ML16200A083

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Boiling Water Reactor, License Amendment Request for the License Termination Plan
ML16200A083
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 07/27/2016
From: Gerard van Noordennen
LaCrosseSolutions
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LC-2016-0022
Download: ML16200A083 (39)
v • d • e


Text

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LACROSSESOLUTIONS June 27, 2016 LC-2016-0022 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:

License Amendment Request for the License Termination Plan

References:

1) Barbara A. Nick, President and CEO, 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
2) Marlayna V aaler, 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 The La Crosse Boiling Water Reactor facility (LACBWR) is owned by Dairyland Power Cooperative (Dairyland). Dairyland purchased LACBWR in July 1973. LACBWR was shut down on April 30, 1987. All spent nuclear fuel elements from LACBWR have been transferred from the Fuel Element Storage Well to dry cask storage at the on-site Independent Spent Fuel Storage Installation (ISFSI) as of September 19, 2012. The remaining LA CB WR unit, and its associated buildings and structures are ready for dismantlement and decommissioning activities.

As documented in Reference 1, Dairyland and LaCrosseSolutions, LLC (Solutions) submitt~d an application requesting that the U.S. Nuclear Regulatory Commission (NRC) consent to the transfer of Dairyland's Possession Only License No. DPR-45 for the LACB WR to Solutions.

The Applicants requested that the NRC consent to the transfer ofDairyland's licensed possession, maintenance and decommissioning authorities to Solutions so as to implement expedited decommissioning at the LACBWR Site. The License transfer was approved on May 20, 2016 as documented in Reference 2. SAFSTOR was utilized prior to license transfer as the decommissioning approach since the permanent shutdown and defueling of LACB WR, with limited decontamination and dismantlement for the LACBWR facility. The new plan is to shift to active decommissioning (DECON), accelerate the decommissioning schedule, and begin decommissioning at this time. Decommissioning is scheduled to be completed by the end of 2018 excluding the ISFSI facility. Dairyland will continue to operate the Genoa 3 c9al-fired generating facility located at the site.

S4601 State Highway 35, Genoa, WI 54632

LaCrosseSolutions LC-2016-0022 Page 2 of3 With the approval of the license transfer, Solutions has assumed responsibility for all licensed

  • activities at the LACBWR Site, including responsibility under the license to complete decommissioning. As such, post license transfer regulatory correspondence will be with the new licensee, Solutions.

The LACBWR facility does not maintain a Safety Analysis Report (SAR). Dairyland's SAFSTOR Decommissioning Plan (D-Plan) was approved on August 7, 1991 via a NRC issued Decommissioning Order. The Decommissioning Order was modified September 15, 1994, by Confirmatory Order to allow Dairyland to make changes in the facility or procedures as described in the D-Plan, and to conduct tests or experiments not described in the D-Plan, without prior NRC approval, if a plant-'specific safety and environmental review procedure containing similar requirements as specified in 10 CFR 50.59 was applied. The NRC withdrew the September 15, 1995 Confirmatory Order in a letter dated March 31, 2016 based on the their determination that staffing requirements imposed by the order are now included in the LACBWR Quality Assurance Program Description (QAPD) and Post-Shutdown Decommissioning Activities Report (PSDAR) and changes to these documents are adequately controlled by 10 CFR 50.54(a), 10 CFR 50.59, and 10 CFR 50.82. The D-Plan includes the PSDAR. The joint document is titled, LACBWR Decommissioning Plan and Post-Shutdown Decommissioning Activities Report (D-Plan/PSDAR). Thus, for the purpose of this submittal, the LACBWR D-Plan/PSDAR is considered the equivalent of a SAR.

Pursuant to 10 CFR 50.90, Solutions proposes to amend its Possession Only License, DPR-45, .

by adding a license condition to reflect the approval of the LAC:BWR License Termination Plan (LTP). The proposed change provides the criteria by which the need for NRC approval of changes to th~ L TP is determined. The license termination plan is to be a supplement to the plant's UFSAR or an equivalent document (D-Plan/PSDAR) and is required to be submitted at least two years before the date of license termination. The proposed license change provided in ,

this attachment is submitted to satisfy the requirements of 10 CFR 50.82(a)(10) for approval of the License Termination Plan (LTP) by license amendment. Solutions is not, at this time, submitting its application for termination of license.

Portions of this submittal provide the NRC with fmancial information to aid in the review of the LACBWR License Termination Plan (LTP). Solutions considers this proprietary financial information to be confidential and requests NRC to withhold it from public disclosure under 10 CFR 2.390(a)(4).

This submittal contains a Solutions Proprietary Financial Information Affidavit pursuant to 10 CFR 2.390. The Affidavit sets forth the basis for which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in 10 CFR 2.3 90(b)(4). Ali documents within the scope of this affidavit are marked as "withhold from public disclosure under 10 CFR 2.390."

  • provides a discussion ofthe.,proposed change, technical analysis, regulatory analysis, and environmental impact consideration. Attachment 2 provides the proposed amended LACB WR Possession Only License. Attachment 3 provides the LACBWR L TP for NRC .

review and approval. Chapter 7 of the LTP *contains the proprietary financial information

LaCrosseSolutions LC-2016-0022 Page 3 of3 Solutions is providing to the NRC and seeks to have withheld from public disclosure in its entirety. Attachment 4 of this submittal contains a redacted version ofLACBWR LTP Chapter 7 for public disclosure. Supporting reference documentation is provided in Attachment 5. Select reference material is unavailable at this time and will be provided in a subsequent transmittal. contains a preflight report for the documentation provided on Computer Disk (CD). In accordance with 10 CFR 50.82(a)(9)(i), the LACBWR LTP is being submitted as a supplement to the SAR equivalent D-Plan/PSDAR, and will be maintained accordingly upon approval.

The proposed change does not impact the public health and safety and does not involve a Significant Hazards Consideration (SHC) pursuant to the provisions of 10 CFR 50.92 (see SHC provided in Section 4.1 of Attachment 1). In addition, the proposed change has been reviewed in consideration of 10 CFR 51.22; and it has been determined that the proposed change meets the criteria for a categorical exclusion from requiring an environmental impact statement.

In accordance with 10 CFR 50.91 (b), a copy of this license amendment request is being provided to the State of Wisconsin.

There are no regulatory commitments contained in this submittal. Solutions requests approval of the proposed change by December 2017. If you should have any questions regarding this submittal, please contact me at (224) 789-4025.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June 27, 2016.

Respectfully, G.~~~-

Gerard van Noordennen Vice President Regulatory Affairs Attachments 1.) Attachment 1, LACBWR License Amendment Request 2.) Attachment 2, LACBWR Proposed License Condition 3.) Attachment 3, LACBWR Proposed License Termination Plan 4.) Attachment 4, License Termination Plan Chapter 7 Redacted Version 5.) Attachment 5, Reference Document~tion 6.) Attachment 6, Preflight Report for CD Attachments cc: Marlayna V aaler, U.S. NRC Project Manager U.S. NRC, Region III, Regional Administrator Service List (Cover letter only, no attachments)

La Crosse Boiling Water Reactor Service List cc:

Ken Robuck Jeffery Kitsembel Group President Disposal and Division of Energy Regulation Decommissfoning \Visconsin Public Service Commission EnergySolutions P.O. Box 7854 299 South Main Street, Suite 1700 Madison, \VI 53707-7854 Salt Lake City, UT 84111 Paul Schmidt, Manager John Sauger Radiation Protection Section Executive VP and Chief Nuclear Officer Bureau of Environmental and Occupational Health ReactorD&D Division of Public Health EnergySolutions \Visconsin Department of Health Services 2701 Deborah Avenue P.O. Box 2659 Zion, IL 60099 Madison, \VI 53701-2659 Gerard van Noordennen Barbara Nick VP Regulatory Affairs President and CEO EnergySolutions Dairyland Power Cooperative 2701 Deborah Avenue 3200 East Avenue South, Zion, IL 60099 La Crosse, \VI 54602-0817 Joseph Nowak Cheryl Olson, ISFSI Manager General Manager La Crosse Boiling \Vater Reactor LaCrosseSolutions Dairyland Power Cooperative S4601 State Highway 35 S4601 State Highway 35 Genoa, \¥154632-8846 P.O. Box 817 Genoa, \¥154632-8846 Dan Shrum Senior VP Regulatory Affairs Lane Peters EnergySolutions La Crosse Boiling \Vater Reactor 299 South Main Street, Suite 1700 Dairyland Power Cooperative Salt Lake City, UT 84111 S4601 State Highway 35 Genoa, \VI 54632-8846 Russ \Vorkman General Counsel Thomas Zaremba EnergySolutions \\!heeler, Van Sickle and Anderson, S.C.

299 South Main Street, Suite 1700 44 East Mifflin Street, Suite 1000 Salt Lake City, UT 84111 Madison, \VI 53703 George Kruck, Chairman John E. Matthews Town of Genoa Morgan, Lewis & Bockius LLP S5277 Mound Ridge Road 1111 Pennsylvania Avenue, N\V Genoa, \VI 54632 \Vashington, DC 20004 Regional Administrator U.S. NRC, Region III 2443 \Varrenville Road Lisle, IL 60532-4352

LaCrosseSolutions, LLC PROPRIETARY FINANCIAL INFORMATION AFFIDAVIT Affidavit of Gerard van Noordennen, Vice President Regulatory Affairs, LaCrosseSolutions, LLC.

LTP Chapter 7, contained in Attachment 3 of this submittal, consists of proprietary financial information that LaCrosseSolutions, LLC considers confidential. Release of this information would cause irreparable harm to the competitive position of LaCrosseSolutions, LLC. The basis for this declaration is: *

1. This information is owned and maintained as proprietary by LaCrosseSolutions, LLC, iL This information is routinely held in confidence by LaCrosseSolutions, LLC and not disclosed to the public,
m. This information is being requested to be held in confidence by the NRC by this petition, iv. This information is not available in public sources,
v. This information would cause substantial harm to LaCrosseSolutions, LLC if it were released publicly, and vi. The information to be withheld is being transmitted to NRC in confidence.

I, Gerard van Noordennen, being duly sworn, state that I am the person who subscribes my name the foregoing statement, I am authorized to execute the Affidavit on behalf of LaCrosseSolutions, LLC, and that the matters and facts set forth in the statement are true to the best of my knowledge, information, and belief.

Name: Gerard van Noordennen

Title:

Vice President Regulatory Affairs Company: LaCrosseSolutions, LLC .

SUBSCRIBED AND SWORN TO BEFORE ME Y of June, 2016 UNDACHOU Otflctlt ltll 1

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Attachment 1 LACBWR License Amendment Request

.*'iro .. * .*

La Crosse Boiling Water Reactor (LACBWR)

License Amendment Request New License Condition Related to the License Termination Plan, Discussion of Changes, Technical and Regulatory Analysis Including Significant Hazards Consideration Discussion

1.0 INTRODUCTION

The LACBWR facility is an Atomic Ene~gy Commission Demonstration Project Reactor, which went critical in 1967 and commenced commercial operation in November 1969 and which was capable of producing 50 megawatts. Dairyland purchased LACBWR in July 1973. LACBWR was shut down on April 30, 1987. All 333 spent nuclear fuel elements from LACBWRhave been transferred from the Fuel Element Storage Well to dry cask storage at the on-site Independent Spent Fuel Storage Installation (ISFSI) as of September 19, 2012. The remaining LACBWR unit, and its associated buildings and structures are ready for dismantlement and decommissioning activities. Dairyland will continue to operate the Genoa 3 coal-fired generating facility located at the site.

SAFSTOR was utilized prior to license transfer as the decommissioning approach since the permanent shutdown and defueling ofLACBWR; with limited decontamination and dismantlement for the LACBWR facility. The new plan is to shift to the .

decommissioning method (DECON), accelerate the decommissioning schedule, and begin decommissioning at this time. The revised schedule reflects that the Reactor was removed and shipped in 2007 and the spent fuel has been previously transferred to the on-site ISFSI facility at the LACBWR Site. The decontamination and dismantlement of the ISFSI and associated systems will occur once the spe,nt fuel is transferred offsite.

Decommissioning is scheduled to be completed by the end of 2018 excluding the ISFSI facility.

Dairyland's SAFSTOR Decommissioning Plan (D-Plan) was approved on August 7, 1991. The D-Plan includes the Post-Shutdown Decommissioning Activities Report (PSDAR). The joint document is titled, LACBWR Decommissioning Plan and Post-Shutdown Decommissioning Activities Report (D-Plan/PSDAR). The PSDAR public meeting was held on May 13, 1998.

Section 50.82(a)(9) to Title 10 of the Code of Federal Regulations requires that a licensee must submit an application for the termination of the site's Part 50 license. The application for termination of the license must be accompanied or preceded by a license termination plan to be submitted for NRC approval. The license termination plan is to be a supplement to the plant's UFSAR or an equivalent document (D-Plan/PSDAR) and is required to be submitted at least two years before the date of license *termination. The proposed license change provided in this attachment is submitted to satisfy the requirements of 10 CFR 50.82(a)(10) for approval of the License Termination Plan (LTP) by license amendment. Solutions is not, at this time, submitting its application for termination of license.

2.0 DESCRIPTION

OF PROPOSED CHANGES Solutions proposes to amend the license to include a provision to allow Solutions to make changes to the approved LTP without prior NRC approval, similar to the flexibility afforded to licensees in making changes to the. facilities or procedures, as described in the SAR or equivalent (D-Plan/PSDAR).

The change method includes nine change criteria elements. Thus, Solutions proposes to amend the LACBWR possession only license to incorporate a new license condition, License Condition. 2.C (5) as follows:

2. C (5) License Termination Plan. (LTP)

Solutions shall implement and maintain in effect all provisions of the approved License Termination Plan, as approved in License Amendment No. xxx subject to and as amended by the following stipulations:

Solutions may make changes to the L TP without prior approval provided the proposed changes do not meet any of the following criteria:

(A) Require Commission approval pursuant to 10 CFR 50.59.

(B) Result in significant environmental impacts not previously reviewed.

(C) Detract or negate the reasonable assurance that adequate funds will be available for decommissioning. *

(D) Decrease a survey unit area classification (i.e., impacted to* not impacted; Class 1 to Class 2; Class 2 to Class 3; or Class 1 to Class 3) without providing the NRC a minimum 14 day notification prior to implementing the change in classification.

(E) Increase the soil or buried piping derived concentration guideline levels (DCGL) and related minimum detectable concentrations (for both scan and fixed measurement methods).

(F) Increase the Basement Dose Factors.

(G) Increase the radioactivity level, relative to the applicable DCGL, at which an investigation occurs. *

(H) Change the statistical test applied other than the Sign test or Wilcoxon Rank Sum test.

(I) Increase the probability of making a Type I decision error above the level stated in the LTP. ...r

3.0 TECHNICAL ANALYSIS

The LACBWR LTP describes the process used to meet the requirements for terminating the LACBWR 10 CFR Part 50 possession only license and release the site for unrestricted use. The L TP has been prepared in accordance with the requirements in 10 CFR 50.82(a)(9) and is submitted as a supplement to the LACBWR SAR equivalent D-Plan/PSDAR. The LTP submittal is accompanied by a proposed license amendment that establishes the criteria for when changes to the LTP require prior NRC approval.

The subsections below provide a brief summary of the eight chapters of the L TP.

The LTP includes a discussion on the following topics:

  • Introduction and general information,
  • Site Characterization to ensure that Final Radiation Surveys (FRS) cover all areas where contamination existed, remains, or has the potential to exist or remain,
  • Identification of remaining dismantlement activities,
  • Plans for site remediation,
  • A description of the FRS plan to confirm that LACBWR will meet the release criteria in 10 CFR 20, Subpart E,
  • Dose-modeling scenarios that ensure compliance with the radiological criteria for license termination,
  • An estimate of the remaining site-specific decommissioning costs, and
  • A supplement to the SAR equivalent (D-Plan/PSDAR) and the Environmental Report describing any new information or significant environmental change associated with proposed license termination activities.

This license amendment request gives the NRC the opportunity to review the LACBWR LTP to ensure Solutions' planned activities and processes meet the criteria in 10 CFR 50.82(a)(9) and NUREG-1700 (Reference 2). Additionally, in accordance with NUREG-1700, Revision 1, Appendix 2, the license condition requires NRC approval for changes to the methodology that could result in increasing the amount of plant-related activity remaining at the time of license termination compared to the methodology the NRC reviewed in the proposed LTP.

Since the L TP is based on NRC guidance and establishes the methodology Solutions will use to meet license termination criteria, this proposed license amendment is appropriate to allow completion of the LACBWR decommissioning project and license termination.

4.0 REGULATORY ANALYSIS

4.1 No Significant Hazards Consideration In accordance with 10 CFR 50.92, Solutions has reviewed the proposed changes and concluded that the proposed changes do not involve a Significant Hazard Consideration (SHC). The proposed changes do not involve an SHC because the changes would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

The only remaining accident following completion of fuel transfer to the ISFSI is a radioactive release accident where spontaneous release of the (non-ISFSI-related) radioactive source term remaining at the LACBWR site in a form and quantity is immediately released through an airborne or

)

liquid release path.

A radioactive release analysis was performed to establish the bounding event at the site considering the current stage of LACB WR decommissioning. 1.175 Ci of radioactive material is conservatively estimated in the .analysis to be present on plant surfaces, and as such represents the assumed total non-ISFSI radioactive source term remaining at the LACBWR site. The LACBWR analysis of postulated release events separately considers the portion of this remaining radioactive contamination that is immediately releasable as airborne* contamination and that is immediately releasable as contaminated liquid.

A conservative fraction of 30 percent of the total remaining source term is assumed in the analysis to be iihmediately available for airborne release.

The analysis results demonstrate that the consequences of releasing 30 percent of the non-ISFSI radioactive source term remaining at the LACBWR site to the atmosphere are well within the applic.able 10 CFR 100.11 and EPA PAG limits.

The portion of the total remaining source term conservatively assumed in

  • the analysis to be available for liquid release at any one time is 80 percent of the radioactively contaminated liquid stored in the site retention tank.

In the unlikely event that 80 percent of the retention tank volume at a total radionuclide concentration of 3.9E-03 µCi/cc were to be released from.the retention tank at a flow rate of 20 gpm, the normal effluent concentration limits of 10 CFR 20, Appendix B, Table 2, would not be exceeded. Thus, the liquid release analysis demonstrates that there is no reasonable likelihood that a postulated radioactive liquid release event could result in exceeding the normal effluent concentration limits of 10 CFR 20, '

Appendix B.

With consideration for the current stage ofLACBWR decommissioning.

and with spent nuclear fuel now stored in the ISFSI, the bounding radioactive release analysis, for both airborne and liquid releases, confirms that the minimal radioactive material resulting from LACBWR operation and remaining on the LACBWR site is insufficient for any potential event to result in exceeding dose limits or otherwise involving a significant adverse effect on public health and safety.

The proposed change does not affect the boundaries used to evaluate compliance with liquid or gaseous effluent limits, and has no impact on plant operations. The proposed changes do not have an adverse impact on the remaining decommissioning activities or any decommissioning related postulated accident consequences.

The proposed changes related to the approval of the LTP do not affect operating procedures or administrative controls that have the function of preventing or mitigating the remaining decommissioning design basis accident. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of any accident previously evaluated.

2. Create the possibility of a new or different kind of accident from any accident previously evaluated.

The accident analysis for the facility related to decommissioning activities is described in the D-Plan/PSDAR. The requested license amendment is consistent with the plant activities described in the D-Plan/PSDAR. Thus, the proposed changes do not affect the remaining plant systems, structures, or components in a way not previously evaluated.

There are sections of the LTP that refer to the decommissioning activities still remaining. These activities are performed in accordance with approved site processes and undergo a 10 CPR 50,59 review as required prior to initiation. The proposed amendment merely makes mention of these processes and does not bring about physical changes to the facility.

Therefore, the facility conditions for which the remaining postulated accident has been evaluated is still valid and no new accident scenarios, failure mechanisms, or single failures are introduced by this amendment.

The system operating procedures are riot affected. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Involve a significant reduction in a margin of safety.

The LTP is a plan for demonstrating compliance with the radiological criteria for license termination as provided in 10 CFR 20.1402 (Reference 3). The margin of safety defined in the statements of consideration for the final rule on the Radiological Criteria for License Termination is described as the margin between the 100 mrem/yr public dose limit established in 10 CFR 20.1301 for licensed operation and the 25 mrem/yr dose limit to the aven~.ge member of the critical group at a site considered acceptable for unrestricted use (one of the criteria of 10 CFR 20.1402). This margin of safety accounts for the potential effect of multiple sources of radiation exposure to the critical group. Since the License Termination Plan is designed to comply with the radiological criteria for license termination for unrestricted use, the LTP supports this margin of safety.

In addition, the LTP provides the methodologies and criteria that will be used to perform remediation activities of residual radioactivity to demonstrate compliance with the ALARA criterion of 10 CFR 20.1402.

Additionally, the LTP is designed with recognition that (a) the methods in MARSSIM (Multi-Agency Radiation Survey and Site Investigation Manual) (Reference 4) and (b) the building surface contamination levels are not directly applicable to use with complex nonstructural components.

Therefore, the LTP states that nonstructural components remaining in

  • buildings (e.g., pumps, heat exchangers, etc.) will be evaluated against the criteria of Regulatory Guide 1.86 (Reference 5) to determine if the components can be released for unrestricted use. The LTP also states that materials, surveyed and evaluated as a-part of normal decommissioning activities and prior to implementation of the final radiation surveys, will be surveyed for release using current site procedures to demonstrate compliance with the "no detectable" criteria. Such materials that do not pass these criteria will be controlled as contaminated.

Also, as previously discussed, the bounding radioactive release accident analysis for decommissioning is based on a: conservative estimate of the radioactive material remaining onsite. Since the bounding accident results*

in a release of more airborne and liquid radioactivity than can be released from planned LTP decommissioning events, the margin of safety associated with the consequences of decommissioning accidents is not reduced by this activity.

Thus, the proposed change does not involve a significant reduction in the margin of safety.

4.2 Applicable Regulatory Requirements/Criteria Pursuant to 10 CPR 50.82(a)(9), nuclear power reactor licensees are required to submit an L TP prior to, or along with, their application for termination of a license. This LTP will become a supplement to the LACBWR D-Plan/PSDAR.

The LTP is required to be submitted at least 2 years before termination of the license.

Solutions is submitting a proposed amendment to the LACBWR possession only license to satisfy the requirements of 10 CPR 50.82(a)(10) for approval of the LACBWR LTP by license amendment. The change to the license will authorize the implementation of the LTP, allows the implementation of the methods outlined in Chapter 5 of the LTP for site compliance with dose-based release criteria, and.provides appropriate and necessary conditions for when changes can be made without prior NRC review and approval.

Solutions prepared the L TP using the guidance in:

  • Regulatory Guide 1.1 79 "Standard P ormat and Contents for License Termination Plans for Nuclear Power Reactors," (Reference 6)
  • NUREG-1575 "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),"
  • NUREG-1700 "Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans," and
  • NUREG-1757 "Consolidated NMSS Decommissioning Guidance" (Reference 7).

5.0 ENVIRONMENTAL CONSIDERATION

Solutions has evaluated the proposed changes against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CPR 51.22 (Reference. 8). Solutions has determined that the proposed changes meet the criteria for categorical exclusion set forth in 10 CPR 51.22(c)(9) and 10 CPR 51.22(c)(10) and as such, has determined that no irreversible consequences exist in accordance with 10 CPR 50.92(b). The following is provided in support of the conclusion.

(i) The proposed changes involve no significant hazards consideration.

As demonstrated in Section 4.1 ofthis attachment, the proposed changes do not involve an SHC.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released off site.

The proposed license amendment is consistent with the plant activities described in the D-Plan/PSDAR. No changes in effluent system requirements or controls are proposed in this change. The environmental impacts associated with radiation dose to members of the public related to decommissioning activities and site release for unrestricted use were considered in NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," (Reference 9) NUREG-0586, Supplement 1, and NUREG-1496, "Generic Environmental Impact Statement in Support of the Rulemaking on Radiological Criteria for License Termination" (Reference 10).

NUREG-0586 provides a generic environmental assessment of decommissioning a reference nuclear facility. Based on the findings in NUREG-0586, the NRC concluded a generic finding of "no significant (environmental) impact." The NRC further concluded that no additional Environmental Impact Statement would need to be prepared in connection with decommissioning a particular nuclear site unless the impacts of a particular plant have site-specific considerations significantly different from those studied generically. LTP Chapter 8 provides an updated assessment of the environmental effects of decommissioning LACBWR. The updated assessment also determined that the environmental effects from decommissioning LACBWR are minimal and there are no adverse effects outside the bounds of NUREG-0586, Supplement 1.

Based on the above, there will not be a significant change in the types or increase in the amounts of effluents released offsite for the remaining decommissioning activities. The release of effluents from the facility will continue to be controlled by site procedures throughout the remaining decommissioning activities, and continue to be performed in accordance with the LACBWR Offsite Dose Calculation Manual, as applicable.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The attributes identified in NUREG-0586, Supplement 1 were compared with the remaining activities for LACBWR and the following conclusion was reached:

  • Solutions w:ill maintain annual occupational radiation exposure to individuals as low as reasonably achievable. These exposures will be at, or below, the estimated values in Table 4-1 ofNUREG-0586, Supplement 1. LTP Section 3.4 provides a dose estimate for LACBWR decommissioning.

LTP Chapter 8 provides an updated assessment of the environmental effects of decommissioning LACBWR. The updated assessment also determined that the environmental effects from decommissioning LACBWR are minimal and there are no adverse effects outside the bounds ofNUREG-0586, Supplement 1.

Based on the above, there is no significant increase in individual or cumulative occupational exposure due to decommissioning LACBWR.

6.0 CONCLUSION

Based on the evaluations above: (1) there is reasonable assurance that the health and safety of the public wili not be endangered by the conduct of activities in the proposed manner, and (2) such activities will be conducted in compliance with the NRC's regulations. Therefore, the proposed amendment will not be inimical to the common

  • defense and security or the health an4 safety of the public.

7.0 REFERENCES

1) IO CFR 50.82, "Termination of License"
2) *NUREG-1700, "Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans"
3) IO CFR20, "Standards for Protection Against Radiation" .
4) NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARS SIM)"
5) Regulatory Guide 1.86, "Termination of Operating Licenses for Nuclear Reactors.
6) Regulatory Guide 1.179, "Standard Format and Contents for License Termination Plans for Nuclear Power Reactors" *
7) NUREG-1757, "Consolidated NMSS Decommissioning Guidance"
8) 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory .actions eligible for categorical exclusion or otherwise not requiring environmental review"
9) NUREG-0586, "Final Generic Environmental ltp.pact Statement on

. Decommissioning of Nuclear Facilities" and NUREG-0586 Supplement 1, "Regarding the Decommissioning of Nuclear Power Reactors"

10) NUREG-1496, "Generic Environmental Impact Statement in Support of the Rulemaking on Radiological Criteria for License Termination"

Attachment 2 LACBWR Proposed License Amendment

The following license condition to be added to the LACBWR possession only license:

2.C (5) License Termination Plan (LTP)

Solutions shall implement and maintain in effect all provisions of the approved License Termination Plan, as approved in License Amendment No. xxx subject to and as amended by the following stipulations:

Solutions may make changes to the LTP without prior approval provided the proposed changes do not meet any of the following criteria:

(A) Require Commission approval pursuant to 10 CFR 50.59.

(B) Result in significant environmental impacts not previously reviewed.

(C) Detract or negate the reasonable assurance that adequate funds will be available for decommissioning.

(D) Decrease a survey unit area classification (i.e., impacted to not impacted; Class 1 to Class 2; Class 2 to Class 3; or Class 1 to Class 3) without providing the NRC a minimum 14 day notification prior to implementing the change in classification.

(E) Increase the soil or buried piping derived concentration guideline levels (DCGL) and related minimum detectable concentrations (for both scan and fixed measurement methods).

(F) Increase the Basement Dose Factors.

(G) Increase the radioactivity level, relative to the applicable DCGL, at which an investigation occurs.

(H) Change the statistical test applied other than the Sign test or Wilcoxon Rank Sum test.

(I) Increase the probability of making a Type I decision error above the level stated in the LTP.

WITHHOLD CHAPTER 7 FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Attachment 3 LACBWR Proposed License Termination Plan (See attached binder or CD)

WITHHOLD CHAPTER 7 FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390,

LTP CHAPTER 7 REDACTED VERSION FOR PUBLIC DISCLOSURE Attachment 4 LACBWR Proposed License Termination Plan Chapter 7 Redacted Version LTP CHAPTER 7 REDACTED VERSION FOR PUBLIC DISCLOSURE

LA CROSSE BOILING WATER REACTOR LICENSE TERMINATION PLAN CHAPTER 7 UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOWTIONS TABLE OF CONTENTS

7. Update of the Site-Specific Decommissioning Costs .......................................................... 7-1 7.1. Introduction .................................................................................................................... 7-1 7 .1.1. Historical Perspective ............................................................................................ 7-1 7 .1.2. Cost Estimates Previously Docketed with the NRC .............................................. 7-2 7.2. Decommissioning Cost Estimate .................................................................................. 7-2 7.2.1. Cost Estimate Description and Methodology .....................................,. .................. 7-2 7.2.2. Summary of the Site-Specific Decommissioning Cost Estimate ........................... 7-3 7.2.3. Radiological Decommissioning Costs ................................................................... 7-4 7.2.4. Spent Fuel Management ......................................................................................... 7-7 7.2.5. Site Restoration Costs ...... :..................................................................................... 7-8 7.2.6. Contingency ............................................................................................................ 7-8 7.3. Decommissioning Funding Plan ................................................................................. 7-10 7.4. References ................................................................................................................... 7-11 LIST OF TABLES .

Table 7-1 Cost Summary for Radiological Decommissioning and Site Restoration ............. 7-4 Table 7-2 Estimated Radiological Decommissioning Cost by Major Project Activity ......... 7-5 Table 7-3 Estimated Radiological Decommissioning Cost by Major Resource Type ........... 7-5 Table 7-4 Breakdown of Radiological Decommissioning Costs by Detailed Activity .......... 7-6 Table 7-5 Estimated Site Restoration Cost by Major Project Activity .................................. 7-8 Table 7-6 Breakdown of Site Restoration Costs by Detailed Activity ................................... 7-9 Table 7-7 LA CB WR Summary of Annualized Costs (in Millions) ..................................... 7-10 7-i

La Crosse Boiling Water Reactor License Tennination Plan ~

Revision 0 LACROSSESOWTIONS LIST OF ACRONYMS AND ABBREVIATIONS Dairyland Dairyland Power Cooperative DOT Department of Transportation D-Plan/

PSDAR Decommissioning Plan and Post-Shutdown Decommissioning Activities Report FESW Fuel Element Storage Well FRS Final Radiation Survey GTCC Greater Than Class C I SF SI Independent Spent Fuel Storage Installation LACBWR La Crosse Boiling Water Reactor LTP License Termination Plan NDT Nuclear Decommissioning Trust NRC Nuclear Regulatory Commission QA Quality Assurance QC Quality Control ZNPS Zion Nuclear Power Station 7-ii

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOWTIONS

7. Update of the Site-Specific Decommissioning Costs 7.1. Introduction In accordance with 10 CFR 50.82(a)(9)(ii)(F) and Regulatory Guide 1.179, "Standard Format and Content for License Termination Plans for Nuclear Power Reactors" (1), the updated site specific cost estimates and funding plans for completing the La Crosse Boiling Water Reactor (LACBWR) decommissioning are provided. Regulatory Guide 1.179 provides guidance on the details of the information to be presented in the License Termination Plan (L TP).

This chapter provides an estimate of the remaining decommissioning costs at the time of L TP submittal and also compares these estimated costs with the present funds set aside for decommissioning .. If it is determined that there is a deficit in the present funding, the L TP must indicate the means for ensuring that adequate funds are available to complete the decommissioning.

The decommissioning cost estimate evaluates the following cost elements:

1. Cost assumptions used, including contingency factors;
2. Major decommissioning activities and tasks;
3. Unit cost factors;
4. Estimated costs for decontamination and removal of equipment and structures;
5. Estimated costs for waste disposal, including disposal site surcharges;
6. Estimated Final Radiation Survey (FRS) costs; and
7. Estimated total costs.

The cost estimate focuses on the remaining work, including costs of labor, materials, equipment, energy, and services. The cost estimate includes the cost of the planned remediation activities as well as the cost of the transportation and disposal of the waste generated by the planned work.

7.1.1. Historical Perspective The LACBWR facility was an Atomic Energy Commission Demonstration Project Reactor. The reactor went critical in 1967 and commenced commercial operation in November 1969. The reactor was capable of producing 50 Megawatt Electric (MWe). Dairyland Power Cooperative (Dairyland) purchased LACBWR in July 1973. LACBWR was shut down on April 30, 1987.

The LACBWR Decommissioning Plan (2) was approved on August 7, 1991. Because the licensing history of LACBWR spans a period that includes several decommissioning regulation changes, The D-Plan has been revised to the LACBWR Decommissioning Plan and Post-Shutdown Decommissioning Activities Report (D-Plan/PSDAR) Revision March 2014 (3).

All 333 spent nuclear fuel elements from LACBWR have been transferred from the Fuel Element Storage Well (FESW) to dry cask storage at the on-site Independent Spent Fuel Storage Installation (ISFSI) as of September 19, 2012. The remaining LACBWR buildings and structures are ready for dismantlement and decommissioning activities. Dairyland will continue to operate the Genoa 3 coal-fired generating facility located adjacent to the LACBWR facility.

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La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOWTIONS In a letter dated October 8, 2015 (1), Dairyland and LaCrosseSolutions, LLC (Solutions) requested Nuclear Regulatory Commission (NRC) consent to transfer Dairyland's possession, maintenance and decommissioning authorities, under Possession Only License No. DPR-45, from Dairyland to Solutions. NRC provided consent to the license transfer in May 2016. In compliance with 10 CFR 50.75(+/-)(1) and 10 CFR 50.82(a)(8)(v)(viii), Solutions will demonstrate financial assurance on an annual basis.

After the balance of the site is remediated and the as-left radiological conditions are demonstrated to be below the unrestricted use criteria specified in 10 CFR 20.1402, the licensed area will be reduced to a small area around the ISFSI and Possession Only License No.

DPR-45 will be transferred back to Dairyland.

7.1.2. Cost Estimates Previously Docketed with the NRC An updated cost study was completed in November 2010 and was included as part of a revised LACBWR D-Plan/PSDAR, submitted by Dairyland to the NRC in November 2012. As part of this cost update, ISFSI decommissioning costs were identified uniquely as a specific item.

An updated cost study completed in March 2013 was included as part a revised LACBWR D-Plan/PSDAR submitted by Dairyland to the NRC in* March 2014. As part of this cost update, some contaminated structures previously assumed to be decontaminated and left intact were evaluated for demolition and disposal.

7.2. Decommissioning Cost Estimate The decommissioning cost estimate presented herein represents the projected costs to complete the remaining decommissioning work as of October 1, 2015. This estimate was prepared based.

upon an assessment of the remaining work and incorporating* experience gained while perfonning similar decommissioning tasks including the ongoing decommissioning of the Zion Nuclear Power Station (ZNPS) through the work of its subsidiary ZionSolutions LLC.

The decommissioning cost estimate includes application of contingency, as specific provision for unforeseeable elements of cost within the defined project scope. Contingencies are paiiicularly important where previous experience has shown that unforeseeable events, which may increase costs, are likely to occur. The contingency, as used in this estimate, does not account for price escalation and inflation in the costs of decommissioning over the remaining project duration.

The site-specific decommissioning cost estimate presents a breakdown of all costs associated with completing the decommissioning and umestricted release of the LA CB WR site, other than the area bounded by the ISFSl. The estimate includes the costs required to accomplish umestricted release and restore the site to. a safe and stable condition as well as the operation of the ISFSI until the site and the remaining ISFSI are transferred back to Dairyland.

The following subsections pre*sent a description of how the cost estimate was prepared and a summary and breakdown of the estimated costs.

7.2.1. Cost Estimate Description and Methodology The cost estimates include consideration of regulatory requirements, contingency for unknown or uncertain conditions, and the availability of low and high-level radioactive waste disposal sites.

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La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOWTIONS The methodology utilized to develop the cost estimate follows the basic approach presented in Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates (4), which uses a unit cost factor approach for estimating the decommissioning activity costs. It also includes the use of site specific information when available (e.g., hourly labor rates, and commodities).

The updated estimate completed in March 2013 has been utilized to obtain site-specific commodity quantities for this estimate. The commodity weights and estimated unit cost factors were applied, which take into consideration the current decommissioning approach and schedule, to arrive at an updated cost estimated to decommission LACBWR. Dairyland and Solutions also utilized 25 years of corporate experience in planning and scheduling as well as the latest available industry experience (e.g., information from the decommissioning of ZNPS).

The estimate does not include the transfer of spent fuel, which has been previously transferred to an ISFSI facility, the security costs for the ISFSI facility, or the removal of ce11ain large components and decommissioning work previously completed.

Additionally, Dairyland and Solutions performed a contingency and risk analysis so that the potential additional costs due to expected but undefined risks and uncertainties could be addressed and included in the cost estimate.

The resulting information was then compiled into a decommissioning cost estimate. The

  • following sections provide a summary of those results.

7.2.2. Summary of the Site-Specific Decommissioning Cost Estimate The overall remaining decommissioning cost (including scope risk conting~ is estimated to be $.Million (in cun-en~ar dollars), with a base estimated cost of $-Million, plus a scope risk contingency of$. Million. The cost estimates include provisions for cost escalation based upon the following assumptions:

  • All estimated costs including labor, staff, materials, equipment, professional services, waste transp011ation and disposal are in 2015 dollars.
  • Although all costs in this L TP are in cun-ent year dollars, the project baseline does include provisions to escalate costs based on the Consumer Price Iri.dex for all Urban Customers - U.S. City Average All Items, Not Seasonally Adjusted (CPI-U NSA).
  • The associated Class A radioactive waste management costs are covered by existing fixed-price contracts with EnergySolutions. Therefore, the waste management costs for these items are well known and not likely to vary due to waste volume uncertainties.
  • No costs for Class B/C waste are included in the estimate, as all materials classified as B/C waste were previously removed by Dairyland.

The cost estimate includes the costs for radiological decommissioning and site restoration. A summary of the cost for each part of the decommissioning program is provided in Table 7-1.

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La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOWTJOM Table 7-1 Cost Summary for Radiological Decommissioning and Site Restoration Radiological Site Restoration 1 Total Project Decommissionin Performance Baseline $II Million $2.6 Million Million

$II Million $0.3 Million Million Total $II Million $2.9 Million Million Note 1: Site restoration is included for completeness, but not required for license tem1ination funding purposes.

Detailed breakdowns of the estimated costs for radiological decommissioning and site restoration programs are provided in sections 7.2.3 and 7.2.5, respectively. Spent fuel management is addressed in section 7.2.4. Estimated contingency costs are addressed in section 7.2.6.

7.2.3. Radiological Decommissioning Costs Consistent with the NRC definition of decommissioning w1der 10 CFR 50.2, the radiological decommissioning costs w1der this category consider only those costs associated with normal decommissioning activities necessary for release of the site (other than the ISFSI) for unrestricted use. It does not include costs associated with the disposal of non-radiological materials or structures beyond those necessary to terminate the Part 50 license or the costs associated with construction or operation of an ISFSI.

The estimated cost for radiological decommissioning is $. Million. A contingency of

$. Million is estimated, bringing the total to $11 Million.

The remaining decommissioning scope of work included in this estimate is described in detail in other chapters of this L TP. Overall , that work scope includes completion of the removal ,

transportation and disposal of the major components; completion of the removal , transportation and disposal of the remaining equipment; decontamination and/or bulk demolition of radiological impacted structures and transportation and disposal of the resulting radioactive wastes; performance of the FRS and associated license tem1ination activities. The estimated costs include the labor, equipment, materials, services and fees needed to conduct the work. The estimated cost also includes all of the program support activities and services necessary to manage and safely carry out a large-scale dismantlement and demolition project. These program support activities include project management, work controls and site administration; technical support services, such as radiation protection, safety, engineering, security, Quality Assurance (QA)/Quality Control (QC), environmental monitoring, waste management and decommissioning subject matter experts needed to support the project.

A high level breakdown of the estimated radiological decommissioning cost by major project activity is provided in Table 7-2.

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La Crosse Boiling Water Reactor License Termination Plan ,:::::=

Revision 0 LACR~SounIONS Table 7-2 Estimated Radiological Decommissioning Cost by Major Project Activity PROJECT ACTIVITY COST 1 Project Development & L TP Preparation $1.7 Million Pre-Mobilization Planning and Rail Upgrades $3.8 Million D&D Mobilization and Management $1 .3 Million Dismantlement & Demolition $26.5 Million Radioactive Waste Transportation and Disposal $. Million Final Radiation Surveys $1.1 Million Program Management $11.1 Million TOTAL $. Million N ote I : Column s ma y not add due to roundin g A high level breakdown of the estimated radiological decommissioning cost by major resource type is provided in Table 7-3. A more detailed breakdown of the estimated radiological decommissioning cost by project activity is provided in Table 7-4.

Table 7-3 Estimated Radiological Decommissioning Cost by Major Resource Type RESOURCE COST 1 Staff Labor $6.1 Million Craft Labor $11.3 Million Rad Protection Teclmicians $3.6 Million Materials & Supplies '

$4.5 Million Equipment $7.5 Million Subcontracts & Professional Services $8.1 Million Radioactive Waste Transportation & Disposal $. Million Other Direct Costs & Fees $4.2 Million TOTAL $. Million Note I : Co lumns may not add due to roun ding 7-5

La Crosse Boiling Water Reactor License Termination Plan Revision 0 Table 7-4 Breakdown of Radiological Decommissioning Costs by Detailed Activity ACTIVITY COST 1 PROJECT DEVELOPMENT & LTP PREPARATION Total $1. 7 Million LACBWR LTP (313196) $0.6 Million ES Bid & Proposal (941351) $1.1 Million PRE-MOBILIZATION PLANNING AND RAIL UPGRADES Total $3.8 Million Program Development & Planning $0.6 Million D&D Pre-Mobilization Planning $0.1 Million Rail Upgrades $2.3 Million Preliminary Characterization $0.7 Million D&D MOBILIZATION AND MANAGEMENT Total $1.3 Million D&D Mobilization and Management $1 .3 Million DISMANTLEMENT & DEMOLITION Total $26.5 Million D&D Reactor Building $8.1 Million D&D Turbine Building $7.7 Million D&D Waste Treatment Building $1 .2 Million D&D Balance of Plant $9.5 Million RADIOACTIVE WASTE TRANSPORTATION AND DISPOSAL Total $. Million FINAL RADIATION SURVEYS Total $1.1 Million Reactor Building FRS & Suppo11 $0.4 Million Turbine Building FRS & Support $0.4 Million Waste Treatment Building FRS & Support $0.2 Million Balance of Plant FRS & Support $0.2 Million PROGRAM MANAGEMENT Total $11.1 Million Project & Site Management $5.5 Million Safety Program $1 .8 Million Regulatory Program & NRC Fees $1.0 Million Radiation Protection Program Management $0.8 Million Characterization Program Management $0.8 Million Waste Program Management $1.2 Million TOTAL $. Million Note I: Columns may not add due to round mg 7-6

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESoumONS The total estimated cost for radioactive waste disposition (containers, transportation and disposal) is $. Million. These waste management costs are comprised of Class A Large Components, Class A Containerized Wastes and Class A Bulk Materials.

The associated Class A radioactive waste management costs are covered by existing fixed-price contracts with EnergySolutions. Therefore, the waste management costs for these items are well known and not likely to vary due to waste volume uncertainties. The resulting radioactive waste streams and the disposal and transportation contracts can be categorized as follows:

Class A Large Components. Tills category of waste includes equipment that will be transported and disposed of intact, enclosed in rail cars or prepared to serve as its own waste container.

These items have been radiologically and physically characterized. As such, the inventory of these items and their disposal volumes are known. The associated waste management costs are covered by existing fixed-price contracts with EnergySoluNons for disposal in Clive, Utah.

Therefore, the waste management costs for these items are well known and not likely to vary.

Class A Bulk Materials. Tills category of waste primarily consists of concrete rubble or similar materials contaminated with low levels of radioactivity, and various large components described above. Waste will be loaded into appropriate containers and trucked to a rail trans-load facility in Winona, MN where the waste container will be transferred to a rail car and then shipped to the EnergySolutions disposal site in Clive, Utah. The cost for disposal and transportation of this material is covered by a fixed-price contract that covers any and all material of this type from this decommissioning project, without regard to the total mass or volwne. Therefore, these costs are known and are unlikely to vary. Tills category of waste generally comprises greater than 95% of the total volume and mass and greater than 80% of the estimated waste management costs for all radioactive waste expected to be generated by this decommissioning effort.

Class A Containerized Wastes. This category of waste primarily consists of material that will need to be packaged in strong-tight/industrial containers, such as intermodals or fabricated steel boxes. Typically, this would include small pieces of contaminated equipment, pipe or debris which require containerization to meet Department of Transportation (DOT) regulations or mitigate radiological handling concerns. Waste will be loaded into appropriate containers and trucked to a rail trans-load facility in Winona, MN where the waste container will be transferred to a rail car and then shipped to the EnergySolutions disposal site in Clive, Utah.

Greater Than Class C CGTCC) and Class B/C Waste. No costs for disposal of GTCC waste are included in the estimate, as it was included as a part of the previously completed spent fuel disposition. Also, no costs for Class B/C waste are included in the estimate, as all materials classified as B/C waste were previously removed by Dairyland.

7.2.4. Spent Fuel Management All spent nuclear fuel elements from LACBWR have been transferred from the FESW to dry cask storage in the ISFSI.

Solutions will assume responsibility for the ISFSI Site, including security requirements.

Solutions will enter into a "Company Services Agreement" with Dairyland, pursuant to willch Dairyland will provide operations, maintenance, access control, and security services to and for 7-7

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOLm'IONS the ISFSI site. Dairyland is responsible for the costs relating to the ISFSI and those costs are not included in this decommissioning estimate.

7.2.5. Site Restoration Costs Solutions acknowledges that the costs to restore the LACBWR property are not considered by the NRC staff as part of decommissioning costs. Nevertheless, there is significant interest by many stakeholders in these costs and they are presented herein. The estimated cost for the anticipated work scope is $2.6 Million. A contingency of $0.3 Million is estimated, bringing the total cost to $2.9 Million. Overall, that work scope includes removal of any remaining hazardous materials, demolition of remaining structures, backfilling of any open excavations or void spaces, and final grading and stabilization against erosion.

The estimated costs include the labor, equipment, materials, professional services and fees needed to conduct the work. In general, most of this work is anticipated to be performed by contractors however, the estimated cost also includes all of the program support activities and services necessary to manage and safely carry out the work.

A hjgh level breakdown of the estimated site restoration cost by major project activity is provided in Table 7-5. A more detailed breakdown of the estimated site restoration cost by project activity is provided in Table 7-6.

Table 7-5 Estimated Site Restoration Cost by Major Project Activity PROJECT ACTIVITY COST' Project Development $0.2 Million Pre-Mobilization Planning $0.1 Million D&D Mobilization and Management $0.2 Million Waste Transportation and Disposal $0.4 Million Site Restoration $0.8 Million Program Management $0.8 Million TOTAL $2.6 Million Note I : Co lumns may not add due to roundin g 7.2.6. Contingency Uncertainty associated with the decommissioning cost estimate, and the need to allocate additional funding to cover contingency has been included in tills estimate. Accounting for contingency has been evaluated from two standpoints, opera6onal efficiency and scope expansion risk. Within the context of this cost estimate, operational efficiency contingency is defined as the occurrence of events or circumstances that can prolong project duration or make the execution of a given work scope more difficult. Examples of these types of events include weather related delays, equipment or tool breakage or unavailability, and interferences from other work activities. Scope expansion risk within the context of this estimate is defined as the need to perform unplanned work activities or expansion of the work activities that were planned.

7-8

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOWTIONS Examples of this type of project risk would be discovering new or additional contaminated media.

Table 7-6 Breakdown of Site Restoration Costs by Detailed Activity ACTIVITY COST 1 PROJECT DEVELOPMENT Total $0.2 Million ES Bid & Proposal (941351) $0.2 Million PRE-MOBILIZATION PLANNING Total $0.1 Million Program Development & Planning $0. 1 Million D&D MOBILIZATION AND MANAGEMENT Total $0.2 Million D&D Mobilization and Management $0.2 Million WASTE TRANSPORTATION & DISPOSAL Total $0.4 Million Non-Radioactive Waste Transportation & Disposal $0.4 Million SITE RESTORATION Total $0.8 Million Reactor Building Site Restoration $0.2 Million Turbine Building Site Restoration $0.2 Million Waste Treatment Building Site Restoration $0.0 Million Balance of Plant Site Restoration $0.4 Million PROGRAM MANAGEMENT Total $0.8 Million Environmental & Project Management $0.6 Million Safety Program $0.2 Million TOTAL $2.6 Million Note I : Co lumns may not add due to ro unding requiring remediation, or a need to perform work in a different manner due to unforeseen conditions or changes in requirements.

As shown in section 7.2.2, the overall contingency is estimated at $. Million; apportioned as

$. Million for radiological decommissioning and $0.3 Million for site restoration. This contingency was estimated using a quantitative Monte Carlo type probability analysis corresponding to a resulting 85 percent confidence level.

The LACBWR contingency analysis process is consistent with that adopted for the ZNPS decommissioning project.

7-9

La Crosse Boiling Water Reactor License Termination Plan Revision 0 7.3. Decommissioning Funding Plan As indicated in section 7.2.2, the estimated cost to complete the radiological decommissioning of the LACBWR, including site restoration costs 1 and contingency, is $84.9 Million (current year dollars) as of October 1, 2015. Table 7. 7 summarizes the annualized costs.

Table 7-7 LACBWR Summary of Annualized Costs (in Millions)

Radiological Decommissioning ....

2015 2016 2017 2018 2019 Total Site Restoration Performance Baseline .... ** .... .... .... ....

Contingency Total Project .. * ..

These decommissioning costs will be paid for with funds from the site' s Nuclear Decommissioning Trust (NDT) fund. The decommissioning of the LA CB WR site ISFSI will be undertaken by Dairyland 2 and will be financed separately to the NDT account amount identified here for decommissioning of the LACBWR site.

The project cash balance of the NDT identified for the decommissioning of the LA CB WR site, a~reed to by Solutions, and held in trust by the Owner trustee as of October 1, 2015 was

$. Million.

Based on a time phased cash flow analysis of the radiological decommissioning and site restoration costs, and assuming NDT returns at an amrnal 2% real , after tax rate of return, the required minimum funding assurance amount to fund the future radiological decommissioning costs equals $. Million, which is below the $. Million avai labl e balance described above.

This NDT position, together with the $. Million Surety Bond payable to the NDT, provides for sufficient funding and financial assurance for the completion of the decommissioning of the LACBWR site.

Additionally, although not relied upon here, Solutions parent EnergySolutions has agreed with Dairyland to provide a performance guaranty defined in the LACBWR Decommissioning Agreement submitted as part of the license transfer application (5).

1 The estimated project decommissioning costs includes an estimate for site restoration costs.

2 The costs of spent fuel management and associated costs are to be incurred by Dairyland, are estimated to be approximately $2 million per year, and are financed from operating and maintenance funds outside of the NDT.

Dairyland has not projected the cost of managing irradiated fuel until title to the fuel and possession of the fuel is transferred to the Secretary of Energy because this cost is indeterminate.

7-10

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOWTIONS Assuming approval by the NRC of the license transfer application on or before March 31, 2016, Solutions will be submitting the annual demonstration of financial assurance for the year ending 2015 in accordance with 10 CFR 50.75(f)(l) and 10 CFR 50.82(a)(8)(v)-(viii). That submission will be based upon future project costs of radiological decommissioning and site restoration, and the NDT balance as of that date.

7.4. References

1. U.S. Nuclear Regulatory Commission Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, Revision 1 - June 2011.
2. Dairyland Power Cooperative (DPC), LACBWR Decommissioning Plan, Revision-:-

. November 2012.

3. Dairyland Power Cooperative, LACBWR Decommissioning Plan and Post Shutdown Decommissioning Activities Report (D-Plan/PSDAR), Revision -March 2014.
4. T.S. LaGuardia et al., Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates, AIF/NESP-036, May 1986.
5. Dairyland Power Cooperative Letter to U.S Nuclear Regulat01y Commission, Application for Order Approving License Transfer and Conforming Administrative License Amendments, dated October 8, 2015.

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Attachment 5 Reference Documentation (PDF files on attached CD)

Attachment 6 Preflight Report For CD Attachments

LaCrosseSolutions, LLC LC-2016-0022: Attachment 6 Page 1of4 This document serves as preflight report for Attachment 3 & 5 to the letter LC-2016-0022. The following files do not pass pre-flight criteria or do not meet NRC criteria, but text is word searchable with clarity/legibility of high quality.

Preflight LTP File Name Reason Status Document contains logos and Chapter 1 LACBWR LTP Chapter 1, Rev 0 Failed color maps< 300 ppi, clear and legible Document contains logos and Chapter2 LACBWR LTP Chapter 2, Rev 0 Failed color maps < 300 ppi, clear and legible Document contains logos <

Chapter 3 LACBWR LTP Chapter 3, Rev 0 Failed 300 ppi, clear and legible Document contains logos <

Chapter4 LACBWR LTP Chapter 4, Rev 0 Failed 300 ppi, clear and legible Document contains logos < -

Chapter 5 LACBWR LTP Chapter 5, Rev 0 Failed 300 ppi, clear and legible Document contains logos and Chapter 6 LACBWR LTP Chapter 6, Rev 0 Failed color maps < 300 ppi, clear and legible Document contains logos <

Chapter 7 LACBWR LTP Chapter 7, Rev 0 Failed 300 ppi, clear and legible Document contains logos <

Chapter 7 LACBWR LTP Chapter 7, Rev 0, Redacted Failed 300 ppi, clear and legible Document contains logos and Chapter 8 LACBWR LTP Chapter 8, Rev 0 Failed color maps < 300 ppi, clear and legible

LaCrosseSolutions, LLC LC-2016-0022: Attachment 6 Page 2of4 Preflight Reference Document Name File Name Reason Status Letter from Dairyland Power Cooperative to the Nuclear Scanned document (unembedded Regulatory Commission, Application for Order Approving LA CB WR Application for Order Approving License fonts), logos, backgrounds, and Failed License Transfer and Conforming Administrative License Transfer & Conforming Admin License Amend signatures< 300 ppi, clear and Amendments, dated October 8, 2015 legible U.S. Nuclear Regulatory Commission NUREG-0191, Final Scanned document (unembedded Environmental Statement related to Operation of the La fonts), logos, backgrounds, and NUREG-0191 Final-NRC Environmental Assessment Passed Crosse Boiling Water Reactor by Dairyland Power signatures < 300 ppi, clear and Cooperative - April 1980 legible Scanned document (unembedded Letter from Dairyland Power Company to the Nuclear fonts), logos, backgrounds, maps, Regulatory Commission,

Subject:

Planning for ISFSI, LAC-14029 - Planning for ISFSI Failed and signatures< 300 ppi, clear and LAC-14029, March 10, 2008.

legible Scanned document (unembedded Dairyland Power Cooperative, Lacrosse Boiling Water Dairyland Power Cooperative LACBWR Decommissioning fonts), logos, backgrounds, maps, Reactor (LACBWR) Decommissioning Plan, revised Failed Plan and signatures < 300 ppi, clear and November 2003 legible EnergySolutions GG-E0-313196-RS-RP-001, LACBWR Document contains logos, Radiological Characterization Survey Report for October GG-E0-313196-RS-RP-OO 1, LA CB WR 2014 Chz Report Failed signatures and color maps <

and November 2014 Field Work - November 2015 300 ppi, clear and legible EnergySolutions LC-RS-PN-164017-001, LACBWR Document contains logos, Radiological Characterization Survey Report for June thru LC-RS-PN-164017-001, Rev. 0 Failed signatures and color maps <

August 2015 Field Work- November 2015 300 ppi, clear and legible Dairyland Power Cooperative, LA CB WR Scanned document Decommissioning Plan and Post-Shutdown (unembedded fonts), logos, DPC to NRC DP and PSDAR Update Failed Decommissioning Activities Report (D-Plan/PSDAR), backgrounds, and signatures <

Revision - March 2014 300 ppi, clear and legible EnergySolutions PG-E0-313196-SV-PL-001, Rev. 1, Document contains logos, Characterization Survey Plan for the La Crosse Boiling PG- EO- 313196- SV- PL- 001Rev1 Failed signatures and color maps <

Water Reactor. 300 ppi, clear and legible EnergySolutions GP-E0-313196-QA-PL-001, Quality Document contains logos, Assurance Project Plan LACBWR Site Characterization GP-E0-313196-QA-PL-001 Characterization QAPP 2014 Failed signatures and color maps <

Project (QAPP). 300 ppi, clear and legible

LaCrosseSolutions, LLC LC-2016-0022: Attachment 6 Page 3of4 Preflight Reference Document Name File Name Reason Status EnergySolutions Technical Support Document RS-TD- Document contains logos, 313196-003, La Crosse Boiling Water Reactor Historical RS-TD-313196-003, LACBWR HSA Rev 0 20151109 Failed signatures and color maps <

Site Assessment (HSA). 300 ppi, clear and legible Document contains *color maps Dairyland Power Corporation LAC-TR-138, Initial Site LAC-TR-138 Initial Site Charac Survey Failed and graphs< 300 ppi, clear and Characterization Survey for SAFSTOR- December 2009.

legible Document contains scanned EnergySolutions Technical Support Document RS-TD- RS-TD-313196-006 Rev 0 - Ludlum Model 44-10 Detector Failed pages< 300 ppi, clear and 313196-006, Ludlum Model 44-10 Detector Sensitivity. Sensitivity legible Document contains scanned ZionSolutions Technical Support Document 13-004, document ( unembedded fonts),

TSD-13-004, Rev. 0 - Examination ofCs-137 Global Examination ofCs-137 Global Fallout in Soils at Zion Failed logos, maps, graphs, and Fallout in Soils at Zion Station Final Station. signatures < 300 ppi, clear and legible Document contains scanned EnergySolutions Technical Support Document RS-TD- pages (unembedded fonts),

313196-001, Radionuclides of Concern During LA CB WR RS-TD-313196-001 Rev 0 Failed. logos, signatures, graphs and Decommissioning color maps< 300 ppi, clear and legible Haley & Aldrich Inc., Hydrogeological Investigation Document contains logos, Report, La Crosse Boiling Water Reactor, Dairyland Power signatures, graphs and color 2015-0115_HAI_Hydrogeologic Investigation Report-Final Failed Cooperative, Genoa Wisconsin, File No. 38705-008, maps< 300 ppi, clear and January 2015 legible

. Document contains scanned pages (unembedded fonts),

EnergySolutions Technical Support Document RS-TD-LACBWRRS- TD- 313196- 005 Failed logos, signatures, graphs and 313196-005, LACBWR Open Air Demolition Limits.

color maps< 300 ppi, clear and legible Radiological Effluent Monitoring and Offsite Dose Scanned pages (unembedded Dairyland ODCM Rev 14 Failed Calculation Manual (ODCM) fonts)

LaCrosseSolutions, LLC LC-2016-0022: Attachment 6 Page 4of4 Preflight Reference Document Name File Name Reason Status EnergySolutions Technical Support Document, RS-TD-RS-TD-313196-007 Radiation Exposure Projections for Scanned pages (unembedded 313196-007, Radiation Exposure for LACBWR Failed LACBWR Decommissioning Rev 0 fonts)

Decommissioning.

Document contains scanned EnergySolutions Technical Support Document RS-TD- RS-TD-313196-002, Rev. 0, LACBWR End State document (unembedded fonts),

313196-002, La Crosse End State Basement Concrete Basement Concrete Surface Areas, Volumes, and Void Failed logos, maps, graphs, and Surface Areas, Volumes, and Void Spaces Spaces signatures < 300 ppi, clear and legible Document contains scanned EnergySolutions Technical Support Document RS-TD-pages (unembedded fonts),

313196-004, LACBWR Soil DCGL and Concrete BFM RS-TD-313196-004 Rev 0 Failed Dose Factors. logos, signatures, and graphs <

300 ppi, clear and legible Document contains scanned EnergySolutions LC QA-LTP-PL-001 Quality Assurance document (unembedded fonts),

Project Plan LA CB WR License Termination Plan (LTP)

LC-QA-LTP-PL-001, Rev. 0, LACBWR QAPP Failed logos, maps, graphs, and Development, Site Characterization and Final Radiation Survey Projects (QAPP). signatures< 300 ppi, clear and legible Document contains scanned ZionSolutions Technical Support Document 14-006, document (unembedded fonts),

Conestoga Rovers & Associates (CRA) Report, Evaluation TSD-14-006, Rev. 5 - CRA Report Failed logos, maps, graphs, and of Hydrological Parameters in Support of Dose Modeling for the Zion Restoration Project. signatures< 300 ppi, clear and legible Sheppard and Thibault, Default Soil/Solid /Liquid Partition Scanned pages (unembedded Coefficients, Kds, for Four Major Soil Types: A Sheppard and Thibault Kd Failed fonts)

Compendium, Health Physics, Vol. 59 No 4, October 1990.

Dairyland Power Cooperative (DPC), LACBWR Scanned pages (unembedded 2012 LACBWRDP and PSDARRevision Failed Decommissioning Plan, Revision - November 2012. fonts)

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