Text

Request for Partial Site Release
	ML16181A068
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	06/27/2016
From:	Gerard van Noordennen; LaCrosseSolutions
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	LC-2016-0021
	Download: ML16181A068 (24)
	v • d • e

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LACROSSESOLUTIONS 10 CFR 50.83(b)

June 27, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 La Crosse Boiling Water Reactor Facility Operating License No. DPR-45 NRC Docket Nos. 50-409 and 72-046

Subject:

La Crosse Boiling Water Reactor Request for Partial Site Release

References:

LC-2016-0021

1) Gerard van Noordennen, LaCrosseSolutions, Letter to U.S. Nuclear Regulatory Commission, "License Amendment Request for the License Termination Plan," dated June 27, 2016 LaCrosseSolutions, the licensee for the La Crosse Boiling Water Reactor (LACBWR), is requesting approval to remove a portion of the site from the Part 50 license (License No. DPR-45). Specifically, LaCrosseSolutions requests approval to remove the non-impacted sur-vey units from its Part 50 license in accordance with 10 CFR 50.83(b ), "Release of part of a power reactor facility or site for unrestricted use.", "LACBWR Supporting Information for Request for Partial Site Release,"

provides the supporting information for a partial release of the site for unrestricted use before receiving approval of the License Termination Plan (LTP) in accordance with the provisions of 10 CFR 50.83(b). The LACBWR LTP was previously submitted as documented in Reference 1 and is currently under review by the NRC. Attachment 1 includes a description of the property and evaluation of the effect of releasing this property. The evaluation concludes that all applicable regulatory requirements will continue to be met and no change to the LACBWR Operating License or the Permanently Defueled Technical Specifications is required.

Reference documents supporting the summary and conclusions described in Attachment 1 were previously provided with the L TP submittal.

There are no regulatory commitments made in this submittal. LaCrosseSolutions requests NRC approval of this request by February 28, 2017. If you should have any questions regarding this submittal, please contact Joe Jacobsen at (608) 689-4259 or myself at 224-789-4025.

Respectfully, G.v~~~j~

Gerard van Noordennen Vice President Regulatory Affairs S4601 State Highway 35, Genoa, WI 54632

LaCrosseSolutions LCS-2016-0021 Page 2 of2

Attachment:

1) Attachment 1, "LA CB WR Supporting Information for Request for Partial Site Release" cc:

Marlayna Vaaler, U.S. NRC Project Manager Service List

La Crosse Boiling Water Reactor Service List cc:

Ken Robuck Group President Disposal and Decommissioning Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 John Sauger Executive VP and Chief Nuclear Officer ReactorD&D Energy Solutions 2701 Deborah Avenue Zion, IL 60099 Gerard van Noordennen VP Regulatory Affairs Energy Solutions 2701 Deborah Avenue Zion, IL 60099 Joseph Nowak General Manager LaCrosseSolutions S4601 State Highway 35 Genoa, WI 54632-8846 Dan Shrum Senior VP Regulatory Affairs Energy Solutions 299 South Main Street, Suit~ 1700 S~t Lake City, UT 84111 Russ Workman General Counsel Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111.

George Kruck, Chairman Town of Genoa S5277 Mound Ridge Road Genoa, WI 54632 Regional Administrator U.S. NRC, Region III 2443 Warrenville Road Lisle, IL 60532-4352 Jeffery Kitsembel Division of Energy Regulation Wisconsin Public Service Cqmmission P.O. Box 7854 Madison, WI 53707-7854 Paul Schmidt, Manager Radiation Protection Section Bureau of Environmental and Occupational Health Division of Public Health.

Wisconsin Department of Health Services P.O. Box 2659 Madison, WI 53701-2659 Barbara Nick President and CEO Dairyland Power Cooperative 3200 East A venue South, La Crosse, WI 54602-081 7 Cheryl Olson, ISFSI Manager La Crosse Boiling Water Reactor Dairyland Power Cooperative S4601 State Highway 35 P.O. Box 817 Genoa, WI54632-8846 Lane Peters L.a Crosse Boiling Water Reactor Dairyland Power Cooperative S4601 State Highway 35 Genoa, WI 54632-8846 Thomas Zaremba Wheeler, Van Sickle and Anderson, S.C.

44 East Mifflin Street, Suite 1000 Madison, WI 53703 John E. Matthews Morgan, Lewis & Bockius LLP 1111 Pennsylvania A venue, NW Washington, DC 20004.

ATTACHMENT 1 LACBWR Supporting Information for Request for Partial Site Release

ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release PURPOSE

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LACROSSESOLUTIONS The purpose of this report is to request Nuclear Regulatory Commission (NRC) approval to remove a portion of the La Crosse Boiling Water Reactor (LACBWR) site from the Part 50 license (License No. DPR-45). Specifically, LaCrosseSolutions intends to remove five (5) non-impacted survey units from its Part 50 License in accordance with 10 CFR 50.83(b ), "Release of Part of a Power Reactor Facility or Site for Unrestricted Use" and 10 CFR 100, "Reactor Site Criteria." LaCrosseSolutions has also reviewed and assessed the subject property to ensure that the subject land area will have no adverse impact on the ability of the site in aggregate to meet 10 CFR Part 20, Subpart E, criteria for unrestricted release. This report contains a summary of the assessment performed, as well as a summary of the characterization surveys performed in these survey units. It is noted that this report does not contain the Final Status Survey (FSS)

Report for this area because the survey units within this area are characterized as non-impacted and as such, no statistical tests, scan and static measurements or elevated measurement comparisons are required. Table 1 provides a classification and description list for the subject survey units. Figure 1 provides a depiction of the site's geographical location and Figures 2 and 3 depict an overview of the survey unit boundaries and the site boundary/non-impacted survey unit comer coordinates, respectively.

Table 1 - Classification and Description List of Non-Impacted Open Land Survey Units Survey Unit Approximate Survey Unit Description Classification Survey Unit ID#

Area (m2)

L4012103 G-3 Plant and related Facilities Area Grounds Non Impacted 66,869 L4012105 Coal Plant Coal Pile Area Grounds Non Impacted 82,894 L4012106 South of Coal Pile Area Grounds w/o ISFSI Non In1pacted 111,899 Controlled Area L4012107 Grounds across Highway 35 to East Non In1pacted 81,254 L4012108 Right of Ways-Highway 35/Railroad Non In1pacted 9,444 Page 1 of20

ATTACHMENT 1 LA CB WR Supporting Infonnation for Request for Partial Site Release

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Figure 1, LACBWR Regional Location Page 2 of20 E1 oa re co

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LACROSSESOLUTIONS

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ATTACHMENT 1 LA CB WR Supporting Infonnation for Request for Partial Site Release

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LACROSSESOLVTIONS Figure 2, Boundaries of Non-Impacted Open Land Survey Units Legend LACB\\NR Buildings Nonimpacted Survey Units

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Date 05123/2016 LlCROSSLSa.UT~ Drawing 16041301.b Page 3 of20

ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release Legend Nonimpected Survey Units LACBWR Buildings survey Unit Vertices Figure 3, Site Boundary/Non-Impacted Survey Units Corner Coordinates Page 4 of20

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LACR~ESOLVTIONS NonimpKMO StlNey Uni

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D4n 9/2016 l..~IOSSt:.Sl'M.LfTR.l.U Drwir~ 1004 llOJ a

ATTACHMENT 1 LACBWR Supporting Information for Request for Partial Site Release BACKGROUND

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LACROSSESOLUTIONS The La Crosse Boiling Water Reactor (LACBWR) was a 50 Megawatt Electric (MWe) BWR that is owned by Dairyland Power Cooperative (DPC). This unit, also known as Genoa 2, is located on the DPC Genoa site on the east shore of the Mississippi River south of the Village of Ge~oa, Vernon County, Wisconsin.

The LACBWR was formerly owned by the Atomic Energy Commission (AEC) and operated by DPC under the provisions of an AEC contract and Provisional Operating Authorization No.

DPRA-6 issued on October 31, 1969 (Docket No. 115-5). On August 28, 1973 the license was converted to Provisional Operating License No. DPR-45 (Docket No. 50-409) issued to DPC.

The DPC operated the LACBWR until April 30, 1987 when it ceased power producing operations. By Amendment No.63 dated August 18, 1988, the license was changed to a Possession Only License No. DPR-45. ISFSI construction and spent fuel off-load to the ISFSI was completed in 2012*. (Reference 1).

On October 8, 2015 Dairyland Power Cooperative and LaCrosseSolutions, LLC submitted an Application for License Transfer and Conforming Administrative License Amendment to the NRC requesting that the NRC consent to the transfer of the DPC Operating License from DPC to LaCrosseSolutions, LLC (Reference 2). The NRC approved the license transfer as documented in the "Order Approving Transfer of License for the La Crosse Boiling Water Reactor from the Dairyland Power Cooperative to LaCrosseSolutions, LLC

and Conforming Administrative License Amendment," dated May 20, 2016 (Reference 3).

Page 5 of20

ATTACHMENT 1 LACBWR

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Supporting Information for Request for Partial Site Release LACROSSESOLUTIONS EVALUATION OF EFFECT OF PROPOSED RELEASE LaCrosseSolutions has evaluated the effect of releasing the subject property from the Part 50 License in accordance with the criteria specified in 10 CFR 50.83(a)(l-3) in order to ensure that LACBWR will continue to comply with all applicable statutory and regulatory requirements that may be affected by the release of the subject property.

Specifically, LaCrosseSolutions evaluation confirmed the following with respect to each of the regulatory areas identified in 10 CFR 50.83(a) (1) (i)-(vi), (a) (2) and (a) (3):

(a) (1)

Evaluate the effects of releasi11g the property to e11sure that:

i.

The dose to i11dividual members of the public does not exceed the limits and standards of 10 CFR Part 20, Subpart D.

LaCrosseSolutions strictly controls effluents to ensure radioactivity released to the environment is maintained ALARA and does not exceed federal release limit criteria. Effluent controls include the operation of radiation monitoring systems within the plant as well as an offsite environmental analysis program. The release of the subject property does not change any controls used to comply with dose limits for individual members of the public and the conservatively estimated yearly dose to a member of the_ public is well below the 10 CFR Part 20, Subpart D limits and standards.

A review of the latest quarterly boundary TLD readings shows that the highest possible dose to a member of the public is 0 along the ISFSI fence line. Table 2 provides the yearly dose to a member of the public at the five locations. closest to the site source te1m. Note this is the first quarter results of 2016 with all 5 Ve1iical Concrete Casks (VCCs) containing spent fuel on the ISFSI pad.

Table 2, REMP Boundary TLD Readings for 1st Quarter of 2016 TLD Occupancy Estimates AVGBKG TLD#

(mR) mR/Qtr mR/year (gross)

Hours Factor 1

21mR 251nR 67 0.01 0.00 0.00 7

21 mR 25mR 67 0.01 0.00 0.00 8

22mR 25mR 67 0.01 0.00 0.00 9

22mR 25mR 67 0.01 0.00 0.00 10 23mR 25mR 67 0.01 0.00 0.00 Page 6 of20

ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release

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LACROSSESOLUTIONS ii.

There is no reduction in the effectiveness of emergency planning or physical security.

No credit is taken for this land in either the Emergency Plan or Security Plan.

Therefore, the release of the subject property has no adverse effect on either plan.

iii.

Effluent releases remain within license conditions.

The LACBWR programs to monitor and maintain effluent releases within license conditions remain in effect and the early release of the subject property does not impact those programs. Therefore, the effluent releases from LACBWR will remain within license conditions.

iv.

The enviromnental monitoring program and offsite dose calculation manual

(ODCM) are revised to account for the changes.

The owner controlled boundary will remain the same and therefore, the Environmental Monitoring Program, ODCM and supporting documents are still valid and no changes are needed.

v.

The siting criteria of 10 CFR Part 100 continues to be met.

The release of the subject property has been reviewed with respect to the siting criteria in 10 CFR 100 and it has been detennined that the requirements of 10 CFR 100 are either not impacted (e.g., 10 CFR 100.11, low population zone or population center distance or 10 CFR 100 Appendix A, Seismic and Geologic Siting Criteria) or are not applicable (e.g., 10 CFR 100, Subpart B, Evaluation Factors for Stationary Power Reactor Site Application on or after January 1 o; 1997). The reactor vessel has been defueled and removed from the site for disposal in 2008. The spent fuel has been relocated to the south end of the site into the licensed ISFSI area in 2012.

vi.

All other applicable statutory and regulat01y requirements continue to be met.

There are no changes to the LACBWR policies and procedures to ensure that statutory and regulatory requirements continue to be met as a result of this early release of the subject property.

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

Page 7 of20

ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release

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LACROSSESOLUTIONS (a) (2)

Pe1form a historical site assessment of the part of the facility or site to be released.

In accordance with the guidance provided in NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)" (Reference 4), Section 3.0, a Historical Site Assessment (HSA) was performed and documented in November 2015 (Reference 1). Historical information, including any 10 CPR 50.75(g) files, employee interviews, radiological incident reports, pre-operational survey data, spill reports, special surveys (e.g., site aerial surveys, marine fauna and sediment surveys),

operational survey records, and annual radiological. operating reports (including sampling of air, groundwater, estuary water, milk, invertebrates, fish and surface vegetation) were reviewed and compiled for this investigation.

The HSA was a detailed investigation to collect existing information (from the start of LACBWR Station's activities related to radioactive materials or other contaminants) for the site and its surroundings. The HSA focused on historical events and routine operational processes that resulted in the contamination of the plant systems, onsite buildings, surface and subsurface soils within the Radiologically Controlled Area (RCA) as well as support structures, open land areas and subsurface soils outside of the RCA, but within the owner controlled area. The infonnation compiled by the HSA was used to establish initial area survey units and classifications and eventually, input into the development of potential site-specific Derived Concentration Guideline Levels (DCGL), development of remediation plans and the design of the Final Radiation Survey (FRS). The scope of the HSA included potential contamination from radioactive materials, hazardous materials, and state-regulated materials.

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

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

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

Based on a review of the operating history of the facility, historical incidents, and operational radiological surveys as documented in the HSA, as well as subsequent additional site characterization surveys perfonned in 2015 to support a non-impacted classification, the subject open land areas and buildings were deemed not impacted by licensed activities or materials and therefore, it was detennined that the "non-impacted" classification is appropriate. The HSA conservatively classified these areas as Class 3 subject to the results of the site characterization surveys. The areas were reclassified to non-impacted based on the results of the site characterization surveys. The surveys performed are discussed in the next section.

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ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release

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LACROSSESOLUTIONS (a) (3)

Pe1form surveys adequate to demonstrate compliance with the radiological criteria for unrestricted use specified in JO CFR 20.1402/or impacted areas.

MARS SIM Section 2.5.2 states, "Non-impacted areas represent areas where all of the information necessary to demonstrate compliance is available from existing sources.

For these areas, no statistical tests are considered necessary." Additionally, Table 2.2 of MARSSIM, "Recommended Conditions for Demonstrating Compliance Based on Survey Unit Classification for a Final Status Survey," requires no elevated measurement comparison, no sampling and/or direct measurements and no scanning to be performed in non-impacted areas. Despite this available waiver, a comprehensive characterization survey was performed.

The site-release criteria for the LACBWR site correspond to the 10 CFR 20.1402 criteria for unrestricted use. The residual radioactivity, including that from ground water sources, that is distinguishable from background, must not cause the total effective dose equivalent (TEDE) to an average member of the critical group to exceed 25 mrem/yr. The residual radioactivity must also be reduced to levels that are ALARA.

The characterization survey was designed and executed using the guidance provided in MARSSIM and NUREG-1757, Volume 2,

Revision 1,

"Consolidated Decommissioning Guidance-Characterization,

Survey, and Determination of Radiological Criteria, Final Report." (Reference 5) In addition, surveys were designed and executed in accordance with the EnergySolutions PG-E0-313196-SV-PL-001, "Characterization Survey Plan for the La Crosse Boiling Water Reactor" (Reference 6) and GP-E0-313196-QA-PL-001, "Quality Assurance Project Plan LACBWR Site Characterization Project)" (Reference 7) which describes policy, organization, functional activities, the Data Quality Objective (DQO) process, and measures necessary to achieve quality data.

Land areas classified as non-impacted received surveys developed to include a combination of systematic and biased survey measurement locations and scan areas.

Biased survey designs used known infonnation to select locations for scan measurements and/or samples. Systematic survey design selected scan measurements and/or sample locations at random or by using a systematic sampling design with a random start. The decision of whether to use primaiily a biased survey design or *a systematic approach was addressed by the DQO process for each survey unit.

Buildings that were classified as non-impacted received surveys including scanning, direct, and removable contamination surveys. Beta scanning surveys using a Ludlum Model 2360 coupled to a 43-93 detector were conducted in two selected facilities that were in the vicinity of the LACBWR Facilities and had a timeline similar to the LACBWR Facilities with a history of high personnel usage. The selected facilities included the G-3 Coal Plant and the Central Warehouse. Based on the results of the beta scanning surveys, static measurements for alpha and beta were taken at the highest observed locations during the scanning surveys. Removable alpha and beta contamination surveys were performed at the location of each static measurement.

From October 2014 to December 2015, sufficient survey coverage and an adequate Page 9 of20

ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release

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LACROSSESOLUTIONS number of samples were obtained in the subject survey units to se~e as the basis for the "Non-Impacted" classification. Within each of the land survey units specified, the survey focused primarily on surface (0 to 15 cm) soils and subsurface (15 to 100 cm) soil samples that were included in the survey design. The sample and gamma scan measurement locations were based on a random design to ensure an unbiased survey.

The characterization survey of* each land survey unit consisted of both qualitative evaluations and quantitative analysis results. Investigative and verification gamma scans using a Ludlum Model 2350-1 and a Model 44-10 NaI detector were performed.

Minimum Detectable Concentrations (MDC) and gamma scanning sensitivities were estimated based on the assumed geometry and the potential plant-derived gamma-emitting radionuclides that may be present. Quantitative analysis results were obtained from radionuclide specific analysis of soil media using a calibrated counting geometry.

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

Surface scanning using a NaI detector was performed in 1 % of each land survey unit focusing on areas that have been.disturbed in the past or low point areas when available. Elevated areas identified during surface scanning were flagged and monitored with a portable multi-channel analyzer to evaluate the elevated area for presence of LACBWR radionuclides of concern.

The "Non-Impacted" subject open land areas at LACBWR totaled 352,360 square meters of surface area. The non-impacted surface area was broken into 5 survey units in accordance with the area descriptions, sizes and boundaries presented in the HSA. Of the 352,360 square meters, approximately 70,000 square meters was deemed as "inaccessible" in L4012107 survey unit. In this context, "inaccessible" is defined as an area where personnel or vehicle transit was inhibited by the presence of, thick underbrush, trees or natural grasses where clearing would be prohibitive or where the slope of the land and related erosion over time was not conducive to performing surveys. The total surface area deemed "accessible" was 282,360 square meters.

Of the 282,360 square meters of surface area, 3,025 square meters were scanned by a Model 2350 paired with a Model 44-10 NaI detector. Alarm set-points for the instrument were set at the observed background plus the Minimum Detectable Count Rate (MDCR) of the instrument. With an average background of 7,364 cpm, the average observed scan result was 8,302 cpm. -Five (5) instrument alarms were logged with a maximum observed scan reading of 11,200 cpm. All alarms were investigated with the use of the po1iable multi-channel analyzer at the area where the elevated reading was verified. In all instances, the elevated readings were attributed to Naturally Occurring Radioactive Material (NORM).

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ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release

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LACROSSESOLUTIONS A total of thirty-two (32) surface and subsurface random type soil samples were taken in the land survey units. Of the total number of surface soil samples taken and analyzed, Cs-137 was identified at concentrations greater than the MDC of the instrument in (17) soil samples but not in excess of the established background levels. Additional detail on the survey and sampling methodology and results of the radiological analysis of each measurement and soil sample obtained during the characterization of non-impacted open land survey units are presented in EnergySolutions GG-E0-313196-RS-RP-001, "LACBWR Radiological Characterization Report for October and November 2015 Field Work Genoa, Wisconsin" (Reference 8 ), Chapter 2 of the LACBWR License Termination Plan (LTP), (Reference 9) and the EnergySolutions LC-RS-PN-164017-001 "LA CB WR Radiological Characterization Survey Report for June thru December 2015 Field Work Genoa, Wisconsin" (Reference 10). Based upon the results of the characterization surveys performed of the non-impacted open land areas, it can be concluded that a non-impacted classification for these areas is appropriate. Cs-137 was the only consistently identified radionuclide that could potentially be classified as plant-derived. However, the concentrations observed are well within the range of activity defined as background due to global fallout (Reference 11). The locations of gamma walkover survey measurements and surface soil samples are illustrated on Figure 4. A summary of the findings of the survey for each individual survey unit are presented in Table 3.

The surveys of the two representative facilities, including the G-3 Coal Plant and the Central Warehouse, did not identify any beta scanned areas greater than the MDC.

Representative static and loose contamination surveys were performed and the results of the surveys for the Coal Plant did not identify any surveyed areas greater than MDC.*

Representative static and loose contamination surveys were performed and the results of the surveys for the Central Warehouse did not identify any surveyed areas greater than MDC other than for the direct beta surveys which identified some locations greater than MDC but at levels less than 1500 dpm/100cm2.

Non-impacted areas are defined in MARSSIM as areas that have no reasonable potential for residual contamination, no radiological impact from site operations and are typically identified during the HSA. LaCrosseSolutions has found no evidence of using, storing, or burying radioactive material in the subject property. None of the event records in the HSA indicated the uncontrolled release of radioactive material to the subject property. Therefore, it can be concluded that the release of the subject property will have no adverse impact on the ability of the LACBWR site in aggregate to meet the Part 20, Subpart E requirements for unrestricted release.

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ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release

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LACROSSESOLUTIONS Figure 4, Non-Impacted Open Land Survey Units Measurement and Sample Locations Page 12 of20 Nonimpacted Survey Units LACBWR Buildings Walkover Survey Areas 0

Random Sample locations

_\\ *I----""-,....._.__,___,,

N D

22D 440 660 feet Noninpected - Survey Uni Measurement end Sample Locations - LACBVVR S~ e Genoa, WI

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Date 04/19/2016 L....C.~

Drawing 16041302.a

ATTACHMENT 1 LA CB WR Supporting Infonnation for Request for Partial Site Release

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LACROSSESOLUTIONS Table 3, Non-Impacted Open Land Survey Units - Characterization Survey Summary Survey Unit Survey Unit L4012103 Survey Unit Survey Unit Survey Unit L4012105 L4012106 L4012107 Surface Area 66,869 m2 82,894 m2 111,899 m2 81,254m2 Description G-3 Coal Plant Grounds Coal Pile Grounds Capped Ash Grounds East of Impoundment Grounds Highway 35 Surface Soil Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

of Samples 3

3 3

3

>CL 0

1 0

2 0

3 Mean (pCi/g) 0.070 0.082 0.071 0.061 0.082 0.100 0.080 0.264 Median (pCi/g) 0.075 0.083 0.072 0.060 0.084 0.099 0.079 0.263 Max (pCi/g) 0.078 0.092 0.084 0.068 0.090 0.121 0.089 0.463 Min (pCi/g) 0.057 0.071 0.057 0.055 0.072 0.079 0.072 0.065 SD 0.011 0.011 0.014 0.006 0.009 0.021 0.009 0.199 Subsurface Soil Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137

of Samples 4

4 3

3 4

4 3

3

>CL 0

1 0

2 0

2 Mean (pCi/g) 0.060 0.048 0.061 0.042 0.081 0.088 0.081 0.068 Median (pCi/g) 0.056 0.038 0.063 0.040 0.083 0.084 0.069 0.057 Max (pCi/g) 0.084 0.081 0.068 0.056 0.102 0.130 0.106 0.091 Min (pCi/g) 0.047 0.036 0.052 0.030 0.056 0.054 0.068 0.056 SD 0.016 0.022 0.008 0.013 0.021 0.037 0.022 0.020 Page 13 of20

ATTACHMENT 1 LACBWR Supporting Infonnation for Request for Partial Site Release

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LACROSSESOLVTIONS Table 3, Non-Impacted Open Land Survey Units - Characterization Survey Summary (con't)

Asphalt Co-60 I Cs-137 Co-60 I Cs-137 Co-60 Cs-137 Co-60 I Cs-137

of Samples 2

2

>CL 0

0 Mean (pCi/g) 0.073 0.062 Median (pCi/g)

None Taken None Taken 0.073 0.062 None Taken Max (pCi/g) 0.082 0.084 Min (pCi/g) 0.065 0.040 SD 0.012 0.031 Surface Scans

% Scanned 1%

1%

<1%

Mean Scan (cpm) 6,086 5,915 8,613 7,892 Max Scan (cpm) 6,700 8,800 12,000 9,080 Page 14of20

ATTACHMENT 1 LA CB WR

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Supporting Information for Request for Partial Site Release LACROSSESOLUTIONS Table 3, Non-Impacted Open Land Survey Units - Characterization Survey Summary Survey Unit Survey Unit L4012108 Surface Area 9,444 m2 Description Hwy 35/Railroad Right of Way Grounds Surface Soil Co-60 Cs-137

of Samples 3

3

>CL 0

2 Mean (pCi/g) 0.079 0.119 Median (pCi/g) 0.075 0.108 Max (pCi/g) 0.095 0.1 56 Min (pCi/g) 0.068 0.093 SD 0.014 0.033 Subsurface Soil Co-60 Cs-137

of Samples 3

3

>CL 0

2 Mean (pCi/g) 0.086 0.189 Median (pCi/g) 0.092 0.091 Max (pCi/g) 0.107 0.409 Min (pCi/g) 0.060 0.067 SD 0.024 0.191 Asphalt Co-60 Cs-137

of Samples

>CL Mean (pCi/g)

Median (pCi/g)

None Taken Max (pCi/g)

Min (pCi/g)

SD Surface Scans

% Scanned 1%

Mean Scan (cpm) 8,662 Max Scan (cpm) 9,200 Page 15 of20

ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release DESCRIPTION OF THE PROPERTY

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LACROSSESOLUTIONS For non-impacted areas, 10 CFR 50.83 (b) (2) requires a description of the part of the facility or site to be released. The owner-controlled site is approximately 163.5acres in size. For LACBWR, the non-impacted open land areqs includes Dairyland Power Cooperative owned land outside of the footprint of the (2.5) acre, fence-enclosed "Radiologically. Restricted Area" and its surrounding approximate (4) acre Class 2 buffer area. The property that is subject to this release request is an approximately 88 acre parcel of land and active Coal Plant operation facilities that have not been negatively impacted by past LACBWR operations or current or future decommissioning activities.

The LACBWR property is located in southwestern Wisconsin, in Vernon County, on the eastern shore of the Mississippi River, about 1 mile south of the Village of Genoa, WI and approximately 19 miles south of the city of La Crosse, WI. The geophysical coordinates for LACBWR are longitude 91°, 13', 53.35"W and latitude 43°, 33', 36.22"N. There are no schools or hospitals within one mile and there are no residences within 1,000 feet of LACBWR station structures.

Non-impacted areas have no reasonable potential for residual contamination because historical information indicates there was no known impact from site operations. These include the outlying open land areas of the site, as well as contiguous areas and facilities that have no impact from site operations based upon the location(s) of licensed operations; site use, topography, site discharge locations, and other site physical characteristics. These areas are not required to be surveyed for demonstrating compliance beyond any characterization surveys perforn1ed to provide a basis for the classification.

P01iions of the 88 acre parcel have limited access for personnel or vehicle transit due to the presence of thick underbrush, trees, natural grasses, or steep sloped eroded land. Survey unit L4012103 contains the Coal Plant as well as ancillary facilities and grounds areas. Survey unit L4012105 contains the coal yard and smTounding grounds.* Survey unit L4012106, located in the southern most area of the site, is an open land area surrounding the capped coal ash pile area and is also a public access area to the Mississippi River for boaters which does not allow camping in the area. Survey unit L4012107 is a steep sloped area to the east of the LACBWR Site which is wooded and has no residences. Survey unit L4012108 is an area of open land with no residents that is east of the LACBWR Site and includes right of way access for the railroad and US Highway 35.

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

LaCrosseSolutions intends to begin undertaking activities associated with the release of the subject property from the LACBWR Part 50 License on or before March 31, 2017. Therefore, LaCrosseSolutions requests that the NRC approve the acceptability of the release of the subject I

property from the Part 50 License by February 28, 2017.

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ATTACHMENT 1 LACBWR Supporting Information for Request for Partial Site Release RESULTS OF 10CFR 50.59 EVALUATION

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LACROSSESOLUTIONS 10 CFR 50.83(b) (4) requires for non-impacted areas that the licensee submit the results of the evaluation performed in accordance with 10 CFR 50.59. The assessment of the release of the subject property is as follows:

The partial site release involves approximately 88 acres of non-impacted land and Coal Plant related facilities out of the approximate l 65 acres the site owns. The release does not involve property that is actively used by the LACBWR Plant for routine or decommissioning operations or that is needed for the site's emergency plan.

The 10 CFR 50.59 review assessed the impact of the change in the site boundary on offsite dose calculations and effluent releases and concluded that the change:

does not adversely affect any design function as described in the Decommissioning Plan I Post Shutdown Decommissioning Activities Report (D-Plan/PSDAR), which is the Safety Analysis Report (SAR) equivalent at LACBWR (Reference 13) does not adversely affect how a design function as described in the D-Plan/PSDAR is performed or controlled does not revise or replace an evaluation method used to establish design basis or safety analysis, and does not involve a test or experiment not described in the D-Plan/PSDAR ENVIRONMENTAL IMPACTS Under 10 CFR 50.83(b)(5), a request for NRC approval of a release of non-impacted areas must include the reasons for concluding that the environmental impacts associated with the proposed release of prope1iy will be bounded by appropriate previously issued Environmental Impact Statements. The Final Enviromnental Statement (FES) for the LACBWR was issued in April 1980. (Reference 12).

More recently, in connection with the development of the License Termination Plan (LTP),

Chapter 8, "Supplement to the Enviromnental Report," was prepared to describe any new information or significant enviromnental changes associated with the site-specific decommissioning and site closure activities performed at LACBWR. The supplement includes a detailed description of the remaining decommissioning and site closure activities, the interaction between those activities and the environment, and the likely environmental impact of those activities. The supplement discusses whether the activities and their impacts are bounded by the impacts predicted in the original FES. Chapter 8 of the LTP concludes the non-radiological environmental impacts from decommissioning are temporary and not significant.

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ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release

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LACROSSESOLUTIONS LaCrosseSolutions has evaluated the environmental impacts associated with the proposed release of the subject property and considered those impacts in light of the original FES and Chapter 8 of the LTP. The evaluation did not identify any significant new environmental impacts or any significant changes from the environmental impacts previously assessed, or currently assessed in the.LTP. In particular, the evaluation found as follows:

The land transfer will have no increase in offsite dose consequences and no change in effluent releases.

The LACBWR radiological monitoring program will account for the revised site area boundary, and no increases in effects are anticipated.

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

ADDITIONAL AREAS TO BE ADDRESSED TO SUPPORT RELEASE OF THE SUBJECT PROPERTY Statement of Dismantling Activities No dismantlement activities are required in the subject survey units.

Potential for Cross-Contamination from Subsequent Activities The potential for cross-contamination of the subject non-impacted areas due to subsequent decommissioning activities is diminutive. The subject areas are bounded on the nmih by right of ways for the railroad and US Highway 35, the west by the Mississippi River, the south by US Wildlife Fish and Game Refuge and the east by US Highway 35 and the railroad prope11y. It is highly unlikely that radioactive materials could be introduced into the subject survey units via these borders. Characterization surveys performed in the Class 3 land areas to date show *that residual contamination levels are below those established for unrestricted use.

Since decommissioning activities are being conducted onsite in parallel with final status survey and release decisions, measures will be taken to protect these adjacent survey areas from contamination during and subsequent to the FSS. The LTP Section 5.6.3 describes isolation and control measures during and following the FSS.

Isolation and control measures in owner-controlled areas adjacent to the subject property will be iniplemented and will remain in force throughout site final survey activities and until there is no undue risk of recontamination from decommissioning. In the event that isolation and control measures established for these survey areas are compromised, evaluations will be performed and documented to confirm that no radioactive material was introduced into the area that would affect the results of the FSS. Given the isolation and controls established for the FSS areas adjacent to the subject property it is highly unlikely that radioactive materials could be introduced into the subject property borders.

Radioactive material generated during the decommissioning process will be handled and controlled in a manner to prevent contamination of the subject non-impacted areas.

These controls include contamination containment, dust control measures, storm water runoff control measures, and proper radiological protection program implementation (including periodic Page 18 of20

ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release

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LACROSSESOLUTIONS surveillances).

Additionally, open-air demolition controls of primary side structures are implemented to limit the spread of contamination during demolition.

Limits on residual contamination levels that allow for the open-air demolition of primary side structures without adverse effects on the environment have been established. Prior to structure demolition, a Contamination Verification Survey is performed to verify the residual contamination levels are below the established limits.

Impact of Releasing the Subject Property on Part 50 License Basis The license basis for the LACBWR includes the maintenance of certain programs to fulfill regulatory requirements and functional responsibilities. Throughout decommissioning, these programs are modified as necessary and terminated when the applicable concern is no longer relevant. These program changes are implemented using the change processes specified for each type of program. The methodology for releasing land requires a review and assessment of the impact on license program for the site lands remaining within the domain of the Part 50 License.

The Technical Specifications are not impacted by the early release of the subject property.

The Decommissioning Plan I Post Shutdown Decommissioning Activities Report, which is the Safety Analysis Report (SAR) equivalent at LACBWR, will not be impacted by the early release of the subject prope1iy.

The Radiological Groundwater Protection Program will not be affected by early release of the subject property.

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

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

The License Te1mination Plan (LTP), will be revised to describe the reduced site area resulting from the release of the subject property.

CONCLUSION The release of the subject prope1iy is part of LaCrosseSolutions overall efforts to te1minate the LACBWR Part 50 License and to achieve unrestricted release of the entire site (with the exception of the ISFSI area) in accordance with the criteria in subpart E of 10 CFR 20.

In addition, 10 CFR 50.82(a) (11) establishes the criteria to be used by the NRC for terminating the license of a power reactor facility.

These criteria include (1) dismantlement has been performed in accordance with the approved license termination plan and, (2) the final radiation survey and associated documentation demonstrate that the facility and site have met the criteria for decommissioning in 10 CFR 20, Subpart E. This early release of the subject property area also supports the process of license termination by demonstrating that this portion of the site lands can be released from the LACBWR license. This report along with future reports provides documentation that demolition activities have been performed in accordance with the LTP and the characterization survey confirms the residual radioactivity in each subject survey unit meets Page 19 of20

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ATTACHMENT 1 LA CB WR Supporting Infonnation for Request for Partial Site Release LACROSSESOLUTIONS the criteria established in the LTP. Thus this action of the early release of the subject land supports the overall license termination process in accordance with NRC regulations.

In summary, based on the considerations discussed above, this release of the subject property from the LACBWR Part 50 License has no impact on LaCrosseSolutions continued compliance with applicable NRC regulatory requirements and standards. LaCrosseSolutions has determined under 10 CFR 50.83 (a and b) that we have adequately evaluated the effect of releasing the subject property, and that the release area has been properly classified as "non-impacted."

Accordingly, LaCrosseSolutions is requesting the NRC to approve the requested release.

REFERENCES

1.

RS-TD-313196-003 "LA CB WR Historical Site Assessment," dated November 9, 2015.

(Reference previously submitted with LaCrosse LTP)

2.

Barbara Nick, Dairyland Power Cooperative, Letter to U.S. Nuclear Regulatory Commission, "Application for Order Approving License Transfer and Conforming Administrative License Amendments," dated October 8, 2015.

3.

Marlayna Vaaler, U.S. Nuclear Regulatory Commission, Letter to Barbara Nick, Dairyland Power Cooperative, "Order Approving Transfer of License for the La Crosse Boiling Water Reactor from the Dairyland Power Cooperative to LaCrosseSolutions, LLC and Conforming Administrative License Amendment," dated May 20, 2016.

4.

Nuclear Regulatory Commission NUREG-1575, Revision 1, "Multi-Agency Radiation Survey and Site Investigation Manual (MARS SIM)" - August 2000.

5.

U.S. Nuclear Regulatory Commission-NUREG-1757, Volume 2, Revision 1, "Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria, Final Report" - September 2003.

6.

EnergySolutions PG-E0-313196-SV-PL-001, "Characterization Survey Plan for the La Crosse Boiling Water Reactor," Revision 1 - June 2015. (Reference previously submitted with LaCrosse LTP)

7.

EnergySolutions GP-E0-313196-QA-PL-001, "Quality Assurance Project Plan LACBWR Site Characterization Project," Revision 0 - October 2014. (Reference previously submitted with LaCrosse LTP)

8.

EnergySolutions GG-E0-313196-RS-RP-001, "LACBWR Radiological Characterization Report for October and November Field Work Genoa, Wisconsin," Revision 0 - November 2015. (Reference previously submitted with LaCrosse LTP)

9.

"LACBWR License Termination Plan," Revision 0 - June 2016.

10.

EnergySolutions LC-RS-PN-164017-001 "LACBWR Radiological Characterization Survey Report for June thru August 2015 Field Work Genoa, Wisconsin," Revision 0 - May 2016.

(Reference previously submitted with LaCrosse LTP)

11.

ZionSolutions Technical Support Document 13-004, Examination of Cs-13 7 Global Fallout in Soils at Zion Station. (Reference previously submitted with LaCrosse LTP)

12.

USNRC NUREG 0191, "Environmental Statement related to Operation of the La Crosse Boiling Water Reactor by Dairyland Power Cooperative" - April 1980.

13.

LA CB WR Decommissioning Plan I Post Shutdown Decommissioning Activities Report -

June 2016. (Reference previously submitted with LaCrosse LTP)

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LACROSSESOLUTIONS 10 CFR 50.83(b)

June 27, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 La Crosse Boiling Water Reactor Facility Operating License No. DPR-45 NRC Docket Nos. 50-409 and 72-046

Subject:

La Crosse Boiling Water Reactor Request for Partial Site Release

References:

LC-2016-0021

1) Gerard van Noordennen, LaCrosseSolutions, Letter to U.S. Nuclear Regulatory Commission, "License Amendment Request for the License Termination Plan," dated June 27, 2016 LaCrosseSolutions, the licensee for the La Crosse Boiling Water Reactor (LACBWR), is requesting approval to remove a portion of the site from the Part 50 license (License No. DPR-45). Specifically, LaCrosseSolutions requests approval to remove the non-impacted sur-vey units from its Part 50 license in accordance with 10 CFR 50.83(b ), "Release of part of a power reactor facility or site for unrestricted use.", "LACBWR Supporting Information for Request for Partial Site Release,"

provides the supporting information for a partial release of the site for unrestricted use before receiving approval of the License Termination Plan (LTP) in accordance with the provisions of 10 CFR 50.83(b). The LACBWR LTP was previously submitted as documented in Reference 1 and is currently under review by the NRC. Attachment 1 includes a description of the property and evaluation of the effect of releasing this property. The evaluation concludes that all applicable regulatory requirements will continue to be met and no change to the LACBWR Operating License or the Permanently Defueled Technical Specifications is required.

Reference documents supporting the summary and conclusions described in Attachment 1 were previously provided with the L TP submittal.

There are no regulatory commitments made in this submittal. LaCrosseSolutions requests NRC approval of this request by February 28, 2017. If you should have any questions regarding this submittal, please contact Joe Jacobsen at (608) 689-4259 or myself at 224-789-4025.

Respectfully, G.v~~~j~

Gerard van Noordennen Vice President Regulatory Affairs S4601 State Highway 35, Genoa, WI 54632

LaCrosseSolutions LCS-2016-0021 Page 2 of2

Attachment:

1) Attachment 1, "LA CB WR Supporting Information for Request for Partial Site Release" cc:

Marlayna Vaaler, U.S. NRC Project Manager Service List

La Crosse Boiling Water Reactor Service List cc:

Ken Robuck Group President Disposal and Decommissioning Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 John Sauger Executive VP and Chief Nuclear Officer ReactorD&D Energy Solutions 2701 Deborah Avenue Zion, IL 60099 Gerard van Noordennen VP Regulatory Affairs Energy Solutions 2701 Deborah Avenue Zion, IL 60099 Joseph Nowak General Manager LaCrosseSolutions S4601 State Highway 35 Genoa, WI 54632-8846 Dan Shrum Senior VP Regulatory Affairs Energy Solutions 299 South Main Street, Suit~ 1700 S~t Lake City, UT 84111 Russ Workman General Counsel Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111.

George Kruck, Chairman Town of Genoa S5277 Mound Ridge Road Genoa, WI 54632 Regional Administrator U.S. NRC, Region III 2443 Warrenville Road Lisle, IL 60532-4352 Jeffery Kitsembel Division of Energy Regulation Wisconsin Public Service Cqmmission P.O. Box 7854 Madison, WI 53707-7854 Paul Schmidt, Manager Radiation Protection Section Bureau of Environmental and Occupational Health Division of Public Health.

Wisconsin Department of Health Services P.O. Box 2659 Madison, WI 53701-2659 Barbara Nick President and CEO Dairyland Power Cooperative 3200 East A venue South, La Crosse, WI 54602-081 7 Cheryl Olson, ISFSI Manager La Crosse Boiling Water Reactor Dairyland Power Cooperative S4601 State Highway 35 P.O. Box 817 Genoa, WI54632-8846 Lane Peters L.a Crosse Boiling Water Reactor Dairyland Power Cooperative S4601 State Highway 35 Genoa, WI 54632-8846 Thomas Zaremba Wheeler, Van Sickle and Anderson, S.C.

44 East Mifflin Street, Suite 1000 Madison, WI 53703 John E. Matthews Morgan, Lewis & Bockius LLP 1111 Pennsylvania A venue, NW Washington, DC 20004.

ATTACHMENT 1 LACBWR Supporting Information for Request for Partial Site Release

ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release PURPOSE

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LACROSSESOLUTIONS The purpose of this report is to request Nuclear Regulatory Commission (NRC) approval to remove a portion of the La Crosse Boiling Water Reactor (LACBWR) site from the Part 50 license (License No. DPR-45). Specifically, LaCrosseSolutions intends to remove five (5) non-impacted survey units from its Part 50 License in accordance with 10 CFR 50.83(b ), "Release of Part of a Power Reactor Facility or Site for Unrestricted Use" and 10 CFR 100, "Reactor Site Criteria." LaCrosseSolutions has also reviewed and assessed the subject property to ensure that the subject land area will have no adverse impact on the ability of the site in aggregate to meet 10 CFR Part 20, Subpart E, criteria for unrestricted release. This report contains a summary of the assessment performed, as well as a summary of the characterization surveys performed in these survey units. It is noted that this report does not contain the Final Status Survey (FSS)

Report for this area because the survey units within this area are characterized as non-impacted and as such, no statistical tests, scan and static measurements or elevated measurement comparisons are required. Table 1 provides a classification and description list for the subject survey units. Figure 1 provides a depiction of the site's geographical location and Figures 2 and 3 depict an overview of the survey unit boundaries and the site boundary/non-impacted survey unit comer coordinates, respectively.

Table 1 - Classification and Description List of Non-Impacted Open Land Survey Units Survey Unit Approximate Survey Unit Description Classification Survey Unit ID#

Area (m2)

L4012103 G-3 Plant and related Facilities Area Grounds Non Impacted 66,869 L4012105 Coal Plant Coal Pile Area Grounds Non Impacted 82,894 L4012106 South of Coal Pile Area Grounds w/o ISFSI Non In1pacted 111,899 Controlled Area L4012107 Grounds across Highway 35 to East Non In1pacted 81,254 L4012108 Right of Ways-Highway 35/Railroad Non In1pacted 9,444 Page 1 of20

ATTACHMENT 1 LA CB WR Supporting Infonnation for Request for Partial Site Release

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Figure 1, LACBWR Regional Location Page 2 of20 E1 oa re co

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LACROSSESOLUTIONS

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ATTACHMENT 1 LA CB WR Supporting Infonnation for Request for Partial Site Release

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LACROSSESOLVTIONS Figure 2, Boundaries of Non-Impacted Open Land Survey Units Legend LACB\\NR Buildings Nonimpacted Survey Units

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Date 05123/2016 LlCROSSLSa.UT~ Drawing 16041301.b Page 3 of20

ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release Legend Nonimpected Survey Units LACBWR Buildings survey Unit Vertices Figure 3, Site Boundary/Non-Impacted Survey Units Corner Coordinates Page 4 of20

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LACR~ESOLVTIONS NonimpKMO StlNey Uni

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D4n 9/2016 l..~IOSSt:.Sl'M.LfTR.l.U Drwir~ 1004 llOJ a

ATTACHMENT 1 LACBWR Supporting Information for Request for Partial Site Release BACKGROUND

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LACROSSESOLUTIONS The La Crosse Boiling Water Reactor (LACBWR) was a 50 Megawatt Electric (MWe) BWR that is owned by Dairyland Power Cooperative (DPC). This unit, also known as Genoa 2, is located on the DPC Genoa site on the east shore of the Mississippi River south of the Village of Ge~oa, Vernon County, Wisconsin.

The LACBWR was formerly owned by the Atomic Energy Commission (AEC) and operated by DPC under the provisions of an AEC contract and Provisional Operating Authorization No.

DPRA-6 issued on October 31, 1969 (Docket No. 115-5). On August 28, 1973 the license was converted to Provisional Operating License No. DPR-45 (Docket No. 50-409) issued to DPC.

The DPC operated the LACBWR until April 30, 1987 when it ceased power producing operations. By Amendment No.63 dated August 18, 1988, the license was changed to a Possession Only License No. DPR-45. ISFSI construction and spent fuel off-load to the ISFSI was completed in 2012*. (Reference 1).

On October 8, 2015 Dairyland Power Cooperative and LaCrosseSolutions, LLC submitted an Application for License Transfer and Conforming Administrative License Amendment to the NRC requesting that the NRC consent to the transfer of the DPC Operating License from DPC to LaCrosseSolutions, LLC (Reference 2). The NRC approved the license transfer as documented in the "Order Approving Transfer of License for the La Crosse Boiling Water Reactor from the Dairyland Power Cooperative to LaCrosseSolutions, LLC

and Conforming Administrative License Amendment," dated May 20, 2016 (Reference 3).

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ATTACHMENT 1 LACBWR

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Supporting Information for Request for Partial Site Release LACROSSESOLUTIONS EVALUATION OF EFFECT OF PROPOSED RELEASE LaCrosseSolutions has evaluated the effect of releasing the subject property from the Part 50 License in accordance with the criteria specified in 10 CFR 50.83(a)(l-3) in order to ensure that LACBWR will continue to comply with all applicable statutory and regulatory requirements that may be affected by the release of the subject property.

Specifically, LaCrosseSolutions evaluation confirmed the following with respect to each of the regulatory areas identified in 10 CFR 50.83(a) (1) (i)-(vi), (a) (2) and (a) (3):

(a) (1)

Evaluate the effects of releasi11g the property to e11sure that:

i.

The dose to i11dividual members of the public does not exceed the limits and standards of 10 CFR Part 20, Subpart D.

LaCrosseSolutions strictly controls effluents to ensure radioactivity released to the environment is maintained ALARA and does not exceed federal release limit criteria. Effluent controls include the operation of radiation monitoring systems within the plant as well as an offsite environmental analysis program. The release of the subject property does not change any controls used to comply with dose limits for individual members of the public and the conservatively estimated yearly dose to a member of the_ public is well below the 10 CFR Part 20, Subpart D limits and standards.

A review of the latest quarterly boundary TLD readings shows that the highest possible dose to a member of the public is 0 along the ISFSI fence line. Table 2 provides the yearly dose to a member of the public at the five locations. closest to the site source te1m. Note this is the first quarter results of 2016 with all 5 Ve1iical Concrete Casks (VCCs) containing spent fuel on the ISFSI pad.

Table 2, REMP Boundary TLD Readings for 1st Quarter of 2016 TLD Occupancy Estimates AVGBKG TLD#

(mR) mR/Qtr mR/year (gross)

Hours Factor 1

21mR 251nR 67 0.01 0.00 0.00 7

21 mR 25mR 67 0.01 0.00 0.00 8

22mR 25mR 67 0.01 0.00 0.00 9

22mR 25mR 67 0.01 0.00 0.00 10 23mR 25mR 67 0.01 0.00 0.00 Page 6 of20

ATTACHMENT 1 LA CB WR Supporting Information for Request for Partial Site Release

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LACROSSESOLUTIONS ii.

There is no reduction in the effectiveness of emergency planning or physical security.

No credit is taken for this land in either the Emergency Plan or Security Plan.

Therefore, the release of the subject property has no adverse effect on either plan.

iii.

Effluent releases remain within license conditions.

The LACBWR programs to monitor and maintain effluent releases within license conditions remain in effect and the early release of the subject property does not impact those programs. Therefore, the effluent releases from LACBWR will remain within license conditions.

iv.

The enviromnental monitoring program and offsite dose calculation manual

(ODCM) are revised to account for the changes.

The owner controlled boundary will remain the same and therefore, the Environmental Monitoring Program, ODCM and supporting documents are still valid and no changes are needed.

v.

The siting criteria of 10 CFR Part 100 continues to be met.

The release of the subject property has been reviewed with respect to the siting criteria in 10 CFR 100 and it has been detennined that the requirements of 10 CFR 100 are either not impacted (e.g., 10 CFR 100.11, low population zone or population center distance or 10 CFR 100 Appendix A, Seismic and Geologic Siting Criteria) or are not applicable (e.g., 10 CFR 100, Subpart B, Evaluation Factors for Stationary Power Reactor Site Application on or after January 1 o; 1997). The reactor vessel has been defueled and removed from the site for disposal in 2008. The spent fuel has been relocated to the south end of the site into the licensed ISFSI area in 2012.

vi.

All other applicable statutory and regulat01y requirements continue to be met.

There are no changes to the LACBWR policies and procedures to ensure that statutory and regulatory requirements continue to be met as a result of this early release of the subject property.