Activity Concentrations in Soils in Non-Impacted Soils Adjacent to the Zion Nuclear Station, - July 2012 2-22 ZionSolutions Technical Support Document 13-004, Examination of Cs-137 Global Fallout in Soils at Zion Station 2-23 ZionSolutions Technical Support Document 11-001, Potential Radionuclides of Concern during the Decommissioning of Zion Station 2-24 ZionSolutions Technical Support Document 14-016, Description of Embedded Piping and Penetrations to Remain in Zion End State 2-25 ZionSolutions Technical Support Document 14-028, Radiological Characterization Report 2-26 ZionSolutions Technical Support Document 13-006, Reactor Building Units 1 & 2 End State Concrete and Liner Initial Characterization Source Terms and Distributions 2-27 ZionSolutions Technical Support Document 14-019, Radionuclides of Concern for Soil and Basement Fill Model Source Terms 2-28 ZionSolutions Procedure ZS-LT-100-001-001, Characterization Survey Package Development 2-29 ZionSolutions Technical Support Document 14-003, Conestoga Rovers & Associates (CRA) Report, Zion Hydrogeologic Investigation Report 2-30 Conestoga-Rovers and Associates, Hydrogeologic Investigation Report, Fleetwide Assessment, Zion Station, Zion Illinois, Revision 1 - September 2006.

2-31 Wisconsin Department of Health Services, Zion Environmental Radioactivity Survey -

2001 2-32 International Standard ISO 7503-1, Part 1, Evaluation of Surface Contamination, Beta-Emitters (maximum beta energy greater than 0.15 MeV) and Alpha-Emitters - August 1998 2-33 U.S. Nuclear Regulatory Commission Regulatory Guide 4.8, Environmental Technical Specifications for Nuclear Power Plants - December 1975 2-54

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-1 Operational History DATE(S) EVENT 02/10/67 ComEd announced intent to build Unit 1 07/11/67 ComEd announced intent to build Unit 2 07/12/67 ComEd dockets applications and PSAR to build both Units 1 and 2 11/25/70 ComEd dockets FSAR for both Units 1 and 2 04/06/73 ComEd receives license to operate Unit 1 11/14/73 ComEd receives license to operate Unit 2 06/19/73 Unit 1 Reactor achieves initial criticality 12/24/73 Unit 2 Reactor achieves initial criticality 12/31/73 Commercial operation begins for Unit 1 09/17/74 Commercial operation begins for Unit 2 03/05/76 to 06/19/76 Unit 1 Spring 1976 Refueling Outage 06/25/76 License received to operate both Units 1 and 2 at 100% power 01/07/77 to 03/27/77 Unit 2 Spring 1977 Refueling Outage 09/09/77 to 12/04/77 Unit 1 Fall 1977 Refueling Outage 02/04/78 to 04/12/78 Unit 2 Spring 1978 Refueling Outage 09/21/78 to 11/02/78 Unit 1 Fall 1978 Refueling Outage 03/09/79 to 04/18/79 Unit 2 Spring 1979 Refueling Outage 10/06/79 to 02/19/80 Unit 1 Fall 1979 Refueling Outage 05/02/80 to 07/26/80 Unit 2 Summer 1980 Refueling Outage 01/15/81 to 04/22/81 Unit 1 Spring 1981 Refueling Outage 09/11/81 to 12/01/81 Unit 2 Fall 1981 Refueling Outage 02/13/82 to 07/07/82 Unit 1 Spring 1982 Refueling Outage 02/24/83 to 05/27/83 Unit 2 Spring 1983 Refueling Outage 09/07/83 to 02/09/84 Unit 1 Fall 1983 Refueling Outage 03/27/84 to 07/10/84 Unit 2 Spring 1984 Refueling Outage 01/30/85 to 06/18/85 Unit 1 Spring 1985 Refueling Outage 09/05/85 to 02/04/86 Unit 2 Fall 1985 Refueling Outage 2-55

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-1 Operational History (continued)

DATE(S) EVENT 09/04/86 to 03/20/87 Unit 1 Fall 1986 Refueling Outage 02/03/87 to 02/04/87 Unit 2 Reactor Shutdown for 2D Main Steam Isolation Valve Oil Leak 04/25/87 to 05/05/87 Unit 1 Shutdown due to H-2 leak from Generator 03/25/87 to 08/08/87 Unit 2 Spring 1987 Refueling Outage 05/10/87 to 05/15/87 Unit 1 Shutdown due to High Vibrations in Generator 10/02/87 to 10/06/87 Unit 2 Reactor Forced Outage for Pressurizer Spray Valve Leakage 02/24/88 to 05/09/88 Unit 1 Spring 1988 Refueling Outage 07/13/88 to 07/16/88 Unit 1 Reactor Trip due to S/G Steam-flow/Feed-flow mismatch 07/23/88 to 07/26/88 Unit 1 Reactor Offline due to Extraction Steam leak in 16 heaters 08/09/88 to 08/12/88 Unit 2 Reactor Shutdown for 2A & 2D S/G Handhole Repairs 10/08/88 to 10/09/88 Unit 2 Reactor Trip during PT-1 10/12/88 to 12/28/88 Unit 2 Fall 1988 Refueling Outage 10/25/88 to 11/04/88 Unit 1 Reactor Shutdown due to Station Blackout 01/15/89 to 02/01/89 Unit 2 Reactor Shutdown to Repair 2A Steam Generator Tube Leak 01/27/89 to 01/29/89 Unit 1 Turbine Trip During EM Troubleshooting 02/06/89 to 03/03/89 Unit 1 Outage for Primary S/G Manway Gasket Replacement 02/20/89 to 02/22/89 Unit 2 Reactor Shutdown Due to Excess Pzr Spray Valve Leakage 03/08/89 to 03/09/89 Unit 1 Reactor Shutdown due to Inoperable RPIs / Sola Transformer 04/22/89 to 04/24/89 Unit 2 Reactor Shutdown due to Excess RCS Leakage - 2SS-9351A 08/21/89 to 08/23/89 Unit 1 Forced Outage due to loss of EHC Fluid from Broken Piping 08/27/89 to 08/31/89 Unit 1 Reactor Shutdown due to Inoperable S/G Safety Valves 09/07/89 to 01/25/90 Unit 1 Fall 1989 Refueling Outage 12/01/89 to 12/04/89 Unit 2 Reactor Forced Outage due to RCS Leak 01/18/90 to 01/19/90 Unit 2 Reactor Forced Outage due to Loss of EHC Control 01/27/90 to 01/28/90 Unit 1 Reactor Trip due to 1D S/G High Level alarm 03/01/90 to 06/13/90 Unit 1 and Unit 2 Reactor Forced Outage due to Diesel Failure 03/21/90 to 08/30/90 Unit 2 Spring 1990 Refueling Outage 2-56

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-1 Operational History (continued)

DATE(S) EVENT 08/13/90 to 08/17/90 Manual Trip of Unit 1 Turbine due to Operator Error 09/07/90 to 09/22/90 Unit 2 Turbine/Reactor Trip on loss of Condenser Vacuum 09/22/90 to 11/03/90 Unit 2 Turbine/Reactor Trip on 2W Main Transformer Failure 11/06/90 to 11/12/90 Shutdown of Unit 1 due to inoperable Diesel Generators 11/11/90 to 11/13/90 Unit 2 Turbine Trip Block Diaphragm Rupture 11/18/90 to 11/19/90 Unit 2 Heater Drain Tank Rupture Disk Repair 12/04/90 to 05/14/91 Unit 1 Reactor Shutdown due to excessive RCS Leakage 01/04/91 to 01/11/91 Unit 2 2A & 2B Safety Injection Pump Failure 03/21/91 to 06/11/91 Fire in the Unit 2 System Auxiliary Transformer 06/08/91 to 06/10/91 Unit 1 Reactor Shutdown required by abnormal 1C RCP Indications 06/11/91 to 06/13/91 Unit 2 Seal Leakoff Flow Transmitter Failed 07/28/91 to 07/30/91 Unit 2 Heater Drain Recirculation Line Rupture 09/27/91 to 11/11/91 Unit 2 1992 Surveillance Outage 12/07/91 to 01/02/92 Hydrogen Leak from Unit 1 Main Generator 02/27/92 to 08/13/92 Unit 1 1992 Refueling Outage 04/04/92 to 06/19/91 Unit 2 System Auxiliary Transformer Replacement 09/17/92 to 10/03/92 Shutdown of Unit 1 Reactor to repair the 1A Aux Feedwater Pump 11/12/92 to 02/22/93 Unit 2 1992 Refueling Outage 02/24/93 to 02/25/93 Unit 2 Main Turbine Overspeed Test 07/07/93 to 07/09/93 Unit 1 Reactor Trip due to trip of 1B RCP 07/10/93 to 07/11/93 Unit 1 Heater Drain Tank Disk Rupture 10/07/93 to 04/18/94 Dual Unit 2 Service Water/Refueling Outage 10/21/93 to 04/03/94 Dual Unit 2 Service Water/Refueling Outage 04/03/94 to 06/14/94 Unit 1 Reactor Trip due to fire at Generator Bus Duct 07/02/94 to 07/16/94 Unit 1 Reactor Trip due to fire at under Main Generator Bus Duct 10/21/94 to 10/23/94 Excessive Secondary Leak on 1A S/G Handhold 01/06/95 to 04/19/95 Unit 2 Refueling Outage 2-57

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-1 Operational History (continued)

DATE(S) EVENT 05/11/95 to 05/14/95 Unit 1 1995 Maintenance Outage 12/07/95 to 12/10/95 Unit 2 EHC Leak Due To Cracked Weld Near Accumulators 01/13/96 to 02/03/96 Unit 2 Maintenance Outage to repair Main Condenser Tubes 02/19/96 to 03/16/96 Unit 1 Shutdown to locate a loose item in the 1B S/G 03/16/96 to 03/22/96 Unit 1 Reactor Scram due to "1C" S/G Hi Level alarm 04/17/96 to 04/26/96 Automatic Scram of Unit 1 Reactor caused by Trip Of "C" Loop Flow 05/19/96 to 05/23/96 Shutdown of Unit 2 due to inoperable Diesel Generators 08/18/96 to 08/22/96 Automatic Trip of Unit 1 due to Failed Limit Switch On "1D" MSIV 08/27/96 to 09/18/96 Unit 1 Forced Outage To Repair Block Valve 1MOV-RC8000B 9/19/96 Last Day of Power Operations for Unit 2 9/19/96 to 01/15/98 Unit 2 Extended Refuel Outage 02/21/97 Last day of power operations for Unit 1 02/21/97 to 02/28/97 Unit 1 Forced Outage due to "1C" Core Spray Pump Inoperability 03/01/97 to 03/30/97 Unit 1 Maintenance Outage 03/31/97 to 01/15/98 Unit 1 Spring Refuel Outage 01/15/98 Decision to Permanently Shutdown Zion Unit 1 and Unit 2 02/13/98 Certification of Permanent Cessation of Operations for both Units 03/09/98 Certification of Permanent Defueled Status for both Units 03/10/98 to 01/25/08 Zion Units 1 and 2 maintained in a SAFSTOR condition 02/14/00 Exelon (formally ComEd) submits PSDAR to NRC.

01/25/08 Exelon submits application to NRC to transfer license to ZionSolutions 02/02/09 Zion NRC Licenses formally transferred to ZionSolutions pending confirmatory orders 09/01/09 Confirmatory orders issued allowing ZionSolutions to begin decommissioning 10/13/10 Physical Decommissioning of Zion Units 1 and 2 commences 2-58

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence Date Incident/Occurrence Citation 07/24/73 RCS spill from pressurizer spray valves. (ROR - No #)

12/27/73 Approximately 12,000 gallons of S/G water of pH 9.7 was (NRC IR released to the lake. Also approximately 2800 pounds of boric 74-17/74-17) acid was also released to the lake.

02/1974 to During this period, forty-six liquid releases were made to the (NRC IR 10/1974 discharge canal from the waste neutralization tank. Two 74-14/74-13) releases had detectable tritium and Co-58. In addition, two liquid releases were made from the Unit 2 Condenser Hotwell to the discharge canal which exhibited detectable tritium.

02/07/74 Spill of approximately 15 ft3 of spent resin from 2B CVCS (ROR 74-01) mixed resin bed demineralizer 04/25/74 Valve leak in Unit 2 Containment leading to >10 gpm RCS (NRC IR leak. 74-07/74-07) 07/26/74 Overflow of both Unit 1 and Unit 2 PWSTs. Unit 1 overflowed (NRC IR approximately 500 gallons and Unit 2 overflowed 74-13/74-12 and approximately 100 gallons. The top one-inch of soil in both 74-14/74-13) spill areas was collected and disposed of as radioactive material.

07/30/74 A Rad Waste shipment to Sheffield arrived with 2 spots of (NRC IR liquid and some resin beads on the floor of the tractor trailer. 74-11/74-10) 08/27/75 Spent resin spill in the Rad Waste Annex Truckbay 592 ft. (ROR 75-30) elevation 09/08/75 Contaminated tools were discovered in the storeroom. (ROR 75-34) 09/12/75 1000 to 2000 gallons of RWST water sprayed through Core (NRC IR Spray into Unit 1 containment. 75-13/75-12) 01/22/76 Approximately 300 gallons of RCS water spilled from (ROR 76-001) 2A S/G manway.

01/26/76 Approximately 3,000 gallons of RCS water spilled from an (ROR 76-003) open check valve on loop 2D.

03/18/76 Legal overexposure of 8.05 Rem occurred in the Unit 1 Incore (NRC IR area. 76-12/)

2-59

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 03/24/76 The Unit 1 RWST overflowed through the vent line (ROR 76-018) contaminating the Unit 1 Auxiliary Building adjacent to the Unit 1 Containment between the 640 ft. to the 592 ft. and into the soil. Contamination levels on the wall were reading up to 3000 cpm/ft2 and direct reading on the soil indicated up to 10,000 cpm.

04/20/76 Contaminated water leaking from the 1 Boric Acid (ROR 76-032)

Evaporator tank leaked into the 1B Charging pump room and into the Laundry Drain Tank area on the 560 ft. elevation of the Auxiliary Building 05/05/76 A rope contaminated was discovered in the Tech Staff area of (ROR 76-39) the Service Building 06/24/76 Contaminated clothing with readings up to 4,500 cpm was (ROR 76-044) discovered in the Shift Engineer office.

08/14/76 Due to leakage from valve 0VC8264, a gaseous release (LER 2-76-029 occurred which exceeded the tech spec limit of 60,000 uCi/sec. and NRC IR The maximum release rate was 100,000 uCi/sec, with a total 76-31/76-27) activity released of 31.8 Ci.

09/19/76 The PRT rupture disc failed due to a trip of Unit 2 Reactor. (NRC IR Approximately 2,500 gallons of PRT water spilled into Unit 2 76-28/76-24)

Containment.

09/19/76 A fire occurred when operating the 2A Diesel Generator (NRC IR 76-28/76-24) 10/01/76 The Turbine Building Floor Drain Analysis Tank (TBFDAT) (ROR 76-53) was found with 5K cpm direct and adjacent pipes up to 175 cpm/ft2 10/02/76 Contaminated tools were discovered in the Tech Staff area of (ROR 76-51) the Service Building 10/02/76 Contaminated tools were discovered in the storeroom. (ROR 76-52) 10/20/76 An unmonitored release (~ 5000 gallons) occurred from the (ROR 76-56 and TBFDAT to the fire sump. LER 1-76-084) 02/15/77 Contaminated protective clothing with readings up to (ROR 77-07) 2,500 cpm was discovered outside of the Gate House 2-60

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 03/07/77 Radiological surveys performed on the 560 ft. and 592 ft. (ROR - No #)

elevations of the Unit 2 Turbine Building identify loose surface contamination.

06/03/77 Fire hoses were found draining the TBFDAT to the Fire Sump. (ROR 77-27 and ROR 77-28) 06/30/77 Water which had collected in the Unit 1 Electrical Conduit (LER 2-77-038)

Sump in the Turbine Building was discharged through the normal discharge path to Lake Michigan. The water in this sump is from ground seepage and has been assumed to be non-radioactive and discharged as such. It was discovered after the release that it was contaminated with low level radioactivity.

The activity released was estimated to be 0.00614 Ci of beta/gamma emitters and 0.0274 Ci of tritium.

06/1977 Release via an unauthorized unmonitored effluent pathway of (NRC IR 77-about 5000 gallons from the Turbine Building Floor Drain 15/77-18)

Analysis Tank via the Turbine Building Fire Sump. Samples indicated concentrations of 2E-5 uCi/ml of fission products and an H-3 concentration of 2E-3 uCi/ml. This incident also resulted in the contamination of the Unit 1 and Unit 2 Oil Separators. The leakage containing H-3 from a Feedwater pump was being collected and routed via a drain to the Waste Neutralization tank.

10/19/77 Contaminated tools were discovered in the IM Hot Shop in an (ROR 77-47) un-posted area.

11/09/77 Contaminated line was discovered in a desk located in the MM (ROR 77-61)

Shop.

11/12/77 Carpet in the control room was identified as radiologically (ROR 77-63) contaminated.

02/25/78 A pipe wrench with contamination up to 500 cpm direct was (ROR 78-20) discovered in the MM Shop tool crib.

02/25/78 A document that was discovered to be radiologically (ROR 78-61) contaminated was discovered in the Tech Staff area of the Service Building. A follow-up survey of the area identified 35 additional contaminated documents in the area.

03/23/78 Contaminated shoe covers and coveralls with readings up to (ROR 78-36) 1,000 cpm direct were discovered in a station pickup truck.

2-61

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 04/15/78 Pipes by the TBFDAT and the Turbine Building Equipment (ROR 78-15)

Drain Analysis Tank (TBEDAT) found to have exposure rates up to 200 mR/h on contact.

06/06/78 Contamination up to 200,000 cpm direct was found on the (ROR 78-43) ground outside the Rad Waste annex.

06/20/78 Spill of approximately 16 gallons of spent resin spill in the Rad (DVR 22-1 Waste Annex area. Incident contaminated a truck and a 107) concrete pad 07/23/78 During the transfer of S/G blowdown resin to an HN-150 cask, (ROR 78-46) the cask was overfilled, causing contaminated resin to fall on the cask, trailer, and onto the ground outside the loading area.

02/01/79 During the transfer of the 2A mixed bed to an HN-200 cask, an (ROR 79-01) overflow occurred, spilling approximately 25 gallons of the water/resin mixture onto the cask exterior, truck-bed, and onto the pavement around truck. Dose rates on the spilled mixture ranged from 180 - 310 mR/h.

03/05/79 A contaminated trailer was found parked outside the Fuel (ROR 79-08)

Building trackway door. Although wrapped in plastic, the trailer still had contamination up to 300,000 cpm and a hot spot of 120 mR/h. The trailer was successfully decontaminated and released on 10/25/1979.

03/30/79 A spill occurred during the filling of a resin cask for (NRC IR solidification and shipment. An estimated 25 gallons of line 79-04/79-04) flush water containing some resins overflowed the cask, contaminating it, the trailer, and the concrete pad outside of the Rad Waste Truckbay where the transfer took place. The occurrence was blamed on failure of a high liquid level alarm together with a frozen overflow line designed to handle such an occurrence.

04/09/79 Surveys conducted outside the fenced area by the Rad Waste (ROR 79-12) loading area noted soil contamination up to 3000 cpm.

06/05/79 After the Rad Waste loading area had been remediated, a large (ROR 79-25) amount of plastic was found in the area with up to 20,000 cpm removable contamination. A wall in the area was found with up to 25,000 cpm/ft2 contamination.

2-62

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 08/07/79 During the transfer of resin into an HN-600 cask, a hose (ROR 79-36A) became disconnected from a sight-glass, spraying a resin/water mixture into the area. Due to the ventilation configuration, most of the spill was contained in the Rad Waste Truckbay and Auxiliary Building, but some radioactive material spread to the area outside of the Truckbay door.

10/26/79 pH of WWTF discharge to Lake Michigan was observed at 8.1 (LER 1-79-085) which are above the limit of 8.0.

12/1979 A spill occurred during the filling of a resin cask for (NRC IR 79-solidification and shipment. An estimated 25 gallons of line 04/79-04) flush water containing some resins overflowed the cask, contaminating it, the trailer, and the concrete pad outside of the Rad Waste Annex where the transfer took place. The occurrence was blamed on failure of a high liquid level alarm together with a frozen overflow line designed to handle such an occurrence. Temperature at the time of the transfer was said to be 10-15 degrees F. A rather extensive cleanup was performed.

The tractor was cleaned and released; the trailer moved to the Fuel Handling Building loading area, where it was stored until final disposition.

12/27/79 The WWTF effluent pH ranged from 4.1 to 4.77 (lower than the (LER 1-79-094)

Tech spec minimum of 6.0). A total of 5,760 gallons of the acidic solution was discharged to the condenser cooling water, where it was further diluted prior to discharge to Lake Michigan.

03/20/80 A hose from the Auxiliary Building Floor Drain Analysis Tank (ROR 80-16)

(ABFDAT) and Equipment Drain Analysis Tank (ABEDAT) to a portable demineralizer ruptured and spilled approximately 20 gallons of contaminated water from the 617 ft. elevation to the 562 ft. elevation. Contamination ranged from 1,000 to 2,000 cpm/ft2.

03/21/80 While using a portable demineralizer system in the Rad Waste (NRC IR Annex, a hose failure resulted in the spill of approximately 30 80-05/80-04) to 40 gallons of radioactive water to the floor.

04/17/80 Spent resin was spilled in the non-posted portion of the Fuel (ROR 80-20)

Handling Building 617 ft. elevation mezzanine 2-63

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 05/1980 Due to a valve connection error, a freeze seal that was applied (NRC IR 80-was applied to a RCS pipe system failed, causing the spill of 12/80-12) approximately 2,000 gallons of refueling cavity water to the basement of the Unit 2 Containment.

05/21/80 Contamination up to 1,000 cpm/ft2 was discovered on the cask (ROR 80-31) overflow liner outside of the posted Contaminated Area.

06/09/80 A spill of contaminated water occurred during the solidification (ROR 80-35) of an HN-100 demineralizer. The spill contaminated the floor in the Fuel Handling Building outer track-way (Car-Shed) up to 35,000 cpm/ft2.

07/08/80 The WWTF effluent pH ranged from 4.0 to 6.0 (lower than the (LER 1-80-033)

Tech spec minimum of 6.0). A total of 317,430 gallons of the acidic solution was discharged to the condenser cooling water, where it was further diluted prior to discharge to Lake Michigan.

07/20/80 The WWTF effluent pH ranged from 4.0 to 6.0 (lower than the (LER 1-80-035)

Tech spec minimum of 6.0). Approximately 70,200 gallons of the acidic solution with a pH of 5.86 was discharged to the condenser cooling water, where it was further diluted prior to discharge to Lake Michigan.

10/24/80 A basic solution from the Waste Neutralization Tank drained to (LER 1-80-045) the Fire Sump and the resulting effluent pH to the WWTF was 8.49. Approximately 8,600 gallons of caustic water was discharged to the condenser cooling water, where it was further diluted prior to discharge to Lake Michigan.

10/30/80 A contaminated metal pipe with readings up to 100,000 cpm (ROR 80-64) was found in a dumpster.

11/01/80 The WWTF effluent pH was measured at 4.45 with a tech spec (LER 1-80-047) allowed range of 6 - 8. Approximately 27,000 gallons of acidic wastewater was discharged to the condenser cooling water, where it was diluted by a factor of 8200 to 1.

11/02/80 A contaminated black hose and plastic with readings up to (ROR 80-56) 1,500 cpm was discovered outside the Unit 2 Containment Emergency hatch.

11/18/80 A contaminated vent duct (up to 3,000 cpm/ft2) was found in a (ROR 80-74) dumpster.

2-64

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 11/20/80 A contaminated vent duct (up to 800 cpm/ft2) was found in a (ROR 80-77) dumpster.

01/15/81 to Primary to Secondary leakage discovered on the 1B S/G and (NRC IR 81-03 01/31/82 1C S/G prior to outage. Leakage observed at 45 gpd. After and NRC IR 81-outage completion, leakage again noted in 1B S/G at ~ 4 to 09/81-05) 32 gpd.

02/08/81 Contaminated water was sprayed into the Rad Waste Annex (ROR 81-25) when a hose from a liner ruptured.

02/26/81 A rug contaminated with readings up to 50,000 cpm direct was (ROR 81-31) discovered adjacent to the old Service Building elevator and a chair contaminated with readings up to 300 cpm direct was discovered in the MM Shop office area.

03/21/81 An individual carrying personal clothing alarmed the Gate (ROR 81-33)

House portal monitor. The individual refused to bag the clothing and return to Radiation Protection. The individual left the clothing in the Gate House and left site.

04/05/81 Four bags containing contaminated materials (up to (ROR 81-35) 80,000 cpm) was found in a dumpster.

04/14/81 A bag containing contaminated Out-Of-Service cards (up to (ROR 81-39) 200,000 cpm) was found in a dumpster.

04/14/81 A contaminated individual was inadvertently released from site (ROR 81-37, resulting in the low level contamination of passenger vehicles NRC IR 81-and the individual's home with identified readings up to 15/81-11 and 700 cpm direct. The total offsite activity released was ComEd estimated to be less than 0.5 uCi. response) 04/15/81 A contaminated hammer with readings up to 500,000 cpm (ROR 81-40) direct was discovered in the Gate House 04/16/81 Three bags containing contaminated materials (up to (ROR 81-38A) 2,500 cpm) was found in a dumpster.

08/20/81 A contaminated tool with readings up to 1,200 cpm fixed was (ROR 81-49) discovered in the Tech Staff office area of the Service Building.

2-65

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 08/21/81 A dry active waste (DAW) shipment from Zion was found to be (NRC IR leaking water upon its arrival at the Richland Washington 81-20/81-16) disposal site. Approximately 2 pints of water containing 20 to 80 pCi of activity was found on the truck bed. The DAW container was found to have been damaged.

09/1981 In September 1981, the leakage from 1B S/G averaged (NRC IR 118 gpd. 81-20/81-16) 09/11/81 During Unit 2 outage, a fuel assembly was damaged (missing (NRC IR spring clip, torn grid strap and a loose rod). The fuel assembly 81-26/81-22) was removed and repaired. Subsequent debris from the failure was observed in 2B and 2C S/Gs.

10/1981 In 4th qtr of 1981, primary to secondary leakage observed was (NRC IR 1A S/G (~12 gpd), 1B S/G (~240 gpd), 1C S/G 81-26/81-22)

(~20 gpd), and 1D S/G (~19 gpd) 10/27/81 A bellows contaminated with readings up to 1,000 cpm direct (ROR 81-57) was discovered in the EM Shop 10/29/81 A contaminated teletector with loose contamination up to (ROR 81-54) 20,000 cpm/ft2 was discovered in the respirator issue room.

12/01/81 Noted RCS leak from Unit 2 RVLIS fitting upon reaching (NRC IR operating pressure. Due to leak, the upper reactor head was 81-26/81-22) saturated with steam and condensed reactor coolant.

12/01/81 to Due to increasing activity in the secondary system of Unit 1 due (NRC IR 01/15/82 to primary to secondary leaks in all four S/G at flow rates 81-29/81-27) exceeding 500 gpd, several areas in the Unit 1 Turbine Building were posted as Radiologically Controlled Areas 12/19/81 to Primary to secondary leakage observed was 1B S/G (218 to (NRC IR 01/19/82 431 gpd) and 1C S/G (8 to 56 gpd) 81-29/81-27) 02/28/82 Contaminated protective clothing was discovered in the clean (ROR 82-35) trash staging area in the Unit 1 Turbine Building Trackway 03/03/82 A health physicist intentionally released approximately 20 (ROR 82-53 and people who had alarmed the gate house portal monitor. One ROR 82-54) individual was noted to have 500 cpm on a shoe.

03/09/82 A pair of contaminated rubber gloves reading up to 300 cpm (ROR 82-88B) was discovered during a daily survey of a trash pile at the dumpster area.

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Date Incident/Occurrence Citation 03/21/82 Contaminated tools and scrap materials with direct readings up (ROR 82-30 and to 900 cpm was discovered in the clean trash staging area in the ROR 82-32)

Unit 1 Turbine Building Trackway 03/24/82 Leakage from the Unit 1 refueling cavity occurred due to gasket (NRC IR failure of a nuclear instrument well cover. The leakage 82-04/82-04) increased beyond the capacity of the installed containment and cavity sump systems. The reactor cavity filled up and overflowed about 2,000 gallons onto the containment floor.

03/25/82 A portable demineralizer in the Rad Waste Annex overflowed, (ROR 82-40) resulting in the spill of an indeterminate amount of radioactive water spilled to floor 03/25/82 Legal overexposure of 3.88 Rem occurred in the Unit 1 Incore (NRC IR 82-area. 09/)

04/04/82 A bag of contaminated trash reading 200 cpm was discovered in (ROR 82-47) the clean trash staging area in the Unit 1 Turbine Building Trackway 04/18/82 Contaminated protective clothing with readings up to 300 cpm (ROR 82-56) was discovered in the clean trash staging area in the Unit 1 Turbine Building Trackway 04/21/82 Contaminated gloves reading up to 300 cpm was discovered in (ROR 82-60) the clean trash staging area in the Unit 1 Turbine Building Trackway 04/29/82 A bag containing contaminated material (200 cpm) was found (ROR 82-63) in a dumpster during daily survey.

05/09/82 A contaminated surgeons cap with readings up to 1,500 cpm (ROR 82-64) was discovered on the ground between the Gate House and the NRC Building 05/25/82 A bag containing contaminated material (400 cpm) was found (ROR 82-69) in a dumpster during daily survey.

06/08/82 A piece of radiologically contaminated waste was discovered in (ROR 82-71) the office area by the control room.

06/17/82 A piece of contaminated pipe reading 45,000 dpm direct was (ROR 82-73) discovered in the dumpster 2-67

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 06/17/82 A barrel from the Unit 1 steam tunnel was transferred to the (ROR 82-74) clean trash compactor and found to have contaminated oil/dirt/grease in bottom. (up to 62,500 dpm). Some material spilled onto the asphalt and was subsequently cleaned.

06/25/82 Unit 2 Reactor tripped from full power due to a ground on the (NRC IR 82-Main Power Transformer. Fire-fighting exercises to the north 14/82-13) of the Turbine Building resulted in the Main Power Transformer being covered with a residue of the fire-fighting chemical ("purple K"). A sudden rain interacted with the chemical causing a conducting solution and the busses arced to ground.

07/17/82 to RCS to CC water system leak in the Unit 1 Pzr Steam Space (NRC IR 08/31/82 Sample Cooler 82-19/82-17) 08/11/82 A fire occurred in the "0" Diesel Generator due to a failure of (NRC IR the turbo charger lube oil filter gasket. The oil sprayed on an 82-19/82-17) exhaust manifold where it ignited. An additional 10-15 gallons of lube oil spilled on the floor.

11/17/82 Trash bags containing contaminated material (up to 100K dpm) (ROR 83-81) were discovered at the trash compacting area. While moving the bags, material spilled which contaminated the asphalt. The surface was subsequently decontaminated. An investigation concluded that the material originated from steam tunnel work areas.

01/31/83 A severe oil leak occurred on the 2B Diesel Generator (NRC IR 83-02/83-02) 04/14/83 Unit 1 shutdown due to severe weather when 4 of 6 incoming (NRC IR 83-4KV lines were lost. This resulted in a surge on the Unit 1 04/83-04)

Main Transformer resulting in an insulator for one phase of the east transformer to explode.

07/13/83 RCS leakage of ~ 1.6 gpm was identified (source from BIT (LER 1-83-020) inlet valves) 08/04/83 Hydrazine spill by Unit 1 Hydrazine Tank on the Turbine (NTS 29520193 Building 560 ft. elevation CAT4-0673) 08/17/83 Fire in the 1A Diesel Generator room due to the failure of the (NRC IR turbocharger oil filter gasket which allowed oil to spray directly 83-17/83-18) onto the turbocharger manifold.

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Date Incident/Occurrence Citation 10/16/83 Contaminated slings reading up to 50,000 dpm was discovered (ROR 83-67) in the clean trash staging area in the Unit 1 Turbine Building Trackway 11/02/83 High noble gas levels in Unit 1 resulted in the contamination of (NRC IR 65 persons 83-21/83-22 and 83-27/83-28 and ROR 83-97) 11/09/83 A bag containing contaminated material (20,000 cpm) was (ROR 83-78) found in a dumpster during daily survey.

11/22/83 An individual alarmed the gate house portal monitor due to (ROR 83-87) contaminated tape stuck to shoe. The investigation led to a probable location of source as outside the east DAW Building.

01/15/84 A contaminated flashlight with readings up to 3,000 cpm direct (ROR 84-07) was discovered at the Gate House.

01/20/84 While performing repairs in the seal table room, a fitting broke (LER 1-84-005, causing an RCS leak of ~ 18 gpm. Approximate 700 gallons of and NRC IR RCS spilled before the leak was stopped. 83-26/83-27) 03/14/84 The Hot Lab and office areas were contaminated during a (ROR 84-20)

Na-24 moisture carryover test.

05/1984 Caustic accidentally entered the RW system, releasing (LER 1 radioactive contaminants which had plated out on the piping 035) and caused higher levels of contaminants in the liquid waste effluents.

05/09/84 Contaminated material with readings up to 1,250,000 dpm (ROR 84-41) direct was discovered in the dumpster 05/11/84 Drained down ~ 3000 gallons of 30% NaOH from the Unit 2 (Letter re: high Spray Add tank. The majority of the caustic ended up in the Na ABEDAT room through vents in the Containment Spray concentration in pumps. Unit 2 RCS) 05/12/84 Materials with loose surface contamination was discovered in (ROR 84-42) the east DAW Building 05/30/84 Found a fire extinguisher in the Turbine Building with fixed (ROR 84-47) contamination up to 1,250 dpm 2-69

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 06/16/84 A contractor who set off the gate house portal monitor allegedly (ROR 84-54) decontaminated his shoe in a puddle outside the gate house.

08/14/84 The Unit 2 Containment exceeded the Technical Specification (LER 2-84-020) limit of 120 degrees F. Actual maximum temperature was 120.48 degrees.

08/26/84 A teletector located in the IM Shop was discovered to be (ROR 84-76) internally contaminated.

09/10/84 Unit 1 was shutdown due to excessive primary to secondary (NRC Log, LER leakage of > 500 gpd (calculated at 1,050 gpd). Unusual Event 1-84-029, NRC declared IR 84-17/84-18) 09/14/84 A pipe wrap contaminated with readings up to 7,500 cpm direct (ROR 84-104) was discovered in the MM Shop.

09/27/84 Contaminated material with readings up to 7,500 dpm direct (ROR 84-80) was discovered in the dumpster 10/06/84 Contaminated material with readings up to 7,500 dpm direct (ROR 84-88) was discovered in the dumpster 11/12/84 RCS leakage reached 10-12 gpm due to packing leaks from (NRC IR 84-valve 2FCV-121. The valve is located in the 2B Charging 23/84-22)

Pump room.

12/07/84 A U.S. Flag was found to be contaminated with readings up to (ROR 84-102) 2,500 cpm direct. The contamination was later found to be naturally occurring materials.

12/10/84 Discovered contaminated material with readings up to (ROR 84-103) 375,000 dpm in an uncontrolled storage cage on the Unit 1 Turbine Building 617 ft. elevation 01/03/85 Radiological surveys discovered contaminated material up to (ROR 85-02) 2,500 cpm fixed in the trash segregation area located in Unit 1 Turbine Building Trackway. Investigations concluded that the material originated in the secondary sample room 01/19/85 During testing, a fuel oil supply line leaked an indeterminate (LER 1-85-002) amount of fuel oil to the Turbine Building floor 2-70

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 02/05/85 Contaminated trash reading up to 2,500 dpm was discovered in (ROR 85-18) the clean trash staging area in the Unit 1 Turbine Building Trackway 03/02/85 Contaminated trash reading up to 2,000 dpm was discovered in (ROR 85-40) the clean trash staging area in the Unit 1 Turbine Building Trackway 02/16/85 to 2 component cooling water leaks identified in relief valves, the (NRC IR 05/17/85 first one on 02/16/85 on 1CC-9427 (total of ~ 1710 gallons of 85-12/85- 13 water), and the second on 05/17/85 on 1CC-9428. A total of ~ and NRC IR 10,000 gallons of component coolant water was discharged to 85-20/85-21) the containment floor 03/16/85 Contaminated trash reading up to 3,700 dpm was discovered in (ROR 85-46) the clean trash staging area in the Unit 1 Turbine Building Trackway 04/06/85 Contaminated material with readings up to 18,750 dpm fixed (ROR 85-49) was discovered in the Tech Staff area of the Service Building 04/24/85 Contaminated tools with fixed contamination up to 5,000 dpm (ROR 85-53) direct was discovered in the EM Shop 05/13/85 A radiological survey of Unit 1 Steam Tunnel identified (ROR 85-61) contaminated material up to 1250 dpm by direct frisk.

08/23/85 A contaminated Rad Waste cask with 200,000 dpm fixed and (ROR 85-74) 3,750 dpm smearable was identified as it was being unloaded inside the north security gate.

09/14/85 A contaminated ladder with readings up to 7,500 dpm direct (ROR 85-80) was discovered leaning against the Unit 1 Discharge Valve house.

09/14/85 Contaminated hoses with readings up to 75,000 dpm direct (ROR 85-81) were discovered in the Crib House.

09/14/85 Contaminated white crystals (up to 2500 dpm) were found (ROR 85-82) under the evergreens outside the Service Building and in the storage shed near the WWTF. Isotopic analysis results showed all activity was due to naturally occurring potassium in the crystals (fertilizer).

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Date Incident/Occurrence Citation 12/10/85 Contaminated plywood reading up to 18,500 dpm was (ROR 85-101) discovered in the clean trash staging area in the Unit 1 Turbine Building Trackway 12/17/85 Contaminated trash reading up to 7,500 dpm was discovered in (ROR 85-104) the clean trash staging area in the Unit 1 Turbine Building Trackway 12/18/85 Contaminated wood pallet reading up to 1,000 dpm was (ROR 85-106) discovered in the clean trash staging area in the Unit 1 Turbine Building Trackway 01/30/86 Contaminated rubber gloves with readings up to 12,500 dpm (ROR 86-05) direct was discovered in a trash can outside of the Auxiliary Building elevator.

01/31/86 During a resin sluice, a hose broke spilling contaminated liquid (ROR 86-06) into the Rad Waste Annex 592 ft. elevation floor. Floor was contaminated to levels up to 675,000 dpm/100cm2 smearable.

02/11/86 Contaminated protective clothing with readings up to (ROR 86-08) 6,250 dpm was discovered in the clean trash staging area in the Unit 1 Turbine Building Trackway 05/16/86 Observed RCS leakage in excess of Technical Specification (NRC IR limit. Source was Pzr spray valve 1PCV-RC06 86-11/86-10) 06/09/86 Flooding was noted in the Unit 2 Tendon tunnels (Zion RP/Decon Log) 06/26/86 Pieces of contaminated metal with readings up to 1,250 dpm (ROR 86-18) direct was discovered in the dumpster 09/16/86 Contaminated protective clothing with readings up to (ROR 86-23) 7,500 dpm was discovered in the clean trash staging area in the Unit 1 Turbine Building Trackway 09/30/86 Spill from the Unit 1 SST following weld repairs on the tank. (Zion RP/Decon Log) 11/17/86 Transportation incident with the shipment of the 1A RCP motor (NRC IR to Westinghouse as the package was damaged in-route. No loss 86-28/86-28) of contamination control occurred.

12/04/86 Contaminated material with readings up to 12,500 dpm was (ROR 86-46) discovered in the clean trash staging area in the Unit 2 Turbine Building Trackway 2-72

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 02/09/87 A spill of approximately 60 gallons of fuel oil occurred in the (Zion RP/Decon Turbine Building Log) 03/27/87 Minor fire in the Turbine Building 560 ft. elevation (NRC IR 87-06/87-06) 03/27/87 Contaminated trash with readings up to 10,000 dpm was (ROR 87-10) discovered in the clean trash staging area in the Unit 1 Turbine Building Trackway 04/29/87 Discovered a contaminated step stool with readings up to (ROR 87-15) 2,500 dpm direct in an outside trash pile 05/21/87 Service water flood into the 2A and 2B Diesel Fuel Oil (NRC IR Storage tank rooms as well as the Turbine Building 560 ft. 87-09/87-11 and elevation. Approximately 181,000 gallons of water was NRC IR discharged 87-16/87-16) 05/31/87 Contaminated metal with direct readings up to 8,750 dpm was (ROR 87-21) discovered in the scrap metal dumpster 06/21/87 Found contaminated protective clothing and tape (up to (ROR 87-25) 2500 dpm direct) near Primary Storage Tank Pumps 08/04/87 Contaminated protective clothing with readings up to (ROR 87-36) 10,000 dpm direct was discovered in a trash pile north of the Crib House.

10/01/87 Observed RSC leakage in Unit 2 Containment from Pzr Spray (NRC IR valve. 87-26/87-27) 10/09/87 Discovered contaminated material with readings up to (ROR 87-41) 25,000 dpm in Tech Staff storage cage on the Unit 1 Turbine Building 617 ft. elevation 03/1988 to Report denotes a 1200 gallon spill of diesel fuel in March 1988, (1988 WWTF 12/1988 a 500 gallon diesel fuel spill in April 1988 and a 300 gallon Report) turbine oil spill in May of 1988. In addition, a Bulk Acid Tank rupture in December of 1988 resulted in the discharge of 92%

sulfuric acid to the WWTF for processing.

03/01/88 An oil spill was identified in Unit 1 Turbine Building that (Zion RP/Decon deposited oil along the wall and on the floor of the insulator Log) workshop in the south Condenser Bay 2-73

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 04/01/88 Contaminated tool with fixed contamination up to 12,500 dpm (ROR 88-33) direct was discovered in the MM tool crib 04/16/88 Discovered contaminated drums of waste oil with smearable (ROR 88-47) levels up to 2,500 dpm on the outside of the drums located in the posted High Radiation Area between the Unit 2 Containment and the Fuel Handling Building 05/1988 Spill of approximately 300 gallons of oil in the Turbine (1988 WWTF Building. Report) 05/03/88 Radiological surveys identified surface contamination up to (ROR 88-54) 10,000 cpm fixed on materials found in an outside trash pad.

An investigation concluded that the material originated in the Unit 2 Steam Tunnel Valve House.

05/04/88 Diesel fuel oil spill in the Unit 1 Containment Spray cubicle in (Zion RP/Decon the Auxiliary Building. Log) 05/27/88 Contaminated material, up to 375,000 dpm direct was (ROR 88-59) discovered in a trash pile located outside of the RCA.

10/22/88 Hydrazine spill by the Unit 1 Chemical Addition area on the (Zion RP/Decon Turbine Building 560 ft. elevation. Log) 10/27/88 License termination order for the Westinghouse Training (NRC License #

reactor housed in the West Training Center received R-119, Docket #

50-87) 11/19/88 Contaminated tools with readings up to 25,000 dpm fixed were (ROR 88-85) discovered in the contractor office trailer located adjacent to the Unit 2 trackway.

12/07/88 Discovered a contaminated hand radio with fixed readings up to (ROR 88-88) 40,000 dpm direct in the IM Shop.

12/19/88 Bulk Acid Tank rupture caused 1,228 gallons of 92% sulfuric (1988 WWTF acid to be sent to the WWTF for processing. Annual Report) 12/19/88 Discovered spill of sulfuric acid in the Unit 2 Turbine Building (NRC IR Trackway. The acid flowed down an floor penetration and 88-23/88-23) deposited acid on the 560 ft. elevation floor 02/12/89 The Rad Waste conveyor system broke down during the (Zion RP/Decon removal and shipment of some of the drums. As a result, some Log) drum with spent resins was spilled outside.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 02/21/89 Rad Waste conveyor system broke during the removal and (Zion RP/Decon shipment of 55 gallon drums of waste. Spent resin was spilled Log) outside the Truckbay door when several barrels broke open 03/16/89 Contaminated insulating blankets (up to 37,500 dpm direct) (ROR 89-21) were found in the Unit 2 Turbine Building trackway trash area.

These blankets were determined to have come from the 2C East MSR Reheat Stop Valve.

03/22/89 Discovered contaminated wood with fixed contamination up to (ROR 89-24) 37,500 dpm direct in the Unit 2 Turbine Building Trackway trash segregation area 05/08/89 Unplanned release of radioactive noble gas and spill of (NRC IR approximately 300 gallons of RCS water during a fill of the 89-20/89-18)

CVCS demineralizer.

07/18/89 Discovered contaminated tool with fixed contamination up to (ROR 89-24) 20,000 dpm direct in the Shift Engineer office.

07/28/89 Discovered contaminated metal with readings up to 75,000 dpm (ROR 89-31) direct in the dumpster trash area.

10/01/89 Identified flooding in Unit 1 Containment through the open (Zion RP/Decon manway openings in all four S/G Log) 01/03/90 Observed RCS leakage of ~ 20 gpm from valve 1MOVRH8702 (LER 1-90-001) 01/16/90 The overflow of the 0A Lake Discharge Tank (LDT) resulted (ROR 90-02) in a substantial contamination of the Auxiliary Building 542 ft.

elevation floor.

01/23/90 Zion became aware of a condenser cooling water leakage from (NRC IR Unit 2 discharge piping approximately 60 feet off shore. It was 90-03/90-03) determined that a 20 foot section of the 14 foot diameter pipe had shifted slightly, resulting in the top portion of the discharge piping's bell spigot joint to be misaligned. This translated to a four inch gap at one construction joint and an 8 inch gap on the other. The estimate at the time was that 10% of the discharge volume was escaping the normal discharge location of 870 feet into Lake Michigan. The intent was to continue operations in this mode until late March 1990.

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Date Incident/Occurrence Citation 03/05/90 A loss of Main Turbine oil of approximately 3,000 gallons from (NRC IR the Unit 2 Turbine Oil reservoir was identified and observed as 90-03/90-03 and an oil slick in the Screen-house afterbay. The leak was isolated ESD Spill and the oil was removed from the afterbay. No detectable oil Summary) was observed in Lake Michigan by the Coast Guard.

03/06/90 Black sand was discovered on the beach adjacent to the site. (SMAD black Analysis indicated that the "black sand" from lake shore was sand analysis) not oil/grease, but ferrotitanium. Oil and grease were less than 40 ug/g.

03/22/90 A contaminated wire with readings up to 3,750 dpm direct was (ROR 90-05) discovered under the stairs in on the Service Building 592 ft.

elevation 03/29/90 Water leakage and system overflow in both Unit 1 and Unit 2 (Zion RP/Decon Containment Spray pump cubicles Log) 04/08/90 Contaminated chairs with readings up to 7,500 dpm direct was (ROR 90-48) discovered in the Gate House 04/02/90 Contaminated material up to 7,500 dpm/100cm2 smearable was (ROR 90-07) discovered in the Fuel Handling Building Car-Shed 04/26/90 Instruments contaminated with readings up to 150,000 dpm (ROR 90-18) direct was discovered in the IM Shop 04/26/90 A contaminated instrument component with readings up to (ROR 90-19) 10,000 dpm fixed was discovered in the trash awaiting compaction at the Crib House 05/04/90 A contaminated clipboard with readings up to 18,750 dpm fixed (ROR 90-24) was discovered in the contractor trailer.

05/07/90 During the refueling of Unit 2, a piece of grid strap was (LER 2-90-006) observed falling from a fuel assembly during movement. The cladding on the assembly remained intact 07/02/90 The overflow of the 0A Lake Discharge Tank (LDT) resulted (ROR 90-35) in a substantial contamination of the Auxiliary Building 542 ft.

elevation floor.

07/31/90 Discovered a bucket containing contaminated concrete with (ROR 90-38) readings up to 57,500 dpm fixed in the outside trash area. It was identified that the bucket originated from the 642 ft.

elevation of the Turbine Building.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 08/22/90 Spill of approximately 200 gallons of radiologically (ROR 90-41) contaminated water from the vendor laundry trailer located at the north missile door entrance to Auxiliary Building. The water spilled onto concrete into the adjacent subsurface soil.

The affected area was approximately 80 feet by 80 feet.

09/10/90 Notification of flooding in the Crib House. Flooding reached (NRC IR 90-levels approximately 2 feet above the basement floor. An 21/90-23) unusual event was declared.

09/22/90 The Unit 2 Main Power Transformer exploded and burned, (NRC IR 90-resulting in a spill of approximately 300 gallons of transformer 21/90-23) oil to the pavement adjacent to the transformer.

09/29/90 Discovered nitrogen tanks with fixed contamination up to (ROR 90-43) 5,000 dpm direct in the Unit 1 Turbine Building trackway 10/16/90 Both LDTs overflowed resulting in the discharge of (Zion RP/Decon approximately 16,000 gallons of contaminated water to the Log)

Auxiliary Building 542 ft. elevation floor.

02/25/91 Discovered contaminated fittings and flanges with readings up (ROR 91-04) to 25,000 dpm direct on a truck leaving the Protected Area.

04/17/91 Due to a leaking valve, the SFP overflowed. Water (NRC IR 91-accumulated in and overflowed the ABEDAT (500 to 10/91-10) 1000 gallons) causing the backup of water through the bedplate drains in the Unit 1 and Unit 2 Containment Spray pump rooms and the Unit 1 Safety Injection pump room. The areas outside the rooms and the level below were contaminated.

06/26/91 Break in a temporary PVC pipe for a temporary demineralizer (Zion RP/Decon skid created a flood on the Turbine Building 560 ft. elevation. Log) 08/01/91 The Boric Acid Mix Tank (BAMT) overflowed, contaminating (Zion RP/Decon Auxiliary Building areas from the 617 ft. elevation to the 562 ft. Log) elevation.

05/13/92 Approximately 4,200 gallons of RCS water was inadvertently (NRC IR sprayed into Unit 2 Containment through the 2A Containment 92-10/92-10)

Spray header 05/17/92 A grass fire was reported adjacent to the West Training area. No citation 2-77

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 05/19/92 to A weld failure in the RWST system resulted in a leak of (NRC IR 07/06/92 approximately 1 gpm to the Unit 1 Equipment Drain Tank 92-14/92-14)

Collector room.

07/15/92 A failure of the 2A Diesel Generator was attributed to zebra (LER 2-92-004 mussels in the lube oil system. Zebra mussels were later also and Zion found in 2B Diesel Generator coolers. RP/Decon Log) 10/24/92 Overflow of the 0B Blow Down Monitor Tank (BDMT) (NTS 2952019 resulted in the contamination of approximately 5,000 ft2 of 208401) floor on the Auxiliary Building 542 ft. elevation.

11/04/92 During a cleanup of the two oil/water separators, the station (NTS 29555492 discovered oil containing PCBs (5 ppm on Unit 1 and 11 ppm CAT3-087) on Unit 2). These were the only positive results for PCBs.

After the separators were cleaned, water and sludge samples were taken and indicated <0.5 ppb and < 1.0 mg/kg PCB respectively.

03/29/93 An oil leak was identified that leak approximately 80 gallons of (NTS 30420193 oil to the floor near the 2C Feed Water pump CAT4-0258) 06/01/93 Unit 1 and Unit 2 oil separator sludge found to be contaminated (NTS 29520193 CAT4-0456) 07/15/93 Underground oil storage tanks for the CS Diesel was identified (NTS 29520193 as leaking CAT4-0586) 11/18/93 A temporary hose rupture in the Circ. Water bay resulted in the (NTS 29520193 spill of sodium hypochlorite. CAT4-1339) 11/18/93 Mercury spill occurred outside the Unit 2 Turbine Building NTS 30420193 trackway adjacent to the Unit 2 Main Transformer on the CAT4-1340) asphalt.

11/27/93 Overflow of the Unit 1 ABEDT resulted in back-leakage into (NTS 29520193 the Containment Spray and Safety Injection cubicles in the CAT4-1381)

Auxiliary Building 12/04/93 Contaminated scaffolding with readings up to 20K dpm fixed (NTS 29520093 was used to repair the temporary Auxiliary Boiler located CAT3-202) outside of the Service Building.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 01/06/94 A mercury spill occurred while removing a hydrogen purity (NTS 29520194 meter. The material spilled at the base of the panel on 617 ft. CAT4-0019) elevation of the Unit 1 Turbine Building. While transporting the device to the IM shop, mercury was spilled on the Turbine Building elevator, on the 592 ft. elevation outside the elevator, inside and outside of the MM shop, outside of the north Service Building elevator, hallway to the IM shop, and in the IM shop.

All areas were cleaned and released.

01/15/94 Oil was observed leaking from the 1E and 1W Main (NTS 29520194 Transformers. CAT4-0110) 01/17/94 Oil spill from the Unit 1 Turbine Oil reservoir seeped through (NTS-29520194 the floor to the 560 elevation of the Turbine Building CAT4-0111) 02/16/94 Contaminated material found in decontamination technician (NTS 29520094 trailer CAT3-038) 03/16/94 A contractor laborer was found to have contaminated clothing (NTS with readings up to 24,000 dpm fixed in a hotel room off-site. 29510094008, The hotel room and vehicle were surveyed and not NTS 29520094 contaminated. CAT3-074 and NRC IR 94-08/94-08) 04/03/94 A fire occurred in the Unit 1 Main Generator Lead Box which (LER 1-94-005, subsequently cause a trip of the Unit 1 Reactor NRC IR 94-09/94-09 and NRC IR 94-12/94-12) 03/07/94 A failure of the 2B Diesel Generator was attributed to zebra (LER 2-94-002) mussels in the lube oil and jacket water coolers.

03/22/94 Two abandoned transformers were found in the owner- (NTS 29520194 controlled fields west of the facility. One had fallen over and CAT4-0790) was leaking oil onto the ground. The oil was tested and did not contain PCBs.

05/31/94 While performing a flush of the Turbine Oil seals, (NTS 29520194 approximately 200 gallons of turbine oil overflowed into the CAT4-1206)

Unit 1 Main Generator 2-79

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 07/02/94 A fire occurred in the three bus duct phases for Unit 1 Main (LER 1-94-010 Generator. The fire resulted in a shutdown of Unit 1 Reactor. and NRC IR 94-17/94-17) 08/19/94 Oil was observed leaking from the #9 cooler on the 1W Main (NTS 29520194 Transformer. CAT4-1844) 08/24/94 The SFP overflowed, resulting in the spill of approximately (NRC IR 1,250 gallons of borated water through the Unit 1 Containment 94-19/94-19 and Spray pump and the Unit 1 Safety Injection pump bedplates. (NTS 29520094 CAT3-204) 09/03/94 A contaminated cart with readings up to 55,000 dpm fixed was (NTS 29520094 discovered in the Radiation Protection office. CAT3-211) 09/06/94 Oil was observed leaking from the #7 cooler on the 1W Main (NTS 29520194 Transformer. CAT4-1985) 03/09/95 Contaminated tool with fixed contamination up to 53,000 dpm (NTS29520095 fixed found in the MM tool crib CAT3-044) 04/1995 Cleansweep Project implemented at Zion site. Project (NTS29520095 implemented the comprehensive survey of site facilities and CAT3-044) grounds to identify uncontrolled radioactive material. The following findings were identified; The survey was conducted between 04/25/95 through 05/04/95. 61 items found with fixed contamination up to 80,000 dpm direct, and 3 items with smearable contamination up to 6,000 dpm/100cm2. Eleven items were discovered in the Bechtel warehouse, one in the east MM training area, one in the decontamination trainer, one in the paint shed and one item on the 4th floor of the Service Building 04/05/95 The Hydrazine Addition Tank overflowed approximately (NTS 29520095 6 gallons of 35% solution hydrazine to the floor in the Turbine CAT3-071)

Building during Auxiliary Boiler layup.

04/21/95 Spill of caustic liquid in the Unit 1 Containment Spray pump (NTS 29520195 cubicle. CAT4-1310) 04/29/95 Resin spill in the 2A De-Borating demineralizer cubicle left (Zion RP/Decon approximately 6 inches of spent resin on the floor of the Log) cubicle.

05/10/95 Contaminated materials discovered in the IM Shop (NTS 29520095 CAT3-090) 2-80

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 06/12/95 A mercury spill occurred inside the Unit 1 Screen Wash panel (NTS 29520195 in the Crib House. CAT4-1629) 08/15/95 Contamination discovered on the internals of the Auxiliary (NTS 29520195 Boiler CAT4-2208 09/11/95 to Contaminated resin (up to 7.15E-7 uCi/g Co-60 and 4.94E- (NTS 29520095 7

10/25/95 uCi/g Cs-137) found in 3 barrels of used resin from non-rad CAT3-160 and systems (only one barrel was identified as Unit 1 stator water). NTS29520195 Additional contaminated resin was also found in cardboard CAT4-3148) drums in the same area.

09/22/95 Fire in the Unit 1 Refueling Cavity (NTS 29520195 CAT4-2663) 11/13/95 Diesel fuel spill on the floors of both Unit 1 and Unit 2 (Zion RP/Decon Containment Spray pump cubicles Log and NTS 29520195 CAT4-3351) 12/04/95 Contaminated tools and rigging slings with fixed contamination (NTS 29520095 up to 109,000 dpm fixed was discovered in the MM tool crib. CAT3-219) 01/22/96 The Lake Discharge Tank (LDT) overflowed, resulting in the (Zion RP/Decon contamination of approximately 11,000 ft2 of the Auxiliary Log)

Building 542 ft. elevation being contaminated.

01/22/96 Three contaminated clipboards with readings up to 31,000 dpm (NTS 29520096 fixed were discovered in the Chemistry Offices. CAT3-010) 02/02/96 Approximately 100 gallons of hydrazine spilled near the 2D (NTS 30420196 Condensate and Condensate Booster Pump CAT4-0296) 02/18/96 Approximately 1 gallon of hydrazine and approximately (PIF 96-4846 100 gallons of an ammonia/hydrazine mixture spilled on the and spill log 560 ft. elevation of the Unit 2 Turbine Building.96-007) 04/15/96 Barrels which contained oil cleaned up from a spill of Turbine (NTS 29520196 oil was knocked over by high winds, resulting in a spill of oil to CAT4-0850) the concrete storage pad.

04/20/96 The 0B LDT overflowed, resulting in approximately (NRC IR 560 gallons of slightly contaminated water discharged to the 96-07/96-07)

Auxiliary Building 542 ft. elevation floor.

2-81

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 05/22/96 Contaminated ISI block reading 2,000 dpm fixed discovered on (NTS 29520096 the Turbine Building 617 ft. elevation by the generator seal oil CAT2-008) unit.

06/27/96 Five clothing bins with fixed contamination were discovered (NTS 2950096 stored in an un-posted area on the 592 ft. elevation of Unit 2 CAT2008 and Turbine Building. PIF 96-1405) 07/15/96 The sludge removed from the Unit 1 and Unit 2 Oil Separators (Zion RP/Decon was discovered to be contaminated. Log) 07/18/96 An unspecified volume of hydraulic oil was spilled into the (PIF 96-1670)

Spent Fuel transfer canal.

07/27/96 Radiological survey of Turbine Building identified fixed (Zion RP/Decon contamination up to 3,800 dpm direct on the MS Stop valve Log) 08/17/96 The 0B LDT overflowed, resulting in approximately (NRC IR 7,000 gallons of slightly contaminated water discharged to the 96-10/96-10)

Auxiliary Building 542 ft. elevation floor.

08/24/96 Approximately 3,000 gallons of demineralized water was (NRC IR inadvertently sprayed into the Unit 2 Containment 568 ft. 96-14/96-14) elevation.

10/01/96 Scaffolding, delivered to the Zion site was discovered to be (PIF 96-2936) contaminated with readings up to 100,000 dpm fixed on various pieces.

10/12/96 to An out-of-service component (2RH-8734A) resulted in the spill (NRC IR 12/06/96 of approximately 400 gallons of contaminated water to the floor 96-17/96-17) of the Auxiliary Building 542 ft. elevation floor.

10/17/96 A spill of approximately 10 gallons of oil occurred on the (PIF 96-3505) 2C RCP pump deck and on the 568 ft. elevation under the pump.

10/23/96 An oil leak was identified from the #1 cooler on the 2E Main (PIF 96-3672)

Transformer.

10/25/96 Contaminated scaffolding with readings up to 2,000 dpm fixed (PIF 96-3724) was discovered adjacent to the missile doors to the Auxiliary Building near Unit 2 Containment.

2-82

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 10/28/96 Received a notice of violation from the North Shore Sanitary (PIF 96-4585 District for discharges with too high levels of Total Suspended and PIF 96-Solids and ammonia. Additional violations for same 4994) parameters were identified on 11/20/1996.

10/30/96 Spill of approximately 30 gallons of ethylene glycol occurred in (PIF 96-3816) the Auxiliary Building heating coil room.

11/01/96 Miscellaneous tools with fixed contamination were discovered (PIF 96-3954 in the IM Shop on the Service Building 592 ft. elevation. and PIF 97-0310) 11/16/96 Approximately 1,000 gallons of turbine oil was spilled into the (PIF 96-4665)

Fire Sump and pumped to the WWTF 11/18/96 Spill of approximately 10 gallons of ethylene glycol occurred in (Spill incident the Auxiliary Building heating coil supply plenum room. log 96-005) 11/19/96 Approximately 145 gallons of glycol spilled in the bermed area (Spill incident above Unit 2 VCT valve aisle. log 96-006) 11/19/96 Contaminated material was discovered in the IM Shop (PIF 96-4351, NTS 29520096 CAT2-0802) 12/06/96 Approximately 100 gallons of turbine oil was spilled into the (PIF 96-4264)

Fire Sump and pumped to the WWTF 12/25/96 Spill of ethylene glycol on the 617 ft. and 642 ft. elevations of (PIF 96-4986) the Auxiliary Building 01/29/97 Approximately 27 gallons of 40% NaOH from the CS system (PIF 97-0497) entered the Unit 2 RWST during CS pump testing.

02/01/97 Approximately 1 gallon of diesel fuel spilled at the CS Day (PIF 97-0672 Tank fill location. and Spill/Incident Log 97-006) 02/24/97 Spill of approximately 1.5 gallons of hydrazine on the Unit 1 (PIF 97-0997 Turbine Building 560 ft. elevation. and NTS 29520097SCAQ 0997 03/21/97 A LSA barrel containing non-contaminated sand and water was (PIF 97-1461) discovered outside the RCA.

2-83

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 03/29/97 A mercury spill (~ 7 grams) occurred in the Crib House by the (Spill/Incident Unit 1 Traveling Screens Log 97-006) 04/02/97 A grass fire occurred in the open land areas adjacent to the (NTS 29520197 reactor site. CAQS-1632) 04/03/97 During semi-annual air quality checks, found 2 Service Air (NTS 29520197 valves (on the 560' Turbine Building E-23 and F-8) leaking CAQD-2143 considerable amount of oil/water mixture. and PIF 97-2143) 04/08/97 Individual left site after successfully passing Gate House portal (NTS 29520097 monitor. Upon return to the site, a single particle reading SCAQ-1725 110,000 dpm contact was found in pants pocket. and PIF 97-1725) 04/12/97 The Fuel Handling Building roof leaked rainwater into the SFP (NTS 29520197 CAQS-1810) 04/18/97 An empty LSA barrel was discovered in a dumpster north of the (PIF 97-1928 &

Construction Building. NTS 29520097 SCAQ-1928) 04/22/97 Four rusty 55 gallon drums and one 30 gallon drum were found (PIF 97-2040) on property east of the BAT warehouse and south of Shiloh Blvd. The barrels were in poor condition and contained a black non-radioactive solid.

04/23/97 A spill of approximately 10 to 15 gallons of hydraulic oil (Spill/Incident spilled in the Unit 2 A/C MSIV room Log 97-007) 05/01/97 An oil spill of approximately 15 gallons occurred on the ground (NTS 29520197 south of the Crib House south doors. The area covered CAQD-2166 approximately 4 feet by 10 feet. Some of the material went into and PIF 97-the storm drains. 2166) 05/03/97 A contaminated posting stanchion with a reading of (NTS 29520097 135,000 dpm fixed was discovered on the Unit 1 Turbine SCAQ-2192 Building 617 ft. elevation and PIF 97-2192) 05/06/97 A contaminated stanchion (40K dpm fixed) was found in the (NTS 29520197 contractor fab shop. CAQD-2298 and PIF 97-2298) 2-84

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-2 Historical Incidents/Occurrence (continued)

Date Incident/Occurrence Citation 05/07/97 A contaminated stanchion (10K dpm fixed) was found in the (NTS 29520197 contractor fab shop. CAQD-2297 and PIF 97-2297) 05/14/97 Contaminated materials with readings up to 10,000 dpm fixed (NTS 29520197 was discovered in the West Training Center CAQD-2407) 05/24/97 Flash fire in the Unit 1 Refueling Cavity during the cleaning of (NTS 29520097 stud plugs SCAQ-2561, PIF 97-2561, and Tech Alert

1. 97-21) 05/27/97 A spill of approximately 5 gallons of diesel fuel occurred in the (NTS 29520197 Auxiliary Boiler Storage Tank area. CAQD-2577 and PIF 97-2577) 07/26/97 Contaminated materials (up to 1,600 dpm fixed) found in a (NTS 29520197 dumpster. The material is believed to have originated from CAQD-0536 work on the Auxiliary Boiler and PIF Z1997-00906 08/05/97 A spill of sodium hypochlorite occurred on concrete by (Spill incident hypochlorite tank. log 97-009) 09/30/97 A spill of approximately 1 gallon of sodium hypochlorite (Spill incident occurred on concrete by hypochlorite tank. log 97-010) 10/09/97 A spill of approximately 10 gallons of transformer oil occurred (Spill incident near the north gate on gravel. log 97-011) 10/17/97 A spill of approximately 3 gallons of diesel fuel occurred in the (Spill incident Turbine Building log 97-013) 12/11/97 Approximately 13 grams of mercury was spilled in the Cold (Spill/Incident Lab. Log 97-016) 12/18/97 An oil spill of approximately 1 quart occurred into the (Spill/Incident southwest corner of the fore-bay. Log 97-017) 12/11/98 A small diesel oil spill occurred outside the Gate House (PIF 96-4731) 2-85

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units Survey Unit Survey Unit Description ID #

01000 Unit 1 Containment (All Interior Surfaces are Class 1) 100 568 Ft Elevation 01 Vessel Bio-Shield 02 Inside Missile Barrier - A Loop 03 Inside Missile Barrier - B Loop 04 Inside Missile Barrier - C Loop 05 Inside Missile Barrier - D Loop 06 Outside Missile Barrier - A Loop 07 Outside Missile Barrier - B Loop 08 Outside Missile Barrier - C Loop 09 Outside Missile Barrier - D Loop 10 Incore Area 543 Ft Elevation 200 592 Ft and 603 Ft Elevation 01 Cavity Area 02 Inside Missile Barrier - A Loop 03 Inside Missile Barrier - B Loop 04 Inside Missile Barrier - C Loop 05 Inside Missile Barrier - D Loop 06 Outside Missile Barrier - A Loop 07 Outside Missile Barrier - B Loop 08 Outside Missile Barrier - C Loop 09 Outside Missile Barrier - D Loop 10 Incore Drive Area/Seal Table Room 603 Ft Elevation 300 617 Ft Elevation 01 Cavity Area 02 A and C Loop Area 2-86

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

03 B and D Loop Area 04 Outside Missile Barrier - A Loop 05 Outside Missile Barrier - B Loop 06 Outside Missile Barrier - C Loop 07 Outside Missile Barrier - D Loop 400 Exterior Surfaces & Roof (All Exterior Surfaces are Class 2) 01 Roof 02 Exterior Walls 02000 Unit 2 Containment (All Interior Surfaces are Class 1) 100 568 Ft Elevation 01 Vessel Bio-Shield 02 Inside Missile Barrier - A Loop 03 Inside Missile Barrier - B Loop 04 Inside Missile Barrier - C Loop 05 Inside Missile Barrier - D Loop 06 Outside Missile Barrier - A Loop 07 Outside Missile Barrier - B Loop 08 Outside Missile Barrier - C Loop 09 Outside Missile Barrier - D Loop 10 Incore Area 543 Ft Elevation 200 592 Ft and 603 Ft Elevation 01 Cavity Area 02 Inside Missile Barrier - A Loop 03 Inside Missile Barrier - B Loop 04 Inside Missile Barrier - C Loop 05 Inside Missile Barrier - D Loop 2-87

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

06 Outside Missile Barrier - A Loop 07 Outside Missile Barrier - B Loop 08 Outside Missile Barrier - C Loop 09 Outside Missile Barrier - D Loop 10 Incore Drive Area/Seal Table Room 603 Ft Elevation 300 617 Ft Elevation 01 Cavity Area 02 A and C Loop Area 03 B and D Loop Area 04 Outside Missile Barrier - A Loop 05 Outside Missile Barrier - B Loop 06 Outside Missile Barrier - C Loop 07 Outside Missile Barrier - D Loop 400 Exterior Surfaces & Roof (All Exterior Surfaces are Class 2) 01 Roof 02 Exterior Walls 03000 Fuel Handling Building (All Interior Surfaces are Class 1) 100 592 Ft Elevation 01 Trackway/Cars Shed/Open Area 02 Spent Fuel Pit Heat Exchangers 03 Spent Fuel Pit Pump Rooms 04 Decon Pit 200 617 Ft Elevation 01 New Fuel Storage Area and 602 Ft Elevation Mezzanine 02 Spent Fuel Pool 03 Cross-town Area and SPING Gallery 2-88

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

300 Exterior Surfaces & Roof (All Exterior Surfaces are Class 2) 01 Roof 02 Exterior Walls 04000 Radwaste Building (All Interior Surfaces are Class 1) 100 579 Ft Elevation 01 Crystallizer 200 592 Ft Elevation 01 Dry Active Waste Storage Area 02 Drum Fill Area 03 Radwaste Annex Truck Loading Zone 300 Exterior Surfaces & Roof (All Exterior Surfaces are Class 2) 01 Roof 02 Exterior Walls 05000 Auxiliary Building (All Interior Surfaces are Class 1) 100 542 Ft Elevation 01 Unit 1A RHR Pump Room 02 Unit 1B RHR Pump Room 03 Unit 2A RHR Pump Room 04 Unit 2B RHR Pump Room 05 Unit 1 Pipe Chase 06 Unit 2 Pipe Chase 07 Hold Up Tanks 08 Central Area 09 South Area 10 North Area 11 West Area 2-89

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

12 Gas Decay Tanks 13 Unit 1 Equipment Drain Collection Tank 14 Unit 2 Equipment Drain Collection Tank 15 HUT Recirculation and BAE Feed Pumps 16 Aux Building Equipment Drain Tank and Pumps 17 Aux Building Sump A 18 Aux Building Sump B 200 560 Ft Elevation 01 Unit 1A Safety Injection Pump 02 Unit 2A Safety Injection Pump 03 Unit 1B Safety Injection Pump 04 Unit 2B Safety Injection Pump 05 Unit 1A RHR Heat Exchanger 06 Unit 2A RHR Heat Exchanger 07 Unit 1B RHR Heat Exchanger 08 Unit 2B RHR Heat Exchanger 09 Unit 1 Containment Spray Pump 10 Unit 2 Containment Spray Pump 11 South Area 12 Central Area 13 North Area 14 West Area 15 Equipment Drain Tank 16 Chemical Drain Tank 17 Unit 1 Vertical Pipe Chase 18 Unit 2 Vertical Pipe Chase 2-90

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

19 Blowdown Heat Exchangers 20 Waste Gas Compressor Area 21 Unit 1 RHR Heat Exchanger Pipe Chase 22 Unit 2 RHR Heat Exchanger Pipe Chase 300 579 Ft Elevation 01 Unit 1A Centrifugal Charging Pump 02 Unit 2A Centrifugal Charging Pump 03 Unit 1B Centrifugal Charging Pump 04 Unit 2B Centrifugal Charging Pump 05 Unit 1C Reciprocating Charging Pump 06 Unit 2C Reciprocating Charging Pump 07 Unit 1 Refueling Water Storage Tank 08 Unit 2 Refueling Water Storage Tank 09 South Area 10 Central Area 11 North Area 12 West Area 13 Unit 1 Horizontal Pipe Chase 14 Unit 2 Horizontal Pipe Chase 15 #1 HUT 16 #0 HUT 17 #2 HUT 18 Anion/Cation Valve Aisle 19 Unit 1 Vertical Pipe Chase 20 Unit 2 Vertical Pipe Chase 400 592 Ft Elevation 01 Unit 1 Letdown Heat Exchanger 2-91

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

02 Unit 2 Letdown Heat Exchanger 03 Unit 1 Seal Water Heat Exchanger 04 Unit 2 Seal Water Heat Exchanger 05 Unit 2 Future Diesel Generator 06 Primary Sample Room 07 Calibration Facility 08 South Area 09 Central Area 10 North Area 11 West Area 12 Unit 1 Vertical Pipe Chase 13 Unit 2 Vertical Pipe Chase 14 Unit 1 BAT and Pumps 15 Unit 2 BAT and Pumps 500 617 Ft Elevation 01 Unit 1 Volume Control Tank 02 Unit 2 Volume Control Tank 03 Unit 1 Pipe Chase 04 Unit 2 Chase 05 Radiation Protection Offices 06 Unit 1 Containment Purge Air Equipment Room 07 Unit 2 Containment Purge Air Equipment Room 08 Tool Crib 09 Waste Evaporator Monitor Tank 10 Radwaste Evaporator 11 Spent Resin Storage Area 12 Laboratory 2-92

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

13 West Area 14 East Area 600 630 Ft Elevation 01 Unit 1 Cable Spreading Room 02 Unit 2 Cable Spreading Room 03 Unit 1 Cable Penetration Room 04 Unit 2 Cable Penetration Room 700 642 Ft Elevation 01 642 Ft Elevation 800 654 Ft Elevation 01 654 Ft Elevation 900 Exterior Surfaces & Roof (All Exterior Surfaces are Class 2) 01 Roof 02 Exterior Walls 06000 Turbine Building (All Interior Surfaces are Class 2) 100 560 Ft Elevation 01 Oil Room 02 South Area 03 Central Area 04 North Area 200 570 Ft Elevation 01 Unit 1 Diesel Fuel Oil Storage 1B 02 Unit 2 Diesel Fuel Oil Storage 2B 03 Unit 1 Diesel Fuel Oil Storage 1A 04 Unit 2 Diesel Fuel Oil Storage 2A 05 Unit 1 Diesel Fuel Oil Storage 0A 06 Unit 2 Future Diesel Fuel Oil Storage 0B 2-93

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

07 Unit 1 Steam Pipe Tunnel 08 Unit 2 Steam Pipe Tunnel 300 592 Ft Elevation 01 Unit 1 Diesel Generator 1A 02 Unit 2 Diesel Generator 1B 03 Unit 1 Diesel Generator 0 04 Unit 2 Diesel Generator 2A 05 Unit 1 Diesel Generator 2B 06 Battery and Charger Room 07 Technical Support Center 08 Secondary Sample Room 09 Auxiliary Heating Boiler 10 South Area 11 Central Area 12 North Area 400 609 Ft Elevation 01 609 Ft Elevation 500 617 Ft Elevation 01 Switchgear Rooms 17, 18 &19 02 Switchgear Rooms 27, 28 &29 03 Air Conditioning Equipment Room 04 QA Records Area 05 South Area 06 Central Area 07 North Area 600 625 Ft Elevation 01 625 Ft Elevation 2-94

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

700 642 Ft Elevation 01 Unit 1 Nonessential Switchgear and Rod Drive MG Set 02 Unit 2 Nonessential Switchgear and Rod Drive MG Set 03 Main Control Room Complex 04 Control Room Annex South 05 Control Room Annex North 06 Unit 1 Auxiliary Electric Equipment Room 07 Unit 2 Auxiliary Electric Equipment Room 08 South Area 09 Central Area 10 North Area 800 656 Ft Elevation 01 656 Ft Elevation 900 Exterior Surfaces & Roof (All Exterior Surfaces are Class 2) 01 Roof 02 Exterior Walls 07000 Service Building (All Interior Surfaces are Class 2) 100 592 Ft Elevation 01 East 02 West 200 608 Ft Elevation 01 East 02 West 300 624 Ft Elevation 01 East 02 West 400 636 Ft Elevation 2-95

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

01 East 02 West 500 648 Ft Elevation 01 East 600 660 Ft Elevation 01 East 700 Exterior Surfaces & Roof (All Exterior Surfaces are Class 2) 01 East Roof 02 West Roof 03 Exterior Walls 08000 Crib House (All Interior Surfaces are Class 2) 100 552 Ft Elevation 01 552 Ft Elevation 200 594 Ft Elevation 01 594 Ft Elevation 300 Exterior Surfaces & Roof (All Exterior Surfaces are Class 2) 01 Roof 02 Exterior Walls 09000 Outbuildings 100 WWTF 01 1st Floor Interior Surfaces (Class 2) 02 2nd Floor Interior Surfaces (Class 2) 03 Roof (Class 2) 04 Exterior Surfaces (Class 2) 200 North Valve House 01 1st Floor Interior Surfaces (Class 2) 02 Roof (Class 2) 2-96

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

03 Exterior Surfaces (Class 2) 300 North Chlorination/Dechlorination Building 01 1st Floor Interior Surfaces (Class 2) 02 Roof (Class 2) 03 Exterior Surfaces (Class 2) 400 Warehouse/Mechanical Maintenance Training Center 01 1st Floor Interior Surfaces (Class 3) 02 Roof (Class 3) 03 Exterior Surfaces (Class 3) 500 Interim Radwaste Storage Facility (IRSF) Building 01 1st Floor Interior Surfaces (Class 2) 02 Mezzanine (Class 2) 03 Roof (Class 2) 04 Exterior Surfaces (Class 2) 600 Fire Training Building 01 1st Floor Interior Surfaces (Class 3) 02 Roof (Class 3) 03 Exterior Surfaces (Class 3) 700 Contractor Break Building 01 1st Floor Interior Surfaces (Class 3) 02 Roof (Class 3) 03 Exterior Surfaces (Class 3) 800 East Training Center 01 1st Floor Interior Surfaces (Class 3) 02 Roof (Class 3) 03 Exterior Surfaces (Class 3) 900 In-Processing Building 2-97

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

01 1st Floor Interior Surfaces (Class 3) 02 2nd Floor Interior Surfaces (Class 3) 03 Roof (Class 3) 04 Exterior Surfaces (Class 3) 110 Station Construction Building 01 1st Floor Interior Surfaces (Class 3) 02 Roof (Class 3) 03 Exterior Surfaces (Class 3) 120 Illinois Department of Nuclear Safety (IDNS) Building 01 1st Floor Interior Surfaces (Class 2) 02 Roof (Class 2) 03 Exterior Surfaces (Class 2) 130 Security Offices 01 1st Floor Interior Surfaces (Class 2) 02 Roof (Class 2) 03 Exterior Surfaces (Class 2) 140 Gate House 01 1st Floor Interior Surfaces (Class 2) 02 2nd Floor Interior Surfaces (Class 2) 03 Roof (Class 2) 04 Exterior Surfaces (Class 2) 150 North Warehouse 01 1st Floor Interior Surfaces (Class 3) 02 Roof (Class 3) 03 Exterior Surfaces (Class 3) 160 South Warehouse 01 1st Floor Interior Surfaces (Class 3) 2-98

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-3 Initial List of Structural Survey Units (continued)

Survey Unit Survey Unit Description ID #

02 Roof (Class 3) 03 Exterior Surfaces (Class 3) 170 South Valve House 01 1st Floor Interior Surfaces (Class 2) 02 Roof (Class 2) 03 Exterior Surfaces (Class 2) 180 South Chlorination/Dechlorination Building 01 1st Floor Interior Surfaces (Class 2) 02 Roof (Class 2) 03 Exterior Surfaces (Class 2) 190 West Training Building 01 1st Floor Interior Surfaces (Class 3) 02 2nd Floor Interior Surfaces (Class 3) 03 Roof (Class 3) 04 Exterior Surfaces (Class 3) 2-99

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-4 Initial List of Open Land Survey Units Survey Survey Unit Description Initial Approximate Unit ID Classification Survey Unit

1. Area (m2) 12000 Security Restricted Area Grounds 12101 WWTF Sludge Drying Bed Area Class 1 2,036 12102 WWTF Facility Class 1 2,024 12103 Unit 2 PWST/SST Area Class 1 2,034 12104 Area Around the North Half of Unit 2 Containment Class 1 1,940 12105 Area Around the South Half of Unit 2 Containment Class 1 1,938 Area Around the North Half of Fuel Handling and 12106 Class 1 1,936 Auxiliary Buildings Area Around the South Half of Fuel Handling and 12107 Class 1 1,934 Auxiliary Buildings 12108 Area Around the North Half of Unit 1 Containment Class 1 1,932 12109 Area Around the South Half of Unit 1 Containment Class 1 1,931 12110 Yard Between Unit 1 Containment and Turbine Class 1 1,740 12111 South Yard Area Northeast of Gate House Class 1 1,964 12112 Unit 1 PWST/SST Area West Class 1 1,658 12113 Unit 1 PWST/SST Area East Class 1 1,693 12201 North Protected Area Yard Class 2 9,610 12202 Gate House and Southwest Yard Class 2 7,562 12203 Soils Around the Service Building and South East Class 2 7,569 Yard 12204 Crib House Area Class 2 5,909 12205 Area Around the Turbine Building Class 2 9,085 10200 Radiological Restricted Area Grounds 10201 NE Corner of Restricted Area - Lakeshore Class 3 8,530 10202 IRSF/Fire Training Area Class 3 7,799 10203 East Training Area Class 3 11,761 10204 North Gate Area Class 3 7,230 10205 Switchyard Class 3 55,432 2-100

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-4 Initial List of Open Land Survey Units (continued)

Survey Survey Unit Description Initial Approximate Unit ID Classification Survey Unit

1. Area (m2) 10206 Station Construction Area Class 3 10,539 10207 North Warehouse Area Class 3 10,284 10208 South Warehouse Area Class 3 12,381 10209 Restricted Area South of Gate House Class 3 5,664 10210 Restricted Area South of Turbine Building Class 3 5,048 10211 Southeast Corner of Restricted Area - Lakeshore Class 3 6,472 10212 North Restricted Area Fence line - Lakeshore Class 3 36,714 10213 Power House Area Class 3 44,471 10214 Construction Parking Area Class 3 29,681 10215 Area Northwest of Switchyard Non-Impacted 26,008 10216 Area West Northwest of Switchyard Non-Impacted 31,171 10217 Area Southwest of Switchyard Non-Impacted 45,984 10218 Area Near South of Switchyard Class 3 17,822 10219 Area Far South of Switchyard Class 3 12,185 10220 Adjacent to South Restricted Area - lakeshore Class 3 46,964 10221 Owner Controlled Area South of Restricted Area Class 3 27,297 10300 Owner Controlled Area Grounds (included in Final Safety Analysis Report [FSAR])

10301 West Training Area Class 3 55,942 10302 Northwest Corner of FSAR Area Non-Impacted 35,162 10303 Southwest Corner of FSAR Area Non-Impacted 61,955 10304 Southern Area of FSAR Non-Impacted 34,387 10305 Area West of Survey Unit #10217 Non-Impacted 121,535 10306 Area West of Survey Unit #10216 Non-Impacted 85,268 10400 Owner Controlled Area Grounds (not included in FSAR) 10401 Northeast Corner of Owner Controlled Property Non-Impacted 76,118 10402 MET Tower Area Non-Impacted 107,618 2-101

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-4 Initial List of Open Land Survey Units (continued)

Survey Survey Unit Description Initial Approximate Unit ID Classification Survey Unit

1. Area (m2) 10403 Area North of West Training Non-Impacted 139,282 10404 Northwest Corner of Owner Controlled Property Non-Impacted 100,075 2-102

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-5 Scan Coverage Guidelines for Characterization Area Recommended Characterization Scan Coverage Classification Class 1 No scanning required unless compelled by a specific survey objective.

Class 2 50% to 100%, concentrating on areas with an increased probability of exhibiting elevated activity (such as Class 1 boundaries, vehicle transit routes, etc.).

Class 3 10% to 50%, with emphasis on areas that were used for plant activities during operation and areas downwind or downstream of known effluent release points.

Non-Impacted 1% to 5%, with emphasis on areas adjacent to impacted areas.

2-103

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-6 Instrument Types and Nominal MDC Typical Detection Sensitivity Detector Model b Meter Model Application MDCscan MDCstatica (dpm/100cm2) (dpm/100cm2)

Ludlum 44-9 Ludlum 2350-1 static & scan 2900 985 Ludlum 43-5 Ludlum 2350-1 static & scan 150 75 Ludlum 43-68 mode Ludlum 2350-1 static & scan 1050 330 Ludlum 43-68 mode Ludlum 2350-1 static & scan 170 70 Ludlum 44-116 Ludlum 2350-1 static & scan 1300 415 Ludlum 43-90 Ludlum 2350-1 static & scan 130 55 Ludlum 44-10 Ludlum 2350-1 scan 3.5 pCi/g 60Co N/A 6.5 pCi/g 137Cs Ludlum 43-37 Ludlum 2350-1 scan 1000 N/A Tennelec LB5100 N/A and/or N/A 18 proportional counting smear system HPGe Gamma N/A Analysis N/A ~0.15 pCi/g Spectroscopy System c for Co-60 and Cs-137 a Based on 1-minute count time; and default values for surface efficiencies (s) as specified in International Standard, ISO 7503-1 (Reference 2-32).

b Functional equivalent instrumentation may be used c MDC Requirements per Regulatory Guide 4.8 (Reference 2-33) 2-104

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-7 Typical Vendor Laboratory Standard MDC Values Solid Water Test Technique Method (pCi/g) (pCi/L)

Gamma Gamma Spectroscopy LANL EM-9 0.1 10 radionuclides Alpha Gas Flow Proportional EPA 900.0 4.0 5.0 Beta Gas Flow Proportional EPA 900.0 10.0 5.0 H-3 Liquid Scintillation EPA 906.0 Mod 6.0 700 C-14 Liquid Scintillation EPA EERF C 2.0 50.0 Fe-55 Liquid Scintillation DOE RESL Fe-1 5.0 100.0 Low Energy Gamma Ni-59 DOE RESL Ni-1 10.0 20.0 Spectroscopy Ni-63 Liquid Scintillation DOE RESL Ni-1 4.0 50.0 Sr-90 Gas Flow Proportional EPA905.0 Mod 2.0 2.0 Tc-99m Liquid Scintillation DOE EML HASL 300 5.0 50.0 Pm-147 Liquid Scintillation EPA EERF PM-1-1 10 10 Np-237 Alpha Spectroscopy DOE EML HASL 0.5 1.0 Pu-238-240 Alpha Spectroscopy DOE EML HASL 300 0.5 1.0 Pu-241 Liquid Scintillation DOE EML HASL 300 15.0 15.0 Am-241 & Alpha Spectroscopy DOE EML HASL 300 0.5 1.0 243 Pu-242 Alpha Spectroscopy DOE EML HASL 300 0.5 1.0 Cm-242-246 Alpha Spectroscopy DOE EML HASL 300 0.5 1.0 2-105

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-8 EnergySolutions Background Study Results Asphalt Results Results in dpm/100cm2 Measurements Min Max Average St. Dev 95% UCLa 25 101 393 257 77 284 a 95% Upper Confidence Level on the average based on 25 measurements or 24 (n-1) degrees of freedom.

Results in pCi/g Nuclide Average Std. Dev 95% UCLa K-40 4.64E+00 9.26E-01 5.06E+00 Cs-137 1.23E-03 1.05E-02 6.02E-03 Tl-208 1.57E-01 5.56E-02 1.82E-01 Pb-212 1.77E-01 3.81E-02 1.95E-01 Bi-214 1.19E-01 4.01E-02 1.37E-01 Pb-214 1.55E-01 3.68E-02 1.72E-01 Ac-228 1.60E-01 6.55E-02 1.90E-01 Th-234 8.60E-02 3.65E-01 2.52E-01 U-235 3.51E-03 4.11E-02 2.22E-02 a 95% Upper Confidence Level on the average based on 15 measurements or 14 (n-1) degrees of freedom.

b Bold values indicate concentration greater than MDC. Italicized values indicate MDC value.

Concrete Results Results in dpm/100cm2 Measurements Min Max Average St. Dev 95% UCLa 25 141 541 356 100 391 a 95% Upper Confidence Level on the average based on 25 measurements or 24 (n-1) degrees of freedom.

Results in pCi/g Nuclide Average Std. Dev 95% UCLa K-40 5.55E+00 2.63E+00 6.74E+00 Cs-137 1.21E-02 1.82E-02 2.03E-02 Tl-208 2.60E-01 8.74E-02 3.00E-01 Pb-212 3.01E-01 1.15E-01 3.54E-01 Bi-214 3.00E-01 6.51E-02 3.30E-01 Pb-214 3.03E-01 6.57E-02 3.32E-01 Ac-228 3.08E-01 1.03E-01 3.55E-01 Th-234 3.48E-01 3.27E-01 4.96E-01 U-235 8.78E-02 9.81E-02 1.32E-01 a 95% Upper Confidence Level on the average based on 15 measurements or 14 (n-1) degrees of freedom.

b Bold values indicate concentration greater than MDC. Italicized values indicate MDC value.

2-106

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-8 EnergySolutions Background Study Results (continued)

Surface Soil Results Surface Scanning Results in cpm (gross)

Measurements Min Max Average St. Dev 95% UCL 8,955 2,520 9,240 5,192 832 5,206 Static Measurements Results in cpm (gross)

Measurements Min Max Average St. Dev 95% UCLa 30 4,530 6,362 5,718 543 5,886 a 95% Upper Confidence Level on the average based on 30 measurements or 29 (n-1) degrees of freedom.

Results in pCi/g Nuclide Average Std. Dev 95% UCLa K-40 1.40E+01 2.00E+00 1.49E+01 Cs-137 6.61E-03 2.15E-02 1.64E-02 Tl-208 4.45E-01 8.78E-02 4.85E-01 Pb-212 5.30E-01 8.94E-02 5.70E-01 Bi-214 5.44E-01 1.10E-01 5.94E-01 Pb-214 5.43E-01 9.21E-02 5.85E-01 Ac-228 5.20E-01 1.02E-01 5.66E-01 Th-234 6.05E-01 4.68E-01 8.18E-00 U-235 9.83E-02 1.16E-01 1.51E-01 a 95% Upper Confidence Level on the average based on 15 measurements or 14 (n-1) degrees of freedom.

b Bold values indicate concentration greater than MDC. Italicized values indicate MDC value.

Sub-Surface Soil Results Results in pCi/g Nuclide Average Std. Dev 95% UCLa K-40 1.36E+01 2.89E+00 1.49E+01 Cs-137 -1.95E-03 1.83E-02 6.35E-03 Tl-208 4.42E-01 9.56E-02 4.85E-01 Pb-212 4.98E-01 1.68E-01 5.74E-01 Bi-214 6.06E-01 1.76E-01 6.86E-01 Pb-214 6.10E-01 1.92E-01 6.97E-01 Ac-228 4.87E-01 1.14E-01 5.39E-01 Th-234 5.74E-01 4.87E-01 7.95E-00 U-235 5.26E-02 7.70E-02 8.76E-02 a 95% Upper Confidence Level on the average based on 15 measurements or 14 (n-1) degrees of freedom.

b Bold values indicate concentration greater than MDC. Italicized values indicate MDC value.

2-107

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-9 Crib House Concrete Core Sample Analysis Results Concrete Core Sample Analysis Results Results in pCi/g Nuclide Average Max Std. Dev K-40 1.39E+01 2.18E+01 2.86E+00 Co-60 1.20E-01 1.44E-01 1.84E-02 Cs-137 7.00E-02 9.24E-02 1.07E-02 Bi-212 1.82E-01 1.90E-01 1.20E-02 Pb-212 2.38E-01 4.20E-01 6.13E-02 Bi-214 4.00E-01 6.53E-01 9.16E-02 Pb-214 4.36E-01 7.07E-01 1.30E-01 Ra-226 1.46E+00 2.64E+00 4.89E-01 Ac-228 6.93E-01 4.79E-01 9.76E-02 U-235 8.30E-02 1.60E-01 3.59E-01 a Sample population consisted of 40 samples with 32 taken on the floor and 8 taken on lower walls b Bold values indicate concentration greater than MDC. Italicized values indicate MDC value.

2-108

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-10 Hosah Park Background Assessment Sample Analysis Surface Soil Sample Analysis Results Results in pCi/g Nuclide Average Max Std. Dev K-40 6.96E+00 8.95E+00 9.01E-01 Co-60 -3.19E-02 2.87E-02 1.88E-01 Sr-90 -6.03E-04 5.26E-02 2.41E-02 Cs-137 2.11E-01 6.51E-01 1.48E-01 Th-228 1.72E-01 4.30E-01 1.18E-01 Th-230 3.45E-01 2.07E+00 3.55E-01 Th-232 1.53E-01 5.11E-01 1.04E-01 U-234 2.03E-01 1.74E+00 3.23E-01 U-235 1.40E-02 1.37E-01 3.24E-02 U-238 2.11E-01 1.86E+00 3.24E-01 Subsurface Soil Sample Analysis Results Results in pCi/g Nuclide Average Max Std. Dev K-40 6.62E+00 8.59E+00 9.49E-01 Co-60 3.72E-04 3.79E-02 1.38E-02 Sr-90 4.40E-03 5.30E-02 2.16E-02 Cs-137 2.64E-02 2.41E-01 6.00E-02 Th-228 1.26E-01 4.50E-01 1.14E-01 Th-230 3.28E-01 8.11E-01 2.09E-01 Th-232 1.21E-01 4.05E-01 9.54E-02 U-234 1.25E-01 7.36E-01 1.57E-01 U-235 1.05E-02 1.10E-01 2.43E-02 U-238 1.31E-01 6.65E-01 1.47E-01 a Bold values indicate concentration(s) greater than MDC. Italicized values indicate MDC value.

2-109

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-11 Investigative Levels for Cs-137 Based on Background Studies Measured Range Range for 95% Distribution Condition and Depth (pCi/g) (pCi/g)

Drainage Areas Surface 0-10 cm Undisturbed 0.00 to 2.80 0.45 to 3.63 Disturbed 0.00 to 1.67 0.35 to 2.86 Non-Drainage Areas Surface 0-10 cm Undisturbed 0.23 to 0.66 0.15 to 0.77 Disturbed 0.27 to 0.34 0.23 to 0.42 2-110

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-12 Initial Suite of Radionuclides Radionuclide Half Life Radionuclide Half Life (years) (years)

H-3 1.24 E 01 Pm-147 2.62 E 00 C-14 5.73 E 03 Sm-146 1.03 E 08 Fe-55 2.70 E 00 Sm-151 9.00 E 01 Ni-59 7.50 E 04 Eu-152 1.33 E 01 Co-60 5.27 E 00 Eu-154 8.80 E 00 Ni-63 9.60 E 01 Eu-155 4.96 E 00 Sr-90 2.91 E 01 Pu-238 8.77 E 01 Mo-93 3.50 E 03 Pu-239/240 2.41 E 04 Nb-94 2.03 E 04 Pu-241 1.44 E 01 Tc-99 2.13 E 05 Np-237 2.14 E 06 Sb-125 2.77 E 00 Am-241 4.32 E 02 Cs-134 2.06 E 00 Am-243 7.38 E 03 Cs-137 3.00 E 01 Cm-244 1.81 E 01 2-111

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-13 Nominal Radiological Data - Structural Survey Units Radiation Contamination Levels Survey Levels (dpm/100cm2)

HSA Major Systems &

(mr/hr) Comments Area Unit Class Total Loose Components Area Description Unit Description ID ID G/A Max G/A Max G/A Max 01100 Unit 1 CTMT 568 ft. el. 01101 Unit 1 Vessel Bio-Shield Class 1 (NOT SURVEYED - INACCESSIBLE) Not Accessible 01102 A Loop I/S Missile Barrier Class 1 5 6 548K 2.2M 5200 10000 1A Reactor Coolant Pump 01103 B Loop I/S Missile Barrier Class 1 6 8 226K 500K 19000 40000 1B Reactor Coolant Pump 01104 C Loop I/S Missile Barrier Class 1 4 7 684K 2.3M 4400 10000 1C Reactor Coolant Pump 01105 D Loop I/S Missile Barrier Class 1 5 10 213K 450K 5000 10000 1D Reactor Coolant Pump 01106 A Loop O/S Missile Barrier Class 1 1.3 5 152K 400K 3000 5000 01107 B Loop O/S Missile Barrier Class 1 2 10 368K 1.5M 3000 1000 01108 C Loop O/S Missile Barrier Class 1 0.2 0.4 150K 490K 3000 1000 01109 D Loop O/S Missile Barrier Class 1 1 5 53K 145K 1000 1000 01110 543 ft. el. Incore Tunnel Class 1 5 10 (not taken) 21K 40K Incore Sump Under Reactor Vessel 01200 Unit 1 CTMT 592 ft. el. 01201 Cavity Area Class 1 100 187 (210 mrad) 500K 1M Unit 1 Reactor Cavity filled with water 01202 A Loop I/S Missile Barrier Class 1 11 20 (not taken) 1600 40K 1A Steam Generator (S/G) 01203 B Loop I/S Missile Barrier Class 1 16 20 (not taken) 1600 40K 1B Steam Generator (S/G) 01204 C Loop I/S Missile Barrier Class 1 11 22 (not taken) 1600 40K 1C Steam Generator (S/G) 01205 D Loop I/S Missile Barrier Class 1 11 18 (not taken) 1600 40K 1D Steam Generator (S/G) 01206 A Loop O/S Missile Barrier Class 1 0.6 1 84K 345K 1600 3000 01207 B Loop O/S Missile Barrier Class 1 0.2 0.3 49K 136K 1200 2000 01208 C Loop O/S Missile Barrier Class 1 0.4 1 83K 198K 1200 2000 01209 D Loop O/S Missile Barrier Class 1 0.2 0.2 21K 46K 2000 5000 01210 603 ft. Seal Table/Incore Drives Class 1 0.5 1.6 359K 780K 4200 5000 HRA Not Accessible 01300 Unit 1 CTMT 617 ft. el. 01301 Cavity Area Class 1 .06 1 32K 55K <1000 <1000 Unit 1 Reactor Upper Area Only 01302 A & C Loop Area Class 1 37 70 (not taken) <1000 <1000 1A & 1C S/G 01303 B & D Loop Area Class 1 13 18 (not taken) <1000 <1000 1B & 1D S/G, Pressurizer 01304 A Loop O/S Missile Barrier Class 1 0.5 0.7 23K 48K <1000 <1000 01305 B Loop O/S Missile Barrier Class 1 0.5 0.7 13K 28K 1500 2000 01306 C Loop O/S Missile Barrier Class 1 2 10 30K 80K 1000 1500 01307 D Loop O/S Missile Barrier Class 1 0.4 2 80K 300K 1000 1000 01400 Unit 1 CTMT Exterior 01401 Roof Class 2 (NOT SURVEYED - INACCESSIBLE) Not surveyed - safety 01402 Exterior Walls Class 2 40 120 225 272 <300 <300 Accessible walls only 02100 Unit 2 CTMT 568 ft. el. 02101 Unit 2 Vessel Bio-Shield Class 1 (NOT SURVEYED - INACCESSIBLE) Not Accessible 02102 A Loop I/S Missile Barrier Class 1 8 25 1.1M 2.5M 20K 60K 2A Reactor Coolant Pump 02103 B Loop I/S Missile Barrier Class 1 5 10 600K 2.1M 4000 12K 2B Reactor Coolant Pump 02104 C Loop I/S Missile Barrier Class 1 7 30 500K 1.3M 3500 6000 2C Reactor Coolant Pump 02105 D Loop I/S Missile Barrier Class 1 5 20 550K 1.4M 4000 10K 2D Reactor Coolant Pump 2-112

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-13 Nominal Radiological Data - Structural Survey Units (continued)

Contamination Levels Survey Radiation Levels (dpm/100cm2)

Area Unit HSA Major Systems &

Area Description Unit Description (mr/hr) Total Loose Comments ID ID Class Components G/A Max G/A Max G/A Max 02106 A Loop O/S Missile Barrier Class 1 0.1 1 90K 270K <1000 1000 02107 B Loop O/S Missile Barrier Class 1 0.3 10 80K 240K <1000 1000 Rx Coolant Drain Tank 02108 C Loop O/S Missile Barrier Class 1 0.1 0.2 19K 50K 1000 2000 02109 D Loop O/S Missile Barrier Class 1 0.1 0.1 120K 350K <1000 1000 02110 543 ft. el. Incore Tunnel Class 1 3 6 (not taken) 25K 900K Incore Sump Under Reactor Vessel 02200 Unit 2 CTMT 592 ft. el. 02201 Cavity Area Class 1 40 250 (not taken) (110 mrad) Unit 2 Reactor Cavity filled with water 02202 A Loop I/S Missile Barrier Class 1 3 6 14K 40K <1000 <1000 2A Steam Generator (S/G) 02203 B Loop I/S Missile Barrier Class 1 5 7.5 14K 20K <1000 <1000 2B Steam Generator (S/G) 02204 C Loop I/S Missile Barrier Class 1 3.2 6 12K 20K <1000 <1000 2C Steam Generator (S/G) 02205 D Loop I/S Missile Barrier Class 1 4 7.5 24K 80K <1000 <1000 2D Steam Generator (S/G) 02206 A Loop O/S Missile Barrier Class 1 0.3 0.3 53K 200K <300 531 02207 B Loop O/S Missile Barrier Class 1 0.2 0.2 9000 40K <300 506 02208 C Loop O/S Missile Barrier Class 1 0.3 0.3 3000 9000 <300 1000 02209 D Loop O/S Missile Barrier Class 1 0.3 0.6 900 2000 <300 367 02210 603 ft. Seal Table/Incore Drives Class 1 2.6 6 62K 200K 2000 5000 02300 Unit 2 CTMT 617 ft. el. 02301 Cavity Area Class 1 40 250 (not taken) (110 mrad) Unit 2 Reactor Cavity filled with water 02302 A & C Loop Area Class 1 0.8 1 4500 7000 2000 5000 2A & 2C S/G 02303 B & D Loop Area Class 1 1.4 4 2000 3000 <1000 <1000 2B & 2D S/G, Pressurizer 02304 A Loop O/S Missile Barrier Class 1 0.5 0.7 1000 4000 <1000 1000 02305 B Loop O/S Missile Barrier Class 1 0.7 1.6 10000 30000 1000 2000 02306 C Loop O/S Missile Barrier Class 1 0.5 2.2 2000 5000 <1000 <1000 02307 D Loop O/S Missile Barrier Class 1 10 24 10000 30000 <1000 <1000 02400 Unit 2 CTMT Exterior 02401 Roof Class 2 (NOT SURVEYED - INACCESSIBLE) Not surveyed - safety 02402 Exterior Walls Class 2 11 15 764 764 <300 <300 Accessible walls only 03100 Fuel Handling Bldg. 592 ft. el. 03101 Trackway/Cars Shed/Open Area Class 1 0.2 0.2 7900 37000 <300 <300 03102 Spent Fuel Pit Heat Exchangers Class 1 0.3 0.6 <634 1790 <300 <300 03103 Spent Fuel Pit Pump Rooms Class 1 0.3 0.6 8700 34000 <300 <300 03104 Decon Pit Class 1 5.7 25 (not taken) 3000 10000 Hot Work during Survey 03200 Fuel Handling Bldg. 617 ft. el. 03201 New Fuel Storage & Mezzanine Class 1 0.2 0.4 1254 2276 <300 <300 03202 Spent Fuel Pool Class 1 <0.2 <0.2 2479 5304 <300 <300 Spent Nuclear Fuel Filled with water 03203 Cross-town & SPING Gallery Class 1 <0.2 0.2 8591 29039 <300 569 03300 Fuel Bldg. Exterior & Roof 03301 Roof Class 2 0.022 0.022 2057 2210 <300 <300 03302 Exterior Walls Class 2 11 14 613 660 <300 <300 04100 Radwaste Bldg. 579 ft. el. 04101 Crystallizer Class 1 0.3 0.5 17K 96K 306 2709 04200 Radwaste Bldg. 592 ft. el. 04201 Dry Active Waste Storage Area Class 1 10 50 (floor covered) <300 <300 2-113

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-13 Nominal Radiological Data - Structural Survey Units (continued)

Radiation Contamination Levels Survey HSA Levels (dpm/100cm2) Major Systems &

(mr/hr) Comments Area Unit Class Total Loose Components Area Description Unit Description ID ID G/A Max G/A Max G/A Max 04202 Drum Fill Area Class 1 4 40 20K 178K <300 <300 04203 Radwaste Annex Truck Loading Class 1 1 4.1 5400 22K <300 426 04300 Radwaste Bldg. Exterior & Roof 04301 Roof Class 2 0.34 0.36 1429 1581 <300 <300 04302 Exterior Walls Class 2 300 600 513 597 <300 <300 Max DR @ RW Truckbay 05100 Auxiliary Bldg. 542 ft. el. 05101 1A RHR Pump Room Class 1 3 10 64K 35K <1000 <1000 1A RHR Pump 05102 1B RHR Pump Room Class 1 2 5 16K 35K <1000 <1000 1B RHR Pump 05103 2A RHR Pump Room Class 1 0.7 1.2 101K 800K <1000 3000 2A RHR Pump 05104 2B RHR Pump Room Class 1 0.7 1 21K 80K <1000 <1000 2B RHR Pump 05105 Unit 1 Pipe Chase Class 1 5 15 60K 240K <1000 3000 05106 Unit 2 Pipe Chase Class 1 2 5 300K 1.7M 8000 50000 05107 Hold Up Tanks Cubicle Class 1 (ACCESSED FROM THE 579 FT. ELEVATION) Hold Up Tanks 05108 Central Area Class 1 <0.2 0.2 3726 31.0K <300 1000 05109 South Area Class 1 0.2 1 1110 3400 <300 <300 05110 North Area Class 1 0.2 0.6 5018 38K <300 <300 05111 West Area Class 1 0.2 0.6 4447 20K <300 <300 05112 Gas Decay Tanks Class 1 <0.2 <0.2 5000 1 mrad <300 <300 05113 Unit 1 EDCT Class 1 1 1.5 120K 13 mrad <300 <300 Equip Drain Collection Tk 05114 Unit 2 EDCT Class 1 0.4 0.5 38K 6 mrad <300 <300 Equip Drain Collection Tk 05115 HUT Recirc & BAE Feed Pmps Class 1 0.5 1 (270 mrad) 50K 300K Hi Contamination Drains 05116 EDT and Pumps Class 1 10 20 15K 70K <1000 1000 Equipment Drain Tank 05117 Sump A Class 1 0.3 0.4 36K 140K 1000 1000 05118 Sump B Class 1 1.7 2 66K 150K 2000 4000 05200 Auxiliary Bldg. 560 ft. el. 05201 Unit 1A Safety Injection Pump Class 1 0.75 1 23K 200K <300 1696 05202 Unit 2A Safety Injection Pump Class 1 0.4 0.4 45K 400K <1000 3000 05203 Unit 1B Safety Injection Pump Class 1 0.5 0.5 2000 42K <300 <300 05204 Unit 2B Safety Injection Pump Class 1 0.4 0.4 41K 400K <1000 2000 05205 Unit 1A RHR Heat Exchanger Class 1 1.8 5 2000 4000 <300 <300 1A RHR Heat Exchanger 05206 Unit 2A RHR Heat Exchanger Class 1 0.8 1.3 2000 4000 <300 <300 2A RHR Heat Exchanger 05207 Unit 1B RHR Heat Exchanger Class 1 1.9 5 2000 3000 <300 <300 1B RHR Heat Exchanger 05208 Unit 2B RHR Heat Exchanger Class 1 0.5 1 1000 2000 <300 <300 2B RHR Heat Exchanger 05209 Unit 1 Containment Spray Pump Class 1 0.4 1.2 11K 60K <300 <300 05210 Unit 2 Containment Spray Pump Class 1 0.3 0.5 84K 222K <300 607 05211 South Area Class 1 0.6 1 17K 61K <300 417 Laundry Drain Tanks 05212 Central Area Class 1 0.3 0.4 9000 15K <1000 15000 Component Cooling Pmps 05213 North Area Class 1 0.3 0.5 7013 61K <300 <300 05214 West Area Class 1 0.3 0.5 26K 227K <300 455 2-114

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-13 Nominal Radiological Data - Structural Survey Units (continued)

Radiation Contamination Levels Survey HSA Levels (dpm/100cm2) Major Systems &

(mr/hr) Comments Area Unit Class Total Loose Components Area Description Unit Description ID ID G/A Max G/A Max G/A Max 05215 Equipment Drain Tank Class 1 4 10 47K 170K <300 1329 05216 Chemical Drain Tank Class 1 16 40 124K 700K <1000 250K Pump Base contaminated 05217 Unit 1 Vertical Pipe Chase Class 1 (ACCESSED FROM THE 579 FT. ELEVATION) 05218 Unit 2 Vertical Pipe Chase Class 1 (ACCESSED FROM THE 579 FT. ELEVATION) 05219 Blowdown Heat Exchangers Class 1 0.1 0.1 <690 2617 <300 <300 05220 Waste Gas Compressor Area Class 1 0.1 0.1 <690 8413 <300 <300 05221 Unit 1 RHR HE Pipe Chase Class 1 30 60 (20 mrad) 12K 30K Boric Acid on Floor 05222 Unit 2 RHR HE Pipe Chase Class 1 5 5 (12 mrad) 7000 18K 05300 Auxiliary Bldg. 579 ft. el. 05301 Unit 1A Charging Pump Class 1 0.4 0.5 1902 3606 <300 <300 1A Centrifugal Charging 05302 Unit 2A Charging Pump Class 1 0.2 0.2 12K 50K <300 <300 2A Centrifugal Charging 05303 Unit 1B Charging Pump Class 1 0.4 0.7 32K 165K <300 <300 1B Centrifugal Charging 05304 Unit 2B Charging Pump Class 1 0.4 0.4 230K 1.3M <300 <300 2B Centrifugal Charging 05305 Unit 1C Charging Pump Class 1 1.3 4 70K 342K <300 <300 1C Reciprocating 05306 Unit 2C Charging Pump Class 1 0.2 0.3 74K 255K <300 784 2C Reciprocating 05307 Unit 1 RWST Class 1 (NOT SURVEYED - INACCESSIBLE) Refueling Wtr Storage Tk 05308 Unit 2 RWST Class 1 (NOT SURVEYED - INACCESSIBLE) Refueling Wtr Storage Tk 05309 South Area Class 1 0.3 0.7 13K 45K <300 <300 05310 Central Area Class 1 1 2 760K 2.9M 560 1860 05311 North Area Class 1 0.2 0.5 17.5K 81K 520 1392 05312 West Area Class 1 <0.2 0.2 760 1280 <300 <300 05313 Unit 1 Horizontal Pipe Chase Class 1 1.6 5 326K 2.5M 4000 30K 05314 Unit 2 Horizontal Pipe Chase Class 1 0.4 0.5 345K 1.6M <1000 <1000 05315 #1 Hold Up Tank Class 1 10 20 (250 mrad) 50K 150K 05316 #0 Hold Up Tank Class 1 5 5 (160 mrad) 50K 110K 05317 #2 Hold Up Tank Class 1 5 40 (125 mrad) 50K 150K 05318 Anion/Cation Valve Aisle Class 1 <0.2 0.2 1380 5700 <300 <300 05319 Unit 1 Vertical Pipe Chase Class 1 5 20 (not taken) 50K 500K 05320 Unit 2 Vertical Pipe Chase Class 1 5 20 (not taken) 4000 20K 05400 Auxiliary Bldg. 592 ft. el. 05401 Unit 1 Letdown Heat Exchanger Class 1 20 40 380K 1.4M 4000 10K 05402 Unit 2 Letdown Heat Exchanger Class 1 1 2 15K 136K <1000 <1000 05403 Unit 1 Seal Water HE Class 1 5 15 48K 220K <300 556 Seal Wtr Heat Exchanger 05404 Unit 2 Seal Water HE Class 1 0.4 0.8 6680 24K <300 1278 Seal Wtr Heat Exchanger 05405 Unit 2 Future Diesel Generator Class 1 <0.2 <0.2 <300 320 <300 <300 05406 Primary Sample Room Class 1 0.25 0.3 19K 60K 10K 30K 05407 Calibration Facility Class 1 0.5 0.6 <300 674 <300 <300 05408 South Area Class 1 0.2 0.3 710 1900 <300 <300 2-115

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-13 Nominal Radiological Data - Structural Survey Units (continued)

Radiation Contamination Levels Survey HSA Levels (dpm/100cm2) Major Systems &

(mr/hr) Comments Area Unit Class Total Loose Components Area Description Unit Description ID ID G/A Max G/A Max G/A Max 05409 Central Area Class 1 0.2 0.4 144K 5.6M 340 556 05410 North Area Class 1 0.2 0.3 463 696 <300 <300 05411 West Area Class 1 0.2 0.5 8000 30K <300 <300 05412 Unit 1 Vertical Pipe Chase Class 1 (ACCESSED FROM THE 579 FT. ELEVATION) 05413 Unit 2 Vertical Pipe Chase Class 1 (ACCESSED FROM THE 579 FT. ELEVATION) 05414 Unit 1 BAT and Pumps Class 1 0.5 1.5 <300 <300 <300 <300 05415 Unit 2 BAT and Pumps Class 1 <0.2 <0.2 6500 15.9K <300 <300 05500 Auxiliary Bldg. 617 ft. el. 05501 Unit 1 Volume Control Tank Class 1 9 15 153K 740K <300 632 05502 Unit 2 Volume Control Tank Class 1 1 2 3800 19K <300 <300 05503 Unit 1 Pipe Chase Class 1 0.6 2 3629 19K <300 1075 U1 CTMT Hatch 05504 Unit 2 Chase Class 1 0.2 0.5 5600 20K <300 <300 U2 CTMT Hatch 05505 Radiation Protection Offices Class 1 0.013 0.06 953 5319 <300 <300 05506 Unit 1 CTMT Purge Room Class 1 <0.2 0.3 60 300 <300 <300 CTMT Purge Air Equip 05507 Unit 2 CTMT Purge Room Class 1 10 40 360 1000 <300 <300 CTMT Purge Air Equip 05508 Tool Crib Class 1 0.3 0.3 8911 47K <300 <300 05509 Waste Evaporator Monitor Tank Class 1 0.3 4 92K 117K <300 734 05510 Radwaste Evaporator Class 1 0.6 2 69K 195K <300 367 Areas not accessible 05511 Spent Resin Storage Area Class 1 (NOT SURVEYED - LOCKED HI RAD AREA) Posted LHRA >15 R/hr 05512 Laboratory Class 1 0.01 0.014 444 1213 <300 <300 05513 West Area Class 1 <0.2 <0.2 8300 26K <300 <300 05514 East Area Class 1 0.3 1 552 1204 <300 <300 05600 Auxiliary Bldg. 630 ft. el. 05601 Unit 1 Cable Spreading Room Class 1 0.007 0.008 905 1031 <300 <300 05602 Unit 2 Cable Spreading Room Class 1 0.007 0.008 760 1031 <300 <300 05603 Unit 1 Cable Penetration Room Class 1 0.006 0.007 763 849 <300 <300 05604 Unit 2 Cable Penetration Room Class 1 0.006 0.007 530 731 <300 <300 05700 Auxiliary Bldg. 642 ft. el. 05701 642 ft. elevation Class 1 0.2 0.3 <658 <658 <300 <300 05800 Auxiliary Bldg. 654 ft. el. 05801 654 ft. elevation Class 1 0.2 0.3 <658 989 <300 <300 Vent Filter Banks 05900 Auxiliary Bldg. Exterior & Roof 05901 Roof Class 2 0.028 0.035 1886 2114 <300 <300 05902 Exterior Walls Class 2 600 300 764 764 <300 <300 Max DR @ RW Truckbay 06100 Turbine Bldg. 560 ft. el. 06101 Oil Room Class 2 0.006 0.007 <514 699 <300 <300 06102 South Area Class 2 0.005 0.006 <366 1383 <300 <300 06103 Central Area Class 2 0.008 0.015 3700 27K <300 <300 06104 North Area Class 2 0.005 0.006 1752 7257 <300 <300 06200 Turbine Bldg. 570 ft. el. 06201 1B Diesel Fuel Oil Storage Class 2 0.005 0.006 <528 787 <300 <300 06202 2B Diesel Fuel Oil Storage Class 2 0.006 0.007 <539 721 <300 <300 06203 1A Diesel Fuel Oil Storage Class 2 0.005 0.005 <465 915 <300 <300 2-116

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-13 Nominal Radiological Data - Structural Survey Units (continued)

Radiation Contamination Levels Survey HSA Levels (dpm/100cm2) Major Systems &

(mr/hr) Comments Area Unit Class Total Loose Components Area Description Unit Description ID ID G/A Max G/A Max G/A Max 06204 2A Diesel Fuel Oil Storage Class 2 0.006 0.007 <539 <539 <300 <300 06205 0A Diesel Fuel Oil Storage Class 2 0.004 0.005 <521 <521 <300 <300 06206 Unit 2 Future Fuel Oil Storage Class 2 0.007 0.008 <606 664 <300 <300 06207 Unit 1 Steam Pipe Tunnel Class 2 0.008 0.04 17K 104K <300 <300 Reclassified to Class 1 06208 Unit 2 Steam Pipe Tunnel Class 2 0.006 0.01 1500 6200 <300 <300 Reclassified to Class 1 06300 Turbine Bldg. 592 ft. el. 06301 Unit 1 Diesel Generator 1A Class 2 0.004 0.004 <433 752 <16 <16 06302 Unit 2 Diesel Generator 1B Class 2 0.004 0.005 <354 638 <16 <16 06303 Unit 1 Diesel Generator 0 Class 2 0.005 0.007 <302 505 <16 <16 06304 Unit 2 Diesel Generator 2A Class 2 0.003 0.004 <353 641 <16 <16 06305 Unit 1 Diesel Generator 2B Class 2 0.004 0.004 <575 <575 <16 <16 06306 Battery and Charger Room Class 2 0.005 0.005 <460 807 <16 <16 06307 Technical Support Center Class 2 0.006 0.006 <442 <442 <16 <16 06308 Secondary Sample Room Class 2 0.007 0.011 <312 819 <300 <300 06309 Auxiliary Heating Boiler Class 2 0.006 0.008 3233 18K <300 <300 06310 South Area Class 2 0.009 0.015 <510 648 <16 <16 06311 Central Area Class 2 0.005 0.008 <670 1048 <300 <300 06312 North Area Class 2 0.006 0.007 <455 1028 <16 <16 06400 Turbine Bldg. 609 ft. el. 06401 609 ft. elevation Class 2 0.004 0.005 <353 589 <16 <16 06500 Turbine Bldg. 617 ft. el. 06501 Switchgear Rooms 17, 18 &19 Class 2 0.006 0.008 <522 738 <16 <16 06502 Switchgear Rooms 27, 28 &29 Class 2 0.006 0.007 <654 928 <16 <16 06503 Air Conditioning Equipment Rm Class 2 0.016 0.025 <553 682 <16 <16 06504 QA Records Area Class 2 0.005 0.005 <539 862 <17 <17 06505 South Area Class 2 0.005 0.008 <438 785 <16 <16 06506 Central Area Class 2 0.005 0.006 <596 1028 <16 <16 06507 North Area Class 2 0.005 0.007 <595 983 <16 <16 06600 Turbine Bldg. 625 ft. el. 06601 625 ft. elevation Class 2 0.005 0.005 661 862 <16 <16 06700 Turbine Bldg. 642 ft. el. 06701 Unit 1 Switchgear & Rod Drive Class 2 0.007 0.009 <690 1171 <16 <16 06702 Unit 2 Switchgear & Rod Drive Class 2 0.005 0.005 <612 873 <16 <16 06703 Main Control Room Complex Class 2 0.005 0.006 <476 <476 <16 <16 06704 Control Room Annex South Class 2 0.004 0.005 <353 <589 <16 <16 06705 Control Room Annex North Class 2 0.004 0.005 <393 1048 <16 <16 06706 Unit 1 Aux Electric Equipment Class 2 0.005 0.006 <416 752 <16 <16 06707 Unit 2 Aux Electric Equipment Class 2 0.005 0.005 <429 674 <16 <16 06708 South Area Class 2 0.007 0.01 <334 600 <16 <16 06709 Central Area Class 2 0.005 0.005 <448 796 <16 <16 06710 North Area Class 2 0.008 0.01 <410 641 <16 <16 2-117

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-13 Nominal Radiological Data - Structural Survey Units (continued)

Radiation Contamination Levels Survey HSA Levels (dpm/100cm2) Major Systems &

(mr/hr) Comments Area Unit Class Total Loose Components Area Description Unit Description ID ID G/A Max G/A Max G/A Max 06800 Turbine Bldg. 656 ft. el. 06801 656 ft. elevation Class 2 0.005 0.006 <507 848 <16 <16 06900 Turbine Bldg. Exterior & Roof 06901 Roof Class 2 0.015 0.016 2490 2790 <300 <300 06902 Exterior Walls Class 2 10 30 <300 <300 <300 <300 Max DR @ Truckbay 07100 Service Bldg. 592 ft. el. 07101 East Class 2 0.008 0.012 <596 789 <17 <17 07102 West Class 2 0.009 0.013 312 705 <16 <16 07100 Service Bldg. 608 ft. el. 07201 East Class 2 0.008 0.012 <716 804 <16 <16 07202 West Class 2 0.009 0.012 1867 473 <16 <16 07100 Service Bldg. 624 ft. el. 07301 East Class 2 0.008 0.012 <716 792 <17 <17 07302 West Class 2 0.013 0.01 222 1067 <17 <17 07100 Service Bldg. 636 ft. el. 07401 East Class 2 0.008 0.012 872 2846 <300 <300 07402 West Class 2 0.011 0.012 160 286 <16 <16 07100 Service Bldg. 648 ft. el. 07501 East Class 2 0.007 0.01 181 343 <16 <16 07600 Service Bldg. 660 ft. el. 07601 East Class 2 0.009 0.013 184 457 <16 <16 07700 Service Bldg. Exterior & Roof 07701 East Roof Class 2 0.017 0.018 890 1000 <300 <300 07702 West Roof Class 2 0.044 0.046 2267 2438 <300 <300 07703 Exterior Walls Class 2 20 30 319 461 <300 <300 Elevated DR waste 08100 Crib House 559 ft. el. 08101 552 ft. elevation Class 2 0.006 0.007 <615 849 <300 <300 Circ Water Pumps 1990 -552 ft flooded 08200 Crib House 594 ft. el. 08201 594 ft. elevation Class 2 0.006 0.007 <702 <702 <300 <300 Fire Pumps, Pmp Motors 08300 Crib House Exterior & Roof 08301 Roof Class 2 0.006 0.007 2412 2504 <300 <300 08302 Exterior Walls Class 2 0.006 0.007 <615 658 <300 <300 09100 Waste Water Treatment Facility 09101 1st Floor Class 2 0.008 0.025 <683 <683 <300 <300 Pits & drying area HSA SU ID# 09101 09102 2nd Floor Class 2 0.008 0.025 <683 <683 <300 <300 HSA SU ID# 09201 09103 Roof Class 2 0.006 0.007 <677 <677 <300 <300 HSA SU ID# 09301 09104 Exterior Walls Class 2 0.008 0.025 <683 <683 <300 <300 09200 North Valve House 09201 1st Floor Class 2 0.006 0.007 1049 1826 <300 <300 HSA SU ID# 09102 09202 Roof Class 2 0.006 0.007 2803 2861 <300 <300 HSA SU ID# 09202 09203 Exterior Walls Class 2 0.006 0.007 737 1266 <300 <300 HSA SU ID# 09302 09300 North Chlor/Dechlor Bldg. 09301 1st Floor Class 2 0.004 0.005 <606 <606 <300 <300 HSA SU ID# 09103 09302 Roof Class 2 0.006 0.007 1165 1276 <300 <300 HSA SU ID# 09203 09303 Exterior Walls Class 2 0.004 0.005 <606 <606 <300 <300 09400 Warehouse/Maint. Training Ctr 09401 1st Floor Class 3 0.006 0.01 <554 1240 <16 <16 09402 Roof Class 3 0.006 0.007 <623 <623 <300 <300 09403 Exterior Walls Class 3 0.006 0.007 <623 <623 <300 <300 09500 IRSF 09501 1st Floor Class 2 0.006 0.007 <680 1964 <300 <300 09502 Mezzanine Class 2 0.006 0.007 <554 575 <300 <300 09503 Roof Class 2 0.006 0.007 927 962 <300 <300 2-118

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-13 Nominal Radiological Data - Structural Survey Units (continued)

Radiation Contamination Levels Survey HSA Levels (dpm/100cm2) Major Systems &

(mr/hr) Comments Area Unit Class Total Loose Components Area Description Unit Description ID ID G/A Max G/A Max G/A Max 09504 Exterior Walls Class 2 0.006 0.007 <554 853 <300 <300 09600 Fire Training Building 09601 1st Floor Class 3 <0.1 <0.1 <607 1306 <300 <300 Fire Pit - 20 dpm 09602 Roof Class 3 0.006 0.007 888 1011 <300 <300 09603 Exterior Walls Class 3 <0.1 <0.1 <607 <607 <300 <300 09700 Contractor Break Building 09701 1st Floor Class 3 0.006 0.007 <642 667 <300 <300 HSA SU ID# 09107 09702 Roof Class 3 0.006 0.007 <677 <677 <300 <300 HSA SU ID# 09207 09702 Roof Class 3 0.006 0.007 <677 <677 <300 <300 HSA SU ID# 09207 09703 Exterior Walls Class 3 0.006 0.007 <642 <642 <300 <300 09800 East Training Center 09801 1st Floor Class 3 0.006 0.007 <650 1110 <300 <300 Old N-GET Bldg 09802 Roof Class 3 0.006 0.007 652 864 <300 <300 09803 Exterior Walls Class 3 0.006 0.007 <650 933 <300 <300 09900 In-Processing Building 09901 1st Floor Class 3 0.008 1.3 <717 <717 <300 <300 Laboratory (sources) Also known as ENC Bldg 09902 2nd Floor Class 3 0.006 0.008 <717 <717 <300 <300 09903 Roof Class 3 0.006 0.007 864 953 <300 <300 09904 Exterior Walls Class 3 0.006 0.007 <717 <717 <300 <300 09010 Station Construction Building 09011 1st Floor Class 3 0.006 0.006 <569 1188 <300 <300 09012 Roof Class 3 0.006 0.007 <623 714 <300 <300 09013 Exterior Walls Class 3 0.006 0.006 <569 <569 <300 <300 09030 Security Offices 09031 1st Floor Class 2 0.04 0.07 <768 1011 <300 <300 HSA SU ID# 09116 09032 Roof Class 2 0.048 0.048 1495 1649 <300 <300 HSA SU ID# 09216 09033 Exterior Walls Class 2 0.04 0.07 <768 <768 <300 <300 09040 Gate House 09041 1st Floor Class 2 0.15 0.5 <749 2209 <300 <300 HSA SU ID# 09117 09042 2nd Floor Class 2 0.15 0.5 <749 <749 <300 <300 HSA SU ID# 09217 09043 Roof Class 2 0.041 0.042 894 1128 <300 <300 HSA SU ID# 09317 09044 Exterior Walls Class 2 0.15 0.5 <749 <749 <300 <300 09050 North Warehouse 09051 1st Floor Class 3 0.006 0.007 <663 697 <663 <663 09052 Roof Class 3 0.006 0.007 <623 <623 <300 <300 09053 Exterior Walls Class 3 0.006 0.007 <623 <623 <300 <300 09060 South Warehouse 09061 1st Floor Class 3 0.006 0.007 <623 137 <300 <300 RAM stored in warehouse 09062 Roof Class 3 0.006 0.007 652 744 <300 <300 09063 Exterior Walls Class 3 0.006 0.007 <609 <609 <300 <300 09070 South Valve House 09071 1st Floor Class 2 0.006 0.007 716 1149 <300 <300 HSA SU ID# 09121 09072 Roof Class 2 0.006 0.007 2856 3074 <300 <300 HSA SU ID# 09221 09073 Exterior Walls Class 2 0.006 0.007 <586 943 <300 <300 09080 South Chlor/Dechlor Bldg. 09080 1st Floor Class 2 0.004 0.005 <492 156 <300 <300 09081 Roof Class 2 0.006 0.007 1846 1926 <300 <300 2-119

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-13 Nominal Radiological Data - Structural Survey Units (continued)

Radiation Contamination Levels Survey HSA Levels (dpm/100cm2) Major Systems &

(mr/hr) Comments Area Unit Class Total Loose Components Area Description Unit Description ID ID G/A Max G/A Max G/A Max 09082 Exterior Walls Class 2 0.004 0.005 <492 <492 <300 <300 09210 Temp Rad Waste Liner Storage 09211 1st Floor Class 3 0.006 0.007 630 2211 <300 <300 Concrete Liners Not included in HSA 09212 Roof Class 3 0.006 0.007 2266 2558 <300 <300 Not included in HSA 09213 Exterior Walls Class 3 0.006 0.007 (not taken) <300 <300 Not included in HSA 09220 Warehouse #13 09221 1st Floor Class 3 0.004 0.005 <672 <672 <300 <300 ISFSI Warehouse Not included in HSA 09222 Roof Class 3 0.006 0.007 <492 <492 <300 <300 Not included in HSA 09223 Exterior Walls Class 3 0.004 0.005 <672 <672 <300 <300 Not included in HSA 2-120

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-14 Unit 1 Containment 568 Foot Elevation Concrete Core Sample Analysis Summary Co-60 Cs-137 Core Avg. Avg.

Surface Surface Location Sample ID# Depth Subsurface Subsurface Activity (a) Activity (a)

(inches) Activity (b) Activity (b)

(pC/g) (pC/g) (pC/g) (pC/g)

A Loop I/S Missile Barrier B101102-CJFCCV-001 1.5 9.69E+01 1.40E+01 3.46E+04 4.76E+03 A Loop I/S Missile Barrier B101102-CJFCCV-002 5.0 1.91E+02 1.90E+01 4.04E+05 1.65E+04 B Loop I/S Missile Barrier B101103-CJFCCV-001 4.0 2.18E+02 2.55E+01 3.05E+05 3.10E+04 B Loop I/S Missile Barrier B101103-CJFCCV-002 4.5 7.97E+03 3.64E+02 9.86E+04 1.00E+04 C Loop I/S Missile Barrier B101104-CJFCCV-001 4.5 1.25E+02 1.69E+01 4.93E+05 6.71E+04 C Loop I/S Missile Barrier B101104-CJFCCV-002 4.0 4.63E+02 2.86E+01 4.40E+05 2.09E+04 D Loop I/S Missile Barrier B101105-CJFCCV-001 3.5 3.66E+04 6.54E+03 2.56E+03 2.09E+02 D Loop I/S Missile Barrier B101105-CJFCCV-002 5.0 1.04E+03 5.88E+01 3.07E+04 5.79E+03 A Loop O/S Missile Barrier B101106-CJFCCV-001 3.0 1.84E+01 1.20E+00 1.39E+03 6.42E+01 A Loop O/S Missile Barrier B101106-CJFCCV-002 1.0 2.66E+01 6.16E+00 8.03E+01 1.23E+01 B Loop O/S Missile Barrier B101107-CJFCCV-001 1.0 2.04E+01 3.36E+00 3.68E+02 5.21E+01 B Loop O/S Missile Barrier B101107-CJFCCV-002 1.0 1.92E+01 3.56E+00 2.41E+02 3.40E+01 C Loop O/S Missile Barrier B101108-CJFCCV-001 2.5 1.50E+01 2.10E+00 8.70E+03 4.71E+02 C Loop O/S Missile Barrier B101108-CJFCCV-002 1.5 6.16E+01 1.16E+01 6.08E+04 8.50E+03 D Loop O/S Missile Barrier B101109-CJFCCV-001 1.0 1.02E+01 1.93E+00 1.94E+02 3.21E+01 D Loop O/S Missile Barrier B101109-CJFCCV-002 1.0 1.18E+02 1.84E+01 7.32E+03 9.08E+02 (a) Represents surface activity of floor following removal of loose contamination (b) Represents average of activity over entire depth of core sample minus the surface activity (c) Italicized values indicate MDC value.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-15 Unit 1 Bio-Shield Concrete Core Samples Gamma Spectroscopy Analysis Sample Depth Co-60 a Cs-137 a Eu-152 a Eu-154 a Sample ID Puck Date (inches) (pCi/g) (pCi/g) (pCi/g) (pCi/g) 11.5 9.15E-02 1.33E-01 2.26E-01 1.22E-01 B101101-CJWCCV-001 - 1st Core Section 01/10/13 1 12 1.46E-01 1.06E-01 1.76E-01 1.42E-01 23.5 1.85E-01 1.89E-01 1.80E-01 1.54E-01 B101101-CJWCCV-001 - 2nd Core Section 01/17/13 2 24 1.43E-01 1.67E-01 2.40E-01 1.09E-01 35.5 1.28E-01 1.02E-01 2.27E-01 1.82E-01 B101101-CJWCCV-001 - 2nd Core Section 01/17/13 3 36 8.28E-02 1.02E-01 2.06E-01 1.76E-01 47.5 2.76E-01 1.95E-01 1.53E+00 2.48E-01 B101101-CJWCCV-001 - 2nd Core Section 01/17/13 4 48 2.67E-01 1.49E-01 1.25E+00 2.29E-01 59.5 1.94E+00 2.77E-01 2.04E+01 8.55E-01 B101101-CJWCCV-001 - 3rd Core Section 02/21/13 5 60 1.94E+00 2.77E-01 2.04E+01 8.95E-01 B101101-CJWCCV-001 - Rebar Metal Piece 02/21/13 Rebar 63 1.76E+01 1.92E-01 4.10E-01 2.53E-01 71.5 1.50E+01 4.22E-01 1.55E+02 6.49E+00 B101101-CJWCCV-001 - 3rd Core Section 02/21/13 6 72 1.52E+01 4.12E-01 1.63E+02 7.04E+00 a Bold values indicate concentration greater than MDC. Italicized values indicate MDC value.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-16 Unit 2 Containment 568 Foot Elevation Concrete Core Sample Analysis Summary Co-60 Cs-137 Core Avg. Avg.

Surface Surface Location Sample ID# Depth Subsurface Subsurface Activity (a) Activity (a)

(inches) Activity (b) Activity (b)

(pC/g) (pC/g) (pC/g) (pC/g)

A Loop I/S Missile Barrier B102102-CJFCCV-001 3.0 7.56E+02 1.78E+02 1.10E+05 1.66E+04 A Loop I/S Missile Barrier B102102-CJFCCV-002 6.0 9.40E+04 1.65E+03 1.75E+03 5.65E+01 B Loop I/S Missile Barrier B102103-CJFCCV-001 5.5 5.64E+02 2.31E+01 4.57E+04 1.57E+03 B Loop I/S Missile Barrier B102103-CJFCCV-002 4.0 1.91E+02 8.11E+00 6.39E+03 2.27E+02 C Loop I/S Missile Barrier B102104-CJFCCV-001 5.5 3.55E+02 1.22E+01 1.94E+04 6.59E+02 C Loop I/S Missile Barrier B102104-CJFCCV-002 1.5 1.40E+02 4.05E+00 1.45E+04 1.73E+02 D Loop I/S Missile Barrier B102105-CJFCCV-001 4.5 1.11E+03 4.39E+01 2.88E+03 8.77E+01 D Loop I/S Missile Barrier B102105-CJFCCV-002 4.0 1.11E+02 4.05E+00 1.25E+04 3.82E+02 A Loop O/S Missile Barrier B102106-CJFCCV-001 5.0 5.59E+01 1.75E+00 8.13E+02 1.70E+01 A Loop O/S Missile Barrier B102106-CJFCCV-002 1.5 2.71E+01 1.20E+01 1.40E+04 2.93E+03 B Loop O/S Missile Barrier B102107-CJFCCV-001 4.5 6.61E+01 8.16E+00 4.10E+03 7.06E+00 B Loop O/S Missile Barrier B102107-CJFCCV-002 1.5 3.57E+01 3.86E+00 2.09E+03 1.82E+02 C Loop O/S Missile Barrier B102108-CJFCCV-001 2.0 1.30E+01 1.17E+00 2.55E+02 1.77E+01 C Loop O/S Missile Barrier B102108-CJFCCV-002 2.0 1.89E+01 1.64E+00 3.97E+02 2.64E+01 D Loop O/S Missile Barrier B102109-CJFCCV-001 4.0 1.13E+03 4.61E+01 6.07E+03 2.15E+02 D Loop O/S Missile Barrier B102109-CJFCCV-002 2.5 8.62E+01 7.46E+00 4.65E+03 3.09E+02 (a) Represents surface activity of floor following removal of loose contamination (b) Represents average of activity over entire depth of core sample minus the surface activity 2-123

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-17 Unit 1 Containment 541 Foot Elevation Concrete Core Sample Analysis Summary Co-60 Cs-137 Eu-152 Eu-154 Avg. Avg. Avg. Avg.

Core Surface Sub- Surface Sub- Surface Sub- Surface Sub-Location Sample ID# Depth Activity surface Activity surface Activity surface Activity surface (a) (a) (a) (a)

(inches) Activity Activity Activity Activity (b) (b) (b) (b)

(pC/g) (pC/g) (pC/g) (pC/g) (pC/g) (pC/g) (pC/g) (pC/g)

Incore Tunnel Floor B101110-CJFCCV-001 15.5 2.79E+01 5.97E+00 5.27E+01 4.07E+00 6.97E+01 3.34E+01 5.23E+00 1.86E+00 Incore Tunnel Floor B101110-CJFCCV-002 4.0 3.48E+02 5.91E+01 2.71E+03 3.28E+02 6.30E+01 9.15E+01 4.35E+00 5.72E+00 Incore Tunnel Wall B101110-CJWCCV-003 3.5 1.12E+01 7.64E+00 3.72E+01 2.61E+00 5.60E+01 6.67E+01 4.19E+00 3.73E+00 (a) Represents surface activity of floor following removal of loose contamination (b) Represents average of activity over entire depth of core sample minus the surface activity 2-124

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-18 Unit 2 Containment 541 Foot Elevation Concrete Core Sample Analysis Summary Co-60 Cs-137 Eu-152 Eu-154 Avg. Avg. Avg. Avg.

Core Surface Sub- Surface Sub- Surface Sub- Surface Sub-Location Sample ID# Depth Activity surface Activity surface Activity surface Activity surface (a) (a) (a) (a)

(inches) Activity Activity Activity Activity (b) (b) (b) (b)

(pC/g) (pC/g) (pC/g) (pC/g) (pC/g) (pC/g) (pC/g) (pC/g)

Incore Tunnel Floor B102110-CJFCCV-001 14.0 2.35E+01 9.15E+00 6.74E+02 1.08E+01 1.14E+02 7.71E+01 8.45E+00 4.33E+00 Incore Tunnel Floor B102110-CJFCCV-002 4.5 1.42E+01 1.37E+01 1.74E+01 9.43E-01 1.13E+02 1.22E+02 8.61E+00 7.38E+00 Incore Tunnel Wall B102110-CJWCCV-003 5.5 1.35E+01 8.45E+00 5.01E+01 1.99E+00 7.08E+01 6.27E+01 5.12E+00 3.56E+00 (a) Represents surface activity of floor following removal of loose contamination (b) Represents average of activity over entire depth of core sample minus the surface activity 2-125

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-19 Unit 1 Containment Concrete Core Samples - Eberline Laboratory Analysis B101102- B101103- B101104- B101105- B101105- B101106- B101107- B101108- B101109- B101110- B101110-CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV-Radionuclide 002 002 001 001 002 002 002 002 001 001 002 (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g)

H-3 1.91E+01 2.60E+01 3.75E+01 2.71E+01 1.19E+02 8.11E+01 5.05E+01 7.61E+01 5.40E+01 1.33E+02 2.20E+02 C-14 2.50E+00 3.62E+00 4.40E+00 2.46E+01 2.71E+00 1.51E+00 1.12E+00 9.52E+00 1.09E+00 9.89E-01 3.30E+00 Co-60 8.12E+01 7.09E+03 8.69E+01 3.35E+04 9.77E+02 4.36E+01 1.50E+01 8.67E+01 8.50E+00 4.45E+01 3.60E+02 Ni-63 1.81E+04 2.26E+03 6.29E+03 2.81E+03 1.14E+01 3.02E+01 5.48E+00 2.39E+01 1.13E+01 1.40E+02 2.98E+01 Sr-90 4.75E+01 7.60E+00 1.63E+02 1.45E+01 7.08E+00 3.97E-01 5.67E-01 8.46E+00 4.74E-01 3.16E-01 6.01E-01 Nb-94 8.56E+01 1.56E+01 5.13E+01 2.56E+01 7.85E+00 6.01E-01 3.03E-01 9.30E+00 2.37E-01 1.47E+00 1.97E+00 Tc-99 2.25E+01 1.22E+00 3.46E+01 9.31E-01 9.35E-01 2.96E-01 2.60E-01 1.13E+00 2.66E-01 2.63E-01 1.33E+00 Ag-108m 2.39E+02 1.72E+01 5.72E+01 2.05E+01 9.25E+00 4.50E-01 2.35E-01 1.19E+01 2.09E-01 1.45E+00 1.91E+00 Sb-125 1.92E+02 5.54E+01 1.23E+02 3.88E+01 4.78E+01 1.86E+00 1.65E+00 5.62E+01 2.96E-02 NA NA Cs-134 5.47E+01 1.61E+01 3.68E+01 1.53E+01 9.47E+00 4.45E-01 3.31E-01 3.92E+01 3.54E-01 6.39E-01 1.61E+00 Cs-137 1.45E+05 9.44E+04 1.22E+05 2.72E+03 4.27E+04 1.38E+02 1.60E+02 5.91E+04 1.43E+02 8.83E+01 2.84E+03 Pm-145 1.49E+04 1.38E+04 3.49E+03 2.75E+02 5.26E+03 1.42E+01 1.74E+00 8.49E+03 2.02E+00 1.63E+01 3.94E+02 Eu-152 4.52E+02 7.31E+01 2.52E+02 1.25E+02 2.29E+01 1.82E+00 8.56E-01 1.95E+01 1.06E+00 1.64E+02 1.08E+02 Eu-154 2.26E+02 3.58E+01 1.29E+02 5.16E+01 1.48E+01 9.41E-01 5.26E-01 1.76E+01 5.44E-01 1.29E+01 8.69E+00 Eu-155 5.39E+01 2.37E+01 3.54E+01 1.70E+01 1.68E+01 6.24E-01 6.11E-01 1.89E+01 6.41E-01 3.69E+00 3.52E+00 Np-237 9.15E-02 9.56E-02 7.24E-02 9.82E-02 7.93E-02 2.40E-02 3.62E-02 1.01E-01 2.56E-02 NA NA Pu-238 1.25E-01 2.35E-01 3.05E-01 3.18E+00 1.31E-01 5.39E-02 1.03E-01 1.65E-01 9.33E-02 5.21E-02 1.22E-01 Pu-239/240 9.84E-02 1.11E-01 1.12E-01 2.30E+00 7.62E-02 5.24E-02 1.64E-01 1.05E-01 5.88E-02 4.50E-02 1.09E-01 Pu-241 8.17E+00 7.08E+00 8.54E+00 1.24E+01 7.86E+00 5.60E-01 4.53E-01 9.36E+00 4.79E-01 4.21E-01 7.28E+00 Am-241 3.58E-01 1.39E+00 4.25E-01 5.15E+01 2.68E-01 1.67E-01 8.80E-02 1.01E-01 5.40E-02 4.36E-02 2.15E-01 Am-243 8.37E-02 1.36E-01 6.05E-03 5.33E-01 8.36E-02 3.80E-02 4.49E-02 7.63E-02 2.96E-02 3.04E-02 9.33E-02 Cm-243/244 8.70E-02 3.34E-01 1.27E-01 1.01E+01 1.43E-01 4.35E-02 4.04E-02 7.26E-02 6.46E-02 6.35E-02 1.56E-01 a Bold values indicate concentration greater than MDC. Italicized values indicate MDC value. NA indicates no analysis 2-126

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-20 Unit 2 Containment Concrete Core Samples - Eberline Laboratory Analysis B102102- B102103- B102103- B102105- B102105- B102106- B102106- B102107- B102110- B102110-CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV- CJFCCV-Radionuclide 001 001 002 001 002 001 002 001 001 002 (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g)

H-3 1.27E+02 7.61E+01 5.57E+00 9.18E+00 2.06E+02 1.12E+01 5.19E+01 7.26E+00 2.41E+02 3.29E+01 C-14 2.80E+00 5.80E+00 1.17E+00 3.94E+00 1.23E+00 2.72E+00 2.51E+00 4.44E+00 9.72E-01 1.84E+00 Co-60 9.96E+02 6.91E+02 2.59E+02 1.09E+03 1.83E+02 8.01E+01 4.35E+01 7.57E+01 4.95E+01 2.27E+01 Ni-63 4.35E+03 1.23E+03 2.72E+02 4.85E+03 1.08E+02 9.98E+00 1.07E+02 3.11E+02 7.31E+01 4.73E+01 Sr-90 4.84E+00 1.41E+00 1.46E+00 1.76E+01 8.33E-01 4.17E-01 3.79E+00 2.08E+00 3.71E-01 3.35E-01 Nb-94 1.92E+01 1.77E+01 1.77E+01 3.50E+00 5.97E+00 1.06E+00 7.04E+00 1.25E+00 3.22E+00 2.48E+00 Tc-99 2.86E-01 2.22E+00 6.85E-01 3.97E-01 2.54E-01 2.95E-01 3.96E-01 2.80E-01 2.60E-01 2.50E-01 Ag-108m 6.85E+01 2.29E+01 1.88E+00 2.93E+00 7.03E+00 8.09E-01 9.72E+00 1.08E+00 4.17E+00 2.08E+00 Sb-125 2.39E+02 1.00E+02 1.00E+02 2.93E+00 5.56E+01 6.51E+00 6.41E+01 1.52E+01 NA NA Cs-134 6.09E+01 2.10E+01 8.27E+00 3.10E+00 8.75E+00 1.26E+00 1.12E+01 1.68E+01 1.30E+00 8.19E-01 Cs-137 2.14E+05 5.58E+04 8.45E+03 2.49E+03 2.09E+04 1.13E+03 2.66E+04 4.51E+03 1.05E+03 1.56E+01 Pm-145 1.23E+04 8.75E+02 1.08E+03 3.31E+01 2.62E+03 1.28E+02 1.12E+03 3.88E+02 4.78E+01 2.79E+01 Eu-152 3.98E+01 5.08E+01 5.08E+01 9.27E+00 1.22E+01 3.28E+00 1.11E+01 3.58E+00 3.97E+02 2.53E+02 Eu-154 2.70E+01 3.35E+01 3.35E+01 5.45E+00 9.97E+00 1.43E+00 1.21E+01 1.75E+00 2.58E+01 2.17E+01 Eu-155 7.97E+01 3.55E+01 6.12E+00 4.05E+00 2.00E+01 2.32E+00 2.39E+01 4.58E+00 7.02E+00 5.98E+00 Np-237 2.74E-02 2.85E-02 2.85E-02 2.96E-02 3.68E-02 3.84E-02 2.90E-02 3.17E-02 NA NA Pu-238 4.15E-02 3.99E-02 2.59E-02 1.64E-01 4.71E-02 2.85E-02 4.43E-02 3.67E-02 3.18E-02 2.71E-02 Pu-239/240 4.40E-02 5.00E-02 4.74E-02 1.54E-01 4.48E-02 2.86E-02 4.04E-02 2.56E-02 2.78E-02 2.36E-02 Pu-241 3.38E+00 4.01E+00 2.79E+00 6.17E+00 4.65E+00 3.45E+00 4.20E+00 3.09E+00 3.30E+00 2.70E+00 Am-241 2.49E-01 1.24E-01 1.27E-01 6.28E+00 5.08E-02 4.55E-02 4.48E-02 4.25E-02 4.95E-02 1.94E-02 Am-243 4.86E-02 3.28E-02 3.92E-02 3.80E-01 3.58E-02 7.19E-02 5.63E-02 3.94E-02 5.18E-02 3.61E-02 Cm-243/244 9.04E-02 4.54E-02 5.56E-02 1.19E-00 3.50E-02 3.98E-02 4.60E-02 3.66E-02 4.96E-02 2.86E-02 a Bold values indicate concentration greater than MDC. Italicized values indicate MDC value. NA indicates no analysis 2-127

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-21 Radionuclide Distributions for Unit 1 and Unit 2 Containments Unit 1 Containment 568 foot Unit 1 Containment 541 foot elevation elevation H-3 0.10% H-3 3.25%

C-14 0.01% C-14 0.04%

Fe-55 0.07% Fe-55 0.27%

Ni-59 0.01% Ni-59 0.51%

Co-60 2.88% Co-60 8.22%

Ni-63 2.04% Ni-63 3.61%

Sr-90 0.05% Sr-90 0.01%

Nb-94 0.01% Nb-94 0.07%

Tc-99 0.01% Tc-99 0.01%

Ag-108m 0.02% Ag-108m 0.07%

Sb-125 0.10% Sb-125 0.09%

Cs-134 0.03% Cs-134 0.41%

Cs-137 94.30% Cs-137 27.28%

Eu-152 0.19% Eu-152 51.89%

Eu-154 0.10% Eu-154 2.82%

Eu-155 0.03% Eu-155 1.36%

Np-237 0.00% Np-237 0.00%

Pu-238 0.00% Pu-238 0.00%

Pu-239 0.00% Pu-239 0.00%

Pu-240 0.00% Pu-240 0.00%

Pu-241 0.01% Pu-241 0.07%

Am-241 0.01% Am-241 0.00%

Am-243 0.00% Am-243 0.00%

Cm-243 0.00% Cm-243 0.00%

Cm-244 0.00% Cm-244 0.00%

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-21 Radionuclide Distributions for Unit 1 and Unit 2 Containments (continued)

Unit 2 Containment 568 foot Unit 2 Containment 541 foot elevation elevation H-3 0.06% H-3 1.13%

C-14 0.00% C-14 0.01%

Fe-55 1.14% Fe-55 0.70%

Ni-59 0.24% Ni-59 1.55%

Co-60 13.70% Co-60 7.84%

Ni-63 45.02% Ni-63 12.94%

Sr-90 0.00% Sr-90 0.00%

Nb-94 0.29% Nb-94 0.05%

Tc-99 0.00% Tc-99 0.00%

Ag-108m 0.46% Ag-108m 0.67%

Sb-125 0.07% Sb-125 0.03%

Cs-134 0.06% Cs-134 0.34%

Cs-137 38.90% Cs-137 4.40%

Eu-152 0.02% Eu-152 65.28%

Eu-154 0.01% Eu-154 3.72%

Eu-155 0.02% Eu-155 1.31%

Np-237 0.00% Np-237 0.00%

Pu-238 0.00% Pu-238 0.00%

Pu-239 0.00% Pu-239 0.00%

Pu-240 0.00% Pu-240 0.00%

Pu-241 0.00% Pu-241 0.02%

Am-241 0.00% Am-241 0.00%

Am-243 0.00% Am-243 0.00%

Cm-243 0.00% Cm-243 0.00%

Cm-244 0.00% Cm-244 0.00%

2-129

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-22 Auxiliary Building 542 Foot Elevation Concrete Core Sample Analysis Summary Co-60 Cs-137 Core Avg. Avg.

Surface Surface Location Sample ID# Depth Subsurface Subsurface Activity (a) Activity (a)

(inches) Activity (b) Activity (b)

(pC/g) (pC/g) (pC/g) (pC/g) 1A RHR Pump Room B105101-CJFCCV-001 5.5 6.11E+01 1.06E+01 3.74E+03 3.06E+02 2A RHR Pump Room B105103-CJFCCV-001 4.0 4.56E+02 2.04E+02 2.51E+04 4.92E+03 2B RHR Pump Room B105104-CJFCCV-001 1.0 4.08E-01 4.20E-01 9.44E+00 1.79E+00 Unit 1 Hot Pipe Chase B105105-CJFCCV-001 5.0 7.00E+00 8.89E-01 9.83E+03 2.65E+03 Unit 2 Hot Pipe Chase B105106-CJFCCV-001 4.5 3.86E+00 1.51E+00 2.77E+03 1.05E+03 Unit 2 Hot Pipe Chase B105106-CJFCCV-002 1.0 1.75E+01 3.60E+00 3.09E+03 4.14E+02 Hold-up Tank Cubicles B105107- CJFCCV-002 14.0 1.18E+01 3.71E-01 1.17E+02 2.26E+00 Central Common Area B105108-CJFCCV-001 4.5 4.32E-01 1.74E-01 1.92E+03 2.18E+02 Central Common Area B105108-CJFCCV-002 4.0 2.80E+00 1.28E+00 1.13E+02 1.53E+01 Central Common Area B105108-CJFCCV-003 3.0 3.03E+01 1.65E+00 1.67E+03 7.26E+01 Central Common Area Elevator Shaft B105108-CJFCCV-004 4.0 4.05E+00 2.71E-01 1.51E+02 4.92E+00 South Common Area B105109-CJFCCV-001 1.0 4.22E+00 8.22E-01 1.43E+03 2.13E+02 North Common Area B105110-CJFCCV-001 1.0 8.09E+00 1.81E+00 2.11E+03 3.50E+02 North Common Area B105110-CJFCCV-002 1.5 3.28E-01 7.85E-02 6.37E+01 5.17E+00 East Common Area B105111-CJFCCV-001 3.5 2.06E+00 7.66E-01 1.13E+03 1.99E+02 East Common Area Wall B101111-CJWCCV-002 0.5 1.94E-01 2.85E-01 9.52E-01 4.25E-01 Unit 1 ABEDCT Room B105113-CJFCCV-001 5.5 1.96E+02 1.33E+01 5.69E+03 1.54E+02 Unit 1 ABEDCT Room B105113-CJFCCV-002 5.5 3.76E+01 6.98E+00 1.79E+03 1.50E+02 Unit 1 ABEDCT Room Wall B105113-CJWCCV-003 1.0 6.71E+02 1.69E+02 1.66E+04 3.77E+03 (a) Represents surface activity of floor following removal of loose contamination (b) Represents average of activity over entire depth of core sample minus the surface activity (c) Bold values indicate concentration greater than MDC. Italicized values indicate MDC value.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-23 Auxiliary Building Concrete Core Samples - Eberline Laboratory Analysis B105101- B105103- B105105- B105106- B105108- B105113-Radionuclide CJFCCV-001 CJFCCV-001 CJFCCV-001 CJFCCV-002 CJFCCV-003 CJWCCV-003 (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g)

H-3 1.12E+01 1.68E+01 6.98E+00 2.96E+01 5.61E+00 4.71E+00 C-14 9.56E-01 4.88E+00 9.98E-01 1.48E+00 1.19E+00 3.10E+00 Fe-55 1.20E+01 3.16E+01 1.81E+01 1.12E+01 8.17E+00 1.73E+01 Ni-59 1.59E+01 2.08E+01 1.81E+01 1.74E+01 1.67E+01 1.75E+01 Co-60 2.62E+01 2.28E+02 3.20E+00 1.01E+01 1.83E+01 2.03E+02 Ni-63 1.52E+02 3.38E+03 2.91E+02 9.18E+01 8.59E+01 1.65E+03 Sr-90 1.07E+00 5.44E+00 1.52E+00 4.04E-01 3.29E-01 8.82E+00 Nb-94 2.29E-01 8.17E-01 6.19E-01 2.13E-01 3.02E-01 6.57E-01 Tc-99 1.45E+00 9.61E-01 6.70E-01 4.73E-01 9.09E-01 5.81E-01 Ag-108m 2.06E-01 1.66E+00 8.06E-01 2.53E-01 1.82E-01 5.96E-01 Sb-125 2.27E+00 7.79E+00 4.39E+00 2.46E+00 1.99E+00 4.57E+00 Cs-134 4.53E-01 1.47E+00 8.63E-01 8.11E-01 2.90E-01 1.23E+00 Cs-137 1.35E+03 1.33E+04 5.29E+03 1.88E+03 1.05E+03 4.19E+03 Pm-147 1.43E+01 8.17E-01 9.63E-01 5.30E+00 9.57E+00 7.19E+00 Eu-152 7.57E-01 2.58E+00 1.05E+00 6.75E-01 7.10E-01 1.80E+00 Eu-154 4.00E-01 1.38E+00 1.19E+00 3.95E-01 3.21E-01 1.05E+00 Eu-155 5.76E-01 1.76E+00 1.16E+00 6.33E-01 4.84E-01 1.05E+00 Np-237 2.04E-02 2.13E-02 2.39E-02 2.10E-01 1.92E-02 3.20E-02 Pu-238 1.77E-02 3.43E-01 1.32E-02 1.37E-02 1.78E-02 1.39E-02 Pu-239/240 1.77E-02 2.74E-01 1.06E-02 1.37E-02 1.33E-02 1.35E-02 Pu-241 2.48E+00 2.46E+00 1.79E+00 2.36E+00 1.73E+00 1.72E+00 Am-241 3.03E-02 2.29E-01 4.38E-02 2.72E-02 4.29E-02 3.17E-02 Am-243 2.89E-02 1.09E-01 6.01E-02 3.62E-02 3.36E-02 3.18E-02 Cm-243/244 3.91E-02 4.41E-02 3.95E-02 3.89E-02 4.02E-02 4.29E-02 a Bold values indicate concentration greater than MDC. Italicized values indicate MDC value.

2-131

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-24 Radionuclide Distribution for the Auxiliary Building Auxiliary Building 542 foot elevation H-3 0.174%

C-14 0.044%

Fe-55 0.106%

Ni-59 0.498%

Co-60 0.908%

Ni-63 23.480%

Sr-90 0.051%

Nb-94 0.013%

Tc-99 0.016%

Ag-108m 0.017%

Sb-125 0.017%

Cs-134 0.010%

Cs-137 74.597%

Eu-152 0.017%

Eu-154 0.009%

Eu-155 0.008%

Np-237 0.0004%

Pu-238 0.001%

Pu-239 0.0005%

Pu-240 0.001%

Pu-241 0.028%

Am-241 0.001%

Am-243 0.001%

Cm-243 0.0003%

Cm-244 0.0003%

2-132

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-25 Turbine Building 560 Foot and 570 Foot Elevation Concrete Core Sample Analysis Summary Co-60 Cs-137 Core Avg. Avg.

Surface Surface Location Sample ID# Depth Subsurface Subsurface Activity (a) Activity (a)

(inches) Activity (b) Activity (b)

(pC/g) (pC/g) (pC/g) (pC/g)

TB 560 el. North @ Grid F8 B206104-CJFCCV-001 5.5 1.14E-01 8.57E-02 1.27E-01 1.30E-01 TB 560 el. North @ Grid F11 B206104-CJFCCV-002 5.0 2.11E-01 1.07E-01 1.65E+00 1.76E-01 TB 560 el. North @ Grid F12 B206104-CJFCCV-003 4.0 2.73E-01 1.10E-01 4.67E+00 1.37E+00 Unit 1 Steam Tunnel @ Grid L32 B206207-CJFCCV-001 2.0 1.04E-01 1.18E-01 4.67E+00 2.98E+00 Unit 1 Steam Tunnel @ Grid K31 B206207-CJFCCV-002 2.0 1.30E-01 6.86E-02 4.52E+01 3.02E+00 Unit 1 Steam Tunnel@ Grid M32 B206207-CJFCCV-003 2.0 1.06E-01 9.61E-02 1.49E+01 1.03E+00 Unit 1 Steam Tunnel o/s West Valve Room B206207-CJFCCV-004 2.0 1.66E-01 7.57E-02 3.97E+01 2.44E+00 Unit 1 Steam Tunnel @ End of Tunnel B206207-CJFCCV-005 1.5 6.56E-02 1.22E-01 1.74E+01 1.70E+00 Unit 2 Steam Tunnel o/s West Valve Room B206208-CJFCCV-001 2.0 1.50E-01 1.17E-01 6.72E+00 5.95E-01 Unit 2 Steam Tunnel o/s West Valve Room B206208-CJFCCV-002 5.0 1.35E-01 8.93E-02 1.86E+01 1.97E-01 (a) Represents surface activity of floor following removal of loose contamination (b) Represents average of activity over entire depth of core sample minus the surface activity (c) Italicized values indicate MDC value.

2-133

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-26 Turbine Building 560 Foot Elevation Floor Drain System Sediment Samples Gamma Spectroscopy Analysis Sample Analysis Co-60 a Cs-137 a Location Sample ID b Date Date (pCi/g) (pCi/g)

S1-00333-CJSMSM-A001 04/01/13 04/22/13 1.92E-01 1.08E-01 Turbine Bldg. 560 ft. South S1-00333-CJSMSM-A002 04/02/13 04/22/13 2.61E-01 6.37E-01 S1-00333-CJSMSM-A004 04/10/13 04/11/13 1.88E-01 6.03E-01 S1-00333-CJSMSM-B001 04/03/13 04/09/13 3.18E-01 1.24E+01 S1-00333-CJSMSM-B002 04/03/13 04/10/13 2.29E-01 5.44E+00 S1-00333-CJSMSM-B003 04/03/13 04/09/13 1.67E-01 2.05E+00 Turbine Bldg. 560 ft. Central S1-00333-CJSMSM-B004 04/03/13 04/09/13 3.02E-01 1.04E+01 S1-00333-CJSMSM-B006 (LAW) 04/17/13 04/18/13 8.22E+00 7.79E+01 S1-00333-CJSMSM-B007 04/17/13 04/18/13 1.50E-01 1.77E+01 S1-00333-CJSMSM-B008 04/17/13 04/18/13 1.43E-01 9.46E-01 S1-00333-CJSMSM-C001 04/04/13 04/10/13 2.77E-01 1.38E+00 S1-00333-CJSMSM-C002 04/04/13 04/16/13 4.38E-01 4.72E+00 S1-00333-CJSMSM-C003 04/04/13 04/11/13 1.36E-01 2.21E-01 Turbine Bldg. 560 ft. North S1-00333-CJSMSM-C004 04/16/13 04/17/13 2.67E-01 3.38E-01 S1-00333-CJSMSM-C005 04/16/13 04/16/13 1.88E-01 1.99E-01 S1-00333-CJSMSM-C006 04/16/13 04/17/13 2.09E-01 2.51E-01 S1-00333-CJSMSM-C007 04/16/13 04/17/13 3.11E-01 2.74E-01 S1-00333-CJSMSM-C008 (LAW) 04/16/13 04/16/13 2.24E+01 2.87E+01

a. Bold values indicate concentration greater than MDC. Italicized values indicate MDC value.

b. LAW indicates Large Area Wipe 2-134

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-27 Non-Impacted Open Land Survey Units - Characterization Survey Summary Survey Unit 10215 10216 10217 Surface Area 26,007.80 m2 31,171.10 m2 50,880.20 m2 Description Area Northwest of Switchyard Area West of Switchyard Area Southwest of Switchyard Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 4 4 4 4 7 7

1. >MDC 0 0 0 3 0 7 Mean <0.06 pCi/g <0.09 pCi/g <0.04 pCi/g 0.23 pCi/g <0.05 pCi/g 0.41 pCi/g Median <0.05 pCi/g <0.09 pCi/g <0.04 pCi/g 0.23 pCi/g <0.05 pCi/g 0.43 pCi/g Max <0.09 pCi/g <0.10 pCi/g <0.05 pCi/g 0.26 pCi/g <0.06 pCi/g 0.52 pCi/g Min <0.04 pCi/g <0.08 pCi/g <0.01 pCi/g 0.20 pCi/g <0.05 pCi/g 0.26 pCi/g Standard Deviation N/A N/A N/A 0.03 N/A 0.09 ISOCS Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 14 14 16 16 27 27

1. >MDC 0 1 0 8 0 10 Mean <0.04 pCi/g 0.05 pCi/g <0.04 pCi/g 0.19 pCi/g <0.04 pCi/g 0.20 pCi/g Median <0.04 pCi/g 0.05 pCi/g <0.04 pCi/g 0.27 pCi/g <0.04 pCi/g 0.21 pCi/g Max <0.05 pCi/g 0.05 pCi/g <0.05 pCi/g 0.27 pCi/g <0.06 pCi/g 0.30 pCi/g Min <0.02 pCi/g 0.05 pCi/g <0.03 pCi/g 0.07 pCi/g <0.04 pCi/g 0.04 pCi/g Standard Deviation N/A N/A N/A 0.07 N/A 0.08 Surface Scans

% Scanned 1% 1% 1%

1. of Alarms 0 0 0 Mean Scan 3,995 cpm 4,828 cpm 4,563 cpm Max Scan 4,725 cpm 5,389 cpm 5,070 cpm Notes

1) 9 of 14 samples in west section 1) 9 of 16 samples in west section 1) 3 additional judgmental ISOCS of survey unit were relocated as of survey unit were relocated as measurement locations were area was deemed as area was deemed as added to account for additional inaccessible. inaccessible. area.

2) Additional ISOCS measurement 2) 1 additional ISOCS

(#14) was taken on discovered measurement added for debris pile. discovered abandoned drain pipe.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-27 Non-Impacted Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10302 10303 10304 Surface Area 64,739.50 m2 68,847.10 m2 34,009.70 m2 Description Northwest Corner of FSAR Area Southwest Corner of FSAR Area Southern Area of FSAR Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 11 11 25 25 5 5

1. >MDC 0 9 0 13 0 3 Mean <0.05 pCi/g 0.30 pCi/g <0.06 pCi/g 0.17 pCi/g <0.05 pCi/g 0.26 pCi/g Median <0.06 pCi/g 0.27 pCi/g <0.06 pCi/g 0.15 pCi/g <0.06 pCi/g 0.23 pCi/g Max <0.08 pCi/g 0.46 pCi/g <0.10 pCi/g 0.39 pCi/g <0.07 pCi/g 0.35 pCi/g Min <0.02 pCi/g 0.12 pCi/g <0.02 pCi/g 0.06 pCi/g <0.02 pCi/g 0.21 pCi/g Standard Deviation N/A 0.11 N/A 0.10 N/A 0.08 ISOCS Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 19 19 18 18 17 17

1. >MDC 0 7 0 9 0 8 Mean <0.05 pCi/g 0.25 pCi/g <0.05 pCi/g 0.21 pCi/g <0.04 pCi/g 0.17 pCi/g Median <0.05 pCi/g 0.22 pCi/g <0.05 pCi/g 0.23 pCi/g <0.04 pCi/g 0.16 pCi/g Max <0.06 pCi/g 0.34 pCi/g <0.06 pCi/g 0.30 pCi/g <0.05 pCi/g 0.27 pCi/g Min <0.04 pCi/g 0.20 pCi/g <0.03 pCi/g 0.09 pCi/g <0.02 pCi/g 0.09 pCi/g Standard Deviation N/A 0.06 N/A 0.07 N/A 0.06 Surface Scans

% Scanned 1% 1% 1%

1. of Alarms 0 7 4 Mean Scan 4,951 cpm 5,858 cpm 4,456 cpm Max Scan 7,474 cpm 9,550 cpm 5,704 cpm Notes

1) 33 designed locations reduced to 1) 35 designed locations reduced to 1) 16 of 17 random locations 22 due to accessibility. 18 due to accessibility. relocated due to accessibility.

2) 3 of 22 locations scanned with 2) 5 of 18 locations scanned with NaI & soil sample only. NaI & soil sample only.

3) 6 of 18 ISOCS taken at height of 3) 17 additional random and 3 1 meter due to obstructions - additional judgmental soil FOV = 3 m2. samples taken.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-27 Non-Impacted Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10305 10306 10402 Surface Area 121,535.20 m2 85,267.80 m2 133,565.00 m2 Area West of Survey Unit Description Area West of Survey Unit #10217 MET Tower Area

1. 10216 Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 17 17 4 4 41 41

1. >MDC 0 4 0 4 0 31 Mean <0.05 pCi/g 0.19 pCi/g <0.05 pCi/g 0.26 pCi/g <0.04 pCi/g 0.20 pCi/g Median <0.05 pCi/g 0.18 pCi/g <0.04 pCi/g 0.23 pCi/g <0.04 pCi/g 0.18 pCi/g Max <0.08 pCi/g 0.33 pCi/g <0.08 pCi/g 0.40 pCi/g <0.07 pCi/g 0.42 pCi/g Min <0.01 pCi/g 0.07 pCi/g <0.02 pCi/g 0.20 pCi/g <0.01 pCi/g 0.04 pCi/g Standard Deviation N/A 0.14 N/A 0.09 N/A 0.10 ISOCS Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 61 61 18 18 39 39

1. >MDC 0 10 0 14 0 5 Mean <0.04 pCi/g 0.19 pCi/g <0.04 pCi/g 0.17 pCi/g <0.05 pCi/g 0.10 pCi/g Median <0.04 pCi/g 0.20 pCi/g <0.04 pCi/g 0.17 pCi/g <0.05 pCi/g 0.11 pCi/g Max <0.06 pCi/g 0.30 pCi/g <0.06 pCi/g 0.27 pCi/g <0.08 pCi/g 0.12 pCi/g Min <0.03 pCi/g 0.08 pCi/g <0.01 pCi/g 0.08 pCi/g <0.03 pCi/g 0.07 pCi/g Standard Deviation N/A 0.06 N/A 0.05 N/A 0.02 Surface Scans

% Scanned 1% 1% 1%

1. of Alarms 9 0 0 Mean Scan 5,473 cpm 4,407 cpm 4,835 cpm Max Scan 7,343 cpm 5,337 cpm 5,543 cpm Notes

1) 43 designed ISOCS 1) 67 designed ISOCS measurement locations reduced measurement locations reduced to 18 due to accessibility. to 39 due to accessibility.

2) 4 of 18 locations scanned with 2) 30 additional random locations NaI & soil sample only. designated for NaI scanning and surface soil samples.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-27 Non-Impacted Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10403 10404 Surface Area 139,282.00 m2 118,735.00 m2 NW Corner of Owner Controlled Description Area North of West Training Property Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137

1. of Samples 18 18 30 30

1. >MDC 0 12 0 20 Mean <0.04 pCi/g 0.18 pCi/g <0.04 pCi/g 0.20 pCi/g Median <0.04 pCi/g 0.17 pCi/g <0.04 pCi/g 0.20 pCi/g Max <0.07 pCi/g 0.39 pCi/g <0.06 pCi/g 0.57 pCi/g Min <0.01 pCi/g 0.05 pCi/g <0.01 pCi/g 0.02 pCi/g Standard Deviation N/A 0.09 N/A 0.14 ISOCS Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 7 7 0 0

1. >MDC 0 3 0 0 Mean <0.04 pCi/g 0.19 pCi/g N/A pCi/g N/A pCi/g Median <0.04 pCi/g 0.19 pCi/g N/A pCi/g N/A pCi/g Max <0.05 pCi/g 0.23 pCi/g N/A pCi/g N/A pCi/g Min <0.03 pCi/g 0.14 pCi/g N/A pCi/g N/A pCi/g Standard Deviation N/A 0.04 N/A N/A Surface Scans

% Scanned <1% 1%

1. of Alarms 4 0 Mean Scan 3,959 cpm 3,391 cpm Max Scan 5,310 cpm 6,964 cpm Notes

1) Approximately 90% of area 1) 60 ISOCS locations were was inaccessible to the ISOCS. designed. Entire area was

2) 70 ISOCS measurements inaccessible to the ISOCS. To reduced to 7. compensate, additional scan and

3) 4.8% of accessible 13,928 m2 soil sample locations were of land area scanned. evenly distributed in areas that

4) 16 additional random locations were accessible. The total area designated for NaI scanning scanned equates to 1,200 m2, or and surface soil samples. approximately 1%.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-28 Recommended Judgmental Sample Population Size The following are the recommended judgmental sample population sizes for impacted survey units that will be subjected to FSS. The judgmental sample population should be taken in addition to any random-based sample population. These are recommended minimum sample population sizes.

Area Structure Land Classification 8 judgmental samples per 8 judgmental samples per Class 1 survey unit survey unit 30 judgmental samples per 30 judgmental samples per Class 2 survey unit survey unit 13 judgmental samples per 13 judgmental samples per Class 3 survey unit survey unit 2-139

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary Survey Unit 10201 10202 10203 Surface Area 6,028.20 m2 6,843.90 m2 9,997.80 m2 NE Corner Restricted Area -

Description IRSF/Fire Training Area East Training Area Lakeshore Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 17 17 17 17 20 20

1. >MDA 0 0 0 0 0 5 Mean <0.05 pCi/g <0.07 pCi/g <0.04 pCi/g <0.06 pCi/g <0.08 pCi/g 0.11 pCi/g Median <0.06 pCi/g <0.06 pCi/g <0.05 pCi/g <0.06 pCi/g <0.08 pCi/g 0.11 pCi/g Max <0.09 pCi/g <0.11 pCi/g <0.08 pCi/g <0.10 pCi/g <0.11 pCi/g 0.16 pCi/g Min <0.02 pCi/g <0.02 pCi/g <0.02 pCi/g <0.01 pCi/g <0.02 pCi/g 0.06 pCi/g Standard Deviation N/A N/A N/A N/A N/A 0.04 Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 2 2 2 2 2 2

1. >MDC 0 0 0 0 0 0 Mean <0.05 pCi/g <0.07 pCi/g <0.06 pCi/g <0.06 pCi/g <0.06 pCi/g <0.08 pCi/g Median <0.05 pCi/g <0.07 pCi/g <0.06 pCi/g <0.06 pCi/g <0.06 pCi/g <0.08 pCi/g Max <0.06 pCi/g <0.08 pCi/g <0.06 pCi/g <0.06 pCi/g <0.06 pCi/g <0.10 pCi/g Min <0.05 pCi/g <0.05 pCi/g <0.05 pCi/g <0.06 pCi/g <0.06 pCi/g <0.07 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Surface Scans

% Scanned 25% 27% 25%

1. of Alarms 0 0 4 Mean Scan 1,224 cpm 1,681 cpm 2,977 cpm Max Scan 1,967 cpm 2,379 cpm 8,706 cpm Notes

1) 13 judgmental locations. 1) 13 judgmental locations. 1) 13 judgmental and 2

2) Subsurface soil samples taken 2) Subsurface soil samples taken to investigative locations.

to 1-meter. 1-meter. 2) Subsurface soil samples taken to 1-meter.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10204 10205 10206 Surface Area 7,228.10 m2 54,573.00 m2 10,529.10 m2 Description North Gate Area Switchyard Station Construction Area Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 18 18 32 32 19 19

1. >MDC 0 1 0 0 0 0 Mean <0.07 pCi/g 0.11 pCi/g <0.05 pCi/g <0.07 pCi/g <0.04 pCi/g <0.05 pCi/g Median <0.05 pCi/g 0.11 pCi/g <0.05 pCi/g <0.07 pCi/g <0.05 pCi/g <0.05 pCi/g Max <0.46 pCi/g 0.11 pCi/g <0.08 pCi/g <0.09 pCi/g <0.12 pCi/g <0.08 pCi/g Min <0.02 pCi/g 0.11 pCi/g <0.05 pCi/g <0.05 pCi/g <0.02 pCi/g <0.01 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 2 2 0 0 2 2

1. >MDC 0 0 0 0 0 0 Mean <0.05 pCi/g <0.08 pCi/g N/A pCi/g N/A pCi/g <0.05 pCi/g <0.05 pCi/g Median <0.05 pCi/g <0.08 pCi/g N/A pCi/g N/A pCi/g <0.05 pCi/g <0.05 pCi/g Max <0.06 pCi/g <0.11 pCi/g N/A pCi/g N/A pCi/g <0.06 pCi/g <0.05 pCi/g Min <0.05 pCi/g <0.06 pCi/g N/A pCi/g N/A pCi/g <0.05 pCi/g <0.05 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Surface Scans

% Scanned 26% 10% 27%

1. of Alarms 2 1 2 Mean Scan 2,071 cpm 2,594 cpm 3,386 cpm Max Scan 5,437 cpm 6,246 cpm 7,406 cpm Notes

1) All samples were dried prior to 1) Initial survey design called for 1) All samples were dried prior to analysis. 25% scan coverage. Scan analysis.

2) Subsurface soil samples taken suspended at 10% due to safety 2) Subsurface soil samples taken to 1-meter. concerns. to 1-meter.

2) Additional surface samples taken to compensate for loss of scan coverage.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10207 10208 10209 Surface Area 10,273.80 m2 11,821.00 m2 5,970.80 m2 Protected Area South of Gate Description North Warehouse Area South Warehouse Area House Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 19 19 33 33 13 13

1. >MDA 0 0 0 0 0 1 Mean <0.05 pCi/g <0.07 pCi/g <0.04 pCi/g <0.05 pCi/g <0.05 pCi/g 0.12 pCi/g Median <0.05 pCi/g <0.07 pCi/g <0.04 pCi/g <0.05 pCi/g <0.05 pCi/g 0.12 pCi/g Max <0.09 pCi/g <0.12 pCi/g <0.06 pCi/g <0.08 pCi/g <0.11 pCi/g 0.12 pCi/g Min <0.02 pCi/g <0.02 pCi/g <0.01 pCi/g <0.01 pCi/g <0.03 pCi/g 0.12 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 2 2 3 3 2 2

1. >MDC 0 0 0 0 0 0 Mean <0.06 pCi/g <0.06 pCi/g <0.06 pCi/g <0.08 pCi/g <0.07 pCi/g <0.07 pCi/g Median <0.06 pCi/g <0.06 pCi/g <0.06 pCi/g <0.09 pCi/g <0.07 pCi/g <0.07 pCi/g Max <0.07 pCi/g <0.07 pCi/g <0.07 pCi/g <0.10 pCi/g <0.09 pCi/g <0.08 pCi/g Min <0.05 pCi/g <0.06 pCi/g <0.06 pCi/g <0.04 pCi/g <0.06 pCi/g <0.07 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Surface Scans

% Scanned 29% 34% 26%

1. of Alarms 6 10 2 Mean Scan 5,688 cpm 3,274 cpm 2,281 cpm Max Scan 12,193 cpm 6,464 cpm 3,006 cpm Notes

1) All samples were dried prior to 1) 8 judgmental and 3 1) 5 judgmental and 2 analysis. investigative locations. investigative locations.

2) Subsurface soil samples taken 2) Subsurface soil samples taken 2) Subsurface soil samples taken to 1-meter. to 1-meter. to 1-meter.

3) Elevated scan readings due to the presence of packaged radioactive material in vicinity during scan performance.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10210 10211 10212A Surface Area 5,593.90 m2 3,198.30 m2 12,225.70 m2 Protected Area South of Turbine SE Corner Protected Area - North Protected Area Fence -

Description Building Lakeshore Lakeshore Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 17 17 16 16 32 32

1. >MDC 0 0 0 1 0 6 Mean <0.04 pCi/g <0.05 pCi/g <0.04 pCi/g 0.02 pCi/g <0.04 pCi/g 0.11 pCi/g Median <0.04 pCi/g <0.05 pCi/g <0.04 pCi/g 0.02 pCi/g <0.04 pCi/g 0.10 pCi/g Max <0.05 pCi/g <0.07 pCi/g <0.06 pCi/g 0.02 pCi/g <0.10 pCi/g 0.14 pCi/g Min <0.01 pCi/g <0.02 pCi/g <0.01 pCi/g 0.02 pCi/g <0.01 pCi/g 0.09 pCi/g Standard Deviation N/A N/A N/A N/A N/A 0.02 Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 3 3 2 2 32 32

1. >MDC 0 0 0 0 0 1 Mean <0.07 pCi/g <0.08 pCi/g <0.04 pCi/g <0.08 pCi/g <0.04 pCi/g 0.08 pCi/g Median <0.07 pCi/g <0.08 pCi/g <0.04 pCi/g <0.08 pCi/g <0.04 pCi/g 0.08 pCi/g Max <0.08 pCi/g <0.09 pCi/g <0.05 pCi/g <0.09 pCi/g <0.06 pCi/g 0.08 pCi/g Min <0.06 pCi/g <0.07 pCi/g <0.02 pCi/g <0.07 pCi/g <0.01 pCi/g 0.08 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Surface Scans

% Scanned 26% 30% 25%

1. of Alarms 40 0 9 Mean Scan 2,686 cpm 2,619 cpm 5,363 cpm Max Scan 4,585 cpm 3,327 cpm 9,014 cpm Notes

1) High number of scan alarms 1) 13 judgmental and 1 1) 5 judgmental and 5 due to improper set-point -area investigative locations. investigative locations.

rescanned with no alarms. 2) Subsurface soil samples taken 2) Subsurface soil samples taken

2) 13 judgmental and 1 to 1-meter. to 1-meter.

investigation sample location. 3) All judgmental samples

3) All subsurface samples taken analyzed for H-3, no activity to 1-meter depth, sample #01 - detected greater than MDA.

taken to 2-meter depth.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10213A 10214 10218A Surface Area 12,255.30 m2 33,551.40 m2 11,559.00 m2 Description Power House Area Construction Parking Lot ISFSI Area East Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 24 24 31 31 32 32

1. >MDA 0 6 0 4 0 11 Mean <0.05 pCi/g 0.17 pCi/g <0.04 pCi/g 0.09 pCi/g <0.04 pCi/g 0.06 pCi/g Median <0.05 pCi/g 0.10 pCi/g <0.04 pCi/g 0.10 pCi/g <0.04 pCi/g 0.05 pCi/g Max <0.08 pCi/g 0.29 pCi/g <0.09 pCi/g 0.11 pCi/g <0.08 pCi/g 0.12 pCi/g Min <0.01 pCi/g 0.09 pCi/g <0.01 pCi/g 0.07 pCi/g <0.02 pCi/g 0.03 pCi/g Standard Deviation N/A 0.08 N/A 0.02 N/A 0.03 Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 24 24 3 3 31 31

1. >MDC 0 2 0 0 0 9 Mean <0.04 pCi/g 0.07 pCi/g <0.05 pCi/g <0.04 pCi/g <0.04 pCi/g 0.05 pCi/g Median <0.04 pCi/g 0.07 pCi/g <0.04 pCi/g <0.04 pCi/g <0.04 pCi/g 0.05 pCi/g Max <0.06 pCi/g 0.08 pCi/g <0.09 pCi/g <0.04 pCi/g <0.07 pCi/g 0.08 pCi/g Min <0.01 pCi/g 0.07 pCi/g <0.03 pCi/g <0.04 pCi/g <0.02 pCi/g 0.03 pCi/g Standard Deviation N/A 0.01 N/A N/A N/A 0.02 Surface Scans

% Scanned 25% 10% 50%

1. of Alarms 3 2 29 Mean Scan 5,459 cpm 2,145 cpm 4,315 cpm Max Scan 9,798 cpm 3,798 cpm 7,440 cpm Notes

1) Subsurface soil samples taken 1) Subsurface soil samples taken 1) Area survey by ESCSG as to 1-meter. to 1-meter. stand-alone survey.

2) Scan alarms due to bkgd from adjacent radioactive material, area rescanned - no alarms.

3) Several samples analyzed for H-3, Fe-55, Ni-63 and Sr-90, no positive results > MDC.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10218B 10218F 10219A Surface Area 11,559.00 m2 3,151.70 m2 2,433.20 m2 Area Far South of Switchyard Description ISFSI Area East Area Near South of Switchyard (Part A)

Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 30 30 4 4 25 25

1. >MDA 0 16 0 0 0 4 Mean <0.05 pCi/g 0.08 pCi/g <0.04 pCi/g <0.06 pCi/g <0.06 pCi/g 0.19 pCi/g Median <0.04 pCi/g 0.07 pCi/g <0.04 pCi/g <0.06 pCi/g <0.05 pCi/g 0.15 pCi/g Max <0.08 pCi/g 0.31 pCi/g <0.04 pCi/g <0.09 pCi/g <0.12 pCi/g 0.34 pCi/g Min <0.02 pCi/g 0.03 pCi/g <0.03 pCi/g <0.04 pCi/g <0.01 pCi/g 0.11 pCi/g Standard Deviation N/A 0.07 N/A N/A N/A 0.11 Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 31 31 0 0 25 25

1. >MDC 0 10 0 0 0 2 Mean <0.04 pCi/g 0.05 pCi/g N/A pCi/g N/A pCi/g <0.05 pCi/g 0.14 pCi/g Median <0.04 pCi/g 0.05 pCi/g N/A pCi/g N/A pCi/g <0.05 pCi/g 0.14 pCi/g Max <0.08 pCi/g 0.08 pCi/g N/A pCi/g N/A pCi/g <0.08 pCi/g 0.15 pCi/g Min <0.03 pCi/g 0.01 pCi/g N/A pCi/g N/A pCi/g <0.01 pCi/g 0.13 pCi/g Standard Deviation N/A 0.03 N/A N/A N/A 0.02 Surface Scans

% Scanned 50% 13% 50%

1. of Alarms 21 0 27 Mean Scan 4,883 cpm 1,507 cpm 6,468 cpm Max Scan 6,897 cpm 1,964 cpm 7,671 cpm Notes

1) Area survey by ESCSG as 1) Majority of surface area in 1) High number of scan alarms stand-alone survey. survey unit occupied by ISFSI due to improper adjustment of

2) Scan alarms due to increase in warehouse. set-point -readjusted and area ambient bkgd from adjacent rescanned with no alarms.

radioactive material, area 2) Subsurface soil samples taken rescanned - no alarms. to 1-meter.

3) Several samples analyzed for 3) Surface & subsurface biased H-3, Fe-55, Ni-63 and Sr-90, samples analyzed for H-3, no no positive results > MDC. activity detected > MDC.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10219B 10220A 10220B Surface Area 7,515.70 m2 8,192.00 m2 8,271.20 m2 Area Far South of Switchyard SE Corner of Exclusion Area - SE Corner of Exclusion Area -

Description (Part B) Lake Shore Inland Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 25 25 28 28 31 31

1. >MDA 0 15 1 4 0 4 Mean <0.05 pCi/g 0.24 pCi/g 0.13 pCi/g 0.15 pCi/g <0.05 pCi/g 0.15 pCi/g Median <0.06 pCi/g 0.25 pCi/g 0.13 pCi/g 0.14 pCi/g <0.05 pCi/g 0.12 pCi/g Max <0.09 pCi/g 0.41 pCi/g 0.13 pCi/g 0.24 pCi/g <0.12 pCi/g 0.27 pCi/g Min <0.01 pCi/g 0.09 pCi/g 0.13 pCi/g 0.06 pCi/g <0.01 pCi/g 0.08 pCi/g Standard Deviation N/A 0.09 N/A 0.08 N/A 0.09 Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 0 0 28 28 31 31

1. >MDA 0 0 0 1 0 2 Mean N/A pCi/g N/A pCi/g <0.04 pCi/g 0.11 pCi/g <0.05 pCi/g 0.12 pCi/g Median N/A pCi/g N/A pCi/g <0.04 pCi/g 0.11 pCi/g <0.04 pCi/g 0.12 pCi/g Max N/A pCi/g N/A pCi/g <0.07 pCi/g 0.11 pCi/g <0.09 pCi/g 0.12 pCi/g Min N/A pCi/g N/A pCi/g <0.01 pCi/g 0.11 pCi/g <0.01 pCi/g 0.11 pCi/g Standard Deviation N/A N/A N/A N/A N/A 0.01 Surface Scans

% Scanned 11% 50% 50%

1. of Alarms 3 2 18 Mean Scan 4,926 cpm 6,766 cpm 5,089 cpm Max Scan 6,355 cpm 9,830 cpm 10,221 cpm Notes

1) No subsurface soil samples 1) Subsurface soil samples taken 1) Subsurface soil samples taken taken in this survey unit. to 1-meter. to 1-meter.

2) 21 random and 4 investigation 2) Investigation samples taken in 2) Investigation samples analyzed surface soil samples taken. wet-land area. for H-3, no activity detected

3) Investigation samples analyzed >MDC.

for H-3, no activity detected 3) Sample location #12 not greater than MDC. sampled due to safety concerns.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10220C 10221A 10221B Surface Area 25,560.00 m2 6,273.60 m2 6,374.00 m2 SE Corner of Exclusion Area - South of Protected Area -

Description South of Protected Area - Inland Inland Lakeshore Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 55 55 30 30 26 26

1. >MDC 0 41 0 3 0 2 Mean <0.05 pCi/g 0.33 pCi/g <0.04 pCi/g 0.16 pCi/g <0.04 pCi/g 0.06 pCi/g Median <0.05 pCi/g 0.26 pCi/g <0.04 pCi/g 0.13 pCi/g <0.05 pCi/g 0.06 pCi/g Max <0.18 pCi/g 1.14 pCi/g <0.08 pCi/g 0.23 pCi/g <0.07 pCi/g 0.07 pCi/g Min <0.01 pCi/g 0.09 pCi/g <0.01 pCi/g 0.12 pCi/g <0.01 pCi/g 0.05 pCi/g Standard Deviation N/A 0.25 N/A 0.06 N/A 0.01 Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 0 0 30 30 3 3

1. >MDC 0 0 0 1 0 0 Mean N/A pCi/g N/A pCi/g <0.03 pCi/g 0.04 pCi/g <0.04 pCi/g <0.07 pCi/g Median N/A pCi/g N/A pCi/g <0.04 pCi/g 0.04 pCi/g <0.02 pCi/g <0.07 pCi/g Max N/A pCi/g N/A pCi/g <0.05 pCi/g 0.04 pCi/g <0.08 pCi/g <0.09 pCi/g Min N/A pCi/g N/A pCi/g <0.01 pCi/g 0.04 pCi/g <0.02 pCi/g <0.05 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Surface Scans

% Scanned 14% 50% 26%

1. of Alarms 9 0 2 Mean Scan 6,037 cpm 5,053 cpm 3,053 cpm Max Scan 8,418 cpm 9,970 cpm 6,464 cpm Notes

1) Extensive investigation of Bull 1) Portion of survey unit 1) Portion of survey unit surveyed Creek, where elevated Cs-137 surveyed by ESCSG as part of by ESCSG as part of rail soil sample was located. rail spur survey. spur survey.

2) Investigation concluded that 2) Subsurface soil samples taken 2) Subsurface soil samples taken elevated Cs-137 due to to 1-meter. to 1-meter.

concentration of global fallout. 3) Subsurface sample #12 labeled

3) Investigation samples 10 thru as QC sample when actually 20 taken outside of survey unit. taken as random sample.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10222 10223 10224 Surface Area 21,777.80 m2 12,371.40 m2 14,607.70 m2 Description North Beach Area Power Block Beach Area South Beach Area Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 30 30 20 20 22 22

1. >MDC 0 0 0 0 0 0 Mean <0.05 pCi/g <0.06 pCi/g <0.06 pCi/g <0.06 pCi/g <0.04 pCi/g <0.07 pCi/g Median <0.05 pCi/g <0.06 pCi/g <0.06 pCi/g <0.06 pCi/g <0.05 pCi/g <0.07 pCi/g Max <0.08 pCi/g <0.09 pCi/g <0.07 pCi/g <0.08 pCi/g <0.07 pCi/g <0.08 pCi/g Min <0.02 pCi/g <0.03 pCi/g <0.02 pCi/g <0.02 pCi/g <0.02 pCi/g <0.04 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 45 45 21 21 24 24

1. >MDC 0 0 0 0 0 1 Mean <0.04 pCi/g <0.05 pCi/g <0.04 pCi/g <0.05 pCi/g <0.04 pCi/g 0.03 pCi/g Median <0.04 pCi/g <0.05 pCi/g <0.04 pCi/g <0.05 pCi/g <0.04 pCi/g 0.03 pCi/g Max <0.06 pCi/g <0.07 pCi/g <0.06 pCi/g <0.08 pCi/g <0.07 pCi/g 0.03 pCi/g Min <0.01 pCi/g <0.03 pCi/g <0.02 pCi/g <0.03 pCi/g <0.01 pCi/g 0.03 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Surface Scans

% Scanned 56% 50% 52%

1. of Alarms 102 0 0 Mean Scan 2,139 cpm 1,788 cpm 2,744 cpm Max Scan 4,316 cpm 2,277 cpm 3,400 cpm Notes

1) Black Beauty sand-blasting 1) Subsurface soil samples taken 1) Subsurface soil samples taken sand cause of elevated scans to 3-meters. to 3-meters.

alarms investigation soil samples taken.

2) Analysis of investigation samples indicate natural U & Th

3) Subsurface soil samples taken to 3-meters.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-29 Impacted Class 3 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10301 VCC Surface Area 55,941.60 m2 15,364.00 m2 Vertical Concrete Cask Description West Training Area Construction Area Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137

1. of Samples 22 22 30 30

1. >MDA 0 11 0 7 Mean <0.05 pCi/g 0.17 pCi/g <0.04 pCi/g 0.04 pCi/g Median <0.06 pCi/g 0.14 pCi/g <0.04 pCi/g 0.04 pCi/g Max <0.08 pCi/g 0.39 pCi/g <0.08 pCi/g 0.08 pCi/g Min <0.02 pCi/g 0.06 pCi/g <0.03 pCi/g 0.03 pCi/g Standard Deviation N/A 0.12 N/A 0.02 Subsurface Soil Samples ISOCS Cs-137 Co-60 Cs-137

1. of Measurements 46 30 30

1. >MDC 7 0 3 Mean 0.18 pCi/g <0.05 pCi/g 0.04 pCi/g Median 0.19 pCi/g <0.04 pCi/g 0.03 pCi/g Max 0.25 pCi/g <0.10 pCi/g 0.06 pCi/g Min 0.11 pCi/g <0.02 pCi/g 0.03 pCi/g Standard Deviation 0.05 N/A 0.02 Surface Scans

% Scanned 14% 20%

1. of Alarms 23 0 Mean Scan 5,433 cpm 5,192 cpm Max Scan 9,499 cpm 9,240 cpm Notes

1) No subsurface soil samples 1) Area survey by ESCSG as taken in this survey unit. stand-alone survey -

2) 46 ISOCS measurements documented in separate report.

acquired. 2) Subsurface soil samples taken to 1-meter.

3) Following survey, area was paved for use as VCC Construction Area.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-30 Impacted Class 2 Open Land Survey Units - Characterization Survey Summary Survey Unit 12201 12202 12203 Surface Area 9,610.40 m2 7,573.90 m2 7,568.70 m2 Under Service Building and Description North Restricted Area Yard Gate House and Southwest Yard South East Yard Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 15 15 16 16 15 15

1. >MDC 0 2 0 1 0 3 Mean <0.06 pCi/g 0.15 pCi/g <0.06 pCi/g 0.12 pCi/g <0.06 pCi/g 0.15 pCi/g Median <0.07 pCi/g 0.15 pCi/g <0.06 pCi/g 0.12 pCi/g <0.06 pCi/g 0.18 pCi/g Max <0.10 pCi/g 0.17 pCi/g <0.09 pCi/g 0.12 pCi/g <0.10 pCi/g 0.18 pCi/g Min <0.02 pCi/g 0.12 pCi/g <0.02 pCi/g 0.12 pCi/g <0.02 pCi/g 0.08 pCi/g Standard Deviation N/A 0.04 N/A N/A N/A 0.06 Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 9 9 9 9 6 6

1. >MDC 0 0 0 0 0 1 Mean <0.06 pCi/g <0.06 pCi/g <0.06 pCi/g <0.08 pCi/g <0.04 pCi/g 0.15 pCi/g Median <0.06 pCi/g <0.06 pCi/g <0.06 pCi/g <0.07 pCi/g <0.04 pCi/g 0.15 pCi/g Max <0.07 pCi/g <0.07 pCi/g <0.10 pCi/g <0.14 pCi/g <0.08 pCi/g 0.15 pCi/g Min <0.02 pCi/g <0.05 pCi/g <0.02 pCi/g <0.05 pCi/g <0.02 pCi/g 0.15 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Surface Scans

% Scanned 66% 26% 45%

1. of Alarms 4 12 1 Mean Scan 2,132 cpm 4,805 cpm 2,541 cpm Max Scan 3,611 cpm 11,264 cpm 5,677 cpm Notes

1) Subsurface soil samples taken 1) Subsurface soil samples taken 1) Subsurface soil samples taken to 3-meters. to 3-meters. to 3-meters.

2) Elevated scans from RAM & 2) ~50% of surface area either systems in vicinity. obstructed or covered.

3) Sample #11 labeled as QC when actually random sample.

4) Scans performed under 2 sample plans.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-30 Impacted Class 2 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 10204 Surface Area 5,908.70 m2 Description Crib House Area Surface Soil Samples Co-60 Cs-137

1. of Samples 13 13

1. >MDC 0 6 Mean <0.08 pCi/g 0.15 pCi/g Median <0.08 pCi/g 0.14 pCi/g Max <0.10 pCi/g 0.21 pCi/g Min <0.07 pCi/g 0.12 pCi/g Standard Deviation N/A 0.04 Subsurface Soil Samples Co-60 Cs-137

1. of Measurements 36 36

1. >MDC 0 2 Mean <0.05 pCi/g 0.08 pCi/g Median <0.05 pCi/g 0.08 pCi/g Max <0.09 pCi/g 0.12 pCi/g Min <0.01 pCi/g 0.04 pCi/g Standard Deviation N/A 0.06 Surface Scans

% Scanned 30%

1. of Alarms 102 Mean Scan 2,569 cpm Max Scan 6,203 cpm Notes

1) Subsurface soil samples taken to 3-meters.

2) Elevated scans from RAM &

contaminated systems in vicinity.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-31 Impacted Class 1 Open Land Survey Units - Characterization Survey Summary Survey Unit 12101 12102 12103 Surface Area 2,035.70 m2 2,024.50 m2 2,033.60 m2 Description WWTF Sludge Drying Bed Area WWTF Facility Unit 2 PWST/SST Area Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 13 13 13 13 13 13

1. >MDC 0 2 0 4 0 2 Mean <0.05 pCi/g 0.19 pCi/g <0.04 pCi/g 0.32 pCi/g <0.06 pCi/g 0.39 pCi/g Median <0.06 pCi/g 0.19 pCi/g <0.05 pCi/g 0.25 pCi/g <0.07 pCi/g 0.39 pCi/g Max <0.09 pCi/g 0.21 pCi/g <0.06 pCi/g 0.70 pCi/g <0.09 pCi/g 0.46 pCi/g Min <0.02 pCi/g 0.17 pCi/g <0.02 pCi/g 0.09 pCi/g <0.03 pCi/g 0.33 pCi/g Standard Deviation N/A 0.03 N/A 0.28 N/A 0.09 Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 38 38 38 38 39 39

1. >MDC 0 1 0 0 1 0 Mean <0.06 pCi/g 0.08 pCi/g <0.06 pCi/g <0.08 pCi/g 0.10 pCi/g <0.06 pCi/g Median <0.06 pCi/g 0.08 pCi/g <0.06 pCi/g <0.08 pCi/g 0.10 pCi/g <0.06 pCi/g Max <0.13 pCi/g 0.08 pCi/g <0.10 pCi/g <0.16 pCi/g 0.10 pCi/g <0.09 pCi/g Min <0.02 pCi/g 0.08 pCi/g <0.02 pCi/g <0.04 pCi/g 0.10 pCi/g <0.03 pCi/g Standard Deviation N/A N/A N/A N/A N/A N/A Surface Scans

% Scanned 100% 100% 100%

1. of Alarms 27 83 232 Mean Scan 3,293 cpm 2,767 cpm 3,320 cpm Max Scan 35,962 cpm 10,759 cpm 30,660 cpm Notes

1) Subsurface soil samples taken 1) Subsurface soil samples taken 1) Subsurface soil samples taken to 3-meters. to 3-meters. to 3-meters.

2) Elevated scans from RAM & 2) Elevated scans from RAM & 2) Elevated scans from RAM &

contaminated systems in contaminated systems in contaminated systems in vicinity. vicinity. vicinity.

3) No HTD analysis performed. 3) Surface soil sample #s 5, 7 & 8 3) Surface soil sample #s 12 & 13 sent to Eberline for HTD and subsurface sample # 8 sent analysis. to Eberline for HTD analysis.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-31 Impacted Class 1 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 12104 12109 12110 Surface Area 1940.3 m2 1930.5 m2 1739.7 m2 Area Under and North of Unit 2 Area Under and South of Unit 1 Description Yard Between U1 CTMT and TB CTMT CTMT Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 1 1 16 16 13 13

1. >MDC 0 0 14 16 0 6 Mean <0.10 pCi/g <0.05 pCi/g 0.13 pCi/g 0.18 pCi/g <0.05 pCi/g 0.12 pCi/g Median <0.10 pCi/g <0.05 pCi/g 0.06 pCi/g 0.14 pCi/g <0.05 pCi/g 0.11 pCi/g Max <0.10 pCi/g <0.05 pCi/g 1.04 pCi/g 0.59 pCi/g <0.08 pCi/g 0.27 pCi/g Min <0.10 pCi/g <0.05 pCi/g 0.02 pCi/g 0.05 pCi/g <0.03 pCi/g 0.03 pCi/g Standard Deviation N/A N/A 0.26 0.13 N/A 0.08 Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 9 9 15 15 24 24

1. >MDC 0 0 0 1 0 2 Mean <0.06 pCi/g <0.07 pCi/g <0.05 pCi/g 0.08 pCi/g <0.07 pCi/g 0.27 pCi/g Median <0.06 pCi/g <0.07 pCi/g <0.05 pCi/g 0.08 pCi/g <0.07 pCi/g 0.27 pCi/g Max <0.10 pCi/g <0.09 pCi/g <0.08 pCi/g 0.08 pCi/g <0.09 pCi/g 0.30 pCi/g Min <0.02 pCi/g <0.05 pCi/g <0.03 pCi/g 0.08 pCi/g <0.03 pCi/g 0.24 pCi/g Standard Deviation N/A N/A N/A N/A N/A 0.05 Surface Scans

% Scanned On date, April 16, 2013, survey unit was not Survey unit was not scanned. On date, April Survey unit was not scanned. On date, April scanned due to prohibitive background from 14, 2013, area posted as "Radiation Area" 25, 2013, area posted as "Radiation Area"

1. of Alarms adjacent systems and stored RAM. Soil for loading RAM on rail cars. Radiation for loading RAM on rail cars. Radiation Mean Scan sample locations were biased based upon area will remain until commodity removal is area will remain until commodity removal is Max Scan visual cues & opportune accessibility complete. Soil sample locations were biased complete. Soil sample locations were biased based upon visual cues & accessibility. based upon visual cues & accessibility.

Notes

1) Subsurface soil samples taken 1) Subsurface soil samples taken 1) Subsurface soil samples taken to 3-meters. to 3-meters. to 3-meters.

2) No surface soil samples were 2) No surface soil samples were 2) SB sample #5 - no soil, SB taken at locations 2 and 3 as taken at locations 1 thru 4 as sample #7 limited to 1-meter surface was covered with surface was covered with and SB sample #4 limited to 2-concrete. concrete. meter due to refusal.

3) SS #5 sent to Eberline for HTD 3) No samples collected at 11, 12 analysis. & 13 due to potential ACM.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-31 Impacted Class 1 Open Land Survey Units - Characterization Survey Summary (continued)

Survey Unit 12111 12112 12113 Surface Area 1964.3 1692.6 m2 1,657.60 m2 South Yard Area NE of Gate Description Unit 1 PWST/SST Area East Unit 1 PWST/SST Area West House Surface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Samples 13 13 14 14 15 15

1. >MDC 0 10 0 9 0 9 Mean <0.07 pCi/g 0.15 pCi/g <0.08 pCi/g 0.82 pCi/g <0.08 pCi/g 0.12 pCi/g Median <0.10 pCi/g 0.14 pCi/g <0.08 pCi/g 0.23 pCi/g <0.08 pCi/g 0.10 pCi/g Max <0.10 pCi/g 0.20 pCi/g <0.12 pCi/g 3.39 pCi/g <0.11 pCi/g 0.22 pCi/g Min <0.05 pCi/g 0.12 pCi/g <0.02 pCi/g 0.07 pCi/g <0.06 pCi/g 0.06 pCi/g Standard Deviation N/A 0.03 N/A 1.19 N/A 0.06 Subsurface Soil Samples Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

1. of Measurements 42 42 39 39 39 39

1. >MDC 0 1 0 2 0 0 Mean <0.05 pCi/g 0.04 pCi/g <0.05 pCi/g 0.45 pCi/g <0.07 pCi/g <0.07 pCi/g Median <0.05 pCi/g 0.04 pCi/g <0.05 pCi/g 0.45 pCi/g <0.07 pCi/g <0.07 pCi/g Max <0.08 pCi/g 0.04 pCi/g <0.07 pCi/g 0.70 pCi/g <0.10 pCi/g <0.12 pCi/g Min <0.03 pCi/g 0.04 pCi/g <0.02 pCi/g 0.19 pCi/g <0.03 pCi/g <0.04 pCi/g Standard Deviation N/A N/A N/A 0.36 N/A N/A Surface Scans

% Scanned Survey unit was not scanned. On date, April 100% 100%

1, 2013, area posted as "Radiation Area" for

1. of Alarms loading RAM on rail cars. Radiation area 98 106 Mean Scan will remain until commodity removal is 3,483 cpm 3,943 cpm Max Scan complete. Soil sample locations were biased 5,225 cpm 7,562 cpm based upon visual cues & accessibility.

Notes

1) Subsurface soil samples taken 1) Subsurface soil samples taken 1) Subsurface soil samples taken to to 3-meters. to 3-meters. 3-meters.

2) SS #s 11, 12 & 13 - asphalt. 2) Elevated scans from RAM & 2) Elevated scans from RAM &

3) SS #s 1, 3 7 4, additional contaminated systems in contaminated systems in 1-meter sample taken. vicinity. vicinity.

4) No SS samples collected at 13, 3) SS #s 1 & 2 - asphalt.

14 & 15 due to safety 4) SS #s 4 & 6 sent to Eberline concerns. for HTD analysis.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Table 2-32 Surface and Subsurface Soil Samples - Eberline Laboratory Analysis L1-12102- L1-12102- L1-12102- L1-12102- L1-12103- L1-12103- L1-12109- L1-12112- L1-12112- L1-12103-CJGSSS- CJGSSS- CJGSSS- CQGSSS- CJGSSS- CJGSSS- CJGS-050- CJGSSS- CJGSSS- CJGSSB-Radionuclide 0510 0710 0810 0810 1210 1310 SS 0410 0610 0821 (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g)

H-3 2.51E+00 2.73E+00 2.54E+00 2.48E+00 2.50E+00 2.51E+00 3.96E+00 3.56E+00 3.61E+00 2.69E+00 C-14 8.52E-01 8.10E-01 9.49E-01 8.76E-01 8.39E-01 8.51E-01 1.01E+00 1.07E+00 9.26E-01 9.56E-01 Fe-55 3.53E+00 3.19E+00 3.24E+00 3.47E+00 3.36E+00 3.06E+00 N/A 7.16E+00 6.34E+00 3.24E+00 Ni-59 7.28E+00 7.23E+00 6.65E+00 6.30E+00 7.40E+00 6.30E+00 N/A 6.12E+00 7.71E+00 5.69E+00 Co-60 4.82E-02 4.52E-02 3.00E-02 3.22E-02 4.29E-02 4.29E-02 2.43E-01 8.80E-02 1.22E-01 3.98E-02 Ni-63 6.22E-01 7.06E-01 6.24E-01 6.41E-01 6.21E-01 6.26E-01 1.77E+00 8.36E-01 7.95E-01 6.10E-01 Sr-90 2.90E-01 3.15E-01 2.35E-01 2.99E-01 2.67E-01 3.33E-01 4.70E-01 3.76E-01 3.59E-01 2.95E-01 Nb-94 3.35E-02 2.64E-02 2.21E-02 2.40E-02 2.92E-02 2.85E-02 5.35E-02 7.05E-02 7.16E-02 2.83E-02 Tc-99 4.03E-01 4.38E-01 4.20E-01 3.95E-01 4.43E-01 4.18E-01 2.61E-01 2.61E-01 2.62E-01 6.39E-01 Ag-108m 2.95E-02 3.05E-02 2.03E-02 2.21E-02 2.97E-02 2.91E-02 4.89E-02 7.14E-02 7.52E-02 2.62E-02 Sb-125 9.26E-02 8.40E-02 6.11E-02 6.35E-02 8.03E-02 8.44E-02 1.68E-01 2.19E-01 2.90E-01 7.13E-02 Cs-134 2.92E-02 2.91E-02 2.24E-02 2.41E-02 2.78E-02 2.85E-02 6.04E-02 7.72E-02 9.92E-02 2.72E-02 Cs-137 6.98E-01 3.85E-01 7.98E-02 8.86E-02 3.15E-01 4.57E-01 1.57E-01 2.30E+00 3.39E+00 3.31E-02 Pm-147 5.09E-01 5.06E-01 5.03E-01 5.04E-01 4.90E-01 5.00E-01 N/A 2.74E-01 2.63E-01 5.02E-01 Eu-152 1.84E-01 2.13E-01 1.61E-01 1.83E-01 1.67E-01 1.76E-01 1.60E-01 6.27E-01 4.74E-01 2.27E-01 Eu-154 1.16E-01 9.27E-02 7.38E-02 7.90E-02 8.26E-02 1.10E-01 8.00E-02 2.23E-01 2.66E-01 9.19E-02 Eu-155 7.42E-02 8.00E-02 6.40E-02 6.32E-02 7.11E-02 7.83E-02 1.43E-01 1.87E-01 2.12E-01 7.41E-02 Np-237 2.43E-02 2.42E-02 2.37E-02 3.22E-02 2.01E-02 2.35E-02 N/A 7.80E-02 7.14E-02 2.58E-02 Pu-238 5.78E-02 3.45E-02 3.33E-02 3.34E-02 3.83E-02 4.30E-02 9.30E-02 7.45E-02 3.95E-02 4.52E-02 Pu-239/240 6.53E-02 4.71E-02 3.33E-02 3.02E-02 3.83E-02 3.88E-02 6.25E-02 6.87E-02 4.49E-02 4.52E-02 Pu-241 8.31E+00 6.13E+00 5.20E+00 5.05E+00 6.56E+00 6.55E+00 N/A 4.89E-01 5.10E-01 7.84E+00 Am-241 6.19E-02 2.91E-02 4.90E-02 3.78E-02 3.57E-02 3.45E-02 4.61E-02 8.29E-02 5.50E-02 4.58E-02 Am-243 3.33E-02 3.90E-02 3.80E-02 4.10E-02 7.03E-02 4.30E-02 N/A 4.51E-02 5.67E-02 4.10E-02 Cm-243/244 5.74E-02 5.40E-02 2.80E-02 4.09E-02 3.44E-02 5.40E-02 N/A 1.22E-01 6.94E-02 3.80E-02 a Bold values indicate concentration greater than MDC. Italicized values indicate MDC value.

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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-1 Zion Nuclear Power Station Owner Controlled Area 2-156

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-2 Zion Nuclear Power Station Radiologically Restricted Area (RRA) 2-157

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-3 Zion Nuclear Power Station Security Restricted Area 2-158

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-4 Non-Impacted Open Land Survey Units 2-159

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-5 Class 3 Open Land Survey Units Outside of Radiologically-Restricted Area 2-160

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-6 Class 3 Open Land Survey Units Inside of Radiologically-Restricted Area 2-161

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-7 Class 1 and Class 2 Open Land Survey Units 2-162

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-8 Unit 1 Containment 568 foot el. Class 1 Survey Units 2-163

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-9 Unit 1 Containment 541 foot el. Class 1 Survey Units 2-164

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-10 Unit 2 Containment 568 foot el. Class 1 Survey Units 2-165

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-11 Unit 2 Containment 541 foot el. Class 1 Survey Units 2-166

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-12 Auxiliary Building 542 foot el. Class 1 Survey Units 2-167

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-13 Auxiliary Building 560 foot el. Class 1 Survey Units 2-168

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-14 Auxiliary Building 579 foot el. Class 1 Survey Units 2-169

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-15 Turbine Building 560 and 570 Foot Elevations Class 2 Survey Units 2-170

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 0 Figure 2-16 Crib House Suction Forebay Class 2 Survey Units 2-171

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-17 Independent Spent Fuel Storage Installation 2-172

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-18 Vertical Concrete Cask Construction Area 2-173

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-19 Energy Solutions Background Study Locations 2-174

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-20 Zion City Park Districts Hosah Park Background Study Location 2-175

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-21 Unit 1 Containment 568 foot el. Concrete Core Sample Locations 2-176

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-22 Unit 1 Containment 541 foot el. Concrete Core Sample Locations 2-177

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-23 Unit 2 Containment 568 foot el. Concrete Core Sample Locations 2-178

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-24 Unit 2 Containment 541 foot el. Concrete Core Sample Locations 2-179

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-25 Auxiliary Building 542 foot el. Concrete Core Sample Locations 2-180

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-26 Turbine Building 560 foot el. and Steam Tunnel 570 foot el. Concrete Core Sample Locations 2-181

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-27 Turbine Building 560 foot el. Floor Drain System Sediment Sample Locations 2-182

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-28 Non-Impacted Open Land Survey Units Measurement and Sample Locations 2-183

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-29 Class 3 Open Land Survey Units Located Outside of the Radiologically-Restricted AreaMeasurement and Sample Locations 2-184

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-30 Class 3 Open Land Survey Units Located Inside of the Radiologically-Restricted Area Measurement and Sample Locations 2-185

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-31 Class 2 Open Land Survey Units Measurement and Sample Locations 2-186

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-32 Class 1 Open Land Survey Units Measurement and Sample Locations 2-187

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 Figure 2-33 ZNPS Locations of Outfalls, Groundwater Monitoring Wells and Surface Water Sampling Locations 2-188