ML20052D015

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Request for Partial Site Release
ML20052D015
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 02/14/2020
From: Gerard van Noordennen
LaCrosseSolutions
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LC-2020-004
Download: ML20052D015 (28)
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LACROSSESOLllTIOl\\[S' 10 CFR 50.82(a)(l 1)

February 14, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 La Crosse Boiling Water Reactor Facility Operating License No. DPR-45 NRC Docket Nos. 50-409 and 72-046

Subject:

La Crosse Boiling Water Reactor Request for Partial Site Release

References:

LC-2020-004

1) John R. Tappert, U.S. Nuclear Regulatory Commission, Letter to John Sauger, Energy Solutions, "La Crosse Boiling Water Reactor -Approval of Partial Site Release for Possession Only License No. DPR-45 (CAC No. L53136),"

dated April 12, 2017

2) Marlayna Vaaler, U.S. Nuclear Regulatory Commission, Letter to John Sauger, EnergySolutions, "La Crosse Boiling Water Reactor-Issuance of License Amendment No. 75 to Approve the LaCrosseSolutions, LLC License Termination Plan (CAC No. 000083; EPID-L-2017-DTP-0008)," dated May 21, 2019
3) Gerard van Noordennen, LaCrosseSolutions, Letter to U.S. Nuclear Regulatory Commission, "Final Status Survey Final Report - Phase 1,"

dated September 11, 2019

4) Gerard van Noordennen, LaCrosseSolutions, Letter to U.S. Nuclear Regulatory Commission, "Final Status Survey Final Report - Phase 2,".

dated December 13, 2019

5) Gerard van Noordennen, LaCrosseSolutions, Letter to U.S. Nuclear Regulatory Commission, "Final Status SurveiFinal Report - Phase 3," dated January 28, 2020 The purpose of this letter is to provide written notification to the Nuclear Regulatory Commission (NRC) that LaCrosseSolutions, the licensee for the La Crosse Boiling Water Reactor (LACBWR), intends to remove a portion of the site from the 10 CFR Part 50 License, License No. DPR-45. Specifically, LaCrosseSolutions intends to remove an area consisting of two basement survey units, eight above grade building survey units, and twenty-one land survey units (including seven below grade excavation survey units), and ten buried pipe survey units.

The area requested to be removed from the license, approximately 36.5 acres, encompasses approximately 22 percent of the original site area of 163.5 acres. The NRC approved the partial site release of approximately 88 acres of non-impacted land from the 10 CFR Part 50 license by letter dated April 12, 2017 (Reference 1). Approximately 39 acres of the licensed site is S4601 State Highway 35, Genoa, WI 54632

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  • LaCrosseSolutions LC-2020-004 Page 2 of2 associated with the Independent Spent Fuel Storage Facility (ISPSI); this area will be retained under the 10 CPR Part 50 license until the ISFSI is decommissioned.

As stated above, LaCrosseSolutions intends to release the site areas outside of the ISPSI and its associated land area from the Part 50 License. In accordance with 10 CFR 50.82(a)(l 1), the LACBWR License Termination Plan, and the NRC safety evaluation dated May 21, 2019 (Reference 2), LaCrosseSolutions has reviewed and assessed the survey units to ensure that the proposed action will have no impact on the ability of the site in aggregate to meet the 10 CPR 20, Subpart E, criteria for unrestricted release. The attachment to this letter contains a summary of the analysis that was completed to support removal of the survey areas from the 10 CPR Part 50 license.

The survey units included in the proposed release of land, for unrestricted use, are provided in Tables 1, 2, and 3 within the attachment. The area associated with the ISFSI that will remain within the license following the proposed removal is depicted in Figure 3 within the attachment.

The Final Status Survey Final Reports for Phases 1, 2, and 3 (References 3, 4, and 5) support the summary and conclusions described in the attachment; however, these documents are not included as part of the attachment as they were previously provided to the NRC.

LaCrosseSolutions plans to begin undertaking activities associated with the release of the subject survey areas from the 10 CFR Part 50 license on or before July 30, 2020. Therefore,

, LaCrosseSolutions requests that the NRC approve the acceptability of the release of the survey areas by July 15, 2020.

There are no regulatory commitments made in this submittal. If there are any questions regarding this submittal, please contact me at (860) 462-9707.

Respectfully, Gerard van Noordennen Senior Vice President Regulatory Affairs

Attachment:

La Crosse Boiling Water Reactor Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License cc:

MarlaynaDoell, U.S. NRC Project Manager Regional Administrator, U.S. NRC, Region III La Crosse Boiling Water Reactor Service List

  • La Crosse Boiling Water Reactor Service List Ken Robuck President and CEO Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 John Sauger President and CNO Reactor D&D EnergySolutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Joseph Nowak Project Manager LaCrosseSolutions S4601 State Highway 3 5 Genoa, WI 54632-8846 Gerard van N oordennen Senior VP Regulatory Affairs Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Russ Workman General Counsel Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 Jerome Pedretti, Clerk Town of Genoa E860 Mundsack Road Genoa, WI 54632 Jeffery Kitsembel Division of Energy Regulation Wisconsin Public Service Commission P.O. Box 7854 Madison, WI 53707-7854 Paul Schmidt, Manager Radiation Protection Section Bureau of Environmental and Occupational Health Division of Public Health Wisconsin Department of Health Services P.O. Box 2659 Madison, WI 53701-2659 Barbara Nick President and CEO Dairyland Power Cooperative 3200 East Avenue South La Crosse, WI 54602-0817 Cheryl Olson, ISFSI Manager La Crosse Boiling Water Reactor Dairyland Power Cooperative S4601 State Highway 35 P.O. Box 817 Genoa, WI 54632-8846 Lane Peters La Crosse Boiling Water Reactor Dairyland Power Cooperative S4601 State Highway 3 5 Genoa, WI 54632-8846 Thomas Zaremba Wheeler, Van Sickle and Anderson, S.C.

44 East Mifflin Street, Suite 1000 Madison, WI 53703 Andrew J. Parrish Wheeler, Van Sickle & Anderson, S.C.

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

LC-2020-004 ATTACHMENT La Crosse Boiling Water Reactor Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CPR Part 50 License TABLE OF CONTENTS

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LACR0SSESOLUT101~

1 BACKGROUND.................................................................................................................... 3 2

PURPOSE............................................................................................................................... 3 3

SITE INFORMATION........................................................................................................... 4 3.1 General Information......................................................................................................... 4 3.2 Description of Survey Units (Covered Under this Partial Site Release Request)............ 4 4

DOSE SUMMATION AND COMPLIANCE........................................................................ 7 4.1 Demonstrating Compliance with Dose Criteria............................................................... 7 4.2, Final Dose Summation..................................................................................................... 8 5

IMPACT OF RELEASE OF THE AREAS............................................................................ 9 5.1 Potential for Cross-Contamination from Subsequent Activities...................................... 9 5.2 Impact of Releasing the Subject Survey Units on Part 50 License Basis...................... 10 5.2.1 Technical Specifications......................................................................................... 10 5.2.2 Final Safety Analysis Report (FSAR) and Environmental Report......................... 11 5.2.3 ISFSI Emergency Plan............................................................................................ 11 5.2.4 Security Plan............................................................................................................ 11 5.2.5 Off-Site Dose Calculation Manual (ODCM).......................................................... 12 5.2.6 Environmental Monitoring Program....................................................................... 12 5.2.7 Groundwater Monitoring Program......................................................................... 12 5.2.8 Fire Protection Program.......................................................................................... 13 5.2.9 Training Program.................................................................................................... 13 5.2.10 Post-Shutdown Decommissioning Activities Report.............................................. 13 5.2.11 License Termination Plan....................................................................................... 13 5.2.12 Complian.ce with 10 CPR 100 Siting Criteria........,................................................ 13 5.3 Consideration oflnteraction between the Proposed Partial Site Release and the Previously Released Site and between the Proposed Partial Site Release and Remaining Licensed Site................................................................................................................................. 13 5.3.1 Effects on the Proposed Site Release from Previous Land Release....................... 14 1

Attachment to LC-2020-004

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Supporting Information for the Phased Release of Land from the 10 CPR Part 50 License LACROSSESOLUTJOA~S 5.3.2 Dose Effects on ISFSI Land (i.e., land that will remain under jurisdiction of the Part 50 license)............................................................................................................... 14 5.3.3 Dose Effect on the Proposed Site Release from the Remaining Decommissioning Activities at the Remaining LACBWR Site........................................................... 15 5.4 Additional Areas to be Addressed to Support the Release of the Subject Survey Units 16 5.5 Site Release Criteria........................................................................................................ 16 5.6 Final Status Survey............................................................................ :............................ 16

5. 7 Conclusion...................................................................................................................... 1 7 6

REFERENCES..................................................................................................................... 17 LIST OF TABLES Table 1 Phase 1 Survey Units.................................................................................................... 6 Table 2 Phase 2 Survey Units............................ ;....................................................................... 6 Table 3 Phase 3 Survey Units.................................................................................................... 7 Table 4 Final Dose Summation................................................................................................. 9 Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 LIST OF FIGURES Impacted Areas of the LACBWR Site......................................................................... 19 Non-Impacted Areas of the LACBWR Site................................................................ 20 Independent Spent Fuel Storage Facility.................................................................... 21 Phase 1 Survey Unit Locations.............................. :.................................................... 22 Phase 2 Survey Unit Locations................................................................................... 23 Phase 3 Survey Unit Locations................................................................ 24 2

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License 1

BACKGROUND On June 27, 2016, LaCrosseSolutions, LLC submitted a License Termination Plan (LTP) and accompanying License Amendment Request (LAR), "License Amendment Request for the License Termination Plan," for the La Crosse Boiling Water Reactor (LACBWR). The LAR proposed to amend Possession Only License No. DPR-45 to reflect approval of the L TP. The L TP was submitted as a supplement to the LACBWR Defueled Safety Analysis Report (DSAR), and was accompanied by a proposed license amendment (in the form of a license condition) that establishes the criteria for when changes to the L TP require prior NRC approval. On December 1, 2016, LaCrosseSolutions submitted additional information to reflect changes to the L TP made in response to public meetings held to discuss the L TP, as well as to incorporate lessons learned from items identified as part of the NRC staffs concurrent review of the L TP -for Zion Nuclear Power Station. On May 31, 2018, LaCrosseSolutions submitted Revision 1 to the L TP (Reference 1) with corresponding changes to the LAR that reflect, among other things, changes made in response to requests for additional information (RAls) that were provided by the NRC in a letter dated August 4, 2017. Finally, on November 15, 2018, LaCrosseSolutions submitted responses to additional RAls related to groundwater that included a change to the proposed license condition associated with the LTP. The supplements dated December 1, 2016, May 31, 2018, and November 15, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on August 30, 2016. On May 21, 2019, the NRC issued a Safety Evaluation Report (SER) (Reference 2) which approved Revision 1 to the LACBWR LTP.

In Section 5.11 of the L TP, LaCrosseSolutions indicated that it will submit final reports to the NRC, that detail the results of Final Status Surveys (FSS), in a phased approach. Additionally, LaCrosseSolutions indicated that it may want to remove areas from the license once decommissioning and remediation tasks are complete and the licensee can demonstrate that the area and any associated basement structures, above~grade buildings, or buried piping, will have no adverse impact on the site in the aggregate to meet the 10 CFR Part 20, Subpart E, criteria for unrestricted release.

2 PURPOSE The purpose of this report is to provide written notification to the NRC of LaCrosseSolutions' intent to release a portion of the LACBWR site from the 10 CFR 50 license. Specifically, LaCrosseSolutions intends to release an area consisting of two (2) basement survey units, eight (8) above grade building survey units, twenty-one (21) land survey units (including seven (7) below grade excavation survey units), and ten (10) buried pipe survey units. This area encompasses approximately 36.5 acres of the original licensed site area of 163.5 acres 3

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License

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LAC:ROSSESOLlfTlat-V:S and constitutes the entire impacted area of the site (see Figure 1). On April 12, 2017, the NRC approved the partial site release of approximately 88 acres of non-impacted land from the 10 CFR Part 50 license (see Figure 2) (Reference 3). Approximately 39 acres of the licensed site is associated with the Independent Spent Fuel Storage Facility (ISFSI) and will remain in the 10 CFR Part 50 license (see Figure 3). In accordance with the LACBWR LTP, the NRC SER dated May 21, 2019, and the requirements of 10 CFR 50.82(a)(ll), LaCrosseSolutions has reviewed and assessed the subject survey units to ensure that this proposed action will have no adverse impact on the ability of the site in aggregate to meet 10 CFR Part 20, Subpart E, criteria for unrestricted release.

3 SITE INFORMATION 3.1 General Information LACBWR was a SO-Megawatt Electric (MWe) BWR that is owned by Dairyland Power.

Cooperative (Dairyland). This unit, also known as Genoa 2, is located on the Dairyland Genoa site on the east shore of the Mississippi River south of the Village of Genoa, Vernon County, Wisconsin. LACBWR has been shut down since 1987.

The site is licensed under Possession Only License No. DPR-45 with Docket Numbers of 50-409 for LACBWR and 72-046 for the Independent Spent Fuel Storage Installation (ISFSI). In a letter dated October 8, 2015, Dairyland and LaCrosseSolutions requested NRC consent to transfer Dairyland's possession, maintenance and decommissioning authorities, under Possession Only License No. DPR-45, from Dairyland to LaCrosseSolutions. In May 2016, the NRC provided consent to transfer the license to LaCrosseSolutions.

Decommissioning and subsequent final radiological surveys were completed in accordance with the LTP and relevant regulatory guidance. Demobilization of personnel from the site occurred in late October, 2019: The spent nuclear fuel stored in the LACBWR ISFSI will be maintained under an amended Part 50 license.

3.2 Description of Survey Units (Covered Under this Partial Site Release Request)

Presently, LaCrosseSolutions intends to release an area consisting of forty-one (41) survey units. This area encompasses 36.5 acres (approximately 22%) of the original licensed site area of 163.5 acre, leaving only the land area associated with the ISFSI within the Part 50 license.

The boundaries of the area subject to this release request, along with GPS coordinates, are depicted in Figure 1.

An FSS was performed on each of the forty-one (41) impacted survey units that are subject to this release request. The FSS was performed in accordance with the LTP, NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (Reference 4),

as well as numerous LACBWR implementing procedures.

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Attachment to LC-2020-004

  • Supporting Information for the Phased Release of Land from the 10 CPR Part 50 License

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.L\\0ROSSESOLUT101V'S As detailed in Section 5.11 of the L TP, an PSS Release Record was prepared for each survey unit to provide complete and unambiguous records of the as-left radiological status. Sufficient data and information are provided in each Release Record to enable an independent re-creation and evaluation at some future time of both the survey activities and the derived results.

Final Reports were written consistent with the guidance provided in NUREG-1757, Vol. 2, Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria (Reference 5), and MARSSIM. To facilitate the data management process, FSS Final Reports incorporate multiple Survey Unit Release Records.

To minimize the incorporation of redundant historical assessment and other FSS program information, and to facilitate potential phased releases from the current license, FSS Final Reports were prepared in a phased approach. Three FSS Final Reports have previously been submitted to the NRC.

The Phase 1 FSS Final Report (Reference 6) was submitted to NRC for review on September 17, 2019, and included four (4) sub-grade excavation (SGE) survey units, three (3) open land (OLA) survey units, and two (2) structure basement {SB) survey units.

The Phase 2 FSS Final Report (Reference 7) was submitted to NRC for review on December 16, 2019, and included eight (8) above-grade building (AGB) survey units and ten (10) buried pipe (BP) survey units.

The Phase 3 FSS Final Report (Reference 8) was submitted to NRC for review on January 28, 2020, and included three (3) sub-grade excavation and eleven (11) open land area survey units. The Phase 3 FSS Final Report also provided an overview of existing groundwater conditions and the methods used for calculating the dose from groundwater. Additionally, the Phase 3 FSS Final Report represents the last of three final reports. As such, a description of how dose compliance is demonstrated through the summation of the five (5) distinct source terms for the end-state (i.e., basements, soil, buried pipe, above-grade structures, and groundwater), was provided to demonstrate that the LACBWR site, as a whole, meets the 25 mrem/yr release criterion as established in NRC Regulation 10 CFR 20.1402, Radiological Criteria/or Unrestricted Use.

A listing of survey units within each of the FSS Final Report phased submittals, along with a description and classification designation for each, is provided in Tables 1, 2, and 3. The boundaries of the forty-one (41) survey units within the scope of this release request, broken down by phase, are depicted in Figures 4, 5, and 6.

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Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License

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LACROSSESOLUI10l\\S Table 3 Phase 1 Survey Units ti$Jfte'f tJitiff '" ?fypJ&;_, :~;:div*- ;s' >'.\\'. sli.;;i' *uriit2De'§~tf7'ti6if\\*;~;; '/¥;/ *;~Pt'* "t'

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LI-SUB-DRS SGE RCA North Area Excavation 1

Ll-SUB-TDS SGE TB, Sump, Pit Diesel Excavation 1

LI-SUB-LES SGE LSA, Eat Shack, Septic Excavation 1

LI-010-101 C SGE Waste Treatment Building Excavation 1

L2-01 l-102 OLA Area South ofLACBWR Site Enclosure (LSE) Fence 2

L2-0l l-103 OLA G-3 Crib House Surrounding Area 2

L3-012-102 OLA Transmission Switch Yard 3

Bl-010-004 SB Waste Gas Tank Vault Basement 1

Bl-010-001 SB Reactor Building Basement 1

Table 2 Phase 2 Survey Units

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B2-010-101 AGB LACBWR Crib House 2

B2-010-102 AGB G-3 Crib House 2

B2-010-103 AGB LACBWR Administration Building 2

B3-012-101 AGB Back-up Control Center 3

B3-012-102 AGB Transmission Sub-Station Switch House 3

B3-012-103 AGB G-1 Crib House 3

B3-012-104 AGB Barge Wash Break Room 3

B3-012-109 AGB Security Shack 3

Sl-011-102 BP Circulating Water Discharge Pipe 1

S2-01 l-103 A BP De-Icing Line 2

S2-0l l-103 BP Circulating Water Intake Pipe 2

S3-012-109 A BP Storm Drain 1 3

S3-012-109 B BP Storm Drain 2 3

S2-0ll-101 A BP Storm Drain 3 3

S2-011-101 B BP Storm Drain 6 3

S3-012-102 A BP Storm Drain 4 3

S3-012-102 B BP Storm Drain 5 3

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Attachment to LC-2020-004

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Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License LAC!Ro~~OL,ll.1101~

4 Table 3 Phase 3 Survey Units Ll-010-101 OLA Reactor Building, WTB, WGTV, Ventilation Stack 1

Grounds Ll-010-102 OLA Turbine Building, Turbine Office Building, 1B Diesel 1

Generator Building Grounds Ll-010-103 OLA LSA Building, Maintenance Eat Shack Grounds 1

Ll-010-104 OLA North LSE Grounds 1

Ll-010-105 OLA North Interim Debris Storage Area 1

Ll-010-106 OLA North Loading Area 1

Ll-010-107 OLA Outside East LSE Area 1

L2-0l l-10I OLA Area North ofLSE Fence 2

L2-0I 1-104 OLA G3 Crib House, Circ. Water Discharge Land 2

L3-012-I01 OLA North End of Licensed Site 3

L3-012-I09 OLA Plant Access, ISFSI Haul Road Grounds 3

Ll-SUB-CDR SGE Stack, Pipe Tunnel, RPGP A 1

Ll-SUB-TDS A SGE Eastern Portion TB, Sump, Pit, Diesel 1

Ll-SUB-TDS B SGE RPGPAArea 1

DOSE SUMMATION AND COMPLIANCE Each radionuclide-specific Base Case Derived Concentration Guideline Level (DCGL) is equivalent to the level of residual radioactivity (above background levels) that could, when considered independently, result in a Total Effective Dose Equivalent (TEDE) of 25 mrem per year to the Average Member of the Critical Group (AMCG). Compliance is demonstrated through the summation of the dose from each of the Radionuclides of Concern (ROCs) in each of the five media (i.e., basement concrete, soil, buried pipe, above grade buildings and existing groundwater). Dose summation for compliance is discussed in further detail in Sections 6.5.6 and 6.22 of the L TP.

4.1 Demonstrating Compliance with Dose Criteria The compliance dose was calculated using Equation 6-11 in the L TP after FSS was completed in all survey units. The equation is replicated below as Equation 1 to this report.

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Attachment to LC-2020-004

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Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License

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.LACR0SSESOLUT10l\\S Equation 1 Compliance Dose

= (Max BcSOFBASEMENT + Max BcSOFsorL + Max BcSOFBURIED PIPE+

BcSOF AG BUILDING+ GW BcSOFBs OB + GW BcSOFBPS OBP + Max SOFEGw) x 25 mrem/yr where:

Compliance Dose Max BcSOFBASEMENT Max BcSOFsorL

=

=

must be less than or equal to 25 mrem/yr, Maximum Base Case (BcSOF) (mean of FSS systematic results plus the dose from any identified elevated areas) for backfilled Basements, Maximum BcSOF (mean of FSS systematic results plus the dose from any identified elevated areas) for open land survey units, Max BcSOFBURIED PIPE =

Maximum BcSOF (mean of FSS systematic results plus the dose from any identified elevated areas) from buried piping survey units, Max BcSOF AG BUILDING =

Maximum BcSOF (mean of FSS systematic results plus the dose from IDIY identified elevated areas) from above grade standing building survey units; GW BcSOFBs OB GW BcSOFBPS OBP Max SOFEGW

=

Groundwater scenario dose from the "Other Basement" (OB) which is defined as the basement not used to generate the Max BcSOFBASEMENT term in Equation 3

=

  • Groundwater scenario dose from the "Other Buried Pipe" (OBP) which is defined as the buried pipe survey unit not used to generate the Max BcSOFBURIED PIPE term in Equation 3

=

Maximum Sum of Fraction (SOF) from existing groundwater (EGW)

The release. records for all survey units have been reviewed to determine the maximum mean dose f~om each of the seven (7) source terms listed in Equation 1. The compliance dose must be less than or equal to 25 mrem/yr. A list of the survey units within each source term, along with their respective BcSOF and dose, is provided in several tables within Section 7 of the Phase 3 FSS Final Report.

4.2 Final Dose Summation The results of the final compliance dose have been calculated using Equation 1 and using the maximum SOF for the five media and the two groundwater scenarios. The final dose summation is presented in Table 4.

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Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License Table 4 Final Dose Summation

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.":.. :* \\*}f;;souf:c~, *t}{*i<:.' :,§~~~iPtitf}f} *.* :Jl?s~};~~(~QFj**;::,:J{l}os{c~f;;Jifa. ;:. ~i Max BcSOFBASEMENT Bl-010-004 0.0233 0.5813 Max BcSOFsorL Ll-SUB-CDR 0.0408 1.0190 Max BcSOPBURIED PIPE S3-012-109 A 0.1204 3.0112 Max BcSOP AG BUILDING B2-010-101 0.0202 0.5055 Max SOFEGW NA 0.1108 2.770 GW BcSOPBs OB Bl-010-001 0.0001 0.0025 GW BcSOPBPS OBP S2-011-101 A 0.0138 0.345 TOTAL 0.3294 8.2345 5

IMPACT OF RELEASE OF THE AREAS With the exception of decommissioning activities at the ISFSI to be undertaken when all spent fuel has been removed, all decommissioning and dismantlement activities have been completed at the LACBWR site. Thus, no dismantlement activities are required in these subject survey units for LaCrosseSolutions to release them.

5.1 Potential for Cross-Contamination from Subsequent Activities Prior to implementing FSS, survey units were isolated and controlled in accordance with LTP Section 5.6.3. This included posting of the survey units as well as notifications to site personnel. Prior permission to enter and work in these areas was required to be obtained from PSS personnel. During decommissioning, control measures were placed on the release of material from radiologically controlled areas and the LACBWR Site Enclosure (LSE) which decreased the probability that the survey units would be impacted from decommissioning activities. These control measures included contamination containment, dust control, storm water runoff measures, building demolition controls, and additional evaluations and radiological surveys of materials leaving the LSE.

Section 5.12 of the L TP describes periodic surveillances/re-surveys to confirm that no radioactive material had been introduced into the survey units that would potentially invalidate the results of the FSS or the final configuration of the survey unit. These isolation and control measures, occurring prior to, during and following PSS, have been implemented in these subject survey units through approved procedures. These procedures were in effect at the time of turnover to the FSS Group and remained in effect throughout site final survey activities and until the risk of recontamination from decommissioning activities was alleviated.

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Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CPR Part 50 License

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. lli.~~.~£J3VL*U'.1.:1V.1'0 These requirements for decommissioning activities, as well as the additional protections afforded from PSS isolation and control measures, provide strong assurance that the potential for cross-contamination of the subject survey units is minimal. In addition, the site has carried out an erosion control program (Storm Water Pollution Prevention Plan) (Reference 9) to reduce the potential for soil erosion into adjacent land areas and surface water bodies.

The spent fuel at the ISPSI is stored in the NAC Multi-Purpose Canister (MPC) System. The NAC-MPC System is a sealed and leak-tight spent fuel storage system and consists of five (5) above-ground Dry Storage Casks with 333 spent fuel assemblies. In addition, in-process inspections and tests were performed during fabrication and sealing of the canisters.

Consequently, there is no release ofradioactive material during normal conditions of storage.

The structural analysis of the canister for off-nonnal and accident conditions of storage shows that the canister is not breached in any of the evaluated events. Consequently, there is no release of radioactive material during off-normal and accident conditions of storage that could impact the survey units proposed for release.

5.2 Impact of Releasing the Subject Survey Units on Part 50 License Basis The license basis for the LACBWR includes the maintenance of certain programs to fulfill regulatory requirements and functional responsibilities. Throughout decommissioning, these programs have been modified as necessary and tenninated when the applicable concern is no longer relevant. These program changes are implemented using the change processes specified for each type of program. The methodology for releasing land requires a review and assessment of the impact on license programs for the site lands remaining within the domain of the Part 50 license. The NRC accepted this approach included in the L TP via License Amendment. The impact of releasing the subject survey units from the Part 50 license on each of the licensing programs is described below. With this submittal, LaCrosseSolutions is not requesting NRC approval of any potential changes described herein.

5.2.1 Technical Specifications The LACBWR Defueled Technical Specifications are not impacted by the release of the subject survey units, as a size and description of the site are not included in the Technical Specifications. The survey and release are consistent with the L TP and associated License Condition.

The NAC-MPC Technical Specifications, associated with allowable surface contamination on the cask after loading, were based upon limiting the dose at the Controlled Area Boundary (CAB) due to a total mechanistic release of the surface contamination. The closest CAB distance is the public boat launch parking lot at 383 feet. As stated in Section 4.3 of the LACBWR ISFSI JO CFR 72.212 Report (Reference 10), an occupancy dose at 350 feet from the ISPSI for an individual for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per year is 10.7 mrern/yr. The partial site 10

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License

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LACROSS.ESOLUTJOA!S release will not affect the basis for this Technical Specification, as the assumed residual plant area dose is on the opposite side of the site. Using a very conservative assumption of combining the dose from the ISFSI and the residual plant area dose, the result confirms that the Technical Specification basis will continue to be maintained after partial site release has been implemented.

5.2.2 Final Safety Analysis Report (FSAR) and Environmental Report The LACBWR Final Safety Analysis Report (FSAR) was last revised in 1986 and is considered a historical document. The document that took the place of the FSAR was the

, Decommissioning Plan (D-Plan). When the NRC decommissioning regulations were revised in the 1990s, the site replaced the D-Plan with the Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 11). The PSDAR does not contain a description of the site in detail and therefore, changes are not required. The PSDAR is also considered the DSAR and the L TP is a supplement to the PSDAR/DSAR.

During preparation of the L TP, the impacts on information provided in the Environmental Report (Reference 12), the Supplemental Environmental Report for LACBWR SAFSTOR (Reference 13) and NUREG-0586, Final Generic Environmental Impact Statement on

  • Decommissioning of Nuclear Facilities (Reference 14) were evaluated. The information contained within the L TP was determined to be consistent or bounded by the information in the Environmental Report, the Supplemental Environmental Report and NUREG-0586. The process of partial site release was included in the LTP, and this partial site release is being proposed consistent with the process in the L TP. Thus, the Environmental Reports and
  • conclusions in Section 8 of the LTP concerning NUREG-0586 are not impacted by partial site release.

5.2.3 ISFSI Emergency Plan As the former nuclear plant has been dismantled and decommissioned, the Emergency Plan for the site has been revised to address the ISFSI only. The ISFSI Emergency Plan describes the location of the ISFSI, the radiologically controlled and protected areas, and the CAB.

None of these locations/areas will be affected by the proposed partial site release. Although portions of the CAB are included in the area proposed for partial site release, Dairyland will continue to maintain control of this area.

5.2.4 Security Plan The Security Plan will not be affected by the release of the proposed areas from the Part 50 license.

11

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CPR Part 50 License 5.2.5 Off-Site Dose Calculation Manual

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LA0RO~"ESOLUTI0Ns Gaseous, liquid, and solid radioactive waste systems associated with the operation of the LACBWR have been removed and disposed of. Site decommissioning activities have been concluded for the site ( except those required in the future for the ISFSI), and discharges of radioactive material (gaseous or liquid) are no longer made. In addition, the ISFSI casks are considered to be leak tight under normal and various postulated accident conditions, and thus are not a source of effluent.

Accordingly, the Off-Site Dose Calculation Manual (ODCM) has been revised to address only the ISFSI. Thus, it no longer includes X/Qs. The National Pollutant Discharge Elimination System (NPDES) permit for the site is now only used for coal plant discharges.

Monitoring in accordance. with the ODCM continues and will not be impacted by the proposed partial site release. Thus, the ODCM will not be affected by the release of the proposed areas.

5.2.6 Environmental Monitoring Program Gaseous, liquid, and solid radioactive waste systems associated with the operation of the LACBWR have been removed and disposed of. Site decommissioning activities have been concluded for the site ( except those required in the future for the ISFSI), and discharges of radioactive material (gaseous or liquid) are no longer made. In addition, the ISFSI casks are considered to be leak tight under normal and various postulated accident conditions, and thus are not a source of effluent.

Accordingly, the Environmental Monitoring Program has been revised to address monitoring associated with the ISFSI only. The Environmental Monitoring Program will not be affected by the release of the proposed areas.

5.2. 7 Groundwater Monitoring Program The Groundwater Monitoring Program is intended to integrate all aspects of groundwater characterization, monitoring and remediation required to support unrestricted release of the LACBWR site. All monitoring and supply wells on site were abandoned with concurrence of the NRC via letter dated October 1, 2019, La Crosse Boiling Water Reactor -

Acknowledgment of Discontinuation of Facility Groundwater Monitoring (Reference 15).

LaCrosseSolutions letter, LC-2019-0042, Request for No Further Action (Reference 16) was submitted to the Wisconsin Department of Natural Resources (WDNR) on September 24, 2019. The WDNR issued the No Further Action letter on January 29, 2020 (Reference 17).

The Groundwater Monitoring Program is no longer required for the purposes of the Part 50 license.

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Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License

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LAOROSSESOLUT:JONS 5.2.8 Fire Protection Program The ISFSI Fire Protection Program will not be affected by the release of the subject survey areas from the Part 50 license.

5.2.9 Training Program The training program for the ISFSI structures, systems and components that are important to safety will not be affected by the release of the subject areas from the Part 50 license.

5.2.10 Post-Shutdown Decommissioning Activities Report The PSDAR does not contain a description of the site in detail; therefore, changes are not required.

5.2.11 License Termination Plan The requested release is consistent with the information in the L TP concerning FSS and partial site release. A minor revision will be made to the L TP to revise the area of the site still under the Part 50 license after this request is approved by the NRC.

5.2.12 Compliance with 10 CFR 100 Siting Criteria The release of the subject property has been revie:wed with respect to the siting criteria in 10 CFR 100 and it has been determined that the requirements of 10 CFR 100 are either not impacted ( e.g., 10 CFR 100.11, Determination of Exclusion Area, Low Population Zone, and Population Center Distance, or 10 CFR 100, Appendix A, Seismic and Geologic Siting Criteria) or are not applicable (e.g., 10 CFR 100, Subpart B, Evaluation Factors for Stationary Power Reactor Site Application on or after January 10, 1997). The reactor vessel has been defueled and removed from the site for disposal. The spent fuel has been relocated to the south end of the site into the licensed ISFSI area.

5.3 Consideration of Interaction between the Proposed Partial Site Release and the Previously Released Site and between the Proposed Partial Site Release and Remaining Licensed Site Appendix L to NUREG 1757, Volume 2, provides guidance for the licensee to identify and analyze the potential interaction between the proposed site release and any other on-site sources. That guidance has been integrated into this partial site release request.

The following sections describe effects of interaction between the proposed site release and previously released site and interaction between the proposed site release and the remaining licensed site.

13

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CPR Part 50 License

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LACROSS.ESOLUT101¥S 5.3.1 Effects on the Proposed Site Release from Previous Land Release On June 27, 2016, LaCrosseSolutions submitted a request (ADAMS Accession No. ML16181A068) to release a portion of the non-impacted LACBWR site from the 10 CPR 50 license in accordance with 10 CPR 50.83, Release of Part of a Power Reactor Facility or Site for Unrestricted Use, and 10 CPR 100, Reactor Site Criteria. A report was generated for the request that addressed the release of 88 of the 163.5 acres that comprise the LACBWR site. That report contains a summary of the final assessment performed as well as a summary of the characterization surveys performed of these non-impacted open-land survey units. LaCrosseSolutions reviewed and assessed the subject property to ensure that the radiological condition of these land areas will have no adverse impact on the ability of the site, in aggregate, to meet the 10 CPR 20, Subpart E, Radiological Criteria for License Termination. The five (5) survey units incorporated within the report are classified as non-impacted, and as such, no statistical tests, scan measurements, static measurements, or elevated measurement comparisons were required. The release of the non-impacted areas from the license(s) was approved by the NRC on April 12, 2017.

These previously released areas were classified as non-impacted and as such, the release criteria were "no detectable plant-related radioactivity above background." Any migration of material from the previously released areas to the proposed release area (although very unlikely) would have radionuclide concentrations which are well below the Operational DCGLs used in the areas of the proposed release. Therefore, the previous land release will not have an adverse effect on the areas of the proposed release.

5.3.2 Dose Effects on ISFSI Land (i.e., land that will remain under jurisdiction of the Part 50 license)

The LACBWR ISFSI is located within the site boundary of the existing LACBWR site. The CAB for an ISFSI, as defined in 10 CPR 72.3, is the area immediately surrounding an ISFSI for which the Licensee exercises authority regulating its use and within which ISFSI operations are performed. The ISFSI CAB will encompass some of the land being requested by this submittal for release from jurisdiction of the Part 50 license; however, this area will continue to be under the authority and control of Dairyland until the spent fuel has been transferred off-site.

As stated previously, certain land around the ISFSI is not the subject of the proposed site release and will remain in the LACBWR Part 50 license (Figure 3). A radiological evaluation was performed for the ISFSI in accordance with 10 CPR 72.212 (b)(2)(i)(C) to establish that the requirements of 10 CPR 72.104 have been met. These requirements specify that the annual dose equivalent to any individual who is located beyond the CA, from normal operation or any anticipated occurrences at the ISFSI, would not exceed 25 mrem to the 14

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the IO CFR Part 50 License

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LACROSSESOLUTia'\\S' whole body, 75 mrem to the thyroid and 25 mrem to any other critical organ as a result of exposure to:

(1) planned discharges or radioactive materials, (2) direct radiation from the ISFSI, and (3) any other radiation from uranium fuel cycle operations within the region.

The spent fuel at the ISFSI is stored in the NAC-MPC System. The NAC-MPC System is a sealed and leak-tight spent fuel storage system. In addition, in-process inspections and tests were performed during fabrication and sealing of the canisters. Consequently, there is no release of radioactive material during normal conditions of storage. The structural analysis of the canister for off-normal and accident conditions of storage shows that the canister is not breached in any of the evaluated events. Consequently, there is no release of radioactive material during off-normal and accident conditions of storage that could impact the survey units proposed for release.

The NAC-MPC Technical Specifications, associated with allowable surface contamination on the cask after loading, were based upon limiting the dose at the Controlled Area Boundary (CAB) due to a total mechanistic release of the surface contamination. The closest CAB distance is the public boat launch parking lot at 3 83 feet. As previously stated, an occupancy dose at 350 feet from the ISFSI for an individual for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per year is 10.7 mrem/yr. The partial site release will not affect the basis for this Technical Specification, as the assumed residual plant area dose is on the opposite side of the site. Using a very conservative assumption of combining the dose from the ISFSI and the residual plant area dose, the result confirms that the Technical Spec~fication basis will continue to be maintained after partial site release has been implemented.

Doses associated with the uranium fuel cycle operations at LACBWR no longer exist, and the areas to be released meet the criteria for unrestricted release in 10 CFR 20.1402. Thus, the limit of25 mrem/year stipulated in 10 CFR 72.104 and 40 CFR 190, is satisfied.

5.3.3 Dose Effect on the Proposed Site Release from the Remaining Decommissioning Activities at the Remaining LACBWR Site Decommissioning activities have been completed at LACBWR. Only activities associated with maintenance and operation of the ISFSI are being conducted. As previously discussed, the casks stored in the ISFSI are sealed and leak-tight such that there is no release of radioactive materials in normal, off-nonnal or accident conditions.

Also discussed previously, the dose to a member of the public outside the CA of the ISFSI will be less than the 25 mrem/year dose as stipulated in 10 CFR 72.104.

15

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License

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LACROSSE80LUTI01~

5.4 Additional Areas to be Addressed to Support the Release of the Subject Survey Units LACBWR will maintain the following records through license termination: (1) a map of the site identifying the facility and site as defined in the original license; (2) a record of the Phase 1, Phase 2 and Phase 3 survey units released under this action; and (3) documentation of the radiological conditions of the land released under this action.

5.5 Site Release Criteria The site release criteria for the LACBWR site correspond to the 10 CFR 20.1402 criteria for unrestricted use. The residual radioactivity, including that from groundwater sources, that is distinguishable from background, must not cause the total effective dose equivalent (TEDE) to an AMCG to exceed 25 mrem/year. The residual radioactivity must also be reduced to levels that are As Low As Reasonably Achievable (ALARA).

The results of the final compliance dose have been calculated using Equation 1 and using the maximum SOF for the five media and the two groundwater scenarios. As shown in Table 4, the final dose summation is 8.2 inrem/year which meets the release criterion as established in 10 CFR 20.1402.

The ALARA criteria for soils as specified in Chapter 4 of the L TP were achieved.

5.6 Final Status Survey The LACBWR LTP, Chapter 5, states that the Final Status Survey Plan encompasses the radiological assessment of all affected basement structures, above-grade buildings, buried pipe, and land areas for the purpose of quantifying the concentrations of any residual activity that exists following all decontamination activities. Final status surveys were performed and reports submitted for the subject survey units, as indicated in Tables 1, 2 and 3.

As described in section 3.2, the reports consisted of a Survey Unit Release Record prepared for each survey unit, and several final reports which are compilations of numerous survey units which were submitted to the NRC in a phased approach. Final Reports were written consistent with the guidance provided in NUREG-1757, Vol. 2, MARSSIM, and the LTP.

These reports concluded that the radiological surveys were conducted in a manner consistent with the L TP and that the survey units passed the FSS. The final reports indicated that:

each survey unit addressed in the final reports have met the Data Quality Objectives (DQOs) of the FSS sample plans; all identified ROC were used for statistical testing to determine the adequacy of the survey unit for FSS; the sample data in each survey unit passed the Sign test; 16

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License a Retrospective Power Curve showed that adequate power was achieved in each survey unit; and the allowable dose for each survey unit have been met.

5. 7 Conclusion The release of the subject survey units is part of LaCrosseSolutions' overall effort to achieve unrestricted release of the site in accordance with the criteria in Subpart E of 10 CFR 20. This action is also consistent with the approach described in Chapter 5 of the LTP and is consistent with the approach endorsed by the NRC in their SER that supported approval of the LACBWR LTP.

In addition, 10 CFR 50.82(a)(l 1) establishes the criteria to be used by the NRC for terminating the license of a power reactor facility that has an approved LTP. These criteria include: (1) dismantlement has been performed in accordance with the approved LTP, and (2) the final radiation survey and associated documentation demonstrate that the facility and site have met the criteria for decommissioning in 10 CFR 20, Subpart E. All decommissioning and dismantlement activities have been completed in the subject survey units, and the release of the subject survey units supports the process oflicense termination by demonstrating that this portion of the site can be released from the Part 50 license. The FSSs have confirmed that the residual radioactivity in each of the survey units meets the criteria established in the LTP.

Thus, the. action of the release of the subject survey units supports the overall goal of unrestricted release -of the site in accordance with NRC regulations.

6 REFERENCES

1. La Crosse Boiling Water Reactor License Termination Plan
2. U.S. NRC Safety Evaluation Report by the Office of Nuclear Material Safety and Safeguards Related to Amendment No. 75 to Possession Only License No. DPR-45, Approval of the License Termination Plan -May 21, 2019
3. Letter to Mr. John Sauger, La Crosse Boiling Water Reactor -Approval of Partial Site Release for Possession Only License No. DPR April 12, 2017
4. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)
5. NUREG-1757, Vol. 2, Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria
6. LaCrosseSolutions, Final Status Survey Final Report - Phase 1 - August 2019
7. LaCrosseSolutions, Final Status Survey Final Report-Phase 2-December 2019
8. LaCrosseSolutions, Final Status Survey Final Report - Phase 3 - January 2020 17

Attachment to LC~2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License

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LACROSSESOLUTIO.NS

9. LaCrosseSolutions, Storm Water Pollution Prevention Plan
10. LACBWRISFSI 10 CFR 72.212 Report
11. Dairyland Power Cooperative, Post-Shutdown Decommissioning Activities Report
12. Environmental Report
13. Supplemental Environmental Report for LACBWR SAFSTOR
14. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities
15. NRC letter to LaCrosseSolutions dated October 1, 2019, La Crosse Boiling Water Reactor -Acknowledgment of Discontinuation of Facility Groundwater Monitoring
16. LaCrosseSolutions letter to the Wisconsin Department of Natural Resources, LC-2019-0042, Request for No Further Action
17. WDNR issued the No Further Action letter on January 29, 2020 18

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License Figure 1 Impacted Areas of the LACBWR Site Legend lmpecltd Area Willln Part 50 UcenH 1642440.57125.569401.35676 1642441.34027.569337.174266 16'12440.57757.569249.46298 16,42431 6338,569203.998852 1642413.18005.569165.615043 1642430.9316.569023.1)87236 -

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Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License Figure 2 Non-Impacted Areas of the LACBWR Site Legend Nonlmpacttd Survey Una, LACBWR Bulldng1 20

~soLUTJO. 'S

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License Figure 3 Independent Spent Fuel Storage Facility 1,641,803.552, 568,378.767.-*

1,642,453.391, 567,621.932 1,642,538.358, 567,717.913 -

Legend ISFSI /l5U&l J m')

ISFSI VOfl<es 21 1,641,317,353, !168,73!5.942 1,641, 6613, 569.3 1:72 1,642 223 666, 569,346 445 1,642,218 946, 66,239 449 1,642.3~.331, 569,103,481 1,642.43 79 1, S 9,025 230 1, 2,524 197, 5G8,9 7 34&

Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License

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,11,J,OL 1U.

Figure 4 Phase 1 Survey Unit Locations 22 Legend

[::~:-;* >J Surface m Sub-surface Ptase 1 Survey Unrt Loca a,s

- LAC6WRS1e Genoa..m.__

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Date 05.()212019 L~ ! SOWTiavs -Dra,vin i 19031401 c 1

  • Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License Figure 5 Phase 2 Survey Unit Locations Lege di 23
  • Attachment to LC-2020-004 Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License Figure 6 Phase 3 Survey Unit Locations 24
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