ML060690401

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Annual Radioactive Effluent Report and Radiological Environmental Monitoring Report
ML060690401
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 02/28/2005
From: Berg W
Dairyland Power Cooperative
To:
Document Control Desk, NRC/FSME
References
LAC-13900
Download: ML060690401 (65)


Text

WILLIAM L. BERG President and CEO DAIRYLAND POWER C O O P E R A T I V E February 28, 2005 In reply, please refer to LAC-13900 DOCKET NO. 50-409 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Dairyland Power Cooperative La Crosse Boiling Water Reactor Possession-Only License No. DPR-45 Annual Radioactive Effluent Report and Radiological Environmental Monitoring Report

REFERENCES:

(1) NRC Letter, Keppler to Linder, dated August 12, 1983, Inspection Report 50-409/83-10 (DRMSP)

(2) LACBWR Technical Specifications 6.4.2, 6.5.1.l.c & d In accordance with 10 CFR 50.36a(a)(2), this letter serves to transmit to you the Radioactive Effluent Report and Radiological Environmental Monitoring Report for the La Crosse Boiling Water Reactor (LACBWR) for 2005.

If you have any questions, please contact us.

Sincerely, DAIRYLAND POWER COOPERATIVE William L. Berg, President & CEO WLB:LLN:tmo Enclosures cc/enc: Peter Lee, Ph.D., NRC Reg. HI, Decommissioning Branch Kristina Banovac, NRC Project Manager Don Hendrikse, Wisc. Div. of Health tr rrsso /

j7-E/7 A Touchstone Energyo Cooperative K*tA r&@

3200 East Ave. S.

  • PO Box 817 . La Crosse, WI 54602-0817 . 608-787-1258 . 608-787-1469 fax . www.dairynet.com

RADIOACTIVE EFFLUENT REPORT AND RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT FOR THE LA CROSSE BOILING WATER REACTOR (LACBWR)

(January 1 to December 31, 2005)

DAIRYLAND POWER COOPERATIVE 3200 EAST AVENUE SOUTH LA CROSSE WI 54602-0817

TABLE OF CONTENTS SECTION A: RADIOACTIVE EFFLUENT REPORT Section Title E Introduction............:.......................................................................... 1 1.0 Regulatory Limits ................................................. 2 2.0 Effluent Release Concentration Limit ............................................... 4 3.0 Average Energy ................................................. 4 4.0 Analytical Methods ................................................. 4 5.0 Batch Releases ................................................. 6 6.0 Abnormal Releases ................................................. 6 7.0 Estimated Total Analytical Error ................................................ 6 8.0 Offsite Dose Calculation Summary and Conclusions ............. .......... 12 9.0 Offsite Dose Calculation Manual (ODCM) Review ........................... 13 10.0 Process Control Program (PCP) Review .......................................... 13 SECTION B: RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT Section Title Eaqe Introduction.......................................................................................I 1.0 Sample Collection .2 2.0 Results of the 2005 Radio-Environmental Monitoring Survey 2 3.0 Conclusions .4 4.0 Interlaboratory Comparison Program Results. 5 i

TABLE OF CONTENTS TABLES SECTION A: RADIOACTIVE EFFLUENT REPORT Table No. Title Page 1A Effluent and Waste Disposal - Gaseous Effluents Summation of All Releases ....................... ......................... 7 1B Effluent and Waste Disposal - Gaseous Effluents Elevated Release ................................................ 8 2A Effluent and Waste Disposal - Liquid Effluents Summation of All Releases. 9 2B Effluent and Waste Disposal - Liquid Effluents. 10 3 Effluent and Waste Disposal Annual Report - 2005 Solid Waste and Irradiated Fuel Shipments ....................................... 11.........

SECTION B: RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT Table No. Title Page 5 Sample Frequency and Analysis of Radio Environmental Samples. 10 6 Permanent Environmental Monitoring Station Locations .11 7 Environmental TLD Locations .12 8 Radio-Environmental Samples Collected January-December 2005. 13 9 Quarterly Thermoluminescent Dosimeter Dose Measurements in the LACBWR Vicinity .14 10 Weekly Gross Beta Air Particulates in the LACBWR Vicinity .15 11 Air Particulate Composite Results .18 12 Results of Analysis of Mississippi River Water in the Vicinity of LACBWR ................................................ 24 13 Results of Analysis of Mississippi River Sediment in the Vicinity of LACBWR .30 14 Fish Sample Activity in the Vicinity of LACBWR .31 ii

TABLE OF CONTENTS FIGURES No. Title Page FIGURE 1 LACBWR Property Map ........................................................... 6 FIGURE 2 Permanent Environmental Monitoring Station Location............ 7 FIGURE 3 LACBWR Environmental Dose Assessment Locations............ 8 FIGURE 4 LACBWR Environmental Dose Assessment Locations............ 9 iii

SECTION A RADIOACTIVE EFFLUENT REPORT

INTRODUCTION:

The La Crosse Boiling Water Reactor (LACBWR), also known as Genoa Station No. 2, is located on the east bank of the Mississippi River near Genoa, Vernon County, Wisconsin. The plant was designed and constructed by the Allis-Chalmers Manufacturing Company. It was completed in 1967 and had a generation capacity of 50 MW (165 MW(th)). The reactor is owned by Dairyland Power Cooperative (DPC).

The reactor went critical in July 1967 and first contributed electricity to DPC's system in April 1968. After completing full power tests in August 1969, the plant operated between 60% and 100% full power, with the exception of plant shutdowns for maintenance and repair.

In April of 1987 plant operation was ceased. The reactor is presently defueled and in a SAFSTOR mode. In August of 1987 a possession-only license was received.

In accordance with LACBWR Technical Specifications 6.5. 1.1.d and in compliance with 10 CFR 50.36a(a)(2), this document is the Radioactive Effluent Report for the period January 1 through December31, 2005.

1

EFFLUENT AND WASTE DISPOSAL REPORT (Supplemental Information)

FACILITY: La Crosse Boiling Water Reactor LICENSEE: Dairyland Power Cooperative DOCKET NO. 50-409 1.0 REGULATORY LIMITS

a. Gaseous Effluent Release Limits:

LACBWR's stack effluent release limitations for gaseous effluent releases of radioactive material limits the release rate of the sum of the individual radionuclides, so that the dose rates to members of the public beyond the Effluent Release Boundary do not exceed 500 mRem/year to the whole body, 3000 mRemlyear to the skin from noble gases, and 1500 mRem/year to a critical organ from H-3 and particulates with half-lives greater than 8 days as per the requirements of the Offsite Dose Calculation Manual (ODCM).

Also, in accordance with 10 CFR 50, Appendix I, the ODCM limitations for gaseous effluent radioactive material limit the air dose to a member of the public from noble gases in areas beyond the Effluent Release Boundary to less than 5 mRad gamma and 10 mRad beta per calendar quarter, and less than 10 mRad gamma and 20 mRad beta per calendar year. The dose limits from H-3 and particulates with half-lives greater than 8 days are less than 7.5 mRem per calendar quarter, and less than 15 mRem per calendar year to any organ.

Cumulative dose contributions from gaseous effluent releases are determined in accordance with the LACBWR Offsite Dose Calculations Manual.

2

EFFLUENT AND WASTE DISPOSAL REPORT - (contd)

b. Liquid Effluent Release Limits:

LACBWR's liquid effluent release limitations for liquid effluent releases are those concentrations specified in 10 CFR 20 Appendix B, Table 2, Column 2.

For alpha emitting radionuclides, the concentration is limited to a total activity concentration of 4.9E-9 pCi/ml, based upon an actual alpha emitting radionuclide analysis performed on a representative water sample. The values reported in tables 2A and 2B, Liquid Effluents, are based on dilution with the combination of LACBWR and Genoa Station No. 3 condenser cooling water flow prior to discharge to the Mississippi River. No credit is taken for further dilution in the mixing zone of the Mississippi River.

Also, in accordance with 10 CFR 50, Appendix I, the dose commitment to a member of the public from radioactive materials released in liquid effluents to areas beyond the Effluent Release Boundary are limited to less than 1.5 mRem whole body and 5.0 mRem organ dose per calendar quarter, and less than 3.0 mRem whole body and 10 mRem organ dose per calendar year via the critical ingestion pathway.

Cumulative quarterly and annual dose contributions from liquid effluent releases are determined for the adult fish ingestion pathway in accordance with the LACBWR Offsite Dose Calculation Manual.

c. Solid Radioactive Waste All solid radioactive wastes are handled in accordance with a Process Control Program as defined by LACBWR procedures in order to assure that all applicable transportation and burial site disposal requirements are met 3

EFFLUENT AND WASTE DISPOSAL REPORT - (contd) 2.0 EFFLUENT RELEASE CONCENTRATION LIMIT The Effluent Release Concentration used to calculate permissible release rates are obtained from 10 CFR 20, Appendix B. Table 2, Column 2.

3.0 AVERAGE ENERGY The release rate limits for LACBWR are not based on average energy.

4.0 ANALYTICAL METHODS

a. Liquid Effluents Liquid effluent measurements for gross radioactivity are performed by HPGe gamma isotopic analysis of a representative sample from each tank discharged. In addition, each batch discharged tank is analyzed for alpha and tritium activity concentration. A composite sample is created by collecting representative aliquots from each tank batch discharged during a calendar quarter. This composite is analyzed for Iron-55 and Strontium-90 by a contractor on a quarterly basis.
b. Airbome Particulates Airborne particulate releases are determined by HPGe gamma isotopic analysis. This analysis is performed by analyzing a glass fiber filter paper taken from the stack monitor which continuously isokinetically samples and monitors the stack effluent. This filter is changed and analyzed on an approximate weekly basis and analyzed within 7 days after removal. This filter is also analyzed for alpha activity. A quarterly composite of these filters is sent to a contractor for Sr-90 analysis.

4

EFFLUENT AND WASTE DISPOSAL REPORT - (contd)

c. Radioiodines Since the plant shutdown in April 1987, the 1-131/1-133 have decayed completely to stable elements. Amendment 66 to the LACBWR Technical Specifications, deleted the requirement for monitoring for iodine.
d. Fission and Activation Gases The concentration of radioactivity (pCi/cc) in gaseous releases from the stack is continuously monitored by two in line stack monitors. These gas concentrations (pCVcc) are corrected for pressure loss in the sampling system and averaged by the monitors microprocessor. The results are used along with the stack flow rate to obtain the daily gaseous release from the plant. Since the plant shutdown in April 1987, gaseous releases have been immeasurable. All fission gases except Kr-85 have decayed to stable elements.
e. Tritium Tritium releases are determined by taking a grab sample of the stack atmosphere at the effluent of the stack monitor. Tritium, as tritiated water, is removed from the sample stream by condensation, using a cold trap. The condensed water vapor Is then distilled and the distillate is analyzed for H-3 concentration (pCVcc), by Internal liquid scintillation spectrophotometry and the results are expressed in terms of tritium release rates. The tritium grab samples are obtained on at least a once/month basis unless the upper reactor cavity is flooded, at which time the sampling frequency is increased to at least once per 7 days.

5

EFFLUENT AND WASTE DISPOSAL REPORT - (contd) 5.0 BATCH RELEASES

a. Airborne All airborne effluent releases at LACBWR are from a single Continuous-Elevated Release Point.
b. Liquid All liquid effluent releases at LACBWR are batch releases. This is summarized as follows:

(1) Number of Batch Releases: 7 (2) Total Time Period for Batch Releases: 106 hours0.00123 days <br />0.0294 hours <br />1.752645e-4 weeks <br />4.0333e-5 months <br /> (3) Maximum Time Period for a Batch Release: 23.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (4) Average Time Period for a Batch Release: 15.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (5) Minimum Time Period for a Batch Release: 12.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> (6) Average Stream Flow Rate During Periods of Release of Effluent into a Flowing Stream: 47565 ft3 /sec 6.0 ABNORMAL RELEASES There were no abnormal releases of radioactivity in plant effluents.

7.0 ESTIMATED TOTAL ANALYTICAL ERROR The reported analytical results contain the following estimated errors:

Counting Error 95% Confidence Level Sampling Volume Error + 5%.

6

EFFLUENT AND WASTE DISPOSAL REPORT - (contd)

TABLE IA EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT 2005 GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES I UNIT QTR QTR QTR QTR TOTAL_

A. FISSION & ACTIVATION GASES

1. TOTAL RELEASE Ci O.00E+00 O.OOE+00 l O.oE+o00 O.OOE+00 O.OOE+00
2. AVERAGE RELEASE RATE FOR pCi 0.00OE+00 0.00E+00 O.OOE+00 O.OOE+00 PERIOD Sec _

B. IODINE 1-131 . No longer analyzed for.

C. PARTICULATES

1. PARTICULATES WITH HALF- Cl 1.08E-06 2.02E-07 1.72E-07 4.42E-07 1.90E-06 LIVES > 8 DAYS _
2. AVERAGE RELEASE RATE FOR pCV 1.39E-07 2.57E-08 2.16E-08 5.56E-08 PERIOD Sec I _
3. GROSS ALPHA RADIOACTIVITY Ci 2.80E-08 3.OOE-08 0.OOE+00 0.OOE+00 5.80E-08 D. TRITIUM
1. TOTAL RELEASE Ci l5.47E-03 J5.47E-03 T6.72E-03 l3.36E-03 2.10E-02
2. AVERAGE RELEASE RATE FOR piCV I7.03E-04 6.96E-04 18.45E-04 4.23E-04 PERIOD Sec E. PERCENTAGE OF ODCM DOSE UMITS FOR GASEOUS EFFLUENT RELEASES

___ QTR QTR QTR QTR YEARLY

1. NOBLE GAS RELEASE BETA M  % 0.00E+00 O.OOE+00 0.OOE+00 0.00E+00 0.00E+00
2. H-3 AND ALL RADIONUCLIDES IN PARTICULATE FORM WITH HALF-LIVES GREATER THAN 8 DAYS I GAMMA (Highest Organ)  % 7.82E-05 3.85E-05 4.18E-05 3.565-05 7.71 E-05 7

EFFLUENT AND WASTE DISPOSAL REPORT - (cont'd)

TABLE lB EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT 2005 GASEOUS EFFLUENTS - ELEVATED RELEASE I CONTINUOS MODE UNIT QTR QTR QTR QTR TOTAL NUCLIDES RELEASED

1. FISSION GASES KRYPTON-85 Ci O.OOE+00 O.OOE+0 0.OOE+00 O.OOE+00 O.OOE+00 TOTAL FOR PERIOD Ci 0.OOE+00 O.OOE+00 0.00E+00 O.OOE+00 O.OOE+00
2. IODINE 1-131 - Analysis no longer required.
3. PARTICULATES STRONTIUM-90 Ci 0.00E+00 O.OOE+00 0.OOE+00 O.OOE+00 O.OOE+00 CESIUM-134 Ci 0.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 CESIUM-137 Ci 1.08E-06 2.02E-07 9.90E-08 3.54E-07 1.74E-06 COBALT-60 Ci O.OOE+00 O.OOE+00 7.30E-08 8.80E-08 1.61 E-07 Ci ===-

Ci _ _ _ _ _ _ _ _ _ _ __ _ _ _ _

Ci 1.08E 06 2 - . 0 E 9E I TOTALS Ci 1.08E-06 2.02E-07 1.72E-07 4.42E-07 1.90E-0 8

EFFLUENT AND WASTE DISPOSAL REPORT - (cont'd)

TABLE 2A EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT 2005 LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES UNIT QTR QTR QTR QTR TOTAL A FISSION & ACTIVATION PRODUCTS

1. TOTAL RELEASE (NOT INCL. Ci 0.OOE+00 3.26E-03 3.63E-03 1.58E-03 8.47E-03 TRITIUM, GASES, ALPHA)
2. AVERAGE DILUTED pCV 0.OOE+00 3.03E-09 2.39E-9 1.44E-09 CONCENTRATION DURING ml PERIOD B. TRITIUM
1. TOTAL RELEASE Ci O.OOE+00 7.87E-03 8.93E-03 2.31 E-03 1.91 E-02
2. AVERAGE DILUTED ,CVU 0.OOE+00 7.33E-09 5.89E-09 2.1OE-09 CONCENTRATION DURING ml PERIOD C. DISSOLVED AND ENTRAINED GASES
1. TOTAL RELEASE Ci O.OOE+00 0.00E+00 0.OOE+00 0.OOE+00 O.OOE+00
2. AVERAGE DILUTED iCi 10.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 CONCENTRATION DURING ml PERIOD D. GROSS ALPHA RADIOACTMTY
1. TOTAL RELEASE Ci 0.00E+00 l 3.15E-06 l4.75E-06 l3.02E-06 7.77E-06 E. VOLUME OF WASTE Liters 0.OOE+00 4.24E+04 6.29E+04 4.33E+04 1.49E+05 RELEASED (PRIOR TO DILUTION)

F. VOLUME OF DILUTION WATER USED DURING PERIO D Liters II 0.OOE+00

_R_

1.79E+09 1.52+09 1.10E+09 I

3.69E+09 G. PERCENTAGE OF ODCM LIMITS FOR LIQUID RELEASES l QTR QTR QTR QTR YEARLY HIGHEST ORGAN __ l 0.00 1.27 0.92 0.42 1.31 WHOLE BODY __ 0.00 2.66 1.94 0.89 2.75 9

EFFLUENT AND WASTE DISPOSAL REPORT - (conrd)

TAB3LE 2B EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT 2005 LIQUID EFFLUENTS NUCLIDES RELEASED UNIT QTR QTR QTR QTR MANGANESE-54 Ci O.OOE+00 0.00E+00 O.OOE+00 O.OOE+00 IRON-55 Ci 0.OOE+00 3.40E-06 4.77E-06 4.30E-6 COBALT-60 Ci O.OOE+00 9.48E-05 2.88E-4 6.35E-05 STRONTIUM-90 Ci O.OOE+00 4.17E-05 3.49E-05 4.29E-5 CESIUM-134 Ci O.OOE+00 0.00E+00 O.OOE+00 O.OOE+00 CESIUM-137 Ci O.OOE+00 3.16E-03 3.30E-03 1.52E-03 TOTAL FOR PERIOD Ci O.OOE+OO 3.30E-03 3.63E-03 1.63E-3 (ABOVE)

KRYPTON-85 Ci O.OOE+00 O.OOE+00 0.OOE+00 O.OOE+00 10

EFFLUENT AND WASTE DISPOSAL REPORT - (conft'd)

TABLE 3 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT - 2005 SOLID WASTE AND IRRADIATED FUEL SHIPMENTS A. SOLID WASTE SHIPPED OFFSITE FOR DISPOSAL (Not Irradiated Fuel)

UNIT 6-MONTH 6-MONTH TOTAL

1. TYPE OF WASTE PERIOD PERIOD
a. SPENT RESINS, FILTER SLUDGES, m30 0 0 EVAPORATOR BOTTOMS, ETC Ci 0 0 0
b. DRYCOMPRESSIBLE WASTE, m3 71.05 87.6 158.65 CONTAMINATED EQUIPMENT, ETC Ci 0.051 0.136 0.187 C. IRRADIATED COMPONENTS, CONTROL m3 0 0 0 RODS, ETC Ci 0 0 0
d. OTHER (DESCRIBE) m 0 0 0 ci 0 0 0
2. ESTIMATE OF MAJOR NUCLIDE PERCENT 06-MONTH 6-MONTH COMPOSITION (BY TYPE OF WASTE) OF TOTAL PERIOD PERIOD
_ :  : hbyCURIES CURIES Co-60 51.1 2.65E-2 6.92E-2 Fe-55 11.7 5.86E-3 1.61 E-2 Ni-63 24.4 1.20E-2 3.37E-2 Pu-241 1.7 8.22E-4 2.31 E-3 H-3 8.8 4.79E-3 1.17E-2 C-14 1.2 6.69E-4 1.63E-3 Eu-152 0.8 4.30E-4 1.05E-3
3. SOLID WASTE DISPOSITION NO. OF SHIPMENTS MODE OF TRANSPORTATION DESTINATION 7 Sole Use Duratek (Oak Ridge, TN)

B. IRRADIATED FUEL SHIPMENTS (DISPOSITION)

NO OF SHIPMENTS MODE OF TRANSPORTATION DESTINATION NONE 11

EFFLUENT AND WASTE DISPOSAL REPORT - (cont'd)

8. 0 OFFSITE DOSE CALCULATIONS

SUMMARY

AND CONCLUSIONS:

a. Gaseous Effluent Releases The maximum quarterly offsite gamma dose due to noble gases was 0.00 mRad. The cumulative 2005 annual offsite gamma dose due to noble gases was 0.00 mRad.

The maximum quarterly offsite beta dose due to noble gases was 0.00 mRad. The cumulative 2005 annual offsite beta dose due to noble gases was 0.00 mRad.

The maximum quarterly offsite dose to any organ from the release of H-3 and all radionuclides in particulate form with half-lives greater than 8 days was approximately 5.87E-6 mRem. The cumulative 2005 annual maximum organ dose from these radionuclides was also approximately 1.46E-5 mRem.

The highest historical annual average X/Q equal to 1.82 E-6 sec/im3 for the period 1985-1987 for the worst case offsite receptor location, in accordance with the ODCM, was used to calculate these offsite dose values.

b. Liquid Effluent Releases The maximum quarterly organ dose from liquid releases was approximately 6.35E-2 mRem. The cumulative 2005 annual organ dose was approximately 1.31 E-1 mRem. The maximum quarterly total body dose for liquid releases was approximately 4.01 E-2 mRem, and the cumulative 2005 annual total body dose was approximately 8.26E-2 mRem.
c. Conclusion All calculated offsite doses were below ODCM limits.

12

EFFLUENT AND WASTE DISPOSAL REPORT - (cont'd)

9. 0 OFFSITE DOSE CALCULATION MANUAL (ODCM) REVIEW The ODCM has been reviewed and updated in 2005. The revised ODCM pages with the. change justification is being included in this report for your review, as required by Technical Specifications. Most of the revisions were to change the use of Containment Building to Reactor Building.

10.0 PROCESS CONTROL PROGRAM (PCP) REVIEW The PCP has been reviewed and updated in 2005. The revised PCP pages are being included in this report for your review, as required by Technical Specifications. Two changes were made:

Page 2 - change building reference from Containment building to Reactor building.

Page 3 of 5, Attachment 1 - add 90-day notification required before shipping irradiated fuel.

13

SECTION B ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

INTRODUCTION:

The Radiological Environmental Monitoring (REM) Program is conducted to comply with the requirements of the ODCM and in accordance with 10 CFR 50 Appendix I. The REM Program provides measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides which could potentially lead to radiation doses to Members of the Public resulting from plant effluents. Environmental samples are taken within the surrounding areas of the plant and in selected control or background locations.

The monitoring program at the LACBWR facility includes monitoring of liquid and gaseous releases from the plant, as weft as environmental samples of surface air, river water, river sediment, milk, fish, and penetrating radiation.

The REM program theory supplements the Radioactive Effluent analyses by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways using the methodology of the Offsite Dose Calculation Manual (ODCM).

An Interdaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental samples are performed.

1

1.0 SAMPLE COLLECTION Environmental samples are collected from the area surrounding LACBWR at the frequencies outlined in the ODCM. A series of figures and tables are included in this report to better show LACBWR's environmental program.

FIGURE 1 This map includes the plant boundary, roads, other generation plants, and the relationship of the plant to the nearest local community.

FIGURE 2 This map shows the location of LACBWR's permanent environmental monitoring stations.

FIGURES 3&4 These maps show the location of LACBWR's TLDs.

TABLE 5 This table shows the sampling frequency of the various environmental samples and the analyses performed on these samples TABLE 6 This table shows the permanent monitoring stations used in LACBWR's environmental program.

TABLE 7 This table shows the TLD locations.

TABLE 8 This table shows the number of various samples collected and analyzed during 2005.

2.0 RESULTS OF THE 2005 RADIO-ENVIRONMENTAL MONITORING SURVEYS During 2005, activity levels in the local environment were normal, indicating no significant plant attributed radioactivity.

2.1 PENETRATING RADIATION The environmental penetrating radiation dose is measured by thermoluminescent dosimeters consisting of four lithium fluoride (LiF) chips.

These ThD's are changed on a quarterly basis and are sent to an outside contractor for reading. The TLD results for 2005 are shown on Table 9.

2

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd) 2.2 AIR PARTICULATE Air samples are collected continuously from various sites (see Table 6) around LACBWR. An air sampler is also located 18 miles north of the plant in La Crosse, Wisconsin, to act as a control station.

Particulate air samples are collected at the rate of approximately 30-60 Ipm with a Gelman Air Sampler. The air filter consists of a glass fiber filter with an associated pore size of approximately 0.45 pm. The particulate filters are analyzed weekly for gross beta activity with an internal proportional counter, and the monthly particulate composites are gamma analyzed for individual isotopic concentration.

TABLE 10 This table shows the weekly gross beta gamma activity concentration from the air particulate filters.

TABLE 11 This table shows the composite air particulate isotopic analysis.

Comparison between the control station at La Crosse and the other stations near LACBWR indicate that there was no significant plant attributable airborne particulate activity.

2.3 RIVER WATER River water is collected monthly. River water samples above, at, and below the plant site are collected and are gamma analyzed for isotopic concentration. The river water gamma isotopic analysis results are shown in Table 12. The results indicate that there is insignificant plant-attributable radionuclides in the river water.

3

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd) 2.4 SEDIMENT SAMPLES Sediment samples were collected twice per year above, at, and below the plant outfall. These samples were gamma analyzed and these results appear on Table 13. They indicated that small amounts of plant attributed radionuclides have accumulated in river sediments near the ouffall. The amount of radionuclide in this sediment has been declining significantly since plant shutdown.

2.5 FISH Fish samples were collected quarterly above and below the plant discharge. The results of gamma spectral analysis of edible portions of fish samples appear in Table 14. There has been no significant accumulation of plant attributed radionuclides in fish in the vicinity of LACBWR.

3.0 CONCLUSION

S All environmental samples collected and analyzed during 2005 exhibited no significant contribution from LACBWR.

4

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd) 4.0 INTERLABORATORY COMPARISON PROGRAM RESULTS During 2005, interlaboratory comparison samples were obtained from an outside contractor. The equipment used to analyze the environmental samples was tested against the contractors' results. The following is the result of this comparison.

ANALYSIS LACBWR CONTRACTOR RATIO

________ RESULTS RESULTS GROSS BETA 127 pCi 148 pCi 0.86 GROSS ALPHA 19.5 pCi 27.2 pCi 0.72 Ce-141 147pCi 154 pCi 0.95 Cr-51 120 pCi 133 pCi 0.90 Cs-134 49 pCi 60.2 pCi 0.81 Cs-137 125 pCi 132 pCi 0.96 Co-58 51 pCi 53.4 pCi 0.96 Mn-54 109 pCi 105 pCi 1.04 Fe-59 62 pCi 56.8 pCi 1.09 Zn-65 112 pCi 106 pCi 1.06 Co-60 75 pCi 76.2 pCi 0.98 H-3 14400 pCu/t 13200pCit 1.09 5

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

LUSIOI BOUI4DAI 1109 ft radiuw 1000 Soo . 0 1000 SCALE OF FEET T-101-N., R:3-W.

OF THE 5th PM. -

JEFFERSON TOWNSHIP HOUSTON COUNTY _,

MINNESOTA //  !

41 SEC. 5 T-12-N.

E. ISLAND 126 IS UNDER THI JURISDICTION OF UPPER MISSISSIPPI RIVER WILD LIFE AND FISH REFUGE.

INDICATES MILES ABOVE THE MOUTH OF THE OHIO RIVER.

FIGURE 1 - LACBWR PROPERTY MAP Erivironmental

=Sample 4n = Locations FIGURE 2 - PERMANENT ENVIRONMENTAL MONITORING STATION LOCATIONS (Refer to Table 6)

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

FIGURE 3 - LACBWR ENVIRONMENTAL DOSE ASSESSMENT LOCATIONS RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

LL (9, FIGURE 4 - LACBWR ENVIRONMENTAL DOSE ASSESSMENT LOCATIONS RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

TABLE 5 SAMPLE FREQUENCY AND ANALYSIS OF RADIO-ENVIRONMENTAL SAMPLES SAMPLE FREQUENCY ANALYSIS PERFORMED TLD (LIF) Dosimeters Quarterly Dose in mRem Particulate Air Glass Weekly Gross Beta and Gamma Fiber Filters Spectroscopy of Composites Monthly (HPGe-MCA)

Milk Obtain sample as directed if Gamma Spectroscopy abnormal stack particulate release occurs.

Sediment Twice per year Gamma Spectroscopy Fish Quarterly Gamma Spectroscopy River Monthly Gamma isotopic analysis and tritium (Liquid Scintillation Analyzer)

Vegetation Obtain sample as directed if Gamma Spectroscopy abnormal stack particulate release occurs.

10

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

TABLE 6 PERMANENT ENVIRONMENTAL MONITORING STATION LOCATIONS (Refer to Figure 2)

LOCATION I AIR NO. LOCATION SAMPLE 1 Radio Tower x 2 Dam No. 8 x 3 Trailer Court x 4 Crib House x 5 Main Office x 11

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

TABLE 7 ENVIRONMENTAL TLD LOCATIONS LOCATION NO. LOCATION 1 LA CROSSE MAIN OFFICE AIR SAMPLER BOX 2 DAM #8 AIR SAMPLER BOX 3 RADIO TOWER BUILDING AT AIR SAMPLER 4 TRAILER COURT AIR SAMPLER BOX 5 CRIBHOUSE AIR SAMPLER BOX 6 G-3 CONTROL ROOM 7 SW GATEPOST AT END OF G-3 DIKE 8 ON FENCE N. SIDE OF FISHERMAN'S ROAD 9 SITE ENTRANCE GUARD AREA 10 ON FENCE AT NE CORNER OF THE SWITCHYARD 11 ON N. SITE AREA FENCE GATE 12 G-1 CRIBHOUSE 13 ON MOORING WALKWAY WEST OF LACBWR #2 WAREHOUSE 14 G-3 COAL UNLOADING CRANE 15 POWER POLE ON BLUFF SIDE EAST OF PLANT 16 RESTRICTED AREA FENCE N. SIDE 17 RESTRICTED AREA FENCE E. SIDE 18 RESTRICTED AREA FENCE S. SIDE 19 RESTRICTED AREA FENCE SW CORNER 20 RESTRICTED AREA FENCE W. SIDE 21 RESTRICTED AREA FENCE NW CORNER 12

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (contd)

TABLE 8 RADIO-ENVIRONMENTAL SAMPLES COLLECTED JANUARY-DECEMBER 2005 TYPE OF SAMPLE NUMBER OF Penetrating Radiation (TLD's) 82 Air Particulate 260 River Water 36 Sediment 6 Fish 8 13

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

TABLE 9 QUARTERLY THERMOLUMINESCENT DOSIMETER DOSE MEASUREMENTS IN THE LACBWR VICINITY 2005 JANUARY - DECEMBER 2005 BACKGROUND CORRECTED STATION 1st QUARTER 2nd QUARTER 3rd QUARTER 4th QUARTER NO. mRem mRem mRem mRem 1 0 0 0 0 2 0 0 8.6 0 3 0 0 0 0 4 0 3.3 1.3 1.7 5 0 0.5 0.3 0.7 6 0 0 0 0 7 0 2.5 1.9 0 8 0 0 0 0 9 0 0 0.3 0 10 0 0 0 0 110 0 0 0 12 3.1 2.2 1.8 1.3 13 0 0 0 0 14 0 0 0 0 15 3.8 6.0 7.3 4.5 16 7.3 12.1 9.7 7.6 17 17.0 15.5 20.7 14.0 18 22.8 27.3 27.2 22.3 19 6.9 6.2 2.9 LOST 20 0.7 2.3 2.1 1.9 21 6.9 9.2 LOST 6.8 Station #1 (La Crosse Main Office) located approximately 16 miles north of LACBWR is considered the Control TLD.

14

TABLE 10 WEEKLY GROSS BETA AIR PARTICULATES IN THE LACBWR VICINITY (Reporting Level = 10 times Control Value)

COLLECTION LACBWR PLANT TRAILER COURT DAM #8 RADIO TOWER LA CROSSE DATE:: 3 pCi/mL pCilm p:/n p CONTROL 1/5/05 .031 + .003 .025 + .002 .025 + .003 .024 + .002 .018 + .003 1/12/05 .040 + .004 .032 + .002 .031 + .003 .037 + .003 .027 + .003 1/19/05 .027 + .003 .017 + .002 .027 + .003 .015 + .002 .020 + .003 1/26/05 .028 +.003 .017 +.002 .022 +.002 .015 +.002 .021 +.003 2/2/05 .019 + .003 .018 + .002 .017 + .002 .011 + .002 .018 + .003 2/9/05 .022 +.003 .021 +.002 .024 +.003 .017 +.002 .020 +.003 2/16/05 018 +.003 .015 +.002 .015 +.002 .015 +.002 .018 +.003 2/23/05 017 +.003 .018 +.002 .017 +.002 .014 +.002 .014 +.003 3/2/05 .021 +.003 .017 +.002 .015 +.002 .-015 +.002 .020 +.003 3/9/05 .019 + .003 .018 + .002 .021 + .002 .015 + .002 .020 + .003 3/16/05 .014 + .002 .013 + .002 .015 + .002 .011 + .002 .011 + .003 3/23/05 .011+.002 .009+.002 .011+.002 .011 +.002 .010 +.003 3/30/05 .021 + .002 .018 + .002 .021 + .002 .017 + .002 .017 + .003 4/6/05 .016 +.002 .014 +.002 .020 +.002 .017 +.002 .016 +.003 4/13/05 .013 + .002 .015 +.002 .015 + .002 .013 + .002 .013 + .003 4/20/05 .016 + .003 .018 + .002 .014 +.002 .013 + .002 .016 + .003 4/27/05 .010 +.003 .012 +.002 .012+.002 .01 0+ .002 .008 +.003 5/3/05 .012 + .003 .010 +.002 .011+ .002 .010 + .002 .009 + .003 5/10/05 .021 + .003 .023 + .002 .023 + .002 .020+ .002 .023 + .002 15

TABLE 10 WEEKLY GROSS BETA AIR PARTICULATES IN THE LACBWR VICINITY (Reporting Level = 10 times Control Value)

COLLECTION LACBWR PLANTS TRAILER COURT DAMK#8 ;:; RADIO TOWER LA CROSSE;:

DATE i i/rn 3 irp pi-n pci/rn3 CONTROL/

5/18/05 .008 + .002 .011 + .002 .010 + .002 .012 + .002 .009 + .001 5/25/05 .017 + .003 .014 + .002 .013+ .002 .015 + .002 .016 + .002 6/1/05 .010 + .002 .009 + .002 .010+ .002 .009 + .002 .010 + .001 6/7105 .017 +.002 .016 +.002 .016 +.002 .014 +.002 .018 +.002 6/15/05 .013 + .002 .014 + .002 .009 + .001 .012 + .002 .013 + .001 6/22/05 .012 +.002 .013 +.002 .016 +.002 .012 +.002 .015 +.002 6/29/05 .024 + .003 .023 + .002 .021 + .002 .023 + .002 .025 + .002 717/05 .015 +.002 .016 +.002 .015 +.002 .013 +.002 . .014 +.002 7/13/05 .028 +.003 .024 +.002 .021+.002 .023 +.002 .024 +.002 7/20/05 .028 +.003 .026 +.002 .023 +.002 .028 +.002 .026 +.002 7/27/05 .012 + .002 .013 + .002 .023 + .003 .015 + .002 .013 + .002 8/3/05 .021 + .003 .022 + .002 .022 + .002 .021 + .002 .023 + .002 8/10/05 .026 + .003 .023 + .002 .026 + .002 .020 + .002 .023 + .002 8/17/05 .015 + .003 .014 + .002 .016 + .002 .015 + .002 .015 + .002 8/24/05 .015 +.003 .015+.002 .016 +.002 .018 +.002 .017 +.002 8/31/05 .012 +.002 .015+.002 .018 +.002 .012 +.002 .017 +.002 917/05 .018 + .003 .021 + .002 .015 + .002 0.25 + .002 .025 + .002 9/14/05 .025 + .003 .028 + .003 .024 + .002 .033 + .003 .029 + .002 9/21/05 .020 + .003 .022 + .002 .020 + .002 0.19 + .002 .022 + .002 9/28/05 .016 + .003 .020 + .002 .018 + .002 .017 + .002 .020 + .002 16

TABLE 10 WEEKLY GROSS BETA AIR PARTICULATES IN THE LACBWR VICINITY (Reporting Level = 10 times Control Value)

COLLECTION LACBWR PLANT TRAILERKCOURT :2 DAM #8 RADIO TOWER LA CROSSE DATE pCi/rn 3 pCi/rn: i:rn3 pCi/n CONTROL 10/5/05 .016 + .003 .019 + .002 .019 + .002 .017 + .002 .020 + .002 10_12/05 .008 +.002 .009 +.002 .011 +.002 .008 +.001 .008 +.001 10/19/05 .015 + .003 .019 + .002 .023 + .002 .020 + .002 .018 + .002 10/26/05 .009 + .002 .010 + .002 .008 + .002 .016 + .002 .009 + .002 11/2/05 .023 + .003 .021 + .002 .025 + .003 .021 + .002 .024 + .002 11/09/05 .023 + .003 .030 + .003 .030 + .003 .027 + .002 .027 + .002 11/16/05 .014 +.003 Lost Filter .011 +.003 .012 +.002 .013 +.002 11/22/05 .002 + .007 .015 + .002 .015 +.003 .015 + .002 .015 +.002 11/30/05 .011+ .002 .011 + .002 .008 + .002 .009+ .002 .012+ .001 12/7/05 .013 +.003 .014 +.002 .009 +.002 .011 +.002 .016 +.002 12/13/05 .032 + .004 .035 + .003 .032 + .003 .023 + .002 .027 + .002 12/21/05 .018 +.003 .021 +.002 .024 +.003 .019 +.002 .026 +.002 12/28/05 .037 + .004 .027+ .002 .035 + .003 .026 + .002 .035 + .002 17

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS (Concentrations in pCi/m3 )

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 1-05-05 1-05-05 1-05-05 1-05-05 1-05-05 END DATE 1-26-05 1-26-05 1-26-05 1-26-05 1-26-05 ISOTOPES/RL* _ _

Cs-134/10 <2.59E-3 <3.95E-3 <2.29E-3 <3.50E-3 <4.95E-3 Cs-1 37/20 <2.59E-3 <4.01 E-3 <2.42E-3 <3.71 E-3 <5.12E-3

  • RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 1-26-05 1-26-05 1-26-05 1-26-05 1-26-05 END DATE 2-23-05 2-23-05 2-23-05 2-23-05 2-23-05 ISOTOPES/RL*

Cs-1 34/10 <2.55E-3 <4.20E-3 <2.34E-3 <3.45E-3 <5.17E-3 Cs-1 37/20 1.59E-3+/-5.04E-4 <2.04E-3 <1.43E-3 2.59E-3+/-6.99E-4 <2.73E-3

  • RL = REPORTING LEVEL 18

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS (Concentrations in pCi/M 3 )

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 2-23-05 2-23-05 2-23-05 2-23-05 2-23-05 END DATE 3-30-05 3-30-05 3-30-05 3-30-05 3-30-05 ISOTOPES/RL*

Cs-134/10 <2.03E-3 <3.22E-3 <1.91 E-3 <2.82E-3 <3.29E-3 Cs-I 37/20 <9.92E-4 2.38E-3+/-6.42E-4 1.17E-3+/-3.81 E-4 1.65E-3+/-5.1 E-4 <4.38E-3

  • RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 3-30-05 3-30-05 3-30-05 3-30-05 3-30-05 END DATE 4-27-05 4-27-05 4-27-05 4-27-05 4-27-05 ISOTOPES/RL*

Cs-134/10 <2.47E-3 <4.15E-3 <2.41 E-3 <3.12E-3 <4.83E-3 Cs-1 37/20 <1 33E-3 2.98E-3+/-8.24E-4 1.33E-3+/-4.64E-4 1.66E-3+/-5.48E-4 <5.22E-3 1-*------

  • RL = REPORTING LEVEL 19

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS (Concentrations in pCi/M 3 )

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 4-27-05 4-27-05 4-27-05 4-27-05 4-27-05 END DATE 6-01-05 6-01-05 6-01-05 6-01-05 6-01-05 ISOTOPES/RL*

Cs-134/10 <2.OOE-3 <3.29E-3 <1.91 E-3 <2.19E-3 <1.92E-3 Cs-1 37/20 <2.08E-3 <3.32E-3 <1.33E-3 <2.26E-3 <2.05E-3

  • RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 6-01-05 6-01-05 6-01-05 6-01-05 6-01-05 END DATE 6-29-05 6-29-05 6-29-05 6-29-05 6-29-05 ISOTOPES/RL*

Cs-134/10 <2.47E-3 <3.76E-3 <2.44E-3 <2.50E-3 <2.lOE-3 Cs-137/20 <2.63E-3 <3.92E-3 <2.60E-3 <2.53E-3 <2.19E-3

  • RL = REPORTING LEVEL 20

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS (Concentrations in pCi/M 3 )

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 6-29-05 6-29-05 6-29-05 6-29-05 6-29-05 END DATE 7-27-05 7-27-05 7-27-05 7-27-05 7-27-05 ISOTOPES/RL*

Cs-134/10 c2.51 E-3 <3.91 E-3 c2.52E-3 <2.60E-3 <2.09E-3 Cs-137/20 <2.62E-3 <4.13E-3 <2.66E-3 <2.81 E-3 <2.21 E-3

  • RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 7-27-05 7-27-05 7-27-05 7-27-05 7-27-05 END DATE 8-31-05 8-31-05 8-31-05 8-31-05 8-31-05 ISOTOPES/RL*

Cs-134/10 <1.94E-3 <3.1OE-3 <1.93E-3 <2.1OE-3 <1.78E-3 Cs-137/20 <1.94E-3 <3.26E-3 <2.12E-3 <2.19E-3 <1.84E-3

  • RL = REPORTING LEVEL 21

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS (Concentrations in pCi/M 3 )

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 8-31-05 8-31-05 8-31-05 8-31-05 8-31-05 END DATE 9-28-05 9-28-05 9-28-05 9-28-05 9-28-05 ISOTOPESIRL*

Cs-1 34/10 <2.52E-3 <4.19E-3 <2.55E-3 <2.44E-3 <2.17E-3 Cs-1 37/20 <2.64E-3 <4.32E-3 <2.60E-3 <2.54E-3 <2.30E-3

  • RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 9-28-05 9-28-05 9-28-05 9-28-05 9-28-05 END DATE 11-02-05 11-02-05 11-02-05 11-02-05 11-02-05 ISOTOPES/RL*

Cs-134/10 <2.09E-3 <3.32E-3 <2.1OE-3 <2.45E-3 <1.85E-3 Cs-1 37/20 <2.08E-3 <2.25E-3 <1.15E-3 <1.20E-3 1.36E-3+/-3.66E-4

  • RL = REPORTING LEVEL 22

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS (Concentrations in pCi/m 3 )

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 11-02-05 11-02-05 11-02-05 11-02-05 11-02-05 END DATE 11-30-05 11-30-05 11-30-05 11-30-05 11-30-05 ISOTOPES/RL*

Cs-134/10 <2.48E-3 <5.30E-3 <2.69E-3 <3.80E-3 <2.23E-3 Cs-137/20 <2.53E-3 <5.32E-3 c2.79E-3 <3.83E-3 <2.32E-3

  • RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 11-30-05 11-30-05 11-30-05 11-30-05 11-30-05 END DATE 12-28-05 12-28-05 12-28-05 12-28-05 12-28-05 ISOTOPES/RL*

Cs-134/10 <2.37E-3 <4.35E-3 <2.51 E-3 <3.60E-3 <2.18E-3 Cs-1 37/20 <2.42E-3 <4.59E-3 <2.64E-3 <3.70E-3 <2.30E-3

  • RL = REPORTING LEVEL 23

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER INTHE VICINITY OF LACBWR (Report Concentrations in pCI/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 1-11-05 1-11-05 1-11-05 2-08-05 2-08-05 2-08-05 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

  • H-3 <136 <136 <136 <127 <127 <127 Mn-54/1000 <5.36 <5.30 <5.44 <5.32 <5.42 <5.45 CO-60/300 <5.73 <5.70 <5.77 <5.63 <5.68 <5.76 Zn-65/300 <12.0 <12.1 <11.7 <11.9 <11.7 <11.8 Cs-134/30 <5.81 <5.78 <5.84 <5.87 <5.91 <5.71 Cs-137/50 <3.00 <6.06 <6.14 <5.96 <5.95 <5.93

-.1.-

___________________________________________________________ A .5. A & .5.

  • RL = REPORTING LEVEL 24

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER INTHE VICINITY OF LACBWR (Report Concentrations in pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 3-15-05 3-15-05 3-15-05 4-11-05 4-11-05 4-11-05 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

  • H-3 <129 <129 <129 494+/- 134 520+/- 134 386 +/- 132 Mn-54/1000 <5.13 <5.33 <5.51 <5.29 <5.39 <5.38 Co-60/300 <5.64 <5.70 <5.60 <5.11 <5.19 <5.73 Zn-65/300 <11.9 <11.8 <11.9 <12.1 <11.7 <11.6 Cs-1 34/30 <5.63 <5.70 <5.77 <5.70 <5.81 <5.78 Cs-137/50 <5.98 <5.82 <6.13 <3.27 <2.88 3.14 +/- 1.07
  • RL = REPORTING LEVEL 25

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 5-09-05 5-09-05 5-09-05 6-10-05 6-10-05 6-10-05 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

  • H-3 471+/-136 471*136 468+/-136 363+/- 133 205+/-131 291+/-131 Mn-54/1000 <5.20 <5.33 <5.31 <5.41 <5.24 <5.35 Co-60/300 <5.57 <5.57 <5.47 <5.45 <5.57 <5.62 Zn-65/300 <11.8 <12.2 <11.7 <11.4 <11.7 <11.6 Cs-1 34/30 <5.48 <5.68 <5.63 <5.80 <5.75 <5.74 Cs-I 37/50 <5.94 <5.93 <5.79 <5.97 <3.46 <5.90
  • RL = REPORTING LEVEL 26

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 7-12-05 7-12-05 7-12-05 8-9-05 8-9-05 8-9-05 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

  • H-3 249+/- 127 141 +/- 126 292 +/- 128 390 +/-131 451 +/- 132 430 +/- 132 Mn-54/1000 <5.45 <5.35 <5.29 <5.24 <5.26 <5.27 Co-60/300 <5.70 <5.59 <5.69 <5.56 <5.81 <5.27 Zn-65/300 <11.8 <11.8 <12.3 <11.7 <11.5 <11.4 Cs-134/30 <5.85 <5.71 <5.75 <5.78 <5.64 <5.93 Cs-137/50 <6.09 <5.89 <6.01 <5.99 <5.90 <6.08
  • RL = REPORTING LEVEL 27

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER INTHE VICINITY OF LACBWR (Report Concentrations In pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 9-12-05 9-12-05 9-12-05 10-11-05 10-11-05 10-11-05 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

  • H-3 <142 <142 <142 228+/-128 298+/-128 318+/-128 Mn-54/1000 <5.41 <5.37 <5.35 <5.24 <5.3 <5.29 Co-60/300 <5.60 <5.36 <5.44 <5.39 <5.84 <5.48 Zn-65/300 <11.8 <1 1.4 <11.8 <11.7 <11.7 <12.1 Cs-134/30 <5.84 <5.67 <5.64 <5.83 <5.89 <5.85 Cs-137/50 <3.63 <3.27 <2.80 <6.04 <3.07 <5.53
  • 1 I I I
4. I I I
  • RL = REPORTING LEVEL 28

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 11-14-05 11-14-05 11-14-05 12-14-05 12-14-05 12-14-05 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

  • H-3 <133 214+/-126 183+/-126 <143 <143 <143 Mn-54/1000 <5.52 <5.43 <5.36 <5.30 <5.55 <5.46 Co-60/300 <5.71 <5.69 <5.56 <5.58 <5.62 <5.60 Zn-65/300 <11.6 <11.3 <11.7 <12.0 <11.8 <11.7 Cs-1 34/30 <5.85 <5.69 <5.78 <5.78 <5.88 <5.80 Cs-137/50 3.18+/-1.10 <6.03 <5.85 <3.38 <6.07 <2.90
  • RL = REPORTING LEVEL 29

TABLE 13 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER SEDIMENT IN THE VICINITY OF LACBWR (Concentration in pCi/Kg)

(Reporting Level = 10 times Control Value)

COLLECTION DATE SAMPLE # I SAMPLE # 2 SAMPLE # 3 SAMPLE # 1 SAMPLE # 2 SAMPLE # 3 SAMPLE LOCATION 5-24-05 5-24-05 5-24-05 8-22-05 8-22-05 8-22-05 UPSTREAM OUTFALL DOWNSTREAM UPSTREAM OUTFALL DOWNSTREAM ISOTOPES Cs-134 <8.51 <9.42 <15.8 <8.57 <9.31 <9.16 Cs-1 37 8.47 +/- 1.72 277 +/- 16.0 184 +/-13.4 <7.63 228+/-16.0 <8.09 Co-60 __ 47.12 +/- 2.92_ 54.9+/-3.25 Eu-1 55 49.6+/-14.5 30

TABLE 14 FISH SAMPLE ACTIVITY INTHE VICINITY OF LACBWR (Report Concentrations in pCi/Kg)

SAMPLE #1 SAMPLE #2 SAMPLE #1 SAMPLE #2 SAMPLE #1 SAMPLE #2 COLLECTION DATE: 3-23-05 4-05-05 5-24-05 5-24-05 8-22-05 8-22-05 FISH SPECIES: CARP WALLEYE CARP Walleve CARP WALLEYE ISOTOPES/RL*

Mn-54 / 3E4 <7.96 <8.80 <6.61 <12.0 <7.53 <7.00 Co-60/ 1E4 <9.01 <10.0 <7.73 <13.9 <8.47 <8.00 Zn-65/ 2E4 <20.5 <21.2 <17.3 <30.4 <19.1 <17.6 Cs-134/ 1E3 <7.94 <8.03 <7.20 <12.3 <7.32 <7.03 Cs-1 37/ 2E3 5.20+/-1.56 <5.99 4.75 +/- 1.33 9.53 +/- 2.60 <8.12 <5.14

  • RL =REPORTING LEVEL 31

TABLE 14 FISH SAMPLE ACTIVITY IN THE VICINITY OF LACBWR (Report Concentrations In pCT/Kg)

SAMPLE #1 SAMPLE #2 SAMPLE #1 SAMPLE #2 SAMPLE #1 SAMPLE #2 COLLECTION DATE: 10-13-05 10-13-05 FISH SPECIES: CARP WALLEYE ISOTOPES/RL*

Mn-54/ 3E4 <7.64 <7.35 Co-60/ 1E4 <8.86 <8.37 Zn-65/ 2E4 <19.8 <19.3 Cs-134/ 1E3 <7.67 <7.47 Cs-1 37/ 2E3 5.21+/-1.52 5.89+/-1.56

  • RL =REPORTING LEVEL 32

BOILING WATER REACTOR LA CROSSE LA CROSSE BOILING WATER REACTOR (LACBWR)

OFFSITE DOSE CALCULATION MANUAL Prepared b .

Date Health Physics Review: -411715 Date Radiation Protection Engineer Review: B G o d7 YVA<A f A/ / Yatd Quality Assurance Review:

I~ rZ I v ' Date ORC Approved: 14401-- 4r42S' lbate /

March 2005 Revision 8 Dairyland Power Cooperative 3200 East Avenue South La Crosse, WI 54602-0817

'I_% a The spreadsheet program will then calculate and display the total quarterly dose in mRem to the total body and each organ of an individual in each age group. The cumulative calendar year doses and the percentage of the limits set forth in 2 Section 3.2.2.b are also calculated. This spreadsheet will also print the data tables for E

E the liquid effluent section of the annual report.

C 2.2 Compliance with the Limitations for Gaseous Effluent Releases

_2 a) To assure compliance with the limitations of Section 3.3.3.a, alarm setpoints are Q0 established for the gaseous effluent monitor. These setpoints are calculated or 0

checked annually, or as required by procedure, to confirm that the current setpoints are set correctly for one- or two-stack blower operation.

During SAFSTOR, the offgas treatment system from the condenser to the stack is no longer in operation since the plant is shut down. The principal potential gaseous release pathway is from the Reactor Building ventilation exhaust system. The only noble gas potentially available for release from the facility is Kr-85. The irradiated fuel assemblies stored in the Fuel Element Storage Well (FESW) contain essentially all the Kr-85 inventory. There is a very small potential for a Kr-85 release from the Waste Treatment and Turbine Building ventilation exhaust systems. This would be possible a only if FESW water containing Kr-85 were transferred to the Spent Resin Receiving Tank (SRRT) or the Waste Water Tanks (WWT). Activity in particulate form and H-3 can theoretically be released via any of these release pathways. There will be no

_O I..a,

>0.

a,)

Xz ODCM 13 Rev. 8

3.0 RADIOACTIVE EFFLUENT CONTROL PROGRAM E 3.1 Program Requirements E

0 The Radioactive Effluent Control Program (RECP) shall conform to the guidance of 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as C

0 reasonably achievable. This program shall establish the requirements for monitoring, o sampling and analysis of radioactive gaseous and liquid effluents released from LACBWR to ensure the concentrations in effluents released to areas beyond the EFFLUENT RELEASE BOUNDARY conform to 10 CFR Part 20, Appendix B, Table 2, Columns I and 2. It shall provide limitations on the annual and quarterly dose commitment to a MEMBER OF THE PUBLIC from radioactive effluents in conformance with Appendix I of 10 CFR Part 50.

C The limitations of operability of gaseous and liquid monitoring instrumentation,

& including surveillance test and setpoint determination in accordance with Section 2.0, Offsite Dose Calculations, will be included in this program.

CRequirements for the Reactor Building Ventilation System, including filtration

_ and elevated stack release of exhausted air is included in Section 3.3.1.

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I-t ODM38 38 Rev. 8

_ a 3.3 Gaseous Effluents

_ '3.3.1 Reactor Building Ventilation Normal air discharge from LACBWR is made as an elevated stack 2

release. Air is swept through the Turbine and Reactor Building and then E discharged out the stack. Whenever the Reactor Ventilation dampers are open, the air from the Reactor Building shall be discharged through a set of HEPA particulate filters to reduce the amount of radioactive particulates being

= released to the environment. This filtration of the Reactor Building Ventilation 0) o'System

% exhaust implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50, and the design objectives Ca tgiven in Section ll.D of Appendix I to 10 CFR Part 50.

With Reactor Building Ventilation System exhaust being discharged 0 l s without filtration, prepare and submit to the Commission within 30 days a

$z Special Report which discusses the circumstances and what action will be i i taken to prevent a recurrence.

E 3.3.2 Stack Effluent Samling and Analyses The radioactive gaseous discharge from LACBWR will be sampled and analyzed as per the following table.

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ODCM 46 Rev. 8

_t 3.3.4 Instrumentation a The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.4 shall be OPERABLE with their alarm setpoints set to ensure 2 that the limits of Section 3.3.3a are not exceeded. The stack noble gas

< instrumentation alarm setpoint will be determined and adjusted in accordance E

E i) with the methodology and parameters in Section 2.0, Offsite Dose Calculations.

The radioactive gaseous effluent instrumentation is provided to monitor o and control, as applicable, the releases of radioactive materials in gaseous ieffluents during actual or potential releases of gaseous effluents. The only

= _significant noble gas remaining is Kr-85. The alarm setpoints for these instruments shall be set to ensure that the alarm will occur prior to exceeding the limits of 10 CFR Part 20.

0 a) Gaseous Effluent Instrumentation Surveillance Requirements_-

Each radioactive gaseous effluent monitoring instrumentation channel O sshall be demonstrated OPERABLE by performance of the CHANNEL X CHECK, SOURCE CHECK, CHANNEL FUNCTIONAL TEST, and CHANNEL CALIBRATION operations at the frequencies shown in Table 3.5.

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L.xk ODCM 53 Rev. 8

t b) Corrective Action ED (1) With a radioactive gaseous effluent monitoring instrumenta-tion channel alarm setpoint less conservative than that required, declare the channel inoperable or change the setpoint so that it is acceptably conservative.

a,

>@ (2) With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION required by Table 3.4. Exert best efforts to return the 0 instruments to OPERABLE status within 30 days and, if un-Sh successful, explain in the next Annual Radioactive Effluent a Release Report why the inoperability was not corrected in a timely manner.

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ODCM 54 Rev. 8

_ 11 Table 3.4 0 §RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS APPLICABLE INSTRUMENT OPERABLE CONDITIONS ACTION 2 1. Reactor Building Ventilation Monitor System E a. Particulate Activity Monitor 1

  • A 0

o b. Gaseous Activity Monitor 1

  • A
c. Sampler Flow Rate Measuring I
  • B

> sDevice 40 C

2. Stack Monitor System 0 , a. Gaseous Activity Monitor 1 ** C 0

- b. Particulate Activity Monitor 1 ** D

c. Sampler Flow Rate Measuring I ** B Device

0 \ At all times, unless alternate monitoring is available c kACTIONS:

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C A. With the number of channels OPERABLE less than required by the Minimum through this pathway may Channels OPERABLE requirement, effluent releasesotherwise, X. continue as long as a stack monitor is OPERABLE; secure the Reactor Building Ventilation.

B. With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

C. With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue

> provided the Reactor Building Gaseous Activity Monitor is OPERABLE; otherwise, secure the Reactor Building Ventilation.

A? Z C) D. With the number of channels OPERABLE less than required by the Minimum

_Channels OPERABLE requirement, effluent releases via this pathway may continue oz provided continuous collection of samples with auxiliary sampling equipment is initiated within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

coE ODCM 55 Rev. 8

T- Table 3.5 a,

i 0 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION II SURVEILLANCE REQUIREMENTS CHANNEL CHANNEL SOURCE FUNCTIONAL CHANNEL (4)

INSTRUMENT CHECK CHECK TEST CALIBRATION

1. Reactor Building Ventilation I Monitor System
a. Particulate Activity Monitor DAILY MONTHLY QUARTERLY AT LEAST ONCE (1) PER 18 MONTHS
b. Gaseous Activity Monitor DAILY MONTHLY QUARTERLY AT LEAST ONCE (1) PER 18 MONTHS
c. Sampler Flow Rate DAILY MONTHLY QUARTERLY AT LEAST ONCE Measuring Device (3) PER 18 MONTHS
2. Stack Monitor System 9a, a. Noble Gas Activity Monitor DAILY MONTHLY QUARTERLY AT LEAST ONCE (2) PER 18 MONTHS
b. Particulate Activity Monitor DAILY N/A QUARTERLY AT LEAST ONCE 9 (2) PER 18 MONTHS
c. Sampler Flow Rate DAILY N/A QUARTERLY AT LEAST ONCE
  • X Measuring Device (3) PER 18 MONTHS a,

C Wu NOTES:

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(1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm I

-a- annunciation occurs if any of the following conditions exist:

a. Instrument indicates measured levels at or above the alarm setpoint.
b. Instrument indicates a downscale failure.
c. Instrument indicates a circuit failure.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

a. Instrument indicates measured level above the alarm setpoint on one channel.
b. Instrument indicates a failure by a Low Flow and Low Count Rate signal.

.t0 (3) The CHANNEL FUNCTIONAL TEST shall also demonstrate that the control room local z

E0 -i alarm occurs if the flow instrument indicates measured levels below the minimum and/or above the maximum alarm setpoint.

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(4) The CHANNEL CALIBRATION shall be conducted in accordance with plant procedures.

ODCM 56 Rev. 8

3.4 Total Dose to a Member of the Public a 3 The dose equivalent to any MEMBER OF THE PUBLIC due to release of radioactivity and radiation, shall be limited to < 25 mRem to the total body or any organ o (except the thyroid, which is limited to < 75 mRem) over a period of one calendar year.

E 0

With the calculated doses from the release of radioactive materials in liquid or 0

gaseous effluents exceeding twice the calendar year dose limits specified iri Sections 3.2.2b, 3.3.3b, or 3.3.3c, a determination should be made, including direct radiation C.

E.9 from Reactor Building and radioactive waste storage tanks to determine if the above l 0 > limits have been exceeded. If these limits have been exceeded, prepare and submit a 0 ~

Special Report (including an analysis which estimates the radiation exposure to a MEMBER OF THE PUBLIC for the calendar year) to the Director, Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555, within w 30 days, which defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding these limits. If the release condition c_ resulting in the excess has not already been corrected, the Special Report shall CX uJ include a request for a variance in accordance with the provisions of 40 CFR 190.

E-Submittal of the Special Report is considered a timely request, and a variance is

_= granted until staff action on the request is complete.

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e M ODCM 57 Rev. 8

Cumulative dose contributions from liquid and gaseous effluents shall be determined quarterly and annually in accordance with Section 2.0, Offsite Dose Calculations.

CL Cumulative dose contributions from direct radiation from the reactor E containment or radioactive waste storage tanks shall be determined once per year in 0

accordance with Section 4.0, Radiological Environmental Monitoring Program.

This requirement is provided to meet the dose limitations of 40 CFR 190.

Whenever the calculated doses from plant radioactive effluents exceed twice the 0 design objective doses of Appendix I, a Special Report will be submitted which describes a course of action which should result in the limitation of dose to a real a individual for 12 consecutive months to within the 40 CFR 190 limits.

0s For conservatism, for compliance with this limit, the maximum total dose to any

.5 MEMBER OF THE PUBLIC will be assumed to be the sum of the maximums from

e. X each dose pathway even though the actual maximally exposed individual for each of C

the pathways could not be the same person.

X< The maximum potential dose to a MEMBER OF THE PUBLIC from direct radiation from the Reactor Building and radioactive waste storage tanks is determined a - by TLD dosimeters located at various locations around the perimeter of the LACBWR N0 m

0 Co 0Cz ODCM 58 Rev. 8

LA CROSSE BOILING WATER REACTOR PROCESS CONTROL PROGRAM (PCP)

Prepared b Date X X 1 I I Health Physics Review: E m V -T-j x d4 1/

6-4-I

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' Date Security Reviei N: A^0>fv't 0 i?/3-05 Date QA Reviei IV: & ' 0j. {"/3ot6 Date ORC Approvei T & bake-September 2005 (Revision 10)

Dairyland Power Cooperative 3200 East Avenue South La Crosse, WI 54602

III. WET RADIOACTIVE WASTE The PCP and Health and Safety Procedure (HSP) 4.1 establish the steps used to dewater and stabilize wet radioactive waste material from the process water treatment systems and the liquid waste system. These wastes will be transferred to the Waste Treatment Building (WTB) for storage and processing before its ultimate disposal.

The WTB is located to the northeast of the Reactor Building. The WTB contains facilities and equipment for the collection, processing, storage and handling of low level solid radioactive waste materials.

The grade floor of the WTB contains a shielded compartment which encloses a permanent 320 ft3 stainless steel Spent Resin Receiving Tank (SRRT) with associated resin receiving and transfer piping, SRRT recirculation piping, SRRT demineralized water flush piping, SRRT dewatering piping, SRRT air sparger piping, valves, and a SRRT ultrasonic level indication assembly. This cubicle is in the southeast corner of the building and has nominal 2' 6" to 3' thick reinforced high density concrete shield walls on the outer sides.

Wet radioactive waste materials may typically be described as whole bead demineralizer resins, mechanical cartridge filters, waste sludge, and inorganic particulate residues. When expended, these wet wastes are transferred to the SRRT or, in some cases, directly into a High Integrity Container (HIC) for processing. In the case of Class C wet radioactive waste, as an alternate method to transfer to the SRRT, they may be transferred to a HIC inside a transportation cask and dewatered from the cask to the plant process liquid waste system, thus reducing radiation exposure to personnel involved in performing the necessary package handling operations. Samples of wet waste are analyzed for isotopic composition and for waste classification.

Expended demineralizer resins and waste sludge material from sumps and tanks are transferred to the SRRT as described in the Operating Manual Volume VII.

From the SRRT, partially dewatered spent resins and/or sludge material, which have been sluiced from plant demineralizers and/or tanks, are pumped at a low flow rate/pressure with a Roper-type screw pump to a HIC, located in the adjacent shielded cubicle as described in Operating Manual Volume VII. The wall between the SRRT and the disposal HIC and other walls surrounding the HIC are a nominal 2' thick high density concrete. Also located in this cubicle is an air-driven Sandpiper-type diaphragm HIC dewatering pump, the resin transfer and dewatering valves and hoses, and the disposal HIC level indication connecting cable. Once in the HIC, spent resins and sludge material PCP Rev. 10

Attachment 1 To PCP One shipment of spent resins and sludge made in October 1999 contained 40,900 mCi (40.9 Ci) of radioactivity. This shipment presents a higher security risk than the DAW shipments, but it was made in a heavily shielded Type B cask, certified by the NRC under 10 CFR 71 regulations. However, the relatively low specific activity and large volume (5.35 cubic meters) of the contents of this shipment do not lend themselves to separation and concentration for use as a tool of mass destruction. The potential for sabotage or highjacking for terrorist purposes, warrants consideration.

In the coming years, the majority of our shipments will be LSA or SCO with characteristics similar to those described above. Some will contain higher concentrations of radioactivity, but the security risks will be low because of the large volumes and low specific activities. All large volume LSA/SCO shipments and Type B shipments use sole-use transportation systems, where the transport vehicle is loaded at LACBWR with our shipment and proceeds to the authorized recipient as expeditiously as possible.

At some time, we will make shipments of irradiated reactor fuel assemblies from LACBWR. This type of shipment is considered a relatively high security risk, and these shipments will be made under special security procedures developed at that time to meet then current NRC and DOT requirements. A 90-day prior notification must be made to the NRC before making a shipment of irradiated fuel.

Another type of radioactive material that is considered to have a greater security risk is small encapsulated radioactive sources. We have a number of this kind of sources that will need to be disposed of before license termination. Most have very small quantities of radioactive material and therefore should be considered of very low security risk. However, three of these (two Cs-137 and one PuBe) have higher activity. These will not be shipped until just prior to LACBWR's license termination. Their shipment and disposal will be handled on a case-by-case basis at that time.

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