ML040070459

Boiling Water Reactor - Annual Decommissioning Plan Revision

ML040070459
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	12/16/2003
From:	Berg W Dairyland Power Cooperative
To:	Document Control Desk, NRC/FSME
References
-RFPFR, LAC-13823
Download: ML040070459 (55)

Text

/g PAIRYLAND 7

tZ/ /Z[Z§/jiE / 7 'cOoPERATIvE

• 3200 EAST AVE. SO.

• P.O. BOX 817

• LA CROSSE, WISCONSIN 54602-0817 OFFICE (608) 787-1258 WILLIAM L. BERG FAX (608) 787-1469 President and CEO WEB SITE: www.dairynet.com December 16, 2003 In reply, please refer to LAC-13823 DOCKET NO. 50-409 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Dairyland Power Cooperative La Crosse Boiling Water Reactor (LACBWR)

Possession-Only License DPR-45 Annual Decommissioning Plan Revision

REFERENCES:

(1) DPC Letter, Taylor to Document Control Desk, LAC-12460, dated December 21, 1987 (original submittal of LACBWR's Decommissioning Plan)

(2) NRC Letter, Erickson to Berg, dated August 7, 1991, issuing Order to Authorize Decommissioning of LACBWR (3) NRC Letter, Brown to Berg, dated September 15, 1994, modifying Decommissioning Order The annual update of the LACBWR Decommissioning Plan has been completed, and the pages with changes and their explanations are included with this letter. Each page with a change will have a bar in the right-hand margin to designate the location of the change. None of the changes was determined to require prior NRC approval, and they have been reviewed by both onsite and offsite review committees.

The individual pages requiring revision are attached to this letter. Please substitute these revised pages in your copy(ies) of the LACBWR Decommissioning Plan. Reasons for the changes are listed on a separate attachment.

If you have any questions concerning any of these changes, please contact Jeff Mc Rill of my staff at 608-689-4202.

Sincerely, DAIRYLAND POWER COOPERATIVE (Jdht441.~ 4 IL William L. Berg, PresidAt & CEO WLB:JBM:dh Attachments jjrnSl 53)(t cc: William Huffman NRC Project Mgr. A Touchstone Energy- Partner 1t

i7 DAIRYLAND NRC Docket No. 50-409 lZ/gtZ¶G7 1fL 7 COoPERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR)

• 4601 STATE ROAD 35 GENOA, WISCONSIN 54632-8846 * (608) 689-2331 TO: A)¶PC iA)0-sk CONTROLLED DISTRIBUTION NO. 3 FROM: LACBWR Plant Manager 12/31/2003

SUBJECT:

Changes to LACBWR Controlling Documents I. The following documents have been revised:

DECOMMISSIONING PLAN, revised November 2003 Remove and replace the following pages:

Title Page 0-2 (Table of Contents) 1-2 3-5 5-4, 5-7, 5-10, 5-13, 5-17, 5-19, 5-20, 5-22, 5-23, 5-31, 5-33, 5-37, 5-38, 540, 5-42, 5-45 6-8 thru 6-14 and 6-16 thru 6-18 7-1 8-9, 8-10 9-1 thru 9-6 SITE CHARACTERIZATION SURVEY Remove and replace the following pages:

Title Page pages 24 thru 28 1 The material listed above is transmitted herewith. Please verify receipt of all listed material, destroy superseded material, and sign below to acknowledge receipt.

o The material listed above has been placed in your binder.

o Please review listed material, notify your personnel of changes, and sign below to acknowledge your review and notification of personnel. [To be checked for supervisors for department specific procedures and LACBWR Technical Specifications.]

0 The material listed above has been changed. [To be checked for supervisors when materials applicable to other departments are issued to them.]

/S/ DATE_

Please return this notification to the LACBWR Secretary within ten (10) working days.

2003 LACBWR Decommissioning Plan Review Cover Page Update revision date.

Index, Rename Section 6.7 from "Cost Estimateand Financing." to "SAFSTOR Page 0-2 Funding andDecommissioning Cost Financing." Renumber indexed section pages as needed.

Page 1-2 Section 1.1. Selection of SAFSTOR: Fourth paragraph, third sentence states, "The decommissioning estimate is discussed in Section 6.7. " This revision to the Decommissioning Plan adds the SAFSTOR spent fuel management and funding plan to Section 6.7. The previous statement is changed to reference this plan by stating, "SAFSTOR funding and decommissioningcostfinancing arediscussed in Section 6.7. "

Page 3-5 Section 3.4.4. Flooding and Probable Maximum Flood: First sentence contains an error, ". . . 635.2 feet above main sea level (MSL) for a 50-yearflood," and is corrected to read, ... . 635.2feet above mean sea level (MSL) for a 50-year flood."

Page 5-4 Section 5.2.2. Forced Circulation System: "System Status" is revised to state, "Theforced circulationsystem and attendantoil systems have been drained. The forced circulationpumps, auxiliary oil pumps, and hydraulic coupling oil pumps have been electricallydisconnected and are not maintainedoperational " This change is due to work completed under an approved facility change.

Page 5-7 Section 5.2.5. Emergency Core Spray System: Second paragraph is revised to state, "ReactorBuilding." The term "ContainmentBuilding" is not applicable in discussions of current plant status and configurations. Containment integrity is no longer required. Automatic containment isolation functions have been removed under an approved facility change. During this Decommissioning Plan update cycle a gradual shift away from containment terminology is being undertaken.

The term "containment" remains occasionally when used in an historical context, or as referenced to in an historical record using the term.

Page 5-10 Section 5.2.8. Alternate Core Spray System: The term "Containment Building" is not applicable in discussions of current plant status and configurations. A change is made to "ReactorBuilding" in the "System Status" paragraph.

Page 5-13 Section 5.2.11. Fuel Element Storage Well System: Paragraph under "System Status," last sentence states, "The FuelElement Storage Well System will remain in operation aspart of the SAFSTOR Programuntil allfuel is sent offsite. "

Sentence is revised to state, "The FuelElement Storage Well System will remain in operation aspart of the SAFSTOR Program as long as wet fuel storage or wet fuel handlingis necessary." This revision attempts to accommodate all possibilities in regard to the future status of spent fuel at LACBWR.

Page 5-17 Section 5.2.15. Hydraulic Valve Accumulator System: The term "Containment Building" is not applicable in discussions of current plant status and configurations. A change is made to "ReactorBuilding" in the first paragraph.

Page 1 of 8

2003 LACBWR Decommissioning Plan Review Page 5-19 Section 5.2.17, Demineralized Water System: First paragraph, first sentence, a change is made to "Reactor Building."

Page 5-20 Section 5.2.18. Overhead Storage Tank: The third paragraph is revised as follows to better describe the system, "The Overhead Storage Tank (OHST) serves as a reservoirforwater used to flood the Fuel Element Storage Well and upper vessel cavity duringfuel handling. The OHST is also availableas a receiverfor rejecting waterfrom the reactorvessel using the PrimaryPurificationSystem.

The OHSTsupplied waterfor the Emergency Core Spray System, Reactor Building Spray System, and was a backup sourceforthe Seal Injection System."

Page 5-22 Section 5.2.20. Low Pressure Service Water System: Second sentence states, "This system supplies the Component Cooling Water Coolers, Turbine Lube Oil Coolers, GeneratorHydrogen Coolers, Condenser Vacuum Pump, Reactor FeedwaterPump, and Circulating Water Pump bushings, and is the normal supply to the HPSWSystem through the motor-driven pump. " Revise the sentence as follows, "The Low PressureService Water (LPSWJ system supplies the Component Cooling Water coolers, Circulating Waterpump mechanical seals, and is the normal supply to the High PressureService Water (HPSW) system through the motor-driven HPSWpump. The LPSWsystem also supplied the TurbineLube Oil coolers, generatorhydrogen system coolers, Condenser Vacuum pump, andReactor Feedwaterpumps. " This change is due to equipment being removed under approved facility changes.

Under "System Status" of same section, delete ". . . to provide HPSWSystem pressureunder normal conditions andforthe Component Cooling Water Coolers." Status statement needs only to state, "This system is maintainedin continuous operation." Portion being deleted is redundant to information contained in previous paragraph.

Page 5-23 Section 5.2.21. High Pressure Service Water System: Restate the system discussion to better describe the current configuration as follows: "The High PressureService Water (HPSW. system suppliesfiresuppression water and is availableas backup cooling waterforthe Component Cooling Water coolers.

During normal operation, HPSWsystem pressureis maintainedby the LPSW system. A motor-driven HPSWpump with suctionfrom the LPSWsystem is availableforperiodsofhigh demand. With the motor-drivenpump cycling in automatic, HPSWsystem pressureis maintained75 to 125psig, ASpsig. The pump is protected by a 35-psig low suction pressuretrip. Backup supply is availablefrom two HPSW dieselpumps that startautomaticallyifHPSW system pressuredecreasesto 60psig. TheHPSWdieselpumps will maintain system pressureat approximately 150 psig. System pressureswings are cushioned by the airspace in the HPSWsurge tank.

Page 2 of 8

2003 LACBWR Decommissioning Plan Review Tle HPSW systen is divided into tivo Main loops. The internalloop serves the Turbine Building, Reactor Building, and Waste Treatment Building interior hose stationsand sprinklersystems. The externalloop supplies outsidefire hydrants and Cribhousesprinklers.

Page 5-31 Section 5.2.29. Heating, Ventilation, and Air-Conditioning Systems: First paragraph second sentence contains an error and is corrected to "337,500-BTU/htr capacity." First paragraph, third and fourth sentences state, "The airenters the building through two 20-inch isolation dampers in series and is exhaustedfrom the building by a centrifugal exhaustfan that has a capacity of 6000 cfIn at 4 inches water staticpressure. The exhaustfan dischargesthrough two 20-inch isolation dampers in series to the tunnel." These two sentences are revised to better describe current conditions as follows, "Air enters the building through two series 20-inch dampers and is exhaustedfrom the building by action of the stack blowers. Additional exhaustflow is availableusing a centrifugal exhaust fan that has a capacityof 6000 cfm at 4 inches of water staticpressure. The exhaustfan and building exhiaust airdischargethrough two series20-inch dampers to the ReactorBuilding ventilation outlet plenum connected to the tunnel." In paragraph four a hyphen is added at "35,000-cfm. " In paragraph nine a hyphen is added at "14. 7-kWV, " and a change is made to "Reactor Building."

Page 5-33 Section 5.2.31. Fuel Transfer Bridge: In the first paragraph a change is made to "Reactor Building."

Page 5-37 Section 5.2.34. Post-Accident Sampling Systems: In the first and second sentences, a change is made to "Reactor Building."

Section 5.2.34.1. Containment Atmosphere PASS System

Description:

In the first and third sentences, a change is made to "ReactorBuilding." This change appears on reissued page 5-38.

Page 5-38 Section 5.2.34.3. Reactor Coolant PASS System

Description:

In the second sentence, a change is made to "ReactorBuilding."

Page 5-40 Section 5.4.1. Plant Radiation Levels: In the listing of areas, changes are made to "ReactorBuilding."

Page 5-42 Survey Point Location: Three changes are made to "ReactorBuilding."

Page 5-45 Section 5.7.1.2. Containment Building Air Exhaust Gaseous and Particulate Monitor: The title is not being changed, but two changes are made to "Reactor Building" in the discussion.

Page 6-8 Section 6.4.3.3. Operator Training Program: In item (1), the title, "Control Room Watch (CR A9, " is corrected to "ControlRoom Operator(CRO)" for consistency.

In item (e), "ControlRoom Operator"is abbreviated to "CRO. "

Page 3 of 8

2003 LACBWR Decommissioning Plan Review Page 6-9 Due to changes in a large portion of Section 6, the content of page 6-9 is adjusted and the page is reissued.

Page 6-10 Due to changes in a large portion of Section 6, the content of page 6-10 is adjusted and the page is reissued.

Page 6-11 Section 6.6. Schedule: In the fourth paragraph, the statement "PFSis projecting a startup date of 2005for thefacility, " is deleted. The PFS licensing process remains ongoing. The sentence that follows, "Proposalsforstudies of what is requiredforLA CB WR to ship spentfuel in that timeframe are being initiated," is revised to state, "Proposalsfor LA CBWR spentfuel removal and cask storage technology arebeing evaluated." This change appears in the first paragraph of reissued page 6-11.

Page 6-12 Section 6.7. Cost Estimate and Financing: Delete existing paragraph that states:

"DPCis currently estimatinga 30-S0year SAFSTOR period (Section 6.6). For cost estimatingpurposes, however, it was assumed that dismantlement commences as soon aspossible, which would be shortly after thefuel is sent to a federal repository. The year 2011 was chosen as the earliestpossiblefor DECON to commence. The reasonfor approachingfinancingin this manner was to assure that sufficient monies have accumulated by the earliestpossible date at which they could be used. A laterdismantlingdate will allow additionalfundsto accumulate to compensatefor the cost of inflation. After thefuel is removedfrom site, SAFSTOR costs will decreasesubstantially. These costs will continue to be borne by Dairylandforthe duration of the SAFSTOR period."

Rename the section and restate with the following to provide a better description of the information that follows:

6.7 SAFSTOR FUNDING AND DECOMMISSIONING COST FINANCING "DPC is currently assuming a 30-50yearSAFSTOR period. Forcost estimating purposes, however, it was assumed that dismantlement commences as soon as possible, which would be shortly after thefuel is sent to afederal repository. The year 2011 was chosen as the earliestpossibleforDECONto commence.

SAFSTOR and DECON costs arefunded separately. SAFSTOR funding accommodates management of LACBWR spentfuel andprovides assurance of continuedfunding through all modes offuel storage prior to acceptance by the DOE. Mandated decommissioningfunds will be available during tlheDECON period. " This change appears on reissued page 6-11.

Section 6.7.1. SAFSTOR: The time frame (1987-2010) is removed from the section title. Delete the existing paragraph that states, "The cost ofSAFSTOR will be bonie by the Dairylandsystem. The cost duringthe SAFSTOR periodwill be principallylaborin scope. The cost also will include necessary administrative Page 4 of 8

2003 LACBWR Decommissioning Plan Review costs, partsandsupplies and consultant support." Restate section information with the following:

"Pursuantto 10 CFR 50.54(bb), DairylandPower Cooperative (DPC) has promulgatedthefollowing SAFSTOR spentfuel management andfunding plan for LACBWYR.

Independent offunding costsfor SAFSTOR, DPChas establisheda Decommissioning Trust Fund, and reportsannuallyto the Nuclear Regulatory Commission the status of the fund. DPCunderstandsthat none of the funds in the Decommissioning Trust Fund may be usedfor spentfuel removal orfor developing an Independent Spent FuelStorageInstallation (ISFSI). DPChas no plans to use any of the Decommissioning Trust Fundfor an ISFSI orfor spentfuel removal purposes.

DPCcontinues tofund the expense ofSAFSTOR activities, includingfuel storage costsfrom the annual operatingandmaintenancebudget. As partof generationexpenses, SAFSTOR costs are recovered in rates thatDPCcharges distributioncooperative members under long-term, all requirementswholesale power contracts. DPCsrates to member cooperatives are annually submitted to the UnitedStates Rural Utilities Service (RUS) as partofRUS oversight ofDPC operations. DPCis requiredby RUS lending covenants andRUS regulationsto set rates at levels sufficient to recover costs and to meet certainfinancial performance covenants. DPC has always met thosefinancialperformance covenants andhas satisfiedthe RUS regulationsconcerningsubmission and approval of its rates.

DPC's25 member cooperativesset theirown rates throughparticipationin the DPC boardofdirectors. Tte operationsand maintenancebudget approved by the DPCBoard, andincorporatedinto rates submitted to and approvedby the RUS, will befunded and availableto pay SAFSTOR expenses as incurred.

DPChasfound no need to separatelyfund SAFSTOR costs outside the regular operatingandmaintenance budget. SAFSTOR costs are relatively small compared to DPC'sannualO&M costsfor generation and transmission facilities, and DPChas continuedthe long-standingpolicy ofrecovering SAFSTOR costs aspart of regularrates. DPChas seen no need to change the fundingplanforSAFSTOR underthose circumstances.

DPCcontinues to considerseveral alternativesto maintainingthe LACBWR spentfuel in the current, wet-pool storagefacility. IfDPCdecides to implement one of those alternatives,the fundsfor that alternativewill be generated through DPCoperatingand maintenancebudgetsfor the years when those activities will be undertaken. DPCdoes not intend to use anyfunds from the Decommissioning Trust Fundforthose purposes.

DPC'sannualbudgetforoperatingand maintenanceactivities at LA CBMR accommodates SAFSTOR activities, and includesfunds forperforminglimited Page 5 of 8

2003 LACBWR Decommissioning Plan Review dismantlement at the LACB WRfacility. Accomplishilg limiteddismantlement activities during SAFSTOR reduces the amount that will ultimately be necessaryfor decommissioningLACBWR after removal of thtefuel. This approachtakes advantageof the collective experience andfamiliarityof the LA CB WR staff with te plant, and buildsfurther conservatism into thefunding planfor ultimate decommissioning ofthefacility. " This change appears on reissued pages 6-11 and 6-12.

Page 6-13 Section 6.7.2. DECON: Fourth paragraph of page is revised to include changes as a result of a cost study update performed in July 2003. The following is added after the second sentence of the paragraph, "During2003, the cost study was revisited again to include changes in escalation rates,progressin limited dismantlement, anda revised reactorvessel weight definition. This update placedthe cost to complete decommissioningat $79.5 million in year 2003 dollars." This change appears in the fifth paragraph of reissued page 6-13.

Page 6-14 Section 6.8. Special Nuclear Material (SNM) Accountability: In the first paragraph a change is made to "Reactor Building." In the second paragraph, the phrase "and in fission detectors" is deleted. All fission detectors have been shipped for disposal as of 10/25/91.

Page 6-16 Section 6.9.2.4. Fire Suppression Water System: In the third paragraph a change is made to "Reactor Building."

Page 6-17 Section 6.9.2.6. Portable Fire Extinguishers and Other Fire Protection Equipment:

In the fourth paragraph, "Took kits " is corrected to "Tool kits. "

Page 6-18 Section 6.9.2.9. Reporting: In regard to fire emergency reporting, second bulleted statement, "Anyfire requiringoutsidefireservice assistanceshallrequire activation ofthe Emergency Plan and shall requiredeclaration of Unusual Event, " is changed to state, "Any incident requiringoutsidefire service assistancewithin the LA CB WR Site Enclosure (LSEfence) shall require declarationof Unusual Event. " Purpose of change is to define exact condition at which emergency action level shall be declared. Outside fire service assistance includes rescue and response to situations requiring use of self-contained breathing apparatus.

Section 6.9.2.10. Training: A correction is made from "Unescortedvisitorsand contractors," to "Security badged visitors andcontractors." Change more appropriately defines training discussion.

Section 6.10. Security During SAFSTOR and/or Decommissioning: Restate second paragraph as follows to identify new hazardous material transportation plan: "Guidanceand controlfor securityprogram implementation arefound within the LA CB WR Security Plan, Safeguards Contingency Plan, Guard Force Trainingand Quali~fcationPlan, and Security ControlProcedures. Thle Security Planfor TransportationofLA CBR R HazardousMaterialsisfound in the Process ControlProgram.

Page 6 of 8

2003 LACBWR Decommissioning Plan Review Page 7-1 Section 7.2. SAFSTOR Modifications: Remove paragraph three which states, "Even though credit is not taken in the safety analyses (Section 9) for containment integrity,the automaticclosure signalsfor containment isolation valves which will still be used have been modified. The valves close on either a high Containment Building activity signal or a low FESW level signal, which has been set below the normal water level range. An FESWlevel indicatoris used to generate the low FESW level signal. A new Contaihment Building activity monitor has been installed,which will generate the high activity signal."

Containment integrity is no longer required. Automatic containment isolation functions have been removed under an approved facility change. At the beginning of the final paragraph, add the following mention of air activity monitoring system upgrade, "The airactivity monitoringsystem has been replaced with new equipment."

Page 8-9 Section 8.6. Radioactive Waste Handling and Disposal: Discussion of radioactive waste is changed to include a third category of waste from dismantlement.

Section is changed to read as follows:

"Radioactive waste generatedat LACB WR during the SAFSTOR periodwill primarily consist of thefollowing:

a) Resin b) Dry Active Waste (DAW) c) Dismantlement (Metallic)

Radioactive waste generationwill be maintainedas low as possible to minimize the volume of materialrequiringreprocessingand disposal."

Page 8-10 A new section is added to include discussion of waste from dismantlement. The last sentence of Section 8.6.2 is placed at the end of new Section 8.6.3.

8.6.3 Dismantlement (Metallic)

"Duringthe SAFSTOR period, LA CB WR employees will pursue limited dismantlement ofthefacility. Thtis project willgenerate metallic wastesfrom system removal. This metallic waste will be placed in approved shipping containers and sent to an approved reprocessor.

Disposal of all radioactive waste will be in accordance with allpertaining guidelines."

Page 9-1 Section 9.1.

Introduction:

Last paragraph is restated grammatically, "One additionalevent involvingfire was examined. Fireprotection is covered in Section 6.9. The potentialsafety consequences of anyfire scenariofallwithin the scope of other evaluatedevents. "

Section 9.2. Spent Fuel Handling Accident: Second paragraph, third sentence states, "ContainmentBuilding ventilation would isolate on high activity, butfor this analysis, no containmentintegrity is assumed. " Revise the sentence to state, Page 7 of 8

., I .- ;..

2003 LACBWR Decommissioning Plan Review "ReactorBuilding ventilation dampers would be closed manuallyfrom the Control Room on high activity, butfor this analysis, no containment integrity is assumed." Containment integrity is no longer required. Automatic containment isolation functions have been removed under an approved facility change. The remote manual closure of ventilation dampers has been established as a required immediate action during high activity alarm response. A change is also made to "ReactorBuilding. "

Page 9-2 Section 9.2. Spent Fuel Handling Accident: The curie content remaining as of through October 2002 and calculated values for Whole Body Dose and Skin Dose as of Page 9-3 October 2002 are updated to October2003. The maximum whole body dose is updated as a factor of 30,000 below the 10 CFR 100 dose limit as opposed to a factor of 11,000 below that limit. A change is also made to "ReactorBuilding."

Page 9-4 Section 9.3. Shipping Cask or Heavy Load Drop into FESW: The curie content remaining as of October 2002 and calculated values for Whole Body Dose and Skin Dose as of October 2002 are updated to October2003. The maximum whole body dose is updated as a factor of 3 75 below the 10 CFR 100 dose limit as opposed to a factor of 100 below that limit.

Page 9-5 Section 9.5. FESW Pipe Break: The following information is added to the end of the first paragraph, "In November 1999, the FESW return line was reroutedto enter the top of the storage well andextends down to dischargeat elevation 695feet. The bottom inlet line now ends at the biologicalshield wall and is sealed with a welded plug." This change is due to work completed under an approved facility change.

Page 9-6 Section 9.6. Uncontrolled Waster Water Discharge: Second paragraph, "waste water monitor" is renamed to 'liquid waste monitor" to definitively identify the instrument used for liquid waste discharge monitoring. Delete the second sentence of the paragraph, "The Turbine Condenser Cooling Water Monitor will also alarm, ifthe activity is high enough. " The Turbine Condenser Cooling Water Monitor has been removed under an approved facility change. Liquid waste activity concentrations have decreased to low levels. Liquid waste discharges are procedurally disallowed without the liquid waste monitor being functional.

INITIAL SITE CHARACTERIZATION SURVEY FOR SAFSTOR (LAC-TR-138):

Cover Page Update revision date.

Page 24 Update curie content stated in pages 24-28. These pages of through Attachments 1, 2, and 3 have been decay-corrected to October2003, Page 28 replacing pages that had been decay-corrected to October 2002.

Page 8 of 8

2 LA CROSSE BOILING WATER REACTOR (LACBWR)

DECOMMISSIONING P LA N Revised November 2003 DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR) 4601 State Road 35 Genoa, WI 54632-8846

TABLE OF CONTENTS Page No.

5.4 Radiation Levels 5-40 5.5 Plant Personnel Dose Estimate 5-43 5.6 Sources 5-44 5.7 Radiation Monitoring Instrumentation 5-44

6. Decommissioning Program 6-1 6.1 Objectives 6-1 6.2 Organization and Responsibilities 6-1 6.3 Contractor Use 6-4 6.4 Training Program 6-5 6.5 Quality Assurance 6-10 6.6 Schedule 6-10 6.7 SAFSTOR Funding and Decommissioning Cost Financing 6-11 6.8 Special Nuclear Material (SNM) Accountability 6-13 6.9 SAFSTOR Fire Protection Program 6-14 6.10 Security During SAFSTOR and/or Decommissioning 6-18 6.11 Records 6-19

7. Decommissioning Activities 7-1 7.1 Preparation for SAFSTOR 7-1 7.2 SAFSTOR Modifications 7-1 7.3 Activities during SAFSTOR Period 7-2 7.4 Plant Monitoring Program 7-4

8. Health Physics 8-1 8.1 Organization and Responsibilities 8-1 8.2 ALARA Program 8-1 8.3 Radiation Protection Program 8-3 D-PLAN 0-2 November 2003

1. INTRODUCTION - (cont'd)

The choice between SAFSTOR and DECON must be made based on a variety of factors including availability of fuel and waste disposal, land use, radiation exposure, waste volumes, economics, safety, and availability of experienced personnel. Each alternative has advantages and disadvantages. The best option for a specific plant has to be chosen based on an evaluation of the factors involved.

The overriding factor affecting the decommissioning decision for LACBWR is that a federal repository is not expected to be available for fuel storage for about 20 years. With the fuel in the Fuel Element Storage Well, the only possible decommissioning option is SAFSTOR. Limited decontamination and dismantling of unused systems can be performed during this period.

There are other reasons to choose the SAFSTOR alternative. The majority of piping radioactive contamination is Co-60 (5.27 yr half-life) and Fe-55 (2.7 yr half-life). If the plant is placed in SAFSTOR for 50 years, essentially all the Co-60 and Fe-55 will have decayed to stable elements. Less waste volume will be generated and radiation doses to personnel performing the decontamination and dismantling activities will be significantly lower. Therefore, delayed dismantling supports the ALARA (As Low As Reasonably Achievable) goal. The reduction in dismantling dose exceeds the dose the monitoring crew receives during the SAFSTOR period.

The shutdown of LACBWR occurred before the full funding for DECON was acquired. The SAFSTOR period will permit the accumulation of the full DECON funding. SAFSTOR funding and decommissioning cost financing are discussed in Section 6.7. The majority of studies show that while the total cost of SAFSTOR with delayed DECON is greater than immediate DECON, the present value is less for the SAFSTOR with delayed DECON option.

The main disadvantage of delayed DECON is that the plant continues to occupy the land during the SAFSTOR period. The land cannot be released for other purposes. DPC also operates a 350 MWe coal-fired power plant on the site. Due to the presence of the coal-fired facility, DPC will continue to occupy and control the site, regardless of the nuclear plant's status. Therefore, the continued commitment of the land to LACBWR during the SAFSTOR period is not a significant disadvantage.

A second disadvantage of delaying the final decommissioning is that the people who operated the plant would not be available for the DECON period. When immediate DECON is selected, some of the experienced plant staff would be available for the dismantling. Their knowledge of plant characteristics and events could be extremely helpful. In the absence of these knowledge-able people, all information has to be obtained from plant records. When SAFSTOR is chosen, efforts must be made to maintain excellent records to compensate for the lack of staff continuity.

The remaining factor to be discussed is safety. As of August 1987, 43 power reactors have been shut down worldwide, 19 ofwhich are in the United States. All three methods of decommission-ing are being used. Experience has shown that all can be used safely.

D-PLAN 1-2 November 2003

3. FACILITY SITE CHARACTERISTICS - (cont'd)

The main channel of the river varies greatly in width above and below the site. A series of dams are operated by the United States Army Corps of Engineers for navigational purposes. Above Dam No. 8 (about 3/4 mile north of the site) the river is nearly four miles wide. Below the site, the river is relatively narrow for a distance of 20 miles, then gradually widens as the river approaches Dam No. 9, 33 miles south of the site.

3.4.2 Drainage The site is on a filled-in area south of the original Genoa steam plant. Therefore, drainage at the site must be provided. There is allowance for runoff from the high valley walls to the east. The site is favorably located with respect to this runoff, however, because of two short valleys east of the bluffs bordering the site. One valley drains to the north and one to the south, so that only precipitation that falls on the bluff adjacent to the site and on a small portion of the upland area contributes to runoff directly across the site. This runoff is presently channeled along the highway and railroad to prevent interference with traffic. No problems of flash floods have occurred at the site.

3.4.3 Downstream Water Use For a distance of 40 miles downstream of the site, virtually all municipal water supplies for cities and towns along the river are obtained from ground water. On the basis of readily available published records, the nearest major city using the river water for direct human consumption is Davenport, Iowa, about 195 miles downstream. The nearest user of river water for industrial purposes, excluding the adjacent fossil plant, is the steam-power plant in Lansing, Iowa, about 15 miles downstream. River water is used at this plant for condenser cooling. There is no other known user of river water for industrial purposes between the reactor site and Prairie du Chien, 40 miles down-river.

3.4.4 Flooding and Probable Maximum Flood The flood profile at the site of the La Crosse Boiling Water Reactor has a return frequency (as described by the U.S. Army Corps of Engineers) of 635.2 feet above mean sea level (MSL) foraa 50-year flood, 637.2 feet MSL for 100-year, and 640.0 for a 500-year. The site fill is at 639 feet.

The Nuclear Regulatory Commission, during the Systematic Evaluation Program, determined that the maximum historic flood (1965) was 638.2 feet MSL. The standard project flood is 643.2 feet MSL and the probable maximum flood is 658 feet MSL. The period of record keeping for evaluation of flooding, in the region of the La Crosse plant, goes back to records kept by the United States Weather Bureau in La Crosse, Wisconsin, from approximately 1873 on. Site surface run-off flooding for a local probable maximum precipitation was determined to meet NRC criteria as the total run-off would be approximately 6.4 inches above grade and the equipment is protected to a level of approximately 1 foot or more above grade. This was in compliance with the applicable Regulatory Guide criteria based on a local run-off area of a 35-acre water shed to the east of the facility.

D-PLAN 3-5 November 2003

5. PLANT STATUS - (cont'd) 5.2.2 Forced Circulation System The Forced Circulation System was designed to circulate sufficient water through the reactor to cool the core and to control reactor power from 60 to 100 percent.

Primary water passes upward through the core, and then down through the steam separators to the re-circulating water outlet plenum. The water then flows to the 16-in. forced circulation pump suction manifold through four 16-in. nozzles and is mixed with reactor feedwater that enters the manifold through four 4-in. connections. From the manifold, the water flows through 20-in. suction lines to the two 15,000 gpm variable-speed forced-circulation pumps. The pumps are above the basement floor, within their own shielded cubicles. Hydraulically-operated rotoport valves are at the suction and discharge of each pump. The 20-in. pump discharge lines return the water to the 16-in. forced-circulation pump discharge manifold. From the manifold, the water flows through four equally spaced 16-in. reactor inlet nozzles to the annular inlet plenum, and then downward along the bottom vessel head to the core inlet plenum.

The system piping is designed for a maximum working pressure of 1450 psig at 6500F (a pressure above the maximum reactor working pressure to allow for the static head and the pump head).

Since the piping from the reactor to the rotoport valves is within the biological shield and is not accessible, the valves and piping are clad with stainless steel. The piping between the rotoport valves and the pumps is low-alloy steel. Provisions have been made for determining the rate and type of any corrosion, and the low-alloy piping can be replaced if the corrosion rate is excessive.

To facilitate repair or replacement, decontamination solutions can be circulated to remove radioactive particles.

Each forced circulation pump has an auxiliary oil system and a hydraulic coupling oil system.

Each auxiliary oil system supplies oil to cool and lubricate the three (1 radial and 2 thrust) pump coupling bearings. Each hydraulic coupling oil system supplies cooled oil at a constant flow rate to the hydraulic coupling.

System Status The forced circulation system and attendant oil systems have been drained. The forced circulation pumps, auxiliary oil pumps, and hydraulic coupling oil pumps have been electrically disconnected and are not maintained operational.

D-PLAN 5-4 November 2003

5. PLANT STATUS - (cont'd) 5.2.5 Emergency Core Spray System The Emergency Core Spray System consists of a spray header with individual spray lines for each fuel assembly mounted inside the reactor vessel.

The low pressure supply line allows the demineralized water from the Overhead Storage Tank, or the service water from the High Pressure Service Water (HPSW) supply line, to flow directly to the core spray header. The flow from the Overhead Storage Tank to the spray nozzles has been calculated to be approximately 85 gpm, assuming that the reactor vessel and the Reactor Building are at the same pressure.

The core spray line penetrates the north wall of the biological shield at approximately 11 feet above the intermediate floor and enters the reactor vessel through a 1'2-inch nozzle on the northwest quadrant. The core spray header above the top of the core spray tube support grid, supplies the 72 spray lines. An individual 3/8-inch spray line is provided for each fuel element.

The spray lines are installed concentrically within tubes. Each spray line contains a needle valve on the spray header used to set the flow for each fuel assembly location. The valve stems are staked after being set so the required flow will be obtained when the reactor is operating at 5770F. The required flow per assembly varies between 0.40 and 0.87 gpm, depending on the assembly location.

System Status The Emergency Core Spray Pumps, associated piping and valves have been removed. The low pressure supply is retained to provide Reactor Vessel refill capability.

D-PLAN 5-7 November 2003

5. PLANT STATUS - (cont'd) 5.2.8 Alternate Core Spray System The Alternate Core Spray System consists of two diesel-driven High Pressure Service Water (HPSW) pumps which take a suction from the river and discharge to the reactor vessel through duplex strainers and two motor-operated valves installed in parallel.

The Alternate Core Spray System was installed to provide backup for the High Pressure Core Spray System. It provided further assurance that melting of fuel-element cladding will not occur following a major recirculation line rupture. It has a secondary function of providing backup to the High Pressure Service Water System and Fire Suppression System.

The Emergency Service Water Supply System (ESWSS) Pumps were portable pumps which served as backups to the diesel-driven High Pressure Service Water Pumps in the event the Cribhouse or underground piping were damaged. The ESWSS system has been removed.

System Status Since the reactor is defueled, the Alternate Core Spray System is not required to be operational.

Therefore, the manual isolation valve to the Reactor Building is closed. The balance of the system continues to be operational to provide the requirements of the HPSW System.

D-PLAN 5-10 November 2003

5. PLANT STATUS - (cont'd) 5.2.11 Fuel Element Storage Well System The storage well is a stainless lined concrete structure 11 feet by 11 feet by approximately 42 feet deep. When full, it contains approximately 38,000 gallons.

It is completely lined with Type 316 stainless steel. The walls are 16-gauge sheet and the bottom a 3/8-inch plate. All joints are full penetration welds. Vertical and horizontal expansion joints in the storage well allow for thermal expansion. A three-section aluminum cover, with two viewing windows per section, has been manufactured to cover the pool.

Design values for the storage well are given below:

Well Floor: safe uniform live load ........ 5,000 lb/f 2 Spent fuel elements and control rods are stored in two-tiered racks in the Fuel Element Storage Well until they can be shipped. A transfer canal connects the upper portion of the well to the upper vessel cavity and is closed with a water-tight gate and a concrete shield plug. The water level in the well is normally maintained at an elevation of > 695 feet with fuel in upper rack.

Storage well cooling is accomplished by drawing water through a 6-inch penetration at elevation 679 feet, or a 4-inch line at elevation 679 feet 11 inches, and pumping it through the fuel storage well cooler and returning it to the well, with either of two storage well pumps. The return line enters the top of the storage well and extends down to discharge at elevation 695 feet. The bottom inlet line ends at the biological shield wall and is sealed with a welded plug.

Cleanup is provided by the FESW ion exchanger. A 4-inch line from the Overhead Storage Tank is used to flood the well or pump water back to the Overhead Storage Tank. Overflow and drain pipes from the well and cavity are routed to the retention tanks.

Normal makeup to the storage well is provided by demineralized water through one of two "FESW Remote Operated Fill Valves," which are operated from Benchboard E in the Control Room.

The cooling system is conservatively designed to remove the decay heat of a full core one week after shutdown, with the storage well water at 120'F and the ultimate heat sink, the river, at 850F.

System Status The Fuel Storage Well contains 333 irradiated fuel elements, 10 control rods, startup sources and a number of zirconium and stainless steel shroud cans. The Fuel Element Storage Well System will remain in operation as part of the SAFSTOR Program as long as wet fuel storage or wet fuel handling is necessary.

D-PLAN 5-]3 November 2003

5. PLANT STATUS - (coni'd) 5.2.15 Hydraulic Valve Accumulator System The major components of the Hydraulic Valve Accumulator System are mounted on a common bed plate on the grade floor of the Reactor Building. The system consists of a water accumulator tank, a water return sump tank, two air compressors, two water pumps, piping, valves, and the necessary instrumentation and controls.

Approximately 300 gallons of demineralized water is maintained in the Water Accumulator Tank by pumps which take a suction from the Water Return Sump Tank. The level is automatically maintained by a float switch which operates the pumps as required. The water is stored in the Accumulator Tank under 140 psi air pressure which is supplied by air compressors. The air compressors are automatically controlled by a pressure switch and are interlocked with the level float switch to prevent the compressors from running while a pump is running.

The function of the Hydraulic Valve Accumulator System is to supply the necessary hydraulic force to operate the five piston-type valve actuators, which operate the five Rotoport valves in the Forced Circulation and Main Steam Systems.

System Status This system is not required to be operational.

D-PLAN 5-17 November 2003

5. PLANT STATUS - (cont'd) 5.2.17 Demineralized Water System The Virgin Water Tank provides the supply to the Demineralized Water Transfer Pumps which distribute demineralized water throughout the plant, including to the Overhead Storage Tank and the Fuel Element Storage Well Makeup in the Reactor Building. Water is demineralized in batches at the Genoa #3 generating plant, transferred to LACBWR where it is sampled, and, if of acceptable quality, stored in the Virgin Water Tank.

The Condensate Storage Tank and the Virgin Water Tank are actually two sections of an integral aluminum tank located on the office building roof. The lower section of this tank is the Condensate Storage Tank, and it has a capacity of 19,100 gallons. The upper, virgin-water, section will hold 29,780 gallons. Both tanks have high- and low-level alarm protection, and each tank level is transmitted to and shown on level indicators in the Control Room.

System Status The Demineralized Water System will remain in service, mainly as a source of water for the Fuel Element Storage Well and the heating boiler.

The Condensate Storage Tank status is covered under the Condensate System, as it provided the makeup supply for that system.

D-PLAN 5-19 November 2003

5. PLANT STATUS - (cont'd) 5.2.18 Overhead Storage Tank The Overhead Storage Tank is located at the top of, and is an integral part of, the Reactor Building.

The Overhead Storage Tank System consists of the approximately 45,000-gallon tank, the tank level instrumentation and controls, and the piping to the first valve of the systems served by the tank.

The Overhead Storage Tank (OHST) serves as a reservoir for water used to flood the Fuel Element Storage Well and upper vessel cavity during fuel handling. The OHST is also available as a receiver for rejecting water from the reactor vessel using the Primary Purification System.

The OHST supplied the water for the Emergency Core Spray System and Reactor Building Spray System, and was a backup source for the Seal Injection System.

System Status The Overhead Storage Tank remains in use, primarily for a source of makeup water to the Fuel Element Storage Well.

D-PLAN 5-20 November 2003

5. PLANT STATUS - (cont'd) 5.2.20 Low Pressure Service Water System The system is supplied by two 150-hp 2.3-KV vertical turbine pumps located in the Cribhouse through a duplex strainer unit. The Low Pressure Service Water (LPSW) system supplies the Component Cooling Water coolers and Circulating Water pump mechanical seals, and is the normal supply to the High Pressure Service Water (HPSW) system through the motor-driven HPSW pump. The LPSW system also supplied the Turbine Lube Oil coolers, generator hydrogen system coolers, Condenser Vacuum pump, and Reactor Feedwater pumps. The LPSW pump seals are provided with clean well water via a reservoir and two pumps.

System Status This system is maintained in continuous operation.

D-PLAN 5-22 November 2003

5. PLANT STATUS - (cont'd) 5.2.21 High Pressure Service Water System The High Pressure Service Water (HPSW) system supplies fire suppression water and is available as backup cooling water for the Component Cooling Water coolers. During normal operation, HPSW system pressure is maintained by the LPSW system. A motor-driven HPSW pump with suction from the LPSW system is available for periods of high demand. With the motor-driven pump cycling in automatic, HPSW system pressure is maintained 75 to 125 psig,

+/-5 psig. The pump is protected by a 35-psig low suction pressure trip. Backup supply is available from two HPSW diesel pumps that start automatically if HPSW system pressure decreases to 60 psig. The HPSW diesel pumps will maintain system pressure at approximately 150 psig. System pressure swings are cushioned by the air space in the HPSW surge tank.

The HPSW system is divided into two main loops. The internal loop serves the Turbine Building, Reactor Building, and Waste Treatment Building interior hose stations and sprinkler systems. The external loop supplies outside fire hydrants and Cribhouse sprinklers.

System Status This system is maintained in operation to provide fire protection.

D-PLAN 5-23 November 2003

5. PLANT STATUS - (cont'd) 5.2.29 Heating, Ventilation, and Air-Conditioning Systems The Reactor Building ventilation system utilizes two 30-ton, 12,000-cfin air conditioning units for drawing fresh air into the building and for circulating the air throughout the building. Each air-conditioning unit air inlet is provided with a filter box assembly, face and bypass dampers, and one 337,500-Btu/hr capacity steam coil that is used when heating is required. Air enters the building through two series 20-inch dampers and is exhausted from the building by action of the stack blowers. Additional exhaust flow is available using a centrifugal exhaust fan that has a capacity of 6000 cfin at 4 inches of water static pressure. The exhaust fan and building exhaust air discharge through two series 20-inch dampers to the Reactor Building ventilation outlet plenum connected to the tunnel.

A 20-inch damper is also provided for recirculation of the exhaust fan discharge air. The exhaust system is provided with conventional and high-efficiency filters and with a gaseous and particulate radiation monitor system.

The Waste Treatment Building ventilation is provided by a 2000-cfin exhaust fan that draws air from the shielded vault areas of the building and exhausts the air through a duct out the floor of the building to the waste gas storage vault. The stack blowers then exhaust the air from the waste gas storage vault through the connecting tunnel and discharge the air up the stack.

The exhaust air from the Reactor Building and from the Waste Treatment Building are discharged into the tunnel connecting the Waste Treatment Building, the Reactor Building, and the Turbine Building to a plenum at the base of the stack. The stack is 350 feet high and is of structural concrete with an aluminum nozzle at the top. The nozzle tapers to 4 feet 6 inches at the discharge, providing a stack exit velocity of approximately 70 fps with the two 35,000-cfln stack blowers in operation.

The Turbine Building heating system provides heat to the turbine and machine shop areas through unit heaters and through automatic steam heating units.

The Control Room Heating and Air-Conditioning unit serves the Control Room, Electrical Equipment Room, Shift Supervisor's area, and adjacent office.

The office area and laboratory are provided with a separate multi-zone heating and air-conditioning unit.

The heating boiler is a Cleaver-Brooks, Type 100 Model CB-189, 150-hp unit. At 150 psig, the boiler will deliver 6,275,000 Btu/hr. The boiler fuel is No. 2 fuel oil. The oil is supplied by and atomized in a Type CB-1 burner which will deliver 45 gph.

Two 14.7-kW resistance heaters with power supplied from the essential busses are available to heat the Reactor Building in the event normal heating is lost.

System Status These systems are maintained operational and used as conditions require.

D-PLAN 5-31 November 2003

5. PLANT STATUS - (cont'd) 5.2.31 Fuel Transfer Bridge The fuel transfer bridge is a specially-designed structure which is power-driven north and south on rails recessed in the floor at elevation 701'0" of the Reactor Building.

The bridge traverses over the areas where service operations are performed at the reactor cavity, transfer canal, spent fuel storage pool and the new fuel storage racks. The bridge serves as the structural support for the fuel transfer hoist, and it provides an operating platform for personnel.

System Status The fuel transfer bridge is kept operational and is tested routinely.

D-PLAN 5-33 November 2003

5. PLANT STATUS - (cont'd) through a breaker on Turbine Building MCC IA through a static switch in the inverter. Inverter IC has been removed. Its distribution panel is powered from Turbine Building MCC IA and has been renamed IC 120-v AC Essential Power.

5.2.33.5 125-v DC Distribution The 125-v DC Distribution Systems supply DC power to all Generator Plant, Reactor Plant, and Diesel Building equipment requiring it.

The 125-v DC Distribution Systems were divided into three separate and independent systems each with its own battery, battery charger, and distribution buses. The buses could be cross-connected but were normally isolated from each other. The Reactor Plant and Diesel Building batteries and chargers have been removed. The Generator Plant Battery and Charger remain as the sole sources of DC power to the 125-v DC distribution system. The once three separate systems have been interconnected by using installed bus tie breakers.

For the system, the Generator Plant Battery Charger provides the normal DC supply with the Generator Plant Battery as the reserve supply. The battery floats on the line maintaining a full charge, and provides emergency DC power in the event of a loss of AC power to the battery charger or failure of the charger.

System Status The Electrical Power Distribution System is maintained operational and required surveillance tests are performed on the Emergency Diesel Generators and 125-v batteries.

The Electrical Power Distribution System will continue to be evaluated to gain further simplification and reliability.

5.2.34 Post-Accident Sampling Systems The Post-Accident Sampling Systems (PASS) are designed to permit the removal for analysis of small samples of either Reactor Building atmosphere, reactor coolant, or stack gas when normal sample points are inaccessible following an accident. These samples will aid in determining the amount of fuel degradation and the amount of hydrogen buildup in the Reactor Building.

Samples will be removed to the laboratory for analysis.

D-PLAN 5-37 November 2003

5. PLANT STATUS - (cont'd) 5.2.34.1 Containment Atmosphere PASS System Description The Containment Atmosphere Post-Accident Sampling System consists of a vacuum pump which takes a suction on the Reactor Building atmosphere at the 714' level. The atmosphere sample is drawn through two solenoid operated isolation valves, a heat exchanger, and moisture trap. Then the sample is discharged to the two in-parallel hydrogen analyzers with preset flowmeters; then either through a bypass line or a remote sample cylinder and back to the Reactor Building at the 676' level through two solenoid operated isolation valves.

5.2.34.2 Stack Gas PASS System Description The Stack Gas Post-Accident Sampling System makes use of the same equipment that provides the normal stack gas sample flow. The vacuum pump for stack gas sampling draws the extra flow, above what the stack monitors draw, to make the total flow isokinetic to the stack discharge. This flow can be diverted through the post-accident sample canister by opening manual isolation valves. The sample canister is connected to the system by two quick disconnects and, therefore, can be easily removed from the system and taken to the laboratory for analysis. The sample canister diversion valve is controlled from the local control panel in the No. 3 Feedwater Heater area.

5.2.34.3 Reactor Coolant PASS System Description The Reactor Coolant Post-Accident Sampling System took primary coolant from an incore flux monitoring flushing connection, through 2 solenoid-operated isolation valves with a heat exchanger between them, to a motor-operated pressure reducing valve. Downstream of the pressure reducing valve, the coolant sample could be diluted with demineralized water which then flowed through the sample cylinder or its bypass valve, through another solenoid isolation valve, and back to the Reactor Building basement or to the waste water tanks.

System Status The Stack Gas PASS System is maintained in continuous operation. The Reactor Coolant PASS System has been removed. The Containment Atmosphere PASS System is retained in place.

5.2.35 Containment Integritv Systems With the plant in the SAFSTOR condition, there is no longer a postulated accident that would result in containment pressurization or that takes credit for Containment integrity.

System Status Containment integrity systems are not required to be operable.

D-PLAN 5-38 November 2003

5. PLANT STATUS - (cont'd) 5.4 RADIATION LEVELS 5.4.1 Plant Radiation Levels Upon entering the initial phase of LACBWR's SAFSTOR mode, base line gamma radiation surveys were performed throughout the plant. General area radiation levels are listed below.

These levels will be routinely monitored and tracked. Specific area hot spots will also be looked for and recorded on each area survey.

Area General Area Gamma Radiation Levels Reactor Building: I Shutdown Condenser Platform 10-20 mRem/hr 701' Level 6-12 mRem/hr Mezzanine Level East 5-10 mRemlhr Mezzanine Level West 20-30 mRem/hr West Nuclear Instrument Platform 40-90 mRern/hr East Nuclear Instrument Platform 10-20 mRem/hr Purification Cooler Platform 5-10 mRem/hr Grade Floor North and East 7-20 mRem/hr Grade Floor West 75-120 mRem/hr Upper Control Rod Drive Area 60-120 mRem/hr Basement 10-40 mRem/hr Primary-Purification Demineralizer 7-17 mRem/hr Retention Tank Area 250-400 mRem/hr Lower Control Rod Drive Area 60-150 mRem/hr Forced Circulation Pump Cubicles 150-400 mRem/hr Turbine Buildin:

Main Floor <1-3 mRemlhr Mezzanine <1-4 mRem/hr Stop Valve Area 10-85 mRem/hr Grade Floor 1-10 mRem/hr Feedwater Heater Area 5-20 mRem/hr Tunnel 10-50 mRem/hr Machine Shop <1 mRem/hr IB Diesel Room <1 mRem/hr Electrical Penetration Room 2-7 mRem/hr Waste Treatment Building:

Main Floor 1-20 mRem/hr Basement 10-100 mRem/hr Building Exteriors:

Exterior of Waste Treatment Building <1 except for south side where there is one spot between 3-4 mRem/hr Exterior of Reactor Building <1 except for one spot on south side I reading 7 mRem/hr D-PLAN 5-40 November 2003

5. PLANT STATUS - (cont'd)

Contact Survey Dose Rate Point # Survey Point Location (mRem/hr) 30 Feedwater Heater Bypass Line 24 31 Bottom of Gland Exhaust Condenser 170 32 Top of Gland Exhaust Condenser 20 33 Condensate into Air Ejector Line 7 34 Air Ejector 8 35 Low Pressure Turbine Manhole Cover 6 36 End of High Pressure Turbine 2 37 Primary Purification 1A Filter Inlet Line 38 38 Primary Purification Pump 140 39 Exhaust Ventilation Duct 9 40 Reactor Bldg. Grade Level N Shield Wall 6 41 1A Fuel Element Storage Well Pump 70 42 lB Fuel Element Storage Well Pump 80 43 FESW Filter Discharge Line 180 44 FESW System Cooler 1000 45 Hydraulic Valve Actuation System Header 60 46 Base of Hydraulic Valve Accumulator 24 47 Wall at Electrical Penetration 30 48 Handrail on NW Nuclear Instrumentation (NI) Platform 100 49 Shield Wall on N NI Platform 4 50 Primary Purification to OHST Line 6 51 Above Primary Purification Cooler Inlet Valve 25 52 Cold Leg of Reactor High Level Transmitter Line 46 53 Seal Injection Resevoir 30 54 Reactor Cavity Drain Line 44 55 1A Core Spray Pump Discharge Line 10 56 Reactor Water Level Sightglass Line 180 57 Reactor Water Level Sightglass Line 100 58 Reactor Bldg. Mezzanine Level N Shield Wall 4 59 Steam Trap Reactor Bldg. Mezz. Level NW Wall 23 60 Fuel Element Storage Well Line 400 61 Fuel Element Storage Well Line 420 62 Fuel Element Storage Well Line 60 63 Fuel Element Storage Well Skimmer Line 90 64 Wall near Fuel Transfer Canal Drain 35 65 Relief Valve Platform at Level Transmitter Isolation 80 66 Shutdown Condenser 11 67 Shutdown Condenser Condensate Line 6 68 1B Retention Tank 300 69 1A Retention Tank 130 D-PLAN 5-42 November 2003

5. PLANT STATUS - (cont'd) 5.7.1.2 Containment Building Air Exhaust Gaseous and Particulate Monitor. A monitor is located on the Reactor Building mezzanine level. This monitor has a fixed filter particulate detector and a gaseous detector. It takes suction from the outlet of the Reactor Building ventilation filters.

5.7.1.3 Stack Monitor. A monitor is installed to sample the stack emissions. This monitor draws air from the stack through an isokinetic nozzle. This monitor detects particulate and gaseous activity released to the stack. This monitor alarms locally and in the control room.

5.7.1.4 Fixed Location Monitors. Area radiation monitors are used to detect and measure gamma radiation fields at various remote locations. There are fifteen remote units located throughout the plant. The measured dose rate is displayed on meters located in the Control Room.

5.7.2 Portable Monitors Portable instruments are located throughout the plant. Instruments are available to detect various levels of beta, gamma, and alpha radiation.

5.7.3 Laboratory-Type Monitors Laboratory instruments are available to determine contamination levels and radioisotope concentrations. These instruments consist of internal proportional counters, gamma analyzers, and liquid scintillation counters.

D-PLAN 5-45 November 2003

6. DECOMMISSIONING PROGRAM - (cont'd) 6.4.3.3 Operator Training Program (1) Operators assigned to LACBWR will be qualified to perform the duties of Auxiliary Operator (AO) and Control Room Operator (CRO).

(2) The Operator Initial Training Program consists of the following:

(a) Part I - The initial GET and Indoctrination is presented to give the new employee background information concerning the LACBWR organization, radiation safety, payroll practices, and general plant description and administration.

(b) Part It - The second part of the training program, "Initial Plant Qualification Program," provides a comprehensive outline of material considered necessary for the training of individuals to qualify them for all operator duties. Periodic written and/or oral examinations, plus actual demonstrations of proficiency in practical factors, will be required of the trainees to determine their progress in the program.

(c) Operator Sciences Training (1) Nuclear Theory (2) Radiological Protection and Control (3) Electrical Theory, as applied to operators (4) Chemistry (d) Operator Systems Training (1) Plant Specific Systems (2) Design Bases (3) Flow Paths (4) Components (5) Instrumentation and Control (6) Operational Aspects (e) Control Room Training by familiarization and manipulation under the supervision of a qualified CRO, consisting of training and exercises which apply the operating l philosophy, procedures, and attitudes needed as an operator at LACBWR. The Control Room Training will be documented in the operator Practical Factors Record.

Topics include:

(1) Normal operations (2) Malfunctions (3) Surveillances (4) Procedures (5) Technical Specifications (6) Emergency response actions D-PLAN 6-8 November 2003

6. DECOMMISSIONING PROGRAM - (cont'd)

(f) Emergency Training (1) Emergency Plan and EPP's (2) Plant Emergency Procedures (3) Review of Incident Reports and LER's (g) In addition, operator trainees will take part in the LACBWR Continuing Training Program when assigned to an operating crew. This program is intended as a review for personnel and as such is not intended to serve as the sole means of training for operator trainees. All quiz and examination scores attained by trainees in the requalification program will be used to aid the trainee and not to determine his status in the program. No lecture attendance or retraining requirements are to be based on test results.

(h) The candidate will normally get the necessary signatures for the Auxiliary Operator Watch Card, then Control Room Operator Watch Card and, while standing these watches, work to complete each Progress Card. As the Progress Cards are completed, the training personnel shall prepare and administer a written exam. The trainee must receive a score of 280% to pass exam.

6.4.3.4 Certified Fuel Handler Training Program. A training and certification program has been implemented to maintain a staff properly trained and qualified to maintain the spent fuel, to perform any fuel movements that may be required, and to maintain LACBWR in accordance with the possession-only license. This program provides the training, proficiency testing, and certification of fuel handling personnel. A detailed description of the Certified Fuel Handler (CFH) Program is provided in Section 10.

The Operator Training and Certification Programs ensure that people trained and qualified to operate LACBWR will be available during the SAFSTOR period. Licensee certification of personnel makes it unnecessary for the NRC to periodically conduct license examinations for persons involved in infrequent activities and prevents delays due to obtaining NRC Fuel Handler Licenses for any evolutions that may require fuel movements.

During the SAFSTOR period, it is not expected that movements of spent reactor fuel will be made, except for special tests or inspections to monitor the fuel in storage. At some time during the SAFSTOR period, fuel handling may be performed to transfer the spent fuel assemblies to the Department of Energy (DOE) or other entity.

D-PLAN 6-9 November 2003

6. DECOMMISSIONING PROGRAM - (cont'd) 6.4.5 Other Decommissioning Trainina It is anticipated that other technical topics will be presented to personnel on an as-needed basis.

Current administrative guidelines will be followed to establish new procedures and to ensure the training is completed.

6.4.6 Training Program Administration and Records The LACBWR Plant Manager is responsible for ensuring that the training requirements and programs are satisfactorily completed for site personnel. A LACBWR Shift Supervisor is responsible for the organization and coordination of training programs, for ensuring that records are maintained and kept up-to-date, and assisting in training material preparation and classroom instruction.

6.5 QUALITY ASSURANCE Decommissioning and SAFSTOR activities will be performed in accordance with the NRC-approved Quality Assurance Program Description (QAPD) for LACBWR. "Safety Related" as defined would no longer be applicable in the "possession-only" mode of operation and, therefore, 10 CFR 50, Appendix "B", would no longer apply to activities performed at LACBWR.

Because of DPC's desire to maintain control and continuity in activities performed at and for LACBWR, including spent fuel and radioactive waste shipments, the QAPD will still address all 18 criteria of 10 CFR 50, Appendix "B", but some will be of a reduced scope.

A graded approach will be used to implement this program by establishing managerial and administrative controls commensurate with the complexity and/or seriousness of the activities to be undertaken.

6.6 SCHEDULE The tentative decommissioning schedule is shown in Figure 6-2. As can be seen, DPC received a possession-only license in August 1987. The LACBWR Decommissioning Plan was approved in August 1991, and the facility entered the SAFSTOR mode.

As discussed in Section 7.2, some modifications are considered beneficial to support the plant in the SAFSTOR condition.

During the SAFSTOR period, DPC expects to ship the activated fuel to a federal repository, interim storage facility, or licensed temporary monitored retrievable storage facility. The timing of this action will be dependent on the availability of these facilities and their schedule for receiving activated fuel. A modification to the Decommissioning Plan will then be submitted to describe the change in plant status and associated activities.

D-PLAN 6-10 November 2003

6. DECOMMISSIONING PROGRAM - (cont'd)

DPC is a part of the consortium of utilities that formed the Private Fuel Storage (PFS) Limited Liability Company (LLC) for the sole purpose of developing a temporary site for the storage of spent nuclear fuel for the industry. Proposals for LACBWR spent fuel removal and cask storage technology are being evaluated.

At this time, DPC anticipates the plant will be in SAFSTOR for a 30-50 year period. Prior to the end of the SAFSTOR period, an updated detailed DECON Plan will be submitted. The ultimate plan is to decontaminate the LACBWR facility in accordance with applicable regulations to permit unrestricted access and termination of the license.

6.7 SAFSTOR FUNDING AND DECOMMISSIONING COST FINANCING DPC is currently assuming a 30-50 year SAFSTOR period. For cost estimating purposes, however, it was assumed that dismantlement commences as soon as possible, which would be shortly after the fuel is sent to a federal repository. The year 2011 was chosen as the earliest possible for DECON to commence. SAFSTOR and DECON costs are funded separately.

SAFSTOR funding accommodates management of LACBWR spent fuel and provides assurance of continued funding through all modes of fuel storage prior to acceptance by the DOE.

Mandated decommissioning funds will be available during the DECON period.

6.7.1 SAFSTOR Pursuant to 10 CFR 50.54(bb), Dairyland Power Cooperative (DPC) has promulgated the following SAFSTOR spent fuel management and funding plan for LACBWR.

Independent of funding costs for SAFSTOR, DPC has established a Decommissioning Trust Fund and reports annually to the Nuclear Regulatory Commission the status of the fund. DPC understands that none of the funds in the Decommissioning Trust Fund may be used for spent fuel removal or for developing an Independent Spent Fuel Storage Facility (ISFSI). DPC has no plans to use any of the Decommissioning Trust Fund for an ISFSI or for spent fuel removal purposes.

DPC continues to fund the expense of SAFSTOR activities, including fuel storage costs, from the annual operating and maintenance budget. As part of generation expenses, SAFSTOR costs are recovered in rates that DPC charges distribution cooperative members under long-term, all requirements wholesale power contracts. DPC's rates to member cooperatives are annually submitted to the United States Rural Utilities Service (RUS) as part of RUS oversight of DPC operations. DPC is required by RUS lending covenants and RUS regulations to set rates at levels sufficient to recover costs and to meet certain financial performance covenants. DPC has always met those financial performance covenants and has satisfied the RUS regulations concerning submission and approval of its rates.

D-PLAN 6-11 November 2003

6. DECOMMISSIONING PROGRAM - (cont'd)

DPC's 25 member cooperatives set their own rates through participation in the DPC board of directors. The operations and maintenance budget approved by the DPC Board, and incorporated into rates submitted to and approved by the RUS, will be funded and available to pay SAFSTOR expenses as incurred.

DPC has found no need to separately fund SAFSTOR costs outside the regular operating and maintenance budget. SAFSTOR costs are relatively small compared to DPC's annual O&M costs for generation and transmission facilities, and DPC has continued the long-standing policy of recovering SAFSTOR costs as part of regular rates. DPC has seen no need to change the funding plan for SAFSTOR under those circumstances.

DPC continues to consider several alternatives to maintaining the LACBWR spent fuel in the current, wet-pool storage facility. If DPC decides to implement one of those alternatives, the funds for that alternative will be generated through DPC operating and maintenance budgets for the years when those activities will be undertaken. DPC does not intend to use any funds from the Decommissioning Trust Fund for those purposes.

DPC's annual budget for operating and maintenance activities at LACBWR accommodates SAFSTOR activities and includes funds for performing limited dismantlement at the LACBWR facility. Accomplishing limited dismantlement activities during SAFSTOR reduces the amount that will ultimately be necessary for decommissioning LACBWR after removal of the fuel. This approach takes advantage of the collective experience and familiarity of the LACBWR staff with the plant, and builds further conservatism into the funding plan for ultimate decommissioning of the facility.

6.7.2 DECON The cost of deconning will be based on the selection of total radiological cleanup as the option to be pursued for the final decommissioning of the La Crosse Boiling Water Reactor. Once radio-active material and sources of contamination have been removed and the site meets established release criteria, buildings will be released for whatever activity the Cooperative chooses to perform. They may be used for other Cooperative purposes, sold for another purpose or demolished. The original cost of the DECON phase was indicative of knowledge of technology as it existed at the time of preparation of this plan (1987). It is expected that better technologies will exist by the time that this activity is carried out and Dairyland Power Cooperative is committed to the utilization of the most effective technologies available at the time in optimizing the DECON activity.

In 1983, the Dairyland Power Cooperative Board of Directors resolved to ensure adequate funding for the decommissioning of LACBWR. An annual funding of$1,300,000 was established, to be continued through 1999. This fund, with accumulated earnings, was projected to be able to adequately fund the decommissioning cost in 2010, based on the original cost estimate of $20 million in 1983 dollars.

D-PLAN 6-12 November 2003

6. DECOMMISSIONING PROGRAM - (cont'd)

The decommissioning fund was placed in an external fund, outside DPC's administrative control, invested in instruments such as Treasury.Notes.

By the end of 1987, the decommissioning fund had accumulated to approximately $9,400,000.

The decommissioning fund in the year 2000 was projected to reach $50 million (assumed equal to the original cost estimate), with the fund by the year 2010 at approximately $92,600,000 accrued.

The 1994 site-specific decommissioning cost study performed by Sargent & Lundy identified a need for increased funding. The Dairyland Power Cooperative Board of Directors authorized and approved an adjusted annual decommissioning accrual of $3 million with continued funding through 2010 to provide sufficient funding with commencement of decommissioning in 2019.

The cost study revision completed July 1998 placed the cost to complete decommissioning at

$98.7 million in 1998 dollars. The annual decommissioning funding level required to meet the 2010 objective was $2.2 million. An adjustment to this level of funding was authorized by the Board of Directors.

A cost study update, prompted by significant changes in radioactive waste burial costs, as well as lessons learned on decontamination factors and methods, was prepared in November 2000. This update placed the cost to complete decommissioning at $79.2 million in Year 2000 dollars.

During 2003, the cost study was revisited again to include changes in escalation rates, progress in limited dismantlement, and a revised reactor vessel weight definition. This update placed the cost to complete decommissioning at $79.5 million in Year 2003 dollars. Cooperative management believes that the balance in the nuclear decommissioning funds, together with future expected investment income on such funds, will be sufficient to meet all future decommissioning costs.

The DPC Board of Directors remains committed to assuring that adequate funding will be available for the decommissioning of the LACBWR facility and is prepared to adjust the funding level for the LACBWR Decommissioning Plan, from time to time, and/or take such other actions as it deems necessary or appropriate to provide such assurance, based upon its review of the most recent decommissioning cost estimate and other relevant developments in this area.

Every five years during the SAFSTOR period, a review of the decommissioning cost estimate will be performed in order to assure adequate funds are available at the time final decommission-ing is performed.

6.8 SPECIAL NUCLEAR MATERIAL (SNM) ACCOUNTABILITY The LACBWR Accountability Representative is the person responsible for the custodial control of all SNM located at the LACBWR site and for the accounting of these materials. He is appointed in writing by the Dairyland Power Cooperative President & CEO.

D-PLAN 6-13 November 2003

6. DECOMMISSIONING PROGRAM - (cont'd)

The LACBWR Spent Fuel (333 assemblies) is stored under water in the high density spent fuel storage racks in the LACBWR Fuel Storage Well which is located adjacent to the reactor in the LACBWR Reactor Building, Additional small quantities of SNM are contained in neutron and calibration sources, which are appropriately stored at various locations in the LACBWR plant.

All fuel handling and all shipment and receipt of SNM is accomplished according to approved written procedures. Appropriate accounting records will be maintained and appropriate inventories, reports and documentation will be accomplished by or under the direction of the LACBWR Accountability Representative in accordance with the requirements set forth in 10 CFR 70, 10 CFR 73 and 10 CFR 74.

6.9 SAFSTOR FIRE PROTECTION 6.9.1 Fire Protection Plan LACBWR can safely maintain and control the Fuel Element Storage Well in the case of the worst postulated fire in each area of the plant.

The fire protection plan at LACBWR is to minimize fire loads, identify and correct fire hazards, control ignition sources, detect incipient stage fires, and immediately extinguish incipient stage fires. A trained fire brigade shall be present at the facility at all times. A pressurized, water-based fire protection system comprised of automatic and manual sprinkler systems, fire hose stations, hydrants, and equipment shall be maintained at all times. Portable fire extinguishers shall be available in all areas of the facility. Unavailability of, or impairment to, fire protection equipment shall be compensated for. Fires that progress beyond incipient stage shall be responded to by outside fire services. This fire protection plan provides defense-in-depth to fire emergencies.

The goals of the fire protection plan at LACBWR are to prevent fire and to effectively respond to fire, in order to minimize the impact of fire emergencies and are met through accomplishing the following objectives:

• Prevent fire. With the cessation of plant operations, ignition sources have been greatly reduced. Welding and other hot work shall be performed only under Special Work Permit conditions and the use of a fire watch shall be required. Routine fire and safety inspections by LACBWR staff shall be conducted to identify fire hazards, the discovery of which would result in action to reduce those hazards. General cleanliness and good housekeeping shall continue as an established practice and shall be checked during inspection.

• Detect fire. A fire detection system is installed to detect heat and smoke in spaces and areas of the protected premises of LACBWR. If the fire detection system or components are unavailable, increased monitoring of affected areas by plant personnel shall be required.

D-PLAN 6-14 November 2003

6. DECOMMISSIONING PROGRAM - (cont'd)

The Administration Building fire detection system provides alarm functions using a combination of thermal detectors ionization detectors, and manual pull stations. Audible alarms are sounded throughout the building and provide immediate notice to occupants of fire emergency. The control panel for the Administration Building fire detection system is located within the Security Electrical Equipment Room.

6.9.2.3 Fire Barriers are those components of construction (walls, floors, and doors) that are rated in hours of resistance to fire by approving laboratories. Any openings or penetrations in these fire barriers shall be protected with seals or closures having a fire resistance rating equal to that of the barrier. The breaching of fire barriers is administratively controlled to ensure their fire safety function is maintained.

6.9.2.4 Fire Suppression Water System. The fire suppression water system is designed to provide a reliable supply of water for fire extinguishing purposes in quantities sufficient to satisfy the maximum possible demand. Fire suppression water is supplied by the High Pressure Service Water System (HPSW) which is normally pressurized from the Low Pressure Service Water (LPSW) system. Two HPSW diesel pumps provide fire suppression water when started manually or when started automatically by a decrease in HPSW pressure to <60 PSIG. Fire suppression water can be supplied from Genoa Station No. 3 (G-3) as a backup system to the HPSW system.

Fire suppression water is available from an external underground main at five 6-inch fire hydrants spaced at 200-foot intervals around the plant. Four outside hose cabinets contain the necessary hoses and equipment for hydrant operation.

Fire suppression water is available at five hose cabinets in the Turbine Building, one hose reel in the lB Diesel Generator Building, and one hose cabinet in the Waste Treatment Building. Fire suppression water is available from hose reels located on each of four levels in the Reactor Building.

Fire suppression water is also supplied to sprinkler systems in areas with high fire loads.

Sprinkler systems suppress fire in these areas without exposure to personnel. Automatic sprinkler systems are installed in the Oil Storage Room and in the Crib House HPSW diesel pump and fuel tank area. A manually initiated sprinkler system is installed in 1A Diesel Generator Room. An automatic reaction-type deluge system protects the Reserve Auxiliary Transformer located in the LACBWR switchyard.

6.9.2.5 Automatic Chemical Extinguishing Systems are installed in two areas of LACBWR containing high fire loads. The 1B Diesel Generator Room is protected by a CO2 Flooding system. The Administration Building Records Storage Room is protected by a Halon system.

These systems automatically extinguish fire using chemical agents, upon detection by their associated fire protection circuits. Fire in these areas is extinguished without exposure to personnel.

D-PLAN 6-16 November 2003

6. DECOMMISSIONING PROGRAM - (cont'd) 6.9.2.6 Portable Fire Extinguishers and Other Fire Protection Equipment. An assortment of dry chemical, CO2, and Halon portable fire extinguishers rated for Class A, B, and C fires are located throughout all areas of the LACBWR facility. These extinguishers provide the means to immediately respond to incipient stage fires. Spare fire extinguishers are located on the Turbine Building grade floor.

Portable smoke ejectors are provided for the removal of smoke and ventilation of spaces. Smoke ejectors are located in the Change Room, on the Turbine Building mezzanine floor, and in the Maintenance Shop.

Four outside hose cabinets contain necessary lengths and sizes of fire hose for use with the yard fire hydrants. These hose cabinets also contain hose spanner and hydrant vrenches, nozzles, gate valves, coupling gaskets, and ball-valve wye reducers.

Tool kits are located in the Crib House outside fire cabinet and in the Maintenance Shop. Spare sprinkler heads and other sprinkler equipment is located in the Change Room locker. Recharge-able flashlights are wall-mounted in various locations and at entries to spaces. Portable radios are available at various locations and used for Fire Brigade communication.

6.9.2.7 The Fire Brigade is an integral part of the fire protection program. The Fire Brigade at LACBWR shall be organized and trained to perform incipient fire fighting duties. Personnel qualified to perform Operations Department duties and all LACBWR Security personnel shall be designated as Fire Brigade members and trained as such. Fire Brigade responsibilities shall be assigned to members of these groups while on duty.

The Fire Brigade shall be a minimum of two people at all times. The Duty Shift Supervisor (or his designee) shall respond to the fire scene as the Fire Brigade Leader. One member of the Security detail shall respond, as directed by the Fire Brigade Leader, and perform duties as the second Fire Brigade member.

The Control Room Operator shall communicate the status of fire detection system alarms or specific hazard information with the Fire Brigade, shall monitor and maintain fire header water pressure, and shall expeditiously summon outside fire service assistance as directed by the Fire Brigade Leader. The Control Room Operator shall use the page system to announce reports of fire, evacuation orders, and other information as requested by the Fire Brigade Leader.

6.9.2.8 Outside Fire Service Assistance. The LACBWR Fire Brigade is organized and trained as an incipient fire brigade. Fire Brigade Leaders are responsible for recognizing fire emergencies that progress beyond the limits of incipient stage fire fighting. Fire Brigade Leaders shall then immediately request assistance from outside fire services.

The LACBWR Emergency Plan contains a letter of agreement with the Genoa Fire Department.

This letter of agreement states that the Genoa Fire Department is responsible for providing rescue and fire fighting support to LACBWR during emergencies. Upon request by the Genoa Fire Chief, all fire departments of Vernon County can be coordinated and directed by the Fire D-PLAN 6-17 November 2003

6. DECOMMISSIONING PROGRAM - (cont'd)

Services Director for Vernon County Emergency Management to support the Genoa Fire Department during an emergency at LACBWR.

6.9.2.9 Reporting. Fire emergencies shall be documented under the following reporting guidelines:

• Any fire requiring Fire Brigade response shall be reported by the Duty Shift Supervisor using a LACBWR Incident Report.

• Any incident requiring outside fire service assistance within the LACBWR Site Enclosure (LSE fence) shall require activation of the Emergency Plan and shall require declaration of Unusual Event.

6.9.2.10 Training. Security badged visitors and contractors located at LACBWR shall receive indoctrination in the areas of fire reporting, plant evacuation routes, fire alarm response, and communications systems under General Employee Training.

Personnel who work routinely at LACBWR, and are given basic practical fire fighting instruction annually, are termed designated employees.

In addition to the annual practical fire fighting instruction, Fire Brigade members shall receive specific fire protection program instruction and participate in at least one drill annually.

Personnel not subject to Fire Brigade responsibilities shall receive training prior to performing fire watch duties.

6.9.2.11 Records. Fire Protection records shall be retained in accordance with Quality Assurance records requirements.

6.10 SECURITY DURING SAFSTOR AND/OR DECOMMISSIONING During the SAFSTOR status associated with the LACBWR facility, security will be maintained at a level commensurate with the need to insure safety is provided to the public from unreasonable risks.

Guidance and control for security program implementation are found within the LACBWR Security Plan, Safeguards Contingency Plan, Guard Force Training and Qualification Plan, and Security Control Procedures. The Security Plan for Transportation of LACBWR Hazardous Materials is found in the Process Control Program.

D-PLAN 6-18 November 2003

7. DECOMMISSIONING ACTIVITIES 7.1 PREPARATION FOR SAFSTOR The plant was shut down on April 30, 1987. Reactor defueling was completed June 11, 1987.

Since the plant shut down, some systems have been secured. Additional systems will be shut down following determination of layup methodology. Others are awaiting changes to plant Technical Specifications. Section 5.2 discussed the plant systems and their status.

In addition to preparation of this Decommissioning Plan, proposed revisions to Technical Specifications, the Security Plan, the Emergency Plan, and the Quality Assurance Program Description have been completed. An addendum to the Environmental Report and a preliminary DECON plan have also been submitted.

7.2 SAFSTOR MODIFICATIONS The LACBWR staff reviewed the facility to determine if any modifications should be implemented to enhance safety or improve monitoring during the SAFSTOR period while fuel is stored onsite. Some modifications were evaluated as being beneficial and therefore have been performed.

The majority involve the Fuel Element Storage Well System (FESW). A redundant FESW level indicator has been added. A second remote manually- operated FESW makeup line has been installed, which supplies water from the Overhead Storage Tank. Also, a local direct means of measuring FESW water level has been installed.

The air activity monitoring system has been replaced with new equipment. The gas activity monitors have been recalibrated to a Kr-85 equivalent. Kr-85 will be the predominant gaseous isotope during the SAFSTOR period.

D-PLAN 7-1 November 2003

8. HEALTH PHYSICS - (cont'd) 8.5.1 Portable Instruments There will be sufficient types and quantities of portable instruments to provide adequate beta, gamma, and alpha surveys at LACBWR. This equipment will have the ability to detect these types of radiation over the potential ranges that will be present during SAFSTOR. Portable dose rate instruments will be source checked prior to use, and they will be calibrated semiannually.

8.5.2 Installed Instrumentation There will be sufficient types and quantities of installed instrumentation to provide continuous in-plant and effluent release monitoring. This will assure the safe reliable monitoring of both area dose rates and airborne activity concentration throughout the area. These instruments will be response tested monthly and calibrated once every 18 months.

8.5.3 Personnel Monitoring Instrumentation Friskers and personnel instrumentation monitors will be provided throughout the plant to provide personnel contamination monitoring. These monitors will be of the type and sensitivities necessary to minimize the spread of in-plant contamination and prevent the introduction of contamination to outside areas. This equipment will be checked daily during normal workdays and calibrated semiannually.

8.5.4 Counting Room Instrumentation Laboratory equipment will be available to perform gross alpha and beta analyses and gamma isotopic analyses of samples collected in the plant. There will also be equipment available in a low background area to provide adequate analysis of environmental samples. A quality control program will be in effect for this equipment to ensure the accurate and proper operation of the equipment. Gross alpha/beta counters will be calibrated annually. The HPGe detectors will be calibrated every two years.

8.6 RADIOACTIVE WASTE HANDLING AND DISPOSAL Radioactive waste generated at LACBWR during the SAFSTOR period will primarily consist of the following:

a) Resin b) Dry active waste (DAW) c) Dismantlement (Metallic)

Radioactive waste generation will be maintained as low as possible to minimize the volume of material requiring reprocessing and disposal.

D-PLAN 8-9 November 2003

8. HEALTH PHYSICS - (cont'd) 8.6.1 Resin Spent resin will be transferred to the spent resin receiving tank where it will be held until there is a sufficient quantity available for shipment to an approved processing facility. The resin will be transferred to an approved shipping container where it will be dewatered and made ready for shipment.

8.6.2 Dry Active Waste (DAW)

Any material used within the restricted area will be considered radioactive and will be disposed of as DAW, unless it can be demonstrated to be within established releasable limits. The generation of this material will be maintained as low as possible to reduce the total waste volume generated onsite. The material generated will be placed into approved shipping containers.

8.6.3 Dismantlement (Metallic)

During the SAFSTOR period, LACBWR employees will pursue limited dismantlement of the facility. This project will generate metallic wastes from system removal. This metallic waste will be placed in approved shipping containers and sent to an approved reprocessor.

Disposal of all radioactive waste will be in accordance with all pertaining guidelines.

8.7 RECORDS Records generated in the performance of the radiation protection program will be maintained as required to provide the necessary documentation of the program and in accordance with the QAPD. These records will be maintained in a designated storage area.

8.8 INDUSTRIAL HEALTH AND SAFETY LACBWR will continue to participate in Dairyland Power Cooperative's industrial safety program as prescribed by the DPC Safety Department. These programs will include:

a) Accident prevention b) Hazardous waste management and control c) Asbestos control d) Hearing conservation D-PLAN 8-10 November 2003

9. SAFSTOR ACCIDENT ANALYSIS

9.1 INTRODUCTION

The probability of an accident occurring during the SAFSTOR period is considerably less than during plant operation. The focus of the potential accidents has also changed. During operation, the focus was on minimizing the plant transient and cooling the reactor core. During SAFSTOR, the only major concern is protecting the fuel in the Fuel Element Storage Well.

The fuel in the well, while not benign, is not as much a hazard as the fuel in the operating reactor was. Since April 30, 1987, the fission product inventory has decreased and the decay heat generation is significantly less. These factors reduce the consequences of any accident affecting the fuel. As time passes, the consequences will continue to decrease.

The reactor's design basis accidents were reviewed to determine which could still occur during SAFSTOR. Some other accident scenarios which were not previously considered design basis accidents were also evaluated. A list of 8 postulated accidents was identified. These events are:

• Spent Fuel Handling Accident

• Shipping Cask or Heavy Load Drop into FESW

• Loss of FESW Cooling

• FESW System Pipe Break

• Uncontrolled Liquid Waste Discharge

• Loss of OfMsite Power

• Earthquakes

• Wind and Tornado Each of these postulated events was evaluated based on the revised plant status to identify their potential consequences during the SAFSTOR period. The following sections discuss these accidents.

One additional event involving fire was examined. Fire protection is covered in Section 6.9.

The potential safety consequences of any fire scenario fall within the scope of other evaluated events.

9.2 SPENT FUEL HANDLING ACCIDENT This accident postulates a fuel assembly falling from the hoist into the Fuel Element Storage Well. The probability of this accident is extremely small, since minimal fuel handling will be performed during the SAFSTOR period until the fuel assemblies are removed from the FESW.

Periodic inspections may be conducted during the years the fuel remains onsite. In the almost 20 years of operation and associated fuel handling at LACBWR, no fuel assemblies were ever dropped.

In this event, it is assumed that the cladding of all the pins in two fuel assemblies ruptures. The fuel handling crew evacuates when the local area radiation monitor alarms. Reactor Building ventilation dampers would be closed manually from the Control Room on high activity, but for this analysis, no containment integrity is assumed.

D-PLAN 9-1 November 2003

9. SAFSTOR ACCIDENT ANALYSIS - (cont'd)

The assumptions used in evaluating this event during SAFSTOR were similar to those used in the FESW reracking analyses.1.2 The fuel inventory calculated for October 1987 was used. The only significant gaseous fission product available for release is Kr-85. The plenum or gap Kr-85 represents about 15% (215.7 Curies) of the total Kr-85 in the fuel assembly. However, for conservatism and commensurate with Reference 1, 30% of the total Kr-85 activity, or 431.4 Curies, is assumed to be released in this accident scenario. (Due to decay, as of October 2003 only 35.6% of the Kr-85 activity remains - 153.5 Curies.)

No credit was taken for decontamination in the FESW water or for containment integrity, so all the activity was assumed to be released into the environment. Meteorologically stable conditions at the Exclusion Area Boundary (1109 ft, 338m) were assumed, with a release duration of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> commensurate with 10 CFR 100 and Regulatory Guides 1.24 and 1.25.

A stack release would be the most probable, but a ground release is not impossible given certain conditions. Therefore, offsite doses were calculated for 3 cases. The first is at the worst receptor location for an elevated release, which is 500m E of the Reactor Building. The next case is the dose due to a ground level release at the Exclusion Area Boundary. The maximum offsite dose at the Emergency Planning Zone boundary 3 for a ground level release is also calculated. Adverse meteorology is assumed for all cases.

Elevated Release Average Kr-85 Release Rate 431.4 Curies = 6.00 E-2 Ci/sec 2 hrs. x 3600 sec/hr X

Worst Case Q for 0-2 hours at 500m E = 2.3 E-4 sec/M3 Kr-85 average concentration at 500m E 6.00 E-2 Ci/sec x 2.3 E4 sec/mn = 1.38 E-5 Ci/m' Immersion Dose Conversion at 500m E Kr-85 Gamma Whole Body Dose Factor (Regulatory Guide 1.109) 1.61 E+1 mRem/vr x 106 pCi x 1.142 E4 yr = 1,839 mRemfhr PCi/M3 Ci hr Ci/M3 Whole Body Dose at 500m E 1839 mRem/hr x 1.38 E-5 Ci/M3 x 2 hr = 0.05 mRem (as of 10/03= 0.02 mRem) l Ci/M3 D-PLAN 9-2 November 2003

- (cont'd)

9. SAFSTOR ACCIDENT ANALYSIS K-' Guide 1.109)

Kr-85 Beta/Gamma Skin Dose Factor (Regulatory 1.34E+3 mRernyr x1 xl142E-4 yr =1.53E5 CiGm 3 pCi/mr 3 Ci hr Skin Dose at 500m E of 10/03 = 1.5 mRem) xRem/hr- 5 Ci/m x 2hr = 4.2 mRem (as 3

1.53 E5 x1.38E CiGm 3 Ground Level Release at EAB 338m SSE using Regulatory Guide 1.25 Worst Case X for 2 hrs at 338m NE or Q

2.2 E-3 sec m3 Skin Dose at 339m Whole Body Dose at 338m Ku 10/87 = 40.4 mRem 10/87 = 0.49 mRem 10/03 = 14.4 mRem I 10/03 = 0.17 mRem Planning Zone Boundary Ground Level Release at Emergency Worst Case - for 2 hrs at 100m E Q

1.02 E-2 sec m3 Skin Dose at 100m E Whole Body Dose at 100m E 10/87 = 187 mRem 10/87 = 2.25 mRem 10/03 = 66.6 mRem I 10/03 = 0.80 mRem maximum whole body dose is more than a factor of 30,000 below I As can be seen, the estimated period.

100 dose limit of 25 Rem (25,000 mRem) to the whole body within a 2-hour the 10 CFR 9-3 November 2003 D-PLAN

9. SAFSTOR ACCIDENT ANALYSIS - (cont'd) 9.3 SHIPPING CASK OR HEAVY LOAD DROP INTO FESW This accident postulates a shipping cask or other heavy load falling into the Fuel Element Storage Well. Reference 1 stated that extensive local rack deformation and fuel damage would occur during a cask drop accident, but with an additional plate (installed during the reracking) in place, a dropped cask would not damage the pool liner or floor sufficiently to adversely affect the leak- tight integrity of the storage well (i.e., would not cause excessive water leakage from the FESW).

For this accident, it is postulated that all 333 spent fuel assemblies located in the FESW are damaged. The cladding of all the fuel pins ruptures. The same assumptions used in the Spent Fuel Handling Accident (Section 9.2) are used here. A total of 35,760 Curies of Kr-85 is released within the 2-hour period. The doses calculated are as follows. (Due to decay, as of Oct. 2003 only 35.6% of the Kr-85 activity remains - 12,731 Curies.) I Elevated Release Whole Body Dose at 500m E Skin Dose at 500m E 10/87 = 4.2 mRem 10/87 = 350 mRem 10/03 = 1.5 mRem 10/03 = 124.6 mRem I Ground Level Release at EAB Whole Bodv Dose at 338m Skin Dose at 338m 10/87 = 40.2 mRem 10/87 = 3.34 Rem 10/03 = 14.3 mRem 10/03 = 1.19 Rem I Ground Level Release at Emergency Planning Zone Boundary Whole Body Dose at I00m E Skin Dose at I 00m E 10/87 = 186 mRem 10/87 = 15.6 Rem 10/03 = 66.2 mRem 10/03 = 5.6 Rem I As can be seen, the estimated offsite doses for the cask drop accident are below the 10 CFR 100 limits. The postulated maximum whole body dose is more than a factor of 375 below the I 10 CFR 100 limit of 25 Rem (25,000 mRem).

D-PLAN 94 November 2003

9. SAFSTOR ACCIDENT ANALYSIS - (cont'd) 9.4 LOSS OF FESW COOLING This accident postulates a loss of FESW cooling. The most likely causes of a loss of cooling are:

1) Both FESW pumps fail or FESW piping has to be isolated for maintenance;

2) The Component Cooling Water (CCW) System is out of service due to failure of both pumps or other reason. The CCW System removes heat from the FESW cooler.

3) The Low Pressure Service Water (LPSW) System is out of service due to failure of both pumps or other reason. The LPSW System removes heat from the CCW coolers.

If the third possibility is the cause, cooling to the CCW coolers can be restored by cross-connecting the High Pressure Service Water System to the coolers, in lieu of LPSW.

After the final discharge of fuel to the FESW, a conservative calculation of the FESW heatup rate was performed using the estimated decay heat source in the spent fuel on January 1, 1988.

This calculation indicated that coolant boiling could occur approximately 5 days after the loss of cooling.

In July 1993, a test was conducted to determine the actual heat-up rate of the FESW with all cooling and coolant circulation to the pool isolated. This test, as documented in LACBWR Technical Report, LAC-TR-137, showed that the pool temperature increased from 800F to only 1140F in 15.5 days. The test was terminated at 1141F to limit increasing radioactivity in the pool water, but extrapolation of the data indicates the temperature would stabilize at approximately 150 0 F.

Substantial time is therefore available for restoration of FESW cooling. No immediate action is necessary during this postulated accident.

9.5 FESW PIPE BREAK This accident postulates a break in the FESW system piping, other than in the pump discharge piping between the redundant check valves and the pool liner. A load analysis was performed on this approximately 20 feet of piping. It was concluded that all stresses are within ASME Code allowable. (Reference 1 calls this line the spent fuel pool drain line.) The series check valves were added during the 1980 FESW reracking. In November 1999, the FESW return line was rerouted to enter the top of the storage well and extends down to discharge at elevation 695 ft.

The bottom inlet line now ends at the biological shield wall and is sealed with a welded plug.

If the postulated break occurs, the lowest the FESW could drain is approximately 679 ft. At this level all spent fuel will remain covered. The control rods which are currently stored in the fuel racks will be partially uncovered. The tops of the control rods are about elevation 686 ft.

D-PLAN 9-5 November 2003

9. SAFSTOR ACCIDENT ANALYSIS - (cont'd)

The operator would be alerted to this accident by receipt of the FESW Level Lo/High alarm.

Any makeup water added may run out the break, depending on the size of the break.

A calculation has been performed to determine the radiation levels due to the exposed control rods. In the vicinity of most of the FESW piping and isolation valves, the radiation dose would not be substantially increased due to the loss of water.

A repair team should be able to access the break location or piping isolation valves and either isolate the break or effect temporary repairs. FESW level could then be restored to normal.

There would be no immediate urgency to restore the level. The partially uncovered control rods only create a local problem. No offsite release is associated with this event. Active FESW cooling would be lost during this accident, but as discussed in Section 9.4, considerable time is available to take action. Due to the lesser water volume to act as the heat sink and reduced fuel coverage, less time would be available to restore cooling during this accident scenario than in just a loss of FESW cooling event, but boiling would not commence for more than one (1) day.

As with the loss of FESW cooling event, if water is added to the FESW, any consequences of water heatup can be delayed or prevented. Water can be added from the Demineralized Water System or the Overhead Storage Tank.

9.6 UNCONTROLLED WASTE WATER DISCHARGE This accident postulates that an operator starts pumping a Waste Water or Retention Tank to the river which is not sampled or for which the sample was incorrectly analyzed. If the contents of the tank are of normal activity, this event will not be detected until the lineup is being secured after pumping, if then.

If the liquid in the tank is of high activity, the liquid waste monitor will alarm and the Auto Flow Control Valve (54-22-002) automatically will close, terminating the discharge. If the automatic valve does not close, an operator will try to close it from the Control Room. If it cannot be closed, an operator will close a local valve or secure the pump to terminate the discharge.

After the discharge is terminated, a sample of the tank will be taken to analyze the uncontrolled release. Waste water is diluted by LACBWR Circulating Water and Low Pressure Service Water flow, in addition to circulating water from the adjacent coal-fired plant, prior to being discharged into the river.

9.7 LOSS OF OFFSITE POWER This accident postulates a loss of offsite power. If both Emergency Diesel Generators and a High Pressure Service Water (HPSW) Diesel start, FESW cooling can be provided and adequate instrumentation is available to monitor FESW conditions from the Control Room. All that is needed is for an operator to cross-connect HPSW to the Component Cooling Water (CCW) coolers.

D-PLAN 9-6 November 2003

LAC-TR-138 LACBWR INITIAL SITE CHARACTERIZATION SURVEY FOR SAFSTOR By:

Larry Nelson Health and Safety Supervisor October 1995 Revised: November 2003 Dairyland Power Cooperative 3200 East Avenue South La Crosse, WI 54601

LAC-TR-138 PAGE 24 ATTACHMENT 1 SPENT FUEL RADIOACTIVITY INVENTORY Decay-Corrected to October 2003 I HalfLife Activity HalfLife Radionuclide (Years) (Curies) Radionuclide (Years) (Curies)

Ce-144 7.801 E-1 2.11 Sr-90 2.770 E + 1 7.72E5 Cs-137 3.014 E+l 1.1 6E6 Pu-241 1.440 E+1 5.32E5 Ru-106 1.008 E+0 29.2 Fe-55 2.700 E+0 9.11E3 Cs-134 2.070 E+0 1.66E3 Ni-59 8.000 E+4 287 Kr-85 1.072 E+l 4.18E4 Tc-99 2.120 E+5 276 Ag-I 10m 6.990 E-1 0.02 Sb-125 2.760 E+0 5.17 Co-60 5.270 E+0 8.01E3 Eu-155 4.960 E+0 18.5 Pm-147 2.620 E+0 632 U-234 2.440 E+5 63.7 Ni-63 1.000 E+2 3.17E4 Am-243 7.380 E+3 63 Am-241 4.329 E+2 1.44E4 Cd-113m 1.359 E+l 7.95 Pu-238 8.774 E+1 1.11 E4 Nb-94 2.000 E+4 15.9 Pu-239 2.410 E+4 8.83E3 Cs-135 3.000 E+6 14.0 Pu-240 6.550 E+3 7.15E3 U-238 4.470 E+9 12.2 Eu-154 8.750 E+0 1.15E3 Pu-242 3.760 E+5 8.58 Cm-244 1.812 E+I 1.97E3 U-236 2.340 E+7 6.32 H-3 1.226 E+1 226 Sn-121m 7.600 E+1 3.84 Eu-152 1.360 E+1 228 Np-237 2.140 E+6 2.19 Am-242m 1.505 E+2 456 U-235 7.040 E+8 1.89 Sm-151 9.316 E+1 1.34 Sn-126 1.000 E+5 0.7 Se-79 6.500 E+4 0.55 I-129 1.570 E+7 0.39 Zr-93 1.500 E+6 0.11 Total Activity = 2.60 E6 Curies I

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PAGE 25 ATTACHMENT 2 CORE INTERNALJRX COMPONENT RADIONUCLIDE INVENTORY - OCTOBER 2003 Estimated Curie Content Other Nuclides Components Co-60 Fe-55 Ni-63 T, > 5y Total In Reactor Fuel Shrouds (72 Zr, 8 SS) 2,758 1,087 1,212 8 5,065 Control Rods (29) 609 83 732 8 1,432 Core Vertical Posts (52) 158 10 56 2 226 Core Lateral Support Structure 1,136 369 690 4 2,1.99 Steam Separators (16) 4,171 1,356 2,532 15 8,074 Thermal Shield 180 59 110 0.5 350 Pressure Vessel 43 18 9 70 Core Support Structure 805 262 489 3 1,559 Horizontal Grid Bars (7) 22 7 13 42 Incore Monitor Guide Tubes 38 3 548 3 592 Total 9,920 3,254 6,391 43.5 19,609 In FESW Fuel Shrouds (24 SS) 1,705 258 2,136 13 4,112 Fuel Shrouds (73 Zr) 114 17 85 2 218 Control Rods (10) 431 41 815 9 1,296 Start-up Sources (2) 396 39 140 2 577 Total 2,646 355 3,176 26 6,203

C C LAC-TR-138C PAGE 26 ATTACHMENT 3 PLANT SYSTEMS INTERNAL RADIONUCLIDE INVENTORY - OCTOBER 2003 I Nuclide Activity, in uoCi System Total Plant System 4 Fe-55 4 Alpha 4 Co-60 4 Cs-137

- -- 4 iCi Content CB Ventilation 27 200 118 345 Offgas -

upstream of filters SYSTEMIREMO VED Offgas -

downstream of filters SYSTEM REMOVED TB drains 289 40 2,125 3,473 5,927 CB drains 646 3 4,750 1,667 7,066 TB Waste Water 61 7 450 83 601 CB Waste Water 3,570 79 26,250 1,598 31,497 Main Steam 4,420 290 32,500 37,210 Turbine 16 2 116 139 271 Primary Purification 1,513 12 11,125 12,650 Emergency Core Spray SYSTEM REMOVED Overhead Storage Tank 221 34 1,625 542 2,422 Seal Inject 27 4 200 38 269

C c LAC-TR- 138 C PAGE 27 ATTACHMENT 3 PLANT SYSTEMS INTERNAL RADIONUCLIDE INVENTORY - OCTOBER 2003 - (cont'd) I Nuclide Activity, in uiCi System Total Plant System Fe-55 Alpha Co-60 Mn-54 iCi Content Decay Heat 1,700 490 12,500 14,690 Boron Inject SYSTEM REMOVED Reactor Coolant PASS SYSTEM REMOVED Alternate Core Spray 340 94 2,500 2,934 Shutdown Condenser SYSTEM REMOVED Control Rod Drive Effluent 2,550 720 18,750 22,020 Forced Circulation 25,500 7,000 187,500 1 220,001 Reactor Vessel and Internals 42,500 12,000 312,500 2 367,002 Condensate after beds & Feedwater SYSTEM REMOVED Condensate to beds SYSTEM REMOVED

C C LAC-TR-138 C PAGE 28 ATTACHMENT 3 PLANT SYSTEMS INTERNAL RADIONUCLIDE INVENTORY - OCTOBER 2003 - (cont'd)

=__________ Nuclide Activity, in fLC System Total Plant System Fe-55 Alpha Co-60 Mn-54 Cs-137 pLCi Content Fuel Element Storage Well System 14,450 390 106,250 121,090 Fuel Element Storage Well

- all but floor 22 5 163 3,195 3,385 Fuel Element Storage Well floor 442,000 7,600 3,250,000 1 28,477 3,728,078 Resin lines 2,210 100 16,250 18,560 Main Condenser 187,000 8,500 1,375,000 10 1,570,510