ML16347A026

From kanterella
Jump to navigation Jump to search

Boiling Water Reactor License Termination Plan Update
ML16347A026
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 12/01/2016
From: Gerard van Noordennen
LaCrosseSolutions
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML16347A025 List:
References
LC-2016-0085
Download: ML16347A026 (42)
v • d • e


Text

~

LACROSSESOLUTIONS December 1, 2016 LC-2016-0085 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 Termination Plan Update

References:

1) Gerard van Noordennen, LaCrosseSolutions, Letter to U.S. Nuclear Regulatory Commission, "License Amendment Request for the License Termination Plan," dated June 27, 2016 As documented in Reference 1, LaCrosseSolutions, LLC (Solutions) submitted a License Amendment Request (LAR) for the La Crosse Boiling Water Reactor (LACBWR) License Termination Plan (LTP). Following the submittal, a public meeting was held between the U.S.

Nuclear Regulatory Commission (NRC) staff and Solutions representatives on October 20, 2016.

The purpose of the meeting was to discuss Solutions' proposal regarding an update to the LACBWR LTP to be submitted prior to the NRC's formal acceptance of the LTP for technical review. Changes incorporated into the LTP update provided in this submittal include:

  • Revise terminology and reviewability for conformity with NRC guidance documents and standard review plan.
  • Incorporate change to use screening values and Final Status Surveys (FSS) for above ground buildings as opposed to Multi-Agency Radiation Survey and Assessment of Materials and Equipment (MARSAME) surveys.
  • Replace Basement Dose Factors and Inventory Limits with DCGLs.
  • Include Zion LTP Request for Additional Information (RAI) changes as applicable.
  • Revise the proposed LA CB WR Possession Only License Condition Change to reflect the LTP update.

Portions of this submittal provide the NRC with financial 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 2.390(b)(4). All documents within the scope of this affidavit are marked as "withhold from public disclosure under 10 CFR 2.390." rV µ_ S SD !

S4601 State Highway 35, Genoa, WI 54632 /\)tvf _s SL~ ,

rJM S 5

LaCrosseSolutions LC-2016-0085 Page 2 of2 provides the updated LACBWR Possession Only License change. This updated license condition does not impact the technical analysis, regulatory analysis, or environmental impact consideration provided in Reference 1. Attachment 2 contains a page change matrix identifying the LTP update changes. Attachment 3 provides the updated LACBWR LTP for NRC review and approval. Changes are identified using revision bars. Chapter 7 of the LTP contains the proprietary financial information 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. Attachment 6 contains a preflight report for the documentation provided on Computer Disk (CD).

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 December 1, 2016.

Respectfully, bJI~- ~1-. c)1~~

Gerard van Noordennen Vice President Regulatory Affairs Attachments 1.) Attachment 1, Updated LACBWR Proposed License Condition 2.) Attachment 2, LACBWR LTP Page Change Matrix 3.) Attachment 3, Updated LACBWR Proposed License Termination Plan (CD) 4.) Attachment 4, License Termination Plan Chapter 7 Redacted Version 5.) Attachment 5, Reference Documentation (CD) 6.) Attachment 6, Preflight Report for CD Attachments cc: Marlayna Vaaler, 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 Decommissioning Wisconsin Public Service Commission EnergySolutions P.O. Box 7854 299 South Main Street, Suite 1700 Madison, WI 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 Wisconsin Department of Health Services 2701 Deborah Avenue P.O. Box 2659 Zion, IL 60099 Madison, WI 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, WI 54602-0817 Joseph Nowak Cheryl Olson, ISFSI Manager General Manager La Crosse Boiling Water Reactor LaCrosseSolutions Dairyland Power Cooperative S4601 State Highway 3 5 S4601 State Highway 3 5 Genoa, WI 54632-8846 P.O. Box 817 Genoa, WI54632-8846 Dan Shrum Senior VP Regulatory Affairs Lane Peters EnergySolutions La Crosse Boiling Water Reactor 299 South Main Street, Suite 1700 Dairyland Power Cooperative Salt Lake City, UT 84111 S4601 State Highway 3 5 Genoa, WI54632-8846 Russ Workman General Counsel Thomas Zaremba EnergySolutions Wheeler, Van Sickle and Anderson, S.C.

299 South Main Street, Suite 1700 44 East Mifflin Street, Suite 1000 Salt Lake City, UT 84111 Madison, WI 53703 Jerome Pedretti, Clerk John E. Matthews Town of Genoa Morgan, Lewis & Bockius LLP .

E860 Mundsack Road 1111 Pennsylvania A venue, NW Genoa, WI 54632 Washington, DC 20004

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 ofLaCrosseSolutions, LLC. The basis for this declaration is:

1. This information is owned and maintained as proprietary by LaCrosseSolutions, LLC, ii. 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 ofLaCrosseSolutions, LLC, and that the matters and facts set forth in the statement are true to the best of my knowledge, informatfon, and belief.

Name: Gerard van Noordennen

Title:

Vice President Regulatory Affairs Company: LaCrosseSolutions, LLC SUBSCRIBED AND SWORN TO BEFORE ME THIS 1st DAY of December, 2016

~

Notary Public LINDA CHOU Otflclal Stal NoW.r PuDllc

  • s1111 01 11uno11 My Comml11ion E1plrtt DIC:7. 2019

Attachment 1 LACBWR Updated Proposed License Condition

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, buried piping, or basement concrete derived concentration guideline levels (DCGL) and related minimum detectable concentrations (for both scan and fixed measurement methods).

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

(G) Change the statistical test applied other than the Sign test.

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

Attachment 2 LACBWR L TP Page Change Matrix

'*~

LACBWR LTP Revision 0 November 30, 2016 Matrix of Changes Chapter 1 Page Desciiption of Change List of Acronyms Deleted "FRS - Final Radiation Survey" 1-ii and Abbreviations Deleted "STS - Source Term Survey" Added text claiifying that survey unit boundaiies and 1.3.1. 1-2 classifications in Figure 1-3 may change as decommissioning proceeds.

1.5.2. 1-7 Changed "Radiation" "(FRS)" to "Status" "(FSS)"

1.5.2. 1-8 Changed "FRS" to "FSS" 1.5.4. 1-9 Added buried pipe Added statement that there is "no embedded piping at 1.5.4. 1-9 LA CB WR" 1.5.5. Header 1-9 Changed "Radiation" to "Status" Changed "FRS" to" FSS" (4 times), Deleted "Final 1.5.5. 1-9 Status Survey," Deleted "Source Term Survey (STS)"

and inserted "FSS" 1.5.5. 1-9 Changed "FRS" to "FSS" 1.5.6. 1-9 Deleted "or STS" Deleted "(or decreases dose factors from the Basement 1.6. Bullet 5 1-11 Fill Model)"

Editorial: Deleted "derived concentration guideline level," added "DCGL," deleted "(or corresponding 1.6. Bullet 6 1-11 source term inventory levels in the Basement Fill Model),"

1.6. Bullet 7 1-11 Deleted "or Wilcoxon Rank Sum test" Chapter 2 Page Description of Change Added "CVS - Contamination Verification Survey" List of Acronyms 2-iv and 2-v Deleted "FRS - Final Radiation Survey" and Abbreviations Deleted "STS - Source Term Survey" Deleted wording pertaining to Final Radiation Survey (FRS) and Source Term Survey (STS). Added wording

2. 2-1 to support the terminology ofFSS and changed FRS to FSS. Added clarifying language pertaining to continuing characterization.

Added an additional paragraph to section 2 that discusses

2. 2-2 adequacy of characteiization Rewiitten to clarify the impacted above grade structures
2. 2-2 that will remain.

Deleted complete spelling of HSA as it was referenced 2.1. 2-3 earlier in document 2.1.1. 2-3 Changed "FRS" to "FSS" 2.1.2. 2-4 Changed "FRS" to "FSS" Page 1 of 13

Chapter 2 Page Description of Change 2.1.2.1. 2-4, 2-5 Changed "FRS" to "FSS" Added clarifying text that survey unit boundaries and 2.1.6.1. 2-10 classifications in Figure 2-1 may change as decommissioning proceeds 2.1.6.2. 2-10 Changed "FRS" to "FSS."

Added additional text pertaining to above grade 2.1.6.2. 2-10 structures Changed "FRS" to "FSS" and deleted "designated as 2.1.6.2. 2-10 STS and" 2.1.6.7. 2-12 Changed "FRS" to "FSS" Added bullet for "Security Station" 2.1.6.8. 2-13 Reworded for clarification.

2.1.6.8. 2-13 Changed "FRS" to "FSS."

2.1.6.8. 2-13 Reworded for clarification.

Added additional text clarifying that NUREG-1757 2.1.6.8. 2-13 screening values will be used for above grade structures.

2.2. 2-13, 2-14 Changed "FRS" to "FSS" 2.2.1. 2-14 Changed "FRS" to "FSS" Deleted text no longer applicable due to revised above 2.2.1. 2-15 grade structure approach Added "basement" to Class 1 structures and changed 2.2.2.1. 2-16 "FRS" to "FSS" Added "and Class 3" structural survey units and changed 2.2.2.2. 2-16 "FRS" to "FSS".

Changed "exhibit measurable radioactivity" to 2.2.2.2. 2-17 "exhibited measurable radiation levels above background (i.e. by scanning) 2.2.2.4. 2-17 Changed "FRS" to "FSS" 2.2.2.4.5. 2-18 Changed "FRS" to "FSS" 2.2.5. 2-20 Changed "FRS" to "FSS" Revised to clarify continuing characterization focus and 2.3. 2-21 internal reference to section 2.4 Deleted "concentrations greater than the instrument 2.3.3. 2-23 MDC" Added clarifying text pertaining to "false positive" 2.3.3. 2-24, 2-25 results in lab Added clarifying language pertaining to Cs-13 7 2.3.4.1. 2-26 concentration in expected background range Added clarifying language pertaining to Cs-13 7 2.3.4.1. 2-27 concentration in expected background range Added clarifying language pertaining to Cs-13 7 2.3.4.2. 2-28 concentration in expected background range Added clarifying text pe1iaining to "false positive" 2.3.4.2. 2-28 results in lab analysis Page 2of13

Chapter 2 Page Description of Change Added clarifying text pe1iaining to "false positive" 2.3.4.3. 2-30 results in lab analysis Added clarifying text pertaining to disposition of G-3 2.3.5. 2-31 roof materials 2.3.6. 2-31 Added words "Class 1" 2.3.6. 2-31 Added words "Class 1" and changed "STS" to "FSS" 2.3.6. 2-31 Changed "FRS" to "FSS" Added language to clarify the assessment that the 2.3.6.1. 2-32 concrete characterization was adequate to determine mixture Added clarifying text pertaining to insignificant dose 2.3.6.1. 2-32 contributors and Reference 16 2.3.6.3. 2-33 Reworded for clarification.

2.3.6.3. 2-33 Changed wording from "was initially" to "is".

Changed reference citation (There is no bar marked on 2.3. 7, 1st paragraph 2-34 L TP page showing change, but the bar is in the reference)

Changed reference citation (There is no bar marked on 2.3.7.3, 4th 2-36 L TP page showing change, but the bar is in the paragraph reference)

Added clarifying language pertaining to previous 2.3.7.3. 2-36, 2-37 investigations of the wells.

2.4. 2-38, 2-39 Entire section revised for clarification 2.5. 2-40, 2-41 Updated References.

Chapter 3 Page Description of Change List of Acronyms Changed "FRS -Final Radiation Survey" to "FSS -

3-iii and Abbreviations Final Status Survey" Changed "well water system" to lower case for 3.2.2.10. 3.5 consistency with rest of paragraph 3.3.1. 3-11 Changed "Radiation to Status" and "FRS to FSS" Added clarification for unconditional release surveys and 3.3.2. 3-12 added clarification that recycled material would not remain on site.

3.3.2 3-12 Added manufacturer name for 193-6 Changed "FRS" to "FSS" and added clarification that 3.3.3. 3-13 waste is "radioactive" 3.3.4. 3-13 Sentence reworded for clarification.

Added clarification for unconditional release surveys, 3.3.5. 3-14 added clarification that recycled material would not remain on site, added manufacturer name for 193-6 3.4.1. 3-16 Changed "FRS" to "FSS".

Table 3-4 3-18 Changed Milestone for Q4/2018 from "FRS" to "FSS" Table 3-4 3-19 Changed Milestone for Ql/2019 from "FRS" to "FSS" Page 3of13

Chapter 4 Page Description of Change Deleted "BIL - Basement Inventory Level" List of Acronyms Added "Contamination Verification Survey" 4-iii and Abbreviations Added "In Situ Object Counting System" Deleted "STS - Source Term Survey" Added additional paragraph discussing the expected low 4.1. 4-2 dose consequences at LACBWR Revised section to reference specific above grade buildings. Added text for justification for not performing 4.2.1. 4-2, 4-3 ALARA analysis on above grade structures, added NUREG-17 57 reference.

Specified grade elevation.

Added "below grade" and "basements".

Removed reference to "BFM" and "adjusted gross DCGLs" Changed sentence wording to: "The concrete walls and 4.2.1. 4-3 floors of the basements will be remediated to levels that will provide high confidence that FSS measurements with ISOCS will not exceed radionuclide-specific DCGLs that represent the annual dose criterion for unrestricted use specified in 10 CFR 20.1402."

Revised Table reference number, 4.2.2. 4-6 Deleted "Final Status Survey" 4.4. 4-8 Delete repeat of full title ofNUREG 1757 4.4.1 4-8 Revised Table reference number Revised Table reference number, 4.4.1.5. 4-12, 4-13 Changed Cs-137 soil DCGL value Revised Equation 4-8.

Deleted 3rd sentence which stated: "When the BFM DFs are inverted and multiplied by 25 mrem/yr, the resulting 4.4.2.1. 4-13 mCi value is called the Basement Inventory Level (BIL)."

Revised entire section to describe new approach using 4.4.2. 4-13, 4-14 DCGLs and added description of CVS Deleted 3rd sentence which stated: "When the BFM DFs are inverted and multiplied by 25 mrem/yr, the resulting 4.4.2.1. 4-14 mCi value is called the Basement Inventory Level (BIL)."

Revised entire section to remove references to dose 4.4.2.1. 4-14 factors in approach Added clarifying language pertaining to structure classification and remediation goals 4.4.2.2. 4-15 Added reference to use of ISOCS and revised text to clarify type of tool used for concrete remediation 4.4.2.7. 4-18 Formatting Page 4of13

Chapter 4 Page Description of Change Added clarifying language pertaining to scenario cost 4.4.2.8. 4-19 derivation Formatting, Added bullets and clarifying language 4.4.2.9. 4-19 pertaining to areas used for each scenario Table 4-1 4-19 Modified footnote to table Revised entire section in description of new approach 4.4.2.9.1. 4-19, 4-20 using DCGLs verses inventory Revised entire section in description of new approach 4.4.2.9.2. 4-20 using DCGLs verses inventory Table 4-3 4-20 Changed Table Title and contents Revised all tables to reflect new ALARA calculation and Table 4-4 4-22 to 4-25 analysis Chapter 5 Page Description of Change Chapter Title Title page Changed "Radiation" to "Status" Deleted "BIL - Basement Inventory Limit" Added "CVS" - Contamination Verification Survey Deleted "DF" - Dose Factors List of Acronyms 5-v, 5-vi Deleted "FRS - Final Radiation Survey" and Abbreviations Corrected spelling "in situ" Deleted "STS - Source Term Survey" Added "UCL" - Upper Confidence Level

5. Title 5-1 Changed "Radiation" to "Status" Changed "Radiation" to "Status", Changed "FRS" to
5. 5-1 "FSS" Deleted discussion pertaining to STS and BFM. Added
5. 5-1 statement that above grade buildings will be subjected to FSS using NUREG-1757 screening levels.

Deleted STS. Changed "FRS" to "FSS", added above

5. 5-1 grade buildings to end-state FSS compliance. Remove language pertaining to BFM DFs
5. 5-1 Changed "FRS" to "FSS" Added specific buildings to above grade end-state
5. 5-2 structures
5. 5-2 Changed "STS" to "FSS"
5. 5-2 Added "FSS" Deleted discussion of total inventory and compliance
5. 5-2 based on total inventory Changed ROC dose value to 96% after based on revised 5.1. 5-3 calculations in TSD RS-TD-313196-001.

Table 5-1 5-4 Removed notation symbol from Cm-243/244 Reversed ordering of footnotes and changed values due Table 5-2 5-4 to revision to decay correct the radionuclide mixture to time of license termination 5.1. 5-5 Changed "FRS" to "FSS" Page 5of13

Chapter 5 Page Description of Change Clarified description of action to be taken if concrete 5.1. 5-5 cores collected and analyzed for HTD during continuing characterization Inserted discussion as to how the Sr-90/Cs-137 ratio in 5.1. 5-5 the HTD cores collected during continuing characterization will be evaluated.

5.1. 5-5 Added "continuing" Changed "Dose Factors" to "DCGL", Changed "FRS" to 5.1. 5-5 "FSS", added "continuing" Clarified discussion as to how HTD results would be 5.1. 5-5 used to evaluate Sr-90/Cs-137 ratio.

Added commitment to perform HTD analysis for Sr-90 5.1. 5-6 on 10% of samples during FSS 5.2. 5-6 Removed "and STS" and "BFM DFs" 5.2. 5-6 Deleted description ofDCGL for soil and buried pipe Added units for basement DCGLs and added "For above 5.2. 5-6 grade buildings that will remain and" 5.2. 5-6 Clarified language pertaining to Area Factors 5.2. 5-6 Capitalized "Elevated Measurement Comparison" 5.2. 5-6 Deleted last paragraph discussing use ofBFM DF 5.2.1. Title 5-6 Changed title from BFM DF to DCGL for Basements.

Removed Basement DF and replaced with DCGL8 and 5.2.1. 5-6 DCGL8 s for basement concrete structures.

5.2.2. 5-7 Changed referenced table from 5-4 to 5-5 Added commitment to set administrative action levels to ensure that the mean soil concentrations at license 5.2.2. 5-7 tennination are less than the concentrations in the EPA/NRC MOU as listed in Table H-1ofNUREG1757 Vol 1Rev2.

Changed table title from 5-4 to 5-5, Changed values from Table 5-4 5-8 BFM DP to DCGLs Revise adjusted soil DCGLs to apply insignificant Table 5-5 5-8 contributor percentage of 5%

5.2.3. 5-8 Editorial Changed table title from 5-5 to 5-6. Revise Buried Pipe Table 5-6 5-9 DCGLs to apply insignificant contributor percentage of 5%

5.2.4. 5-9 Changed "FRS" to "FSS", added "in most cases" 5.2.4. 5-9 Added new discussion pertaining to Sr-90/Cs-13 7 ratio 5.2.5. 5-10 Editorial deleted "or the BFM DF" Changed BFM DF to "DCGLs for backfilled basements",

removed the acronym DCGL and revised the numbering 5.2.7. 5-10 for the referenced tables, deleted discussion pertaining to BFMDF Page 6of13

Chapter 5 Page Description of Change Revised equation to remove "inventory", changed "FRS" Equation 5-2 5-10 to "FSS" and following paragraphs discussing compliance with BFM scenarios Revised compliance equation to add dose components Equation 5-3 5-11 from EMC and above grade structures Changed title to specify the AF in this section pertain to 5.2.8. Title 5-11 soil and deleted first sentence stating that AFs apply to soil only.

Changed table numbering and added statement that AF 5.2.8. 5-12 for structures addressed in section 5.5.3 5.3.1. 5-12 Changed "FRS" to "FSS" 5.3.4.3. 5-14 Changed "STS" to "FSS" 5.3.4.3. 5-14 Changed "STS" to "FSS" Changed "STS" to "FSS" (2 times) and added "for below 5.3.4.3. 5-14 grade structures" to sentence.

Changed "FRS" to "FSS", added clarifying text pertaining to what specifically would require continuing 5.3.4.4. 5-15 characterization. Added commitment to provide Continuing characterization plans and reports to NRC for information 5.4. 5-15 Changed "FRS" to "FSS" (3 times) 5.4.1. 5-15 Changed "FRS" to "FSS", renumbered tables Changed title to "Contamination Verification Surveys 5.4.3. Title 5-16 (CVS) of Basement Structural Surfaces Completely revised the entire section describing CVS and how it is used, including incorporation of a concrete 5.4.3. 5-16 core sample for EMC, and use of CVS to identify biased sampling during compliance Added a new section 5.4.4 to describe post-remediation 5.4.4. 5-17 surveys.

Changed title to FSS of Basement Structures and remove 5.5. Title 5-17 STS 5.5. 5-17 Revised entire section to new DCGL approach 5.5.1. 5-17 Revised entire section to new DCGL approach 5.5.2. 5-18 Revised entire section to new DCGL approach Added entire section pertaining to application of EMC in 5.5.3. 5-21 basement structures 5.5.4. 5-24 Revised entire section to new DCGL approach 5.5.5. 5-24 Revised entire section to new DCGL approach 5.6. 5-25 Added "above grade structures" 5.6. 5-25 Deleted discussion of unconditional release surveys Added above grade structures to FSS and clarified 5.6.1. 5-26 description of survey unit considerations 5.6.2.6. 5-29 Renumber tables Page 7of13

Chapter 5 Page Description of Change Deleted "open land" as only consideration for statistical 5.6.4.2. 5-33 test Deleted full spelling of EMC and added statement that 5.6.4.3. 5-33 EMC for structures was addressed in section 5.5.3 Revised section numbering in text and numbering of 5.6.4.3. 5-34 equation Added consideration for above grade structures, 5.6.4.4. 5-35 renumbered tables Added "static measurement" and "measurement" to table Table 5-11 5-35 descriptions 5.6.4.5. 5-35 Added consideration for above grade structures 5.6.4.5.2. 5-36 Renumbered equations Added consideration for above grade structures and 5.6.4.6. 5-37 renumbered tables Table 5-12 5-37 Editorial Clarified process for remediation and resurvey of survey 5.6.4.6.1. 5-37 units. Added statement that DQO will be used as appropriate to evaluate reclassification and resurvey 5.6.4.6.2. 5-38 Added clarifying language Deleted paragraph pertaining to differences between FSS 5.7. 5-38 and STS Added paragraph pertaining to ISOCS FOV as scan 5.7.1.1. 5-39 coverage 5.7.1.2. 5-39 Changed "FRS" to "FSS" 5.7.1.5. 5-41 Changed "FRS" to "FSS" 5.7.1.5.2. 5-42 Deleted "subsurface" 5.7.1.5.2. 5-42 Added text pertaining to HTD analysis during FSS Changed "site-specific" to "soil" and renumbered table 5.7.1.5.3. 5-42 reference, added word "continuing" and specified "Turbine Building" Added commitment to provide continuing 5.7.1.5.3. 5-42 characterization plans and reports to NRC for information 5.7.1.5.3. 5-42 Editorial 5.7.1.5.3. 5-43 Added text pertaining to HTD analysis during FSS Revised entire section to clarify approach for reuse of 5.7.1.6. 5-43 stockpiled soil Added clarifying language pertaining to buried tanks and 5.7.1.8. 5-44 renumbered table reference 5.7.1.8. 5-44 Renumbered table reference 5.7.1.10. 5-44 Renumbered table reference Added text pertaining to FSS of above grade structures 5.7.1.11. 5-44 using NUREG-1757 default screening values Changed title to "Final Status Survey and changed 5.8 Title 5-45 "FRS" to "FSS".

Page 8of13

Chapter 5 Page Description of Change 5.8. 5-45 Changed FRS to PSS 5.8.1. 5-46 Editorial moved text Renumbered Table, changed "FRS" to "FSS", corrected Table 5-13 5-46 spelling "in situ" Table 5-14 5-47 Changed title from FRS to FSS. Renumbered Table 5.8.1. 5-48 FRS to FSS and changed table number 5.8.2. 5-48 Changed "FRS" to "FSS" 5.8.4. 5-49 Changed "FRS" to "FSS", clarified definition of MDC Changed variable in MDC equation from 2.71 to 3 for Equation 5-11 5-49 consistency with MARS SIM Equation 5-12 5-50 Changed equation number Equation 5-13 5-52 Changed equation number 5.8.4.6. 5-52 Renumbered table reference 5.9. 5-52 Changed "FRS" to "FSS" 5.9.1. 5-53 Changed "FRS" to "FSS" and deleted "STS" 5.9.2. 5-53 Changed "FRS" to "FSS" 5.9.2.1. 5-54 Changed "FRS" to "FSS" 5.9.2.2. 5-54 Changed "FRS" to "FSS" 5.9.2.3. 5-54 Changed "FRS" to "FSS" 5.9.2.5. 5-55 Changed "FRS" to "FSS" 5.9.2.6. 5-55 Changed "FRS" to "FSS" 5.9.3. 5-55 Changed "FRS" to "FSS" 5.9.3.1. 5-55 Deleted "STS" 5.9.3.2. 5-56 Added definitions of split and duplicate samples 5.9.4.1. 5-57 Changed "FRS" to "FSS" 5.9.4.3. 5-57 Changed "FRS" to "FSS". Deleted STS 5.9.5. 5-57 Changed "unity" to "unity rule" for consistency 5.9.6. 5-57 Deleted "STS" 5.10. 5-58 Changed "FRS" to "PSS" and deleted "STS" 5.10. 5-58 Deleted "for soil data" 5.10. 5-58 Added "if applicable" 5.10. 5-58 Deleted "expected to be" and changed "FRS" to "PSS" 5.10. 5-58 Added "survey units, structural" Added units of pCi/m1 and added statement that 5.10. 5-59 judgmental samples will be included in the PSS mean calculation using an area weighted average approach 5.10.1. 5-59 Changed "FRS" to "PSS" Replaced "soils and buried pipe" with "most PSS" and 5.10.2. 5-59 deleted sentence pertaining to Mean Inventory Fraction 5.10.2.1. 5-59, 5-60 Changed "FRS" to "PSS" (2 times)

Corrected equation by removing extraneous Sr-90 Equation 5-14 5-61 variable 5.10.3.2. 5-61 Deleted "BIL" and changed "FRS" to "FSS" Added statement that EMC for structures was addressed 5.10.4. 5-62 in section 5.5.3 and renumbered table reference Page 9of13

Chapter 5 Page Description of Change Equation 5-15 5-62 Renumbered equation Changed Title to read Final Status Survey, changed 5.11. 5-64 "FRS" to "FSS" and deleted reference to STS 5.11.1. 5-64 Deleted reference to STS 5.11.2. 5-65 Deleted reference to STS 5.12. 5-66 Deleted reference to STS Chapter 6 Page Description* of Change Dele,ted Dose Factor and Final Radiation Survey. Added List of Acronyms 6-v Field of View of ISOCS measurements and Final Status and Abbreviations Survey List of Acronyms Added In situ Object Counting System 6-v and Abbreviations List of Acronyms Deleted MARSAME 6-v and Abbreviations Added reference to Chapter 2, section 2.1.6.1 for Section 6.2. 6-1 discussion of basis for area classification and-survey unit boundaries in Figure 6-3.

Section 6.3. 6-3 Clarified list of above ground building to undergo FSS Section 6.3. 6-3 Clarifying text regarding G-3 plant status Section 6.3. 6-3 Clarifying text regarding G-3 crib house status Section 6.3. 6-4 Changed FRS to FSS Section 6.3. 6-4 Changed FRS to FSS Section 6.3. 6-4 Changed FRS to FSS Section 6-3. 6-5 Changed FRS to FSS Section 6.3. 6-5 Clarifying text regarding tanks listed in Table 6-2 Changed number of sources from 4 to 5 due to additional Section 6.5. 6-7 of above grade building FSS Changed number of sources from 4 to 5 due to addition Section 6.5. 6-7 of above grade building FSS Changed number of sources from 4 to 5 due to addition Section 6.5. 6-7 of above grade building FS S Section 6.5.1. 6-7 Changed Dose Factor to DCGL and units to pCi/m 2 Changed DF to DCGL and changed units to reflect Section 6.5.1.1. 6-8 DCGL Changed DF to DCGL and changed units to reflect Section 6.5.1.2. 6-8, 6-9 DCGL Section 6.5.2 6-9 Clarified definition of surface soil Section 6.5.2. 6-9 Clarifying statement Section 6.3 states that there is no embedded pipe at Section 6.5.3. 6-9 LACBWR. The same statement is added to section 6.5.3.

Revised to address the change to FSS of above grade Section 6.5.5. 6-10 buildings and clarify list of buildings to undergo FSS Section 6.5.6. 6-10 Clarifying text Page 10of13

Chapter 6 Page Description of Change Added text regarding use of EMC test results and Section 6.5.6. 6-11 judgmental sample results in compliance dose summation. Added clarifying text.

Section 6.5.6. 6-11 Added above grade building to list Section 6.6. 6-12 Changed DF to DCGL and FRS to FSS Section 6.6.1. 6-12 Reference number changes Section 6.6.2. 6-12 Reference number change Clarification of mixture calculation method and that cores were decayed to date of license termination. Added Section 6.6.2. 6-12 and 6-13 clarifying statement that mixture variability is addressed in section 6.13 Revised mixture to include decay to March 2020 license Table 6-3. 6-14 tennination date Section 6.7.1. 6-14 Clarifying text Section 6.7.1. 6-15 Clarifying text Section 6.8. 6-15 Changed title ofTSD due to DCGL approach Section 6.8.1. 6-16 Change DF to DCGL Section 6.8.1. 6-16 Reference number revision Section 6.8.1. 6-16 Reference number revision Section 6.8.2. 6-17 FRS to FSS Section 6.8.3. 6-18 Reference number revision Section 6.10.1. 6-21 Remove "total inventory" and added clarifying statement Section 6.10.1. 6-21 Reference number revision Deleted reference to and discussion of open air Section 6.10.1.2. 6-22 demolition because remediation goals now based on DCGLs Section 6.10.1.3. 6-22 FRS to FSS Section 6.10.1.4. 6-22 Removed statement regarding FRS classification Section 6.11.1.2. 6-26 Change reference number Section 6.11.1.3. 6-27 Change reference number Table 6-15 6-32 Editorial New section describing calculation method for BFM Section 6.11.1.4. 6-33 groundwater DCGLs Section 6.11.2. 6-33 Section reference change Change DF to DCGL and mrem/yr per total mCi to Section 6.11.2. 6-33 pCi/m2 Table 6-16 6-34 Change from BFM DF to DCGL Text describing modified, more conservative, approach Section 6.11.2 6-34 to drilling spoils scenario when using DCGLs Section 6.11.2. 6-35 Added area factor Section 6.11.2. 6-35 Editorial and change DF to DCGL Table 6-17 6-35 Revise to replace Drilling Spoils DF with DCGL Section 6.12. 6-36 Delete reference to total inventory Section 6.12. 6-36 Change DF to DCGL Section 6.12. 6-36 Change DF to DCGL Page 11 of 13

Chapter 6 Page Description of Change Table 6-18 6-36 Revise to replace BFM Excavation DFs with DCGLs Section 6.13. 6-37 Replace DF with DCGL Section 6.13. 6-37 Replace DF with DCGL Full revision of section to provide more detailed Entire section justification of calculation of insignificant contributor Section 6.13.1.

6-37 to 6-41 dose. Section provides direct evaluation of variability in calculation results.

Entire Section New section to specifically address adjustment of soil Section 6.13.2.

6-41 DCGLs for insignificant contributors Entire Section Fully revised section to address adjustment ofBFM Section 6.13.3.

6-42 to 6-43 DCGLs for insignificant contributors Entire Section New section to specifically address the Sr-90/Cs-137 Section 6.13 .4.

6-43 ratio for use in FSS surrogate approach Section 6.14. 6-44 Revision to replace DF with DCGL Section 6.15. 6-44 Change Table number Revised dose values based on calculation using revised (decayed) mixture, use of mean Sr-90/Cs-137 ratio calculated directly from core results per section 6.13.4, and DCGLs.

Section 6.15. 6-44, 6-45 Revised calculation of "Resident Gardener Alternate Scenario Dose assuming BFM Insitu Geometry" and "Alternate Scenario Dose for BFM Insitu Fill Concentrations" Entire section New section to describe calculation ofDCGLEMC for Section 6.16.

6-45 to 6-48 BFM and elevated measurement comparison test Section 6.17. 6-49 Editorial Table 6-28. 6-49 Change table number Section 6.18.3. 6-50 to 6-51 Change table number Section 6.18.4. 6-51 Change table number Description of method to address zero dose result from Section 6.18.4. 6-51 buried pipe RESRAD run Section 6.18.5. 6-51 Revised table number Change of dose value due to decay correcting mixture to March 2020 license termination date. Added statement Section 6.18.5. 6-52 that insignificant contributor dose adjustment factor set to 5% to provide margin Section 6.18.5. 6-52 Table number change Revise Fe-55 and Ni-63 values to adjust for zero Table 6-30 6-53 RESRAD dose result in DCGL calculation Tables 6-31 and 6- DCGL adjustment using higher value of 5% for 6-53 32 insignificant contributor dose Section 6-19. 6-54 Table number change Section 6.20. 6-54 Table number change Section 6.20. 6-54 Replace FRS with FSS and editorial Page 12of13

Chapter 6 Page Description of Change Revise text to clarify, add above grade building to equation, add commitment to include judgmental sample result into calculation of mean FSS value used, added Section 6.20. 6-55 commitment to provide detailed procedure on method for implementing Equation 6-6 and provide the procedure to NRC.

Due to additional evaluations of insignificant contributor dose in section 6-13, Tables copied from TSD RS-TD-313196-001" Radionuclides of Concern During -3 Attachment 6-3 LACBWR Decommissioning" were deleted from Attachment 6-3 and all revised and new tables supporting more detailed evaluation provided in attachments to TSD RS-TD-313196-001.

Chapter 7 Reda6ted Page Description of Change List of Acronyms 7-ii Changed "FRS" to "FSS" and Abbreviations 7.1. 7-1 Changed "Radiation" to "Status" and "FRS" to "FSS" 7.2.3. 7-4 Changed "FRS" to "FSS" Table 7-2 7-5 Changed "Radiation" to "Status" Changed "Radiation" to "Status" and "FRS" to "FSS" (4 Table 7-4 7-6 times)

Chapter 7 NRC Page Description of Change Verion List of Acronyms 7-ii Changed "FRS" to "FSS" and Abbreviations 7.1. 7-1 Changed "Radiation" to "Status" and "FRS" to "FSS" 7.2.3. 7-4 Changed "FRS" to "FSS" Table 7-2 7-5 Changed "Radiation" to "Status" Changed "Radiation" to "Status" and "FRS" to "FSS" (4 Table 7-4 7-7

' times)

Chapter 8 Page Description of Change List of Acronyms 8-iii Changed "FRS" to "FSS" and Abbreviations Changed "Radiation" to "Status" and changed "FRS" to 8.2.1. 8-4, 8-5 "FSS" Page 13of13

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 CHAPTER7 UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOLUTIONS 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 LACBWR Summary of Annualized Costs (in Millions) ..................................... 7-10 7-i

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOLUTIONS 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 FSS Final Status Survey GTCC Greater Than Class C ISFSI Independent Spent Fuel Storage Installation LACB WR 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 LACROSSESOLUTIONS

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 (LTP).

This chapter provides an estimate of the remaining decommissioning costs at the time of LTP 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 LTP 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 Status Survey (FSS) 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.

7-1

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOLUTIONS 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 performing 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 particularly 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 unrestricted release of the LACB WR site, other than the area bounded by the ISFSI. The estimate includes the costs required to accomplish unrestricted 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 present 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.

7-2

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOLUTIONS 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 certain 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 curren~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 transportation and disposal are in 2015 dollars.
  • Although all costs in this LTP are in current year dollars, the project baseline does include provisions to escalate costs based on the Consumer Price Index 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.

7-3

La Crosse Boiling Water Reactor License Termination Plan ~

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

$.Million $0.3 Million Million Total $.Million $2.9 Million Million Note 1 : Site restoration is included for completeness, but not required for license termination 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 under 10 CFR 50.2, the radiological decommissioning costs under 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 $ . Million.

The remaining decommissioning scope of work included in this estimate is described in detail in other chapters of this LTP. 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 FSS and associated license termination 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.

7-4

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOLUTIONS 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 Status Surveys $1.1 Million Program Management $11.1 Million TOTAL $.Million Note 1: Columns may not add due to rounding 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 COST1 Staff Labor $6.1 Million Craft Labor $11.3 Million Rad Protection Technicians $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 1: Columns may not add due to rounding 7-5

La Crosse Boiling Water Reactor License Termination Plan ~~

Revision 0 LACROSSESOLUTIONS Table 7-4 Breakdown of Radiological Decommissioning Costs by Detailed Activity ACTIVITY COST 1 PROJECT DEVELOPMENT & LTP PREPARATION Total $1.7 Million LACBWRLTP (313196) $0.6 Million ES Bid & Proposal (941351) $1. l 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 STATUS SURVEYS Total $1.1 Million Reactor Building FSS & Support $0.4 Million Turbine Building FSS & Support $0.4 Million Waste Treatment Building FSS & Support $0.2 Million Balance of Plant FSS & 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 1: Columns may not add due to roundmg 7-6

La Crosse Boiling Water Reactor License Termination Plan ~

Revision 0 LACROSSESOLUTIONS 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. This 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 EnergySolutions 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. This 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 volume. Therefore, these costs are known and are unlikely to vary. This 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 (GTCC) 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 which 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 LACROSSESOLUTIONS 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 high 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 COST1 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: Columns may not add due to rounding 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 this estimate. Accounting for contingency has been evaluated from two standpoints, operational 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 LACROSSESOLUTIONS 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: Columns may not add due to rounding 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 LACROSSESOLUTIONS 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 LACBWR site ISFSI will be undertaken by Dairyland2 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 LACBWR 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 annual 2% real, after tax rate of return, the required minimum funding asslirance amount to fund the future radiological decommissioning costs equals $ . Million, which is below the $ . Million available 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 LACROSSESOLUTIONS 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 Regulatory Commission, Application for Order Approving License Transfer and Conforming Administrative License Amendments, dated October 8, 2015.

7-11

Attachment 5 Reference Documentation RS-TD-313196-001, Rev. 1 RS-TD-313196-004, Rev. 1 (PDF files on Attachment 3 CD)

Attachment 6 Preflight Report for Electronic Files on Attachment 3 CD to LC-2016-0085

LaCrosseSolutions, LLC LC-2016-0085: Attachment 6 Page 1of5 This document serves as preflight report for electronic files to Attachment 3 CD to LC-2016-0085. 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 Document Name File Name Reason Status License Termination Plan ,

Document contains La Crosse Boiling Water Reactor embedded fonts, logos, License Termination Plan LACBWR LTP Ch 1 Rev 0 Failed graphics, and color maps Chapter 1

< 300 ppi, clear and General Information legible Document contains La Crosse Boiling Water Reactor embedded fonts, logos, License Termination Plan LACBWRLTP Ch2 Rev 0 Failed graphics, and color maps Chapter 2

< 300 ppi, clear and Site Characterization legible La Crosse Boiling Water Reactor Document contains License Termination Plan embedded fonts and logos Chapter 3 LACBWR LTP Ch 3 Rev 0 Failed

< 300 ppi, clear and Identification of Remaining Site Dismantlement legible Activities La Crosse Boiling Water Reactor Document contains License Termination Plan embedded fonts and logos LACBWR LTP Ch 4 Rev 0 Failed Chapter 4 < 300 ppi, clear and Remediation Plan legible La Crosse Boiling Water Reactor Document contains License Termination Plan embedded fonts and logos LACBWR LTP Ch 5 Rev 0 Failed Chapter 5 < 300 ppi, clear and Final Status Survey Plan legible

LaCrosseSolutions, LLC LC-2016-0085: Attachment 6 Page 2of5 Preflight Document Name File Name Reason Status La Crosse Boiling Water Reactor Document contains License Termination Plan embedded fonts, logos, Chapter 6 LACBWR LTP Ch 6 Rev 0 Failed graphics, and color maps Compliance With The Radiological Criteria For < 300 ppi, clear and License Termination legible La Crosse Boiling Water Reactor Document contains License Termination Plan embedded fonts and logos Chapter 7 LACBWR LTP Ch7 Rev 0 Failed

< 300 ppi, clear and Update Of The Site-Specific Decommissioning legible Costs La Crosse Boiling Water Reactor Document contains License Termination Plan embedded fonts and logos Chapter 7 Redacted LACBWR LTP Ch 7 Rev 0 Redacted Failed

< 300 ppi, clear and Update Of The Site-Specific Decommissioning legible Costs La Crosse Boiling Water Reactor Document contains License Termination Plan embedded fonts and logos LACBWR LTP Ch 8 Rev 0 Failed Chapter 8 < 3 00 ppi, clear and Supplement To The Environmental Report legible

LaCrosseSolutions, LLC LC-2016-0085: Attachment 6 Page 3of5 Preflight Document Name File Name Reason Status Reference Documents to License Termination Plan Document contains RS-TD-313196-001 embedded fonts, logos, Radionuclides of Concern During LACBWR RS-TD-313196-001Rev1 112816 Failed and graphics< 300 ppi, Decommissioning, Revision 1 clear and legible Document contains RS-TD-313196-004 embedded fonts, logos, LACBWR Soil DCGL and Basement Concrete RS-TD-313196-004 Rev 1 112916 Failed and graphics< 300 ppi, DCGL, Revision 1 clear and legible Supporting Documents to RS-TD-313196-004 Calculations in Support of TSD RS-TD- Calculations in Support of TSD RS-Excel file 313196-004 Revision 1 TD-313196-004 Revision 1 pswrd RESARD files to RS-TD-313196-004, Rev 1 Alt Scenario Soil Resident Gardener Passed 20151019 Alternate Scenario WTB 20151019 Passed LACBWR BFM Drilling Spoils Area Passed Factor 20151014 LACBWR BFM Remaining Structures Passed DSR Summary Report 20151019 LACBWR BFM RS Uncertainty Passed Analysis Uncertainty Report 20150901 LACBWR BFM Rx Above 619 DSR Passed Summary Report 20151019 LACBWR BFM Rx Above 619 Uncertainty Analysis Uncertainty Passed Report 20150901

LaCrosseSolutions, LLC LC-2016-0085: Attachment 6 Page 4of5 Preflight Document Name File Name Reason Status LACBWR BFM Rx Below 619 DSR Passed Summary Report 20151019 LACBWR BFM Rx Below 619 Uncertainty Analysis Uncertainty Passed Report 20150901 LACBWR BFM WGTV Summary Passed Report 20151019 LACBWR BFM WGTV Uncertainty Passed Analysis Uncertainty Report 20150901 LACBWR BFM WTB Summary Passed Report 20151019 LACBWRBFM WTB Uncertainty Passed Analysis Uncertainty Report 20150901 LACBWR Buried Pipe Excavation Circ Passed 032616 LACBWR Buried Pipe Excavation Passed Group 032616 LACBWR Buried Pipe Insitu Circ Passed 120115 LACBWR Buried Pipe Insitu Group Passed 120115 LACBWR Soil Area Factor 1 m2 Passed 20151019 LACBWR Soil Area Factor 2 m2 Passed 20151019 LACBWR Soil Area Factor 5 m2 Passed 20151019 LACBWR Soil Area Factor 10 m2 Passed 20151019

LaCrosseSolutions, LLC LC-2016-0085: Attachment 6 Page 5of5 Preflight Document Name File Name Reason Status LACBWR Soil Area Factor 100 m2 Passed 20151019 LACBWR Soil DCGL Initial Suite Passed Summary Report 20151014 LACBWR Soil Uncertainty Analysis Uncertainty Report Initial Suite Passed 20150903

Retrieved from "https://kanterella.com/w/index.php?title=ML16347A026&oldid=2441858"